ORIGINAL COMPLAINT Page 1 of 16
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`SECURE COMMUNICATION
`TECHNOLOGIES, LLC,
`P
`laintiff,
`v.
`SAMSUNG ELECTRONICS CO., LTD.,
`and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`D
`efendants.
`Case No. 2:24 CV 484
`Jury Trial Demanded
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`Plaintiff Secure Communication Technologies, LLC (“SCT”) files this Original Complaint
`for patent infringement against Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung
`Electronics America, Inc. (“SEA”) alleging as follows:
`BACKGROUND AND NATURE OF THE SUIT
`1. This is a claim for patent infringement arising under the patent laws of the Unite d
`S
`tates, Title 35 of the United States Code. This case asserts infringement of United States Patent
`Nos. 11,334,918 (the “’918 Patent”), 11,443,344 (the “’344 Patent”), and 11,687,971 (the “’971
`Patent”) (collectively, “the Patents-in-Suit”).
`2. The Patents-in-Suit are owned by SCT .
`3. The
` inventions described and claimed in the Patents-in-Suit were invented an d
`de
`veloped by Mr. James Proctor Jr. (a pioneering researcher, inventor, entrepreneur and well-
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`ORIGINAL COMPLAINT Page 2 of 16
`recognized technical expert in the field of wireless communications) and his father, James A.
`Proctor III.
`THE PARTIES
`4. SCT is a Texas limited liability company with its principal place of business at
`204 North Fredonia Street, Longview, Texas 75601.
`5. Defendant SEC is a company organized and existing under the laws of the
`Republic of Korea with a principal place of business located at 129 Samsung-ro, Yeongtong-gu,
`Suwon-si, Gyeonggi-do, 443-742 in the Republic of Korea. SEC may be served at least by
`process under the Hague Convention.
`6. Defendant SEA is a New York corporation having a principal place of business at
`85 Challenger Road, Ridgefield Park, New Jersey 07660 and is a wholly-owned subsidiary of
`SEC. SEA may be served via its registered agent, CT Corporation System, 1999 Bryan Street,
`Suite 900, Dallas, Texas 75201.
`JURISDICTION AND VENUE
`7. This action arises under the patent laws of the United States, 35 U.S.C. § 101, et
`seq. This Court’s jurisdiction over this action is proper under the above statutes, including 35
`U.S.C. § 271, et seq., 28 U.S.C. § 1331 (federal question jurisdiction) and § 1338 (jurisdiction over
`patent actions).
`8. The Court has personal jurisdiction over each Defendant consistent with the
`requirements of the Due Process Clause of the United States Constitution and the Texas Long
`Arm Statute.
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`ORIGINAL COMPLAINT Page 3 of 16
`9. Each Defendant has regularly and systematically transacted business in Texas ,
`di
`rectly or through subsidiaries or intermediaries, and/or committed acts of patent infringement
`in Texas as alleged more particularly below.
`10. Samsung has placed infringing products into the stream of commerce by shippi ng
`t
`hose products into Texas or knowing that the products would be shipped into Texas.
`11. In addition, on information and belief, Samsung’s business relating to mobile
`devices, including devices accused of infringement in this Action, are conducted at its Texas
`facilities.
`12. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b) .
`13.
`With respect to Defendant SEC, a Korean company, venue is proper because suits
`against foreign entities are proper in any judicial district, including the Eastern District of Texas.
`14. With respect to Defendant SEA, venue is proper in this district under 28 U.S.C .
`§1400(
`b) because Defendant SEA has a regular and established place of business in this district
`and has committed acts of infringement in this district.
`15. On information and belief, Defendant SEA has a regular and established place of
`business in Plano, Texas, and is responsible for importing and selling smartphones, tablets, and
`other mobile devices and equipment in the United States.
`16. Samsung makes, uses, sells, offers for sale, and/or imports Samsung-branded
`smartphones, tablets, laptops, and other electronics in this District, including the products
`accused of infringement herein.
