Litigation
Untitled case
Active litigation2:24-cv-01057
Patents at issue (1)
Summary
An active litigation case filed in 2024 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 litigation, Case No. 2:24-cv-01057, is currently active in the U.S. District Court for the Eastern District of Texas, Marshall Division, presided over by Judge Rodney Gilstrap. The plaintiff is XiFi Networks R&D, Inc. ("XiFi"), which appears to be a patent assertion entity (PAE) given its R&D designation and the nature of the suit asserting multiple patents against a large technology company. The defendants are Samsung Electronics Co., Ltd. and [[Samsung Electronics America](/litigations/by-defendant/Samsung%20Electronics%20America), Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) (collectively, "Samsung"), a major operating company known for its consumer electronics, including smartphones, TVs, laptops, tablets, and wearable devices. The accused technology centers on Samsung devices that implement Multi-Link Operation (MLO) functionality, as specified in the IEEE 802.11be Draft Standard for Wi-Fi, using two or more transceivers.
The litigation involves eleven asserted patents, all stemming from a single patent family. These include U.S. Patent Nos. 11,818,591, 11,849,337, 11,856,414, 11,974,143, 11,950,105, 12,003,976, 12,015,933, 12,114,177, 12,169,756, 12,190,198, and 12,250,564. While a specific one-line technical sketch for patent 12190198 is not explicitly detailed in publicly available summaries, the asserted patents generally relate to methods and apparatus for processing bandwidth-intensive data streams using virtual media access control and physical layers, specifically pertaining to multi-link Wi-Fi operations functionality, such as band allocation decision-making. The case is proceeding with active discovery, and a Markman hearing was held on May 1, 2026.
The Eastern District of Texas is a significant venue for patent litigation, known for its judges' extensive experience with patent cases and their commitment to bringing cases to trial quickly. This district was the top patent forum in 2025 for both overall and non-practicing entity (NPE) litigation. A notable aspect of this case is that Samsung filed numerous inter partes review (IPR) and post-grant review (PGR) petitions challenging eight of the eleven asserted patents at the Patent Trial and Appeal Board (PTAB). However, Judge Gilstrap denied Samsung's motion to stay the district court proceedings pending the outcome of these PTAB reviews on March 12, 2026, signaling the court's intention to maintain its expedited schedule, with trial currently set for October 19, 2026. This denial highlights the court's preference for advancing its docket despite parallel PTAB challenges, a common characteristic of EDTX patent litigation. The case is notable for its assertion of a broad patent portfolio against a leading consumer electronics manufacturer in the high-stakes Wi-Fi technology sector, and the court's refusal to stay proceedings pending IPR/PGR outcomes.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Key Legal Developments and Outcome for XiFi Networks R&D, Inc. v. Samsung Electronics Co., Ltd. et al.
This patent infringement litigation, Case No. 2:24-cv-01057, is currently active in the U.S. District Court for the Eastern District of Texas. The following outlines the key legal developments in chronological order:
Filing & Initial Pleadings
- Complaint Filed (2024-12-17): Plaintiff XiFi Networks R&D, Inc. ("XiFi") filed the initial complaint against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. ("Samsung") asserting infringement of nine patents.
- First Amended Complaint Filed (2025-03-11): XiFi filed a First Amended Complaint, which remains the operative pleading, adding two more patents to the asserted portfolio, bringing the total to eleven. The asserted patents include U.S. Patent Nos. 11,818,591, 11,849,337, 11,856,414, 11,974,143, 11,950,105, 12,003,976, 12,015,933, 12,114,177, 12,169,756, 12,190,198, and 12,250,564. These patents generally relate to methods and apparatus for processing bandwidth-intensive data streams using virtual media access control and physical layers, specifically pertaining to multi-link Wi-Fi operations functionality.
- Plaintiff's Infringement Contentions Served (2025-03-26): XiFi served its infringement contentions.
- Defendants' Answer and Affirmative Defenses (2025-06-09): Samsung filed its answer and affirmative defenses to XiFi's First Amended Complaint. Samsung denied the allegations of infringement and asserted various defenses.
- Defendants' Invalidity Contentions Served (2025-06-18): Samsung served its invalidity contentions.
Pre-Trial Motions of Substance
- Samsung Files IPR/PGR Petitions (2025-07-03 to 2025-07-21): Samsung filed eight inter partes review (IPR) petitions challenging eight of the originally asserted patents on July 3 and July 10, 2025. On July 21, 2025, Samsung filed three post-grant review (PGR) petitions challenging the remaining three patents that were eligible for PGR.
