Sam A. Lindsay

Judge Sam A. Lindsay: Patent Litigation Profile

Judge Overview

Sam A. Lindsay is a United States District Judge for the Northern District of Texas, sitting in Dallas. He was nominated by President Bill Clinton in November 1997 and confirmed in March 1998. Prior to his judicial appointment, Judge Lindsay had an extensive career with the Dallas City Attorney's office from 1979 to 1998, ultimately serving as City Attorney from 1992 to 1998. He began his legal career as a staff attorney for the Texas Aeronautics Commission after graduating from the University of Texas School of Law in 1977.

Patent Docket

While precise statistics on Judge Lindsay's patent caseload are not publicly available, docket activity suggests he manages a mixed civil docket rather than specializing in patent law. In one 2013 matter, he reassigned a patent action to a judge on the district's specialized "Patent Panel," which may indicate a practice of deferring complex patent cases. His docket includes recently filed cases, such as AML IP LLC v. Cinemark USA Inc., which involves electronic commerce technology. In other patent cases, he has referred pretrial management to a magistrate judge.

Judge Lindsay’s approach to claim construction is exemplified by a detailed 2005 Markman opinion he authored while sitting by designation in the District of Massachusetts in MBO Laboratories, Inc. v. Becton, Dickinson & Co. In that case, involving hypodermic needle safety technology, he conducted a formal hearing and issued a comprehensive memorandum construing multiple disputed claim terms based on the intrinsic evidence. The Federal Circuit later affirmed in part and reversed in part his constructions, providing further insight into his analytical framework.

Notable Rulings and Trends

A notable trend in Judge Lindsay's recent patent jurisprudence is his application of procedural mechanisms to manage multi-defendant litigation efficiently. In a March 2026 order in Intellectual Ventures Management, LLC v. Southwest Airlines, Co., he granted the defendant’s motion to sever and administratively close the case. The ruling applied the "customer-suit exception," deferring the action against a downstream user (Southwest) in favor of pending litigation in Delaware against the technology manufacturers. This decision highlights a pragmatic approach to avoiding duplicative litigation and promoting judicial economy. In a 2025 case, he accepted a magistrate judge's recommendation to transfer a patent action to a different division within the district based on convenience.

Local Rules and Procedures

Judge Lindsay operates under the Northern District of Texas's local rules and the district's specific local patent rules, currently governed by Second Amended Miscellaneous Order No. 62. His individual courtroom procedures, available on the district's website, emphasize early and active case management. While he does not require a preliminary conference under Federal Rule of Civil Procedure 16, he issues a scheduling order promptly after the parties submit their joint status report. His procedures state that he generally rules on motions based on the briefs but may grant oral argument upon request or on his own initiative. For trial, Judge Lindsay strongly encourages the use of electronic equipment for presenting evidence and generally conducts the initial voir dire himself, while allowing for a brief follow-up by counsel.