Litigation
Untitled case
Not Instituted - ProceduralIPR2025-01551
Patents at issue (1)
Defendants (1)
Summary
An Inter Partes Review (IPR) was filed against patent 8554671, which was subsequently not instituted due to procedural reasons.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Case Overview: PayGeo LLC v. Samsung Electronics Co., Ltd. et al.
This patent infringement litigation centers on an action filed by PayGeo, LLC (Plaintiff) against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (Defendants) in the U.S. District Court for the Eastern District of Texas, Case No. 2:25-cv-00334. The suit, initiated on April 1 or 2, 2025, asserts infringement of multiple patents, including U.S. Patent No. 8,554,671. In response to this litigation, Samsung filed an Inter Partes Review (IPR) petition, IPR2025-01551, challenging the validity of patent 8,554,671 before the Patent Trial and Appeal Board (PTAB). However, this IPR was not instituted due to procedural reasons.
PayGeo, LLC's business model presents a mixed profile. While some records from the district court litigation refer to PayGeo LLC as an "Operating Company," its primary public activity appears to be the assertion of patents against major technology companies. The company's patent portfolio, including U.S. Patent No. 12,014,347 (also asserted in the district court case), describes technology for preventing fraudulent financial transactions and mobile digital wallet applications, such as a "Good Deal" payment platform and user profiling capabilities. This technology is allegedly infringed by Samsung's Wallet, Pay, and Knox platforms, which offer secure transaction and payment initiation functionalities. [cite: 3 (previous search)] The involvement of "PICCADILLY PATENT FUNDING LLC, AS SECURITY HOLDER" in an assignment involving PayGeo LLC further suggests a strategy focused on patent monetization. [cite: 7 (previous search)] Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. are well-known global technology giants.
The procedural posture of this case involves parallel proceