Litigation

Untitled case

active

2:25-cv-00378

Patents at issue (1)

Summary

An active patent infringement case concerning US Patent 10944901 filed in the Texas Eastern District Court.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

This patent infringement case, 2:25-cv-00378, is active in the Eastern District of Texas, Marshall Division, presided over by District Judge Robert W. Schroeder III and Magistrate Judge Roy S. Payne. The plaintiff is SnapAid Ltd, an Israeli entity described both as an "Operating Company" and as having "no apparent business operations other than asserting its patent portfolio," suggesting it may operate as a patent assertion entity (PAE). The defendants are Samsung Electronics Co Ltd and Samsung Electronics America Inc., major operating companies in the consumer electronics sector. The lawsuit alleges infringement by Samsung's smartphones and tablets, specifically targeting "picture quality functionalities" such as Flaw Detection, Shot Suggestions, and Palm Gesture features.

The case concerns US Patent 10944901, one of eight closely related patents asserted by SnapAid, all titled "Real Time Assessment of Picture Quality". These patents generally cover systems and methods designed to perform real-time image quality analysis, providing users with immediate feedback during photo and video capture. The Eastern District of Texas is a common venue for patent litigation, known for its plaintiff-friendly procedural rules, accelerated trial schedules, and historical reputation for higher plaintiff success rates, though the Supreme Court's TC Heartland decision has led to new strategies for plaintiffs to establish venue there. A trial in this case is scheduled for April 2027.

The litigation is notable for several reasons, particularly regarding SnapAid's assertion patterns and the interplay with Patent Trial and Appeal Board (PTAB) proceedings. The plaintiff claims that the alleged infringement is willful, citing a 2015 non-disclosure agreement under which SnapAid disclosed its technology to Samsung, followed by Samsung's release of products incorporating similar capabilities. Samsung has filed inter partes reviews (IPRs) challenging some of SnapAid's patents, but strategically omitted others from the same family, which SnapAid argues is an attempt to fragment validity challenges and avoid efficient resolution. This scenario highlights the ongoing strategic tension between district court litigation and PTAB challenges in patent disputes, especially when faced with an asserted portfolio from an entity focused on patent enforcement.

Key legal developments & outcome

Major rulings, motions, claim construction, settlements, and the present posture or final disposition.

Key Legal Developments and Outcome for SnapAid, Ltd. v. Samsung Electronics Co., Ltd. et al.

Case Number: 2:25-cv-00378
Court: U.S. District Court for the Eastern District of Texas
Patents at Issue: US Patent 10944901 (among others)
Current Status: Active, proceeding toward trial

This patent infringement litigation, filed by SnapAid, Ltd. against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., is active in the Eastern District of Texas and is advancing towards a scheduled jury trial in April 2027.

Chronological Summary of Legal Developments:

  • 2025-04-10: Complaint Filed. SnapAid, Ltd. filed its complaint alleging infringement by Samsung of eight closely related U.S. patents, including US Patent 10944901, all titled "Real Time Assessment of Picture Quality."
  • 2025-11-17: Parallel PTAB Proceedings Initiated & Patent Owner's Requests for Discretionary Denial. Samsung filed several Inter Partes Review (IPR) and Post-Grant Review (PGR) petitions against five of the eight asserted patents, including IPR2025-01520 (targeting US Patent 11,671,702) and PGR2025-00083 (targeting US Patent 12,250,452). SnapAid, as Patent Owner, filed requests for discretionary denial of institution in these PTAB proceedings. SnapAid argued that Samsung strategically challenged only five patents (those issued within the last six years) while leaving three earlier-issued patents uncontested, despite having long-standing knowledge of the patent family since 2015. SnapAid asserted that institution would lead to duplicative proceedings and staggered adjudications, as the district court case was moving forward without a stay.
    • US Patent 10944901 Issue Date: U.S. Patent 10,944,901 was issued on March 9, 2021. This places it within the "last six years" as of Samsung's PTAB filings in November 2025, indicating it is likely one of the five patents challenged in the PTAB proceedings.
  • 2025-12-01: Samsung's Invalidity Contentions. Samsung filed its Invalidity Contentions in the district court.
  • 2026-01-05: Patent Owner's Sur-Reply in PTAB & Inconsistent Positions Noted. In a sur-reply for PGR2025-00083, SnapAid highlighted Samsung's inconsistent claim construction and indefiniteness positions between the district court litigation and the PTAB proceedings, arguing that Samsung asserted different claim phrases as indefinite in each forum.
  • 2026-01-09: PTAB Denies Institution for PGR2025-00083. The USPTO Director issued a notice denying institution for PGR2025-00083 (U.S. Patent 12,250,452) based on discretionary considerations. The notice did not list IPR2025-01520 (U.S. Patent 11,671,702) as denied, implying it was either referred for merits review or still pending a decision.
  • 2026-04-02: Docket Control Order Issued. A Docket Control Order was issued, setting key dates for the litigation.
  • 2026-05-13: Plaintiff's Motion to Amend Infringement Contentions Granted. The Court granted SnapAid's unopposed motion for leave to amend its infringement contentions to supplement P.R. 3-2 disclosures, based on newly discovered documents related to reduction to practice and conception of the patents-in-suit.
  • Pre-Trial Motions to Stay: Samsung filed a "Motion to Stay Pending Ex Parte Reexamination" in the district court (Docket No. 63). While a specific order on this motion is not explicitly available in the provided snippets, PTAB documents from November 2025 noted that the "district court action is moving forward without a stay" and that the Eastern District of Texas "routinely deny requests to stay pending IPRs." This indicates that any motions to stay in the district court, including those related to PTAB proceedings or reexamination, have been denied or not granted.
  • Claim Construction (Markman): A Markman hearing is scheduled for 2026-10-30 at 09:00 AM before Magistrate Judge Roy S. Payne. Claim construction briefs had not yet been submitted as of early 2026.
  • Discovery: Fact discovery is scheduled to close on 2026-11-16. As of early 2026, no depositions had been taken and email search terms had not been exchanged.
  • Trial: Jury selection is set for 2027-04-19 at 09:00 AM before District Judge Robert W. Schroeder III, with the trial itself scheduled for April 2027.

The case remains active, with the district court proceeding without a stay, despite parallel PTAB challenges where at least one petition (PGR2025-00083) has been denied institution.


Citations:
SnapAid, Ltd. v. Samsung Electronics Co., Ltd. et al (2:25-cv-00378), Texas Eastern District Court, Docket entries for April 02, 2026 and May 13, 2026.
Notice of Decisions on Institution, before John A. Squires, Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office, dated January 9, 2026. USPTO.
SnapAid, Ltd. v. Samsung Electronics Co., Ltd. et al (2:25-cv-00378), Texas Eastern District Court, Filed: 04/10/2025. PacerMonitor.
Patent Owner's Request for Discretionary Denial, PGR20200083, U.S. Patent 2,250,452, dated November 17, 2025. USPTO.
Patent Owner's Request for Discretionary Denial, IPR20201520, U.S. 11,671,702, dated November 17, 2025. USPTO.
SnapAid filed a civil action in the Eastern District of Texas, Case No. 2:25- cv-00378, asserting eight closely related U.S. patents, each titled “Real Time Assessment of Picture Quality.”
Patent Owner's Sur-Reply, PGR2025-00083, U.S. Patent No. 12,250,452, dated January 5, 2026. USPTO.
District court has not granted a stay, and a stay is unlikely because the Eastern District of Texas and Judge Gilstrap in particular routinely deny requests to stay pending IPRs.
Defendants' Motion to Stay Pending Ex Parte Reexamination, SnapAid, Ltd. v. Samsung Electronics Co., Ltd. et al, Case No. 2:25-CV-00378-RWS. PacerMonitor.

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Plaintiff SnapAid Ltd. is represented by attorneys from Steptoe & Johnson LLP and Miller Fair Henry PLLC.

Here is a breakdown of the identified counsel:

From Steptoe & Johnson LLP:

  • James R. Nuttall

    • Role: Likely lead counsel or significant counsel.
    • Firm: Steptoe & Johnson LLP (Specific office location for this case to be confirmed, but the firm has multiple offices. Given the Eastern District of Texas venue, they may be operating from an office with relevant patent litigation presence or coordinating with local counsel).
    • Note: As a partner in Steptoe's Intellectual Property group, James R. Nuttall focuses on patent litigation.
  • Jacob T. Michalakes

    • Role: Counsel.
    • Firm: Steptoe & Johnson LLP.
    • Note: He is a lawyer at Steptoe & Johnson LLP, involved in patent litigation.
  • James Winn

    • Role: Counsel.
    • Firm: Steptoe & Johnson LLP.
    • Note: He is a lawyer at Steptoe & Johnson LLP, involved in patent litigation.

From Miller Fair Henry PLLC:

  • Claire A. Henry

    • Role: Likely local counsel or significant counsel given the firm's presence in Texas.
    • Firm: Miller Fair Henry PLLC, based in Tyler, Texas.
    • Note: Claire A. Henry is a partner at Miller Fair Henry PLLC, a Texas-based law firm that frequently represents clients in patent litigation in the Eastern District of Texas.
  • Charles Everingham, IV

    • Role: Likely local counsel or significant counsel.
    • Firm: Miller Fair Henry PLLC, based in Tyler, Texas.
    • Note: Charles Everingham, IV is a partner at Miller Fair Henry PLLC, with experience in patent litigation in the Eastern District of Texas.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Defendant(s) Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. are represented by counsel from Kirkland & Ellis LLP and Gillam & Smith LLP.

Here is a breakdown of the identified counsel:

From Kirkland & Ellis LLP:

  • Gregory S. Arovas

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP (New York office).
    • Note: Gregory S. Arovas is a partner at Kirkland & Ellis, known for his work in intellectual property litigation, particularly in patent disputes.
  • Todd M. Friedman

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP (New York office).
    • Note: Todd M. Friedman is a partner at Kirkland & Ellis, focusing on patent litigation across various technologies.
  • David Rokach

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP.
    • Note: David Rokach is a partner at Kirkland & Ellis with experience in high-stakes intellectual property cases.
  • Alex R. Henriques

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP (New York office).
    • Note: Alex R. Henriques is an attorney at Kirkland & Ellis, specializing in patent litigation.
  • F. Christopher Mizzo

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP (Washington D.C. office).
    • Note: F. Christopher Mizzo is a partner at Kirkland & Ellis, active in patent infringement cases.
  • Peter Jason Evangelatos

    • Role: Counsel (Pro Hac Vice).
    • Firm: Kirkland & Ellis LLP.
    • Note: Peter Jason Evangelatos has filed a Notice of Attorney Appearance - Pro Hac Vice on behalf of both Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd.
  • Austin Pennington

    • Role: Counsel.
    • Firm: Kirkland & Ellis LLP.
    • Note: Austin Pennington is an attorney at Kirkland & Ellis, involved in intellectual property litigation.

From Gillam & Smith LLP:

  • Melissa R. Smith
    • Role: Counsel, likely local counsel given the firm's presence in Texas.
    • Firm: Gillam & Smith LLP.
    • Note: Melissa R. Smith is a partner at Gillam & Smith LLP, a Texas-based firm frequently involved in patent litigation in the Eastern District of Texas.