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`ORIGINAL COMPLAINT Page 4 of 16
`17. On information and belief, Defendant SEA has operated, and on information a nd
`be
`lief continues to operate, a permanent office located at 6625 Excellence Way, Plano, TX
`75023.
`18. Defendant SEA also employs full-time personnel, such as engineers and managers
`in this district, including in Collin County.
`19. On information and belief, Samsung’s business operations relating to cellular
`mobile devices are conducted at these SEA facilities located in this district.
`20. Defendant SEA has also committed acts of infringement in this district by
`c
`ommercializing, marketing, selling, distributing, and servicing certain Samsung-branded
`devices, including but not limited to phones and tablets, which are devices Plaintiff accuses of
`infringement in this Action.
`THE PATENTS-IN-SUIT
`The 918 Patent
`21. The ’918 Patent, entitled “Exchanging identifiers between wireless communicati on
`t
`o determine further information to be exchanged or further services to be provided,” duly and
`legally issued on May 17, 2022, from U.S. Patent Application No. 15/271,410, filed on September
`21, 2016, naming James A. Proctor, Jr. and James A. Proctor III as the inventors. A true and
`correct copy of the ’918 Patent is attached hereto as Exhibit 1 and is incorporated by reference.
`22. The ’918 Patent claims priority to U.S. Patent Application No. 14/861,563, whic h
`w
`as filed on September 22, 2015. The ’918 Patent also claims priority to U.S. Patent Application
`Nos. 14/472,477 (filed on August 29, 2014 and which issued as U.S. Patent No. 9,161,164),
`13/775,435 (filed on February 25, 2013 and which issued as U.S. Patent No. 8,849,698),
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`ORIGINAL COMPLAINT Page 5 of 16
`13/212,723 (filed on August 18, 2011 and which issued as U.S. Patent No. 8,385,896), and
`12/364,828 (filed on February 3, 2009 and which issued as U.S. Patent No. 8,090,359). The ’918
`Patent also claims priority to U.S. Provisional Patent Application Nos. 61/095,359 (filed on
`September 9, 2008) and 61/095,001 (filed on September 8, 2008).
`23. The ’918 Patent claims patent-eligible subject matter under 35 U.S.C
`. § 101.
`24. The
` ’918 Patent claims are not directed to an abstract idea and are thus patent-
`eligible under 35 U.S.C. § 101.
`25. The ’918 Patent claims contain inventive concepts such that they are patent-eligible
`under 35 U.S.C. § 101.
`26. SCT is the owner and assignee of all rights, title, and interest in and under the ’918
`Patent.
`27. SCT has standing to sue for infringement of the ’918 Patent .
`T
`he 344 Patent
`28. The ’344 Patent, entitled “Efficient and secure communication using wireless
`service identifiers,” duly and legally issued on September 13, 2022, from U.S. Patent Application
`No. 17/366,826, filed on July 2, 2021, naming James A. Proctor, Jr. and James A. Proctor III as
`the inventors. A true and correct copy of the ’344 Patent is attached hereto as Exhibit 2 and is
`incorporated by reference.
`29. The ’344 Patent claims priority to U.S. Patent Application No. 16/817,896, whic h
`w
`as filed on March 13, 2020 and issued as U.S. Patent No. 11,074,615. The ’344 Patent also claims
`priority to U.S. Patent Application Nos. 15/271,410 (filed on September 21, 2016), 14/861,563
`(filed on September 22, 2015), 14/472,477 (filed on August 29, 2014 and which issued as U.S.
`SCT Exhibit 2014
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`ORIGINAL COMPLAINT Page 6 of 16
`Patent No. 9,161,164), 13/775,435 (filed on February 25, 2013 and which issued as U.S. Patent
`No. 8,849,698), 13/212,723 (filed on August 18, 2011 and which issued as U.S. Patent No.
`8,385,896), and 12/364,828 (filed on February 3, 2009 and which issued as U.S. Patent No.
`8,090,359). The ’344 Patent also claims priority to U.S. Provisional Patent Application Nos.
`61/095,359 (filed on September 9, 2008) and 61/095,001 (filed on September 8, 2008).
`30. The ’344 Patent claims patent-eligible subject matter under 35 U.S.C
`. § 101.
`31. The
` ’344 Patent claims are not directed to an abstract idea and are thus patent-
`eligible under 35 U.S.C. § 101.
`32. The ’344 Patent claims contain inventive concepts such that they are patent-eligible
`under 35 U.S.C. § 101.
`33. SCT is the owner and assignee of all rights, title, and interest in and under the ’344
`Patent.
`34. SCT has standing to sue for infringement of the ’344 Patent .
`T
`he ’971 Patent
`35. The ’971 Patent, entitled “Efficient and secure communication using wireless
`service identifiers,” duly and legally issued on June 27, 2023, from U.S. Patent Application No.
`17/942,197, filed on September 12, 2022, naming James A. Proctor, Jr. and James A. Proctor III
`as the inventors. A true and correct copy of the ’971 Patent is attached hereto as Exhibit 3 and is
`incorporated by reference.
`36. The ’971 Patent claims priority to U.S. Patent Application No. 17/366,826 (filed on
`J
`une 2, 2021 and which issued as the ’344 Patent), 16/817,896 (filed on March 13, 2020 and which
`issued as U.S. Patent No. 11,074,615), 15/271,410 (filed on September 21, 2016), 14/861,563
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`ORIGINAL COMPLAINT Page 7 of 16
`(filed on September 22, 2015), 14/472,477 (filed on August 29, 2014 and which issued as U.S.
`Patent No. 9,161,164), 13/775,435 (filed on February 25, 2013 and which issued as U.S. Patent
`No. 8,849,698), 13/212,723 (filed on August 18, 2011 and which issued as U.S. Patent No.
`8,385,896), and 12/364,828 (filed on February 3, 2009 and which issued as U.S. Patent No.
`8,090,359). The ’344 Patent also claims priority to U.S. Provisional Patent Application Nos.
`61/095,359 (filed on September 9, 2008) and 61/095,001 (filed on September 8, 2008).
`37. The ’971 Patent claims patent-eligible subject matter under 35 U.S.C
`. § 101.
`38. The
` ’971 Patent claims are not directed to an abstract idea and are thus patent-
`eligible under 35 U.S.C. § 101.
`39. The ’971 Patent claims contain inventive concepts such that they are patent-eligible
`under 35 U.S.C. § 101.
`40. SCT is the owner and assignee of all rights, title, and interest in and under the ’971
`Patent.
`41. SCT has standing to sue for infringement of the ’971 Patent .
`G
`ENERAL ALLEGATIONS OF PATENT INFRINGEMENT
`42. As detailed below and in the accompanying claim charts (Exhibits 4-30), Sams ung
`ha
`s infringed (and continues to infringe) one or more claims of the Patents-in-Suit by making,
`using, selling, offering for sale, and/or importing into the United States at least the following
`products (the “Accused Products”):
`S amsung smartphones which include at least one of the Nearby Share, Quick Share,
`Fast Pair, Find My Mobile and/or SmartThings Find features, e.g., the Galaxy S24
`and Z4 series;
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`ORIGINAL COMPLAINT Page 8 of 16
`Samsung tablets which include at least one of the Nearby Share, Quick Share, Fast
`Pair, Find My Mobile and/or SmartThings Find features, e.g., the Galaxy Tab S9
`series; and
`Samsung laptop computers which include at least the Quick Share feature, e.g., the
`Galaxy Book4 series.
`43. Samsung’s acts of infringement have caused damage to SCT. SCT is entitled t o
`r
`ecover from Samsung the damages sustained by SCT as a result of Samsung’s wrongful acts in
`an amount subject to proof at trial.
`44. Further discovery may reveal earlier knowledge of one or more of the Patents-in-
`Suit, which would provide additional evidence of Samsung’s willful infringement of the Patents-
`in-Suit.
`45. For each count of infringement listed below, SCT incorporates and re-states the
`allegations contained in the preceding paragraphs above, including these General Allegations, as
`if fully set forth in each count of infringement.
`COUNT I – INFRINGEMENT OF THE ’918 PATENT
`46. SCT incorporates herein the allegations made in paragraphs 1 thr ough 45.
`47.
`Samsung has directly infringed (either literally or under the doctrine of equivalents)
`one or more claims of the ’918 Patent, including, for example, claim 1, in violation of 35 U.S.C. §
`271(a) by making, using, selling, offering for sale, and/or importing into the United States
`infringing products including, but not limited to, the Accused Products.
`48. Exemplary claim charts demonstrating Samsung’s infringement of the 918 Patent
`are attached as Exhibits 4-12 and incorporated herein by reference.
`SCT Exhibit 2014
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`ORIGINAL COMPLAINT Page 9 of 16
`49. Additionally, on information and belief, Samsung has indirectly infringed the ’ 918
`P
`atent in violation of 35 U.S.C. § 271(b) at least by inducing customers to purchase the Accused
`Products and/or by instructing customers how to use the Accused Products in a way that directly
`infringed at least claim 1 of the ’918 Patent.
`50. Samsung has had knowledge of the ’918 Patent and of its infringement of the ’ 918
`P
`atent at least through the service of this Complaint.
`51. On information and belief, despite Samsung’s knowledge of the ’918 Patent and of
`its infringement of the ’918 Patent, Samsung has not sought to remedy its infringement or sought
`to identify any good faith belief as to why it does not infringe the ’918 Patent.
`52. On information and belief, Samsung’s actions represented a specific intent t
`o
`i
`nduce infringement of at least claim 1 of the ’918 Patent. For example, Samsung offered its
`customers extensive customer support and instructions that instructed and encouraged its
`customers to infringe the ’918 Patent via at least their use of the Accused Products. See, e.g.,
`https://www.samsung.com/au/support/mobile-devices/using-nearby-sharing/;
`https://www.samsung.com/ph/support/mobile-devices/how-to-use-quickshare-feature-on-galaxy-
`mobile-device/; https://insights.samsung.com/2022/11/16/how-to-use-nearby-share-on-your-
`galaxy-smartphone-3/; https://www.samsung.com/ie/support/computing/what-is-quick-share-
`and-how-do-i-use-it-on-my-galaxy-book/;
`https://www.samsung.com/us/support/answer/ANS00087283/;
`https://www.samsung.com/us/support/answer/ANS00087102/;
`https://insights.samsung.com/2023/07/19/how-to-use-samsung-find-my-mobile-to-track-down-
`your-phone-
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`2/#:~:text=On%20your%20Galaxy%20mobile%20device,don't%20already%20have%20one;
`https://www.samsung.com/us/support/answer/ANS00080182/; see also Exhibits 4-12 and
`materials cited therein.
`53. Since issuance of the ’918 Patent, neither SCT nor its predecessors or licensees
`have made, offered for sale, sold, or imported a product that practices any claim of the ’918 Patent
`or that would otherwise require marking under 35 U.S.C. § 287.
`54. SCT may recover pre-suit damages for Samsung’s infringement of the ’918 Patent
`under 35 U.S.C. § 287.
`55. As a result of Samsung’s infringement of the ’918 Patent, SCT has suffered and is
`owed monetary damages adequate to compensate it for the infringement under 35 U.S.C. § 284,
`but in no event less than a reasonable royalty.
`COUNT II – INFRINGEMENT OF THE ’344 PATENT
`56. SCT incorporates herein the allegations made in paragraphs 1 thr ough 45.
`57.
`Samsung has directly infringed (either literally or under the doctrine of equivalents)
`one or more claims of the ’344 Patent, including, for example, claim 29, in violation of 35 U.S.C.
`§
`271(a) by making, using, selling, offering for sale, and/or importing into the United States
`infringing products including, but not limited to, the Accused Products.
`58. Exemplary claim charts demonstrating Samsung’s infringement of the ’344 Patent
`are attached as Exhibits 13-21 and incorporated herein by reference.