- Motion to Stay Pending IPR/PGR (Filed prior to 2026-03-12): Samsung filed a motion to stay the district court proceedings pending the outcome of its IPR and PGR petitions at the Patent Trial and Appeal Board (PTAB).
- Motion to Stay Denied (2026-03-12): Judge Rodney Gilstrap denied Samsung's Motion to Stay Proceedings Pending Inter Partes and Post-Grant Review. The court noted that a final written decision from the PTAB would not be due until January 10, 2027, over two months after the scheduled district court trial date of October 19, 2026. This proximity of the trial date to the anticipated PTAB final written decisions weighed against granting a stay, as did the active engagement in discovery.
Claim Construction (Markman) Outcomes
- Joint Claim Construction Statement Filed (2026-02-27): XiFi and Samsung submitted an amended joint claim construction statement in preparation for the Markman hearing, which included disputed claim terms and the parties' proposed constructions.
- Markman Hearing Held (2026-05-01): A Markman hearing was held on May 1, 2026, as indicated in the case overview. The court is expected to issue a claim construction order following this hearing. The court further ordered that the parties file a Joint Notice indicating whether the case should be referred for mediation within fourteen days of the issuance of the claim construction order.
Discovery Milestones
- Fact Discovery Deadline (2026-05-22): The deadline to complete fact discovery and file motions to compel discovery was May 22, 2026.
- Expert Witness Disclosures (2026-05-22 & 2026-06-12): The party with the burden of proof (XiFi) was required to serve expert witness disclosures by May 22, 2026. Disclosures for rebuttal expert witnesses are due by June 12, 2026.
- Expert Discovery Deadline (2026-06-22): The deadline to complete expert discovery is June 22, 2026.
Trial Events, Verdict, and Post-Trial Motions
- Jury Selection (2026-10-19): Jury selection and trial are currently set to begin on October 19, 2026, in Marshall, Texas.
Final Disposition or Present Posture
- The case is in active litigation in the Eastern District of Texas, proceeding through discovery and towards trial, with a Markman order pending.
Parallel PTAB IPR/PGR Proceedings
- Petitions Filed (2025-07-03 to 2025-07-21): Samsung filed eight IPR petitions and three PGR petitions across the eleven asserted patents.
- Institution Decisions: At least one IPR (IPR2025-01204 for U.S. Patent No. 11,818,591) has been filed and XiFi, as Patent Owner, has requested discretionary denial of institution. Samsung's petitions faced arguments from XiFi concerning the timing of the filings relative to the district court schedule and the overlap with district court arguments. It has also been noted that IPR2025-01206 for U.S. Patent No. 11,974,143 is "Pending - Instituted".
- Effect on Litigation: Judge Gilstrap explicitly denied Samsung's motion to stay the district court proceedings, citing the advanced stage of discovery and the late filing of the PTAB petitions in relation to the scheduled trial date. This indicates that the district court intends to proceed with its schedule independently of the PTAB outcomes, at least for now.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Robins Kaplan
- Aaron R. Fahrenkrog · lead counsel
- Logan J. Drew · of counsel
- Jessica L. Gutierrez · of counsel
- Rebecca Bact · case attorney
- Cyrus A. Morton · lead PTAB counsel
- Miller Fair Henry
- Andrea L. Fair · local counsel
- In-house counsel
- Jeff Salmon · in-house
I'll research plaintiff's counsel for XiFi Networks R&D, Inc. in this case.
Good leads. Let me dig deeper into the district court docket and firm/attorney details.
Plaintiff's Counsel of Record — XiFi Networks R&D, Inc.
Bottom line: XiFi is represented by a two-tier structure: Robins Kaplan LLP serves as national trial/appellate counsel (Minneapolis HQ, with Boston participation), and Miller Fair Henry, PLLC (Longview, Texas) supplies the Eastern District of Texas "of counsel"/local presence that signs the pleadings. XiFi also has in-house counsel who appear at depositions. The same Robins Kaplan team is handling the parallel PTAB proceedings, which is notable because the IPR/PGR track (final written decisions due December 2026) runs roughly in parallel with the October 19, 2026 trial.
Caveat on sourcing: I was unable to pull a live PACER docket sheet for this case in this session. The roster below is reconstructed from (i) the signature block of the operative complaint and the original complaint as reproduced in PTAB exhibits, (ii) PTAB mandatory notices and deposition transcripts in the co-pending IPRs/PGRs that identify the same counsel, and (iii) Law360's firm/attorney case listing. No sealed appearance or confidential-designation issue appears to be implicated in counsel's identity, but I have not been able to verify every notice of appearance filed in E.D. Tex. (e.g., whether each Robins Kaplan attorney has filed a formal E.D. Tex. notice of appearance versus relying on the complaint signature and pro hac vice orders).
District Court Team
| Attorney | Role | Firm / Office | Note |
|---|---|---|---|
| Aaron R. Fahrenkrog | Lead trial counsel of record (signature attorney on Complaint, Dkt. 1, and First Amended Complaint, Dkt. 13) | Robins Kaplan LLP — Minneapolis, MN (800 LaSalle Ave., Suite 2800) | Listed on the FAC as "admitted in this District" (MN Bar No. 0386673); also designated additional back-up counsel in the PTAB proceedings (pro hac vice to follow). |
| Andrea L. Fair | Of counsel / Texas local counsel (signature block on Complaint and FAC) | Miller Fair Henry, PLLC — Longview, TX (1507 Bill Owens Pkwy.) | Texas State Bar No. 24078488. A fixture of E.D. Tex. patent practice as local/of counsel for NPE plaintiffs — verified appearances for plaintiffs in Wilus Institute of Standards & Technology v. Samsung-related matters (No. 2:24-cv-00752-JRG), Headwater Research LLC (E.D. Tex.), and VirtaMove Corp. |
| Logan J. Drew | Of counsel / case attorney | Robins Kaplan LLP — Minneapolis, MN | Listed on the FAC signature block as "admitted in this District" (MN Bar No. 0389449). |
| Jessica L. Gutierrez | Of counsel / case attorney; back-up counsel in PTAB | Robins Kaplan LLP — Minneapolis, MN | Listed on the FAC (MN Bar No. 0396359, "to appear pro hac vice"); registered practitioner (Reg. No. 75,094) and designated back-up counsel in Samsung's IPRs/PGRs. |
| Rebecca Bact | Case attorney (appeared for XiFi at the Feb. 26, 2026 deposition of Dr. Mark Mahon in the district case) | Robins Kaplan LLP — Boston, MA (800 Boylston St., Suite 2500) | Identified in the deposition transcript as appearing "on behalf of the Plaintiff" in No. 2:24-cv-01057-JRG. Her formal E.D. Tex. appearance status (pro hac vice) is not confirmed in the sources reviewed. |
| Cyrus A. Morton | Lead PTAB counsel for XiFi (Patent Owner); senior member of the overall XiFi team | Robins Kaplan LLP — Minneapolis, MN | Reg. No. 44,954; designated Lead Counsel in XiFi's mandatory notices across Samsung's IPR/PGR challenges. Handles the discretionary-denial briefing against Samsung's petitions and the Patent Owner Responses. |
In-House Counsel
| Attorney | Role | Note |
|---|---|---|
| Jeff Salmon | In-house counsel, XiFi Networks R&D, Inc. | Identified as "XiFi In-House Counsel" in the appearance page of the Feb. 26, 2026 Mahon deposition transcript taken in this case. |
Cross-Reference / Consistency Notes
- Consistent with prior sections: This confirms the earlier observation that Quinn Emanuel filed the PTAB petitions while a separate firm handles XiFi's side; the mirror-image is that Robins Kaplan handles both XiFi's district court case and its PTAB defenses. The PTAB service addresses (CMorton@RobinsKaplan.com, JGutierrez@RobinsKaplan.com, AFahrenkrog@RobinsKaplan.com, RKXiFi@RobinsKaplan.com) match the district court team.
- Minor data quirk, flagged: In one reproduced filing, Andrea Fair's signature block lists the email "garrett@millerfairhenry.com" (Garrett C. Parish's address) rather than her own — this appears in other Miller Fair Henry filings as well and is likely a template carryover, not a substitution of counsel. Garrett Parish himself is not confirmed as counsel of record in this case.
- No contradiction with the case metadata found. Note, however, that the metadata's "patents at issue" field lists only 12,190,198, while the operative FAC asserts eleven patents — the same discrepancy already noted in the case overview.
- Samsung's side lists Quinn Emanuel partners in the same PTAB papers (James M. Glass, Patrick T. Schmidt, Benjamin Kleinman, Quincy Lu), confirming the earlier defendant-representatives section.
Sources: First Amended Complaint signature block, No. 2:24-cv-01057-JRG (E.D. Tex. Mar. 11, 2025), reproduced at https://www.docketalarm.com/cases/PTAB/PGR2025-00069/Samsung_Electronics_Co._Ltd._v._XiFi_Networks_R%26D_Inc/docs/10-01-2025-Patent_Owner/Exhibit-2003-Ex_2003.pdf; original Complaint signature block, reproduced at https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1558117](/patent/1558117)/download-documents; XiFi Patent Owner Mandatory Notices (Aug. 11, 2025), https://ptacts.uspto.gov/ptacts/public-informations/petitions/[1558255](/patent/1558255)/download-documents; Mahon deposition transcript (Feb. 26, 2026), Ex. 2030 in PGR2025-00069, https://www.docketalarm.com/cases/PTAB/PGR2025-00069/Samsung_Electronics_Co._Ltd._v._XiFi_Networks_R%26D_Inc/03-12-2026-Patent_Owner/Exhibit-2030-Ex_2030/; XiFi Networks R&D, Inc. v. Samsung Elecs. Co., No. 2:24-cv-01057-JRG, Dkt. 67 (E.D. Tex. Mar. 12, 2026) (stay denial), https://law.justia.com/cases/federal/district-courts/texas/txedce/2:2024cv01057/[234895](/patent/234895)/67/; Andrea Fair appearances in other E.D. Tex. matters, e.g., https://storage.courtlistener.com/recap/gov.uscourts.txed.[224022](/patent/224022)/gov.uscourts.txed.224022.371.0.pdf and https://archive.org/download/gov.uscourts.txed.[232954](/patent/232954)/gov.uscourts.txed.232954.13.0.pdf.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Quinn Emanuel Urquhart & Sullivan
- Sean S. Pak · lead counsel
- Patrick Thomas Schmidt · lead counsel
- Jason Clarence Williams · lead counsel
- Kevin Hardy · lead counsel
- Brady Huynh · lead counsel
- Jared Kneitel · lead counsel
- Gillam & Smith
- Melissa R. Smith · local counsel
- Harry "Gil" Gillam · local counsel
- In-house counsel
- Tim Jezek · in-house
- Matthew Bathon · in-house
- Phillip Lee · in-house
- Jordan Flournoy · in-house
Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. are represented by several attorneys from Quinn Emanuel Urquhart & Sullivan, LLP, and local counsel from Gillam & Smith LLP. Additionally, Samsung has in-house legal counsel involved in managing their patent litigation docket.
Here's a breakdown of the counsel of record for Samsung:
Quinn Emanuel Urquhart & Sullivan, LLP (Lead Counsel)
- Sean S. Pak: Partner, based in San Francisco. He is listed as defense counsel in the Markman hearing minute entry. Quinn Emanuel is a prominent firm for patent litigation, and Mr. Pak is known for his work in this area.
- Patrick Thomas Schmidt: Partner, based in Los Angeles. He is listed as defense counsel and has participated in filing documents such as the amended joint claim construction statement.
- Jason Clarence Williams: Attorney, based in New York. He is listed as admitted in the Eastern District of Texas.
- Kevin Hardy: Partner, based in Washington D.C. He is listed as counsel for Defendants and receives electronic service.
- Brady Huynh: Attorney. He is listed as defense counsel in the Markman hearing minute entry.
- Jared Kneitel: Attorney. He is listed as defense counsel in the Markman hearing minute entry.
Gillam & Smith LLP (Local Counsel)
- Melissa R. Smith: Partner, based in Marshall, Texas. She is Texas State Bar No. 24001351 and is listed as counsel for Defendants. She also requested the transcript for the May 1, 2026 Markman Hearing.
- Harry "Gil" Gillam: Partner, based in Marshall, Texas. He is listed as defense counsel in the Markman hearing minute entry.
O'Melveny & Myers LLP (Counsel for PTAB IPRs)
While the district court denied a stay pending PTAB reviews, O'Melveny & Myers LLP represents Samsung in the inter partes review (IPR) petitions.
- Benjamin Haber: Based in Los Angeles, CA.
- William M. Fink: Based in Washington, DC.
- Patric M. Reinbold: Based in Washington, DC.
- Caitlin Hogan: Based in New York, NY.
Samsung Electronics (In-house Counsel)
Samsung employs in-house legal counsel to manage their intellectual property matters and coordinate litigation.
- Tim Jezek: Principal Legal Counsel at Samsung Electronics America, focusing on IP litigation and related policy issues. He has over two decades of litigation and intellectual property counseling experience.
- Matthew Bathon: Principal Legal Counsel at Samsung Electronics, responsible for coordinating Samsung's ITC and district court dockets. He previously was a partner at Steptoe LLP, focusing on ITC and district court IP disputes.
- Phillip Lee: Principal Legal Counsel at Samsung Electronics US IP Center. He has extensive experience in patent litigation, prosecution, and licensing, and manages a docket of patent cases with outside counsel.
- Jordan Flournoy: Senior Director, Litigation for Samsung Electronics America, Inc.