`59. Additionally, on information and belief, Samsung has indirectly infringed the ’ 344
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`atent in violation of 35 U.S.C. § 271(b) at least by inducing customers to purchase the Accused
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`ORIGINAL COMPLAINT Page 11 of 16
`Products and/or by instructing customers how to use the Accused Products in a way that directly
`infringed at least claim 29 of the ’344 Patent.
`60. Samsung has had knowledge of the ’344 Patent and of its infringement of the ’ 344
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`atent at least through the service of this Complaint.
`61. On information and belief, despite Samsung’s knowledge of the ’344 Patent and of
`its infringement of the ’344 Patent, Samsung has not sought to remedy its infringement or sought
`to identify any good faith belief as to why it does not infringe the ’344 Patent.
`62. On information and belief, Samsung’s actions represented a specific intent t
`o
`i
`nduce infringement of at least claim 29 of the ’344 Patent. For example, Samsung offered its
`customers extensive customer support and instructions that instructed and encouraged its
`customers to infringe the ’344 Patent via at least their use of the Accused Products. See, e.g.,
`https://www.samsung.com/au/support/mobile-devices/using-nearby-sharing/;
`https://www.samsung.com/ph/support/mobile-devices/how-to-use-quickshare-feature-on-galaxy-
`mobile-device/; https://insights.samsung.com/2022/11/16/how-to-use-nearby-share-on-your-
`galaxy-smartphone-3/; https://www.samsung.com/ie/support/computing/what-is-quick-share-
`and-how-do-i-use-it-on-my-galaxy-book/;
`https://www.samsung.com/us/support/answer/ANS00087283/;
`https://www.samsung.com/us/support/answer/ANS00087102/;
`https://insights.samsung.com/2023/07/19/how-to-use-samsung-find-my-mobile-to-track-down-
`your-phone-
`2/#:~:text=On%20your%20Galaxy%20mobile%20device,don't%20already%20have%20one;
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`ORIGINAL COMPLAINT Page 12 of 16
`https://www.samsung.com/us/support/answer/ANS00080182/; see also Exhibits 13-21 and
`materials cited therein.
`63. Since issuance of the ’344 Patent, neither SCT nor its predecessors or licensees
`have made, offered for sale, sold, or imported a product that practices any claim of the ’344 Patent
`or that would otherwise require marking under 35 U.S.C. § 287.
`64. SCT may recover pre-suit damages for Samsung’s infringement of the ’344 Patent
`under 35 U.S.C. § 287.
`65. As a result of Samsung’s infringement of the ’344 Patent, SCT has suffered and is
`owed monetary damages adequate to compensate it for the infringement under 35 U.S.C. § 284,
`but in no event less than a reasonable royalty.
`COUNT III – INFRINGEMENT OF THE ’971 PATENT
`66. SCT incorporates herein the allegations made in paragraphs 1 thr ough 45.
`67.
`Samsung has directly infringed (either literally or under the doctrine of equivalents)
`one or more claims of the ’971 Patent, including, for example, claim 37, in violation of 35 U.S.C.
`§
`271(a) by making, using, selling, offering for sale, and/or importing into the United States
`infringing products including, but not limited to, the Accused Products.
`68. Exemplary claim charts demonstrating Samsung’s infringement of the ’971 Patent
`are attached as Exhibits 22-30 and incorporated herein by reference.
`69. Additionally, on information and belief, Samsung has indirectly infringed the ’ 971
`P
`atent in violation of 35 U.S.C. § 271(b) at least by inducing customers to purchase the Accused
`Products and/or by instructing customers how to use the Accused Products in a way that directly
`infringed at least claim 37 of the ’971 Patent.
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`ORIGINAL COMPLAINT Page 13 of 16
`70. Samsung has had knowledge of the ’344 Patent and of its infringement of the ’ 971
`P
`atent at least through the service of this Complaint.
`71. On information and belief, despite Samsung’s knowledge of the ’971 Patent and of
`its infringement of the ’971 Patent, Samsung has not sought to remedy its infringement or sought
`to identify any good faith belief as to why it does not infringe the ’971 Patent.
`72. On information and belief, Samsung’s actions represented a specific intent t o
`i
`nduce infringement of at least claim 37 of the ’971 Patent. For example, Samsung offered its
`customers extensive customer support and instructions that instructed and encouraged its
`customers to infringe the ’971 Patent via at least their use of the Accused Products. See, e.g.,
`https://www.samsung.com/au/support/mobile-devices/using-nearby-sharing/;
`https://www.samsung.com/ph/support/mobile-devices/how-to-use-quickshare-feature-on-galaxy-
`mobile-device/; https://insights.samsung.com/2022/11/16/how-to-use-nearby-share-on-your-
`galaxy-smartphone-3/; https://www.samsung.com/ie/support/computing/what-is-quick-share-
`and-how-do-i-use-it-on-my-galaxy-book/;
`https://www.samsung.com/us/support/answer/ANS00087283/;
`https://www.samsung.com/us/support/answer/ANS00087102/;
`https://insights.samsung.com/2023/07/19/how-to-use-samsung-find-my-mobile-to-track-down-
`your-phone-
`2/#:~:text=On%20your%20Galaxy%20mobile%20device,don't%20already%20have%20one;
`https://www.samsung.com/us/support/answer/ANS00080182/; see also Exhibits 22-30 and
`materials cited therein.
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`ORIGINAL COMPLAINT Page 14 of 16
`73. Since issuance of the ’971 Patent, neither SCT nor its predecessors or licensees
`have made, offered for sale, sold, or imported a product that practices any claim of the ’971 Patent
`or that would otherwise require marking under 35 U.S.C. § 287.
`74. SCT may recover pre-suit damages for Samsung’s infringement of the ’971 Patent
`under 35 U.S.C. § 287.
`75. As a result of Samsung’s infringement of the ’971 Patent, SCT has suffered and is
`owed monetary damages adequate to compensate it for the infringement under 35 U.S.C. § 284,
`but in no event less than a reasonable royalty.
`DEMAND FOR A JURY TRIAL
`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, SCT demands a trial by jury
`on all issues triable of right by a jury.
`PRAYER FOR RELIEF
`WHEREFORE, SCT respectfully requests that this Court enter judgment in its favor and
`grant the following relief:
`a. A judgment that Samsung has directly infringed one or more claims of each of the
`Patents-in-Suit;
`b. A judgment and order requiring Samsung to pay SCT past and future damages
`under 35 U.S.C. § 284, including for supplemental damages arising from a ny
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`ontinuing post-verdict infringement for the time between trial and entry of the final
`judgment with an accounting, as needed, as provided by 35 U.S.C. § 284;
`c. A judgment and order requiring Samsung to pay SCT reasonable ongoing royalties
`on a going-forward basis after final judgment;
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`ORIGINAL COMPLAINT Page 15 of 16
`d. A judgment and order requiring Samsung to pay SCT pre-judgment and post-
`judgment interest on the damages award;
`e. A judgment and order requiring Samsung to pay SCT’s costs; a nd
`f
`. Such other and further relief as the Court may deem just and proper .
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`ORIGINAL COMPLAINT Page 16 of 16
`Dated: July 3, 2024 Respectfully submitted,
`/s/ Jennifer L. Truelove
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`Email:jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
`OF COUNSEL:
`Timothy E. Grochocinski
`Illinois Bar No. 6295055
`tim@nelbum.com
`Charles Austin Ginnings
`New York Bar No. 4986691
`austin@nelbum.com
`NELSON BUMGARDNER CONROY PC
`745 McClintock Road, Suite 340
`Burr Ridge, Illinois 60527
`708.675.1974 (telephone)
`Christopher G. Granaghan
`Texas Bar No. 24078585
`chris@nelbum.com
`NELSON BUMGARDNER CONROY P.C.
`3131 West Seventh Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-9111
`Attorneys for Plaintiff
`Secure Communication Technologies, LLC
`SCT Exhibit 2014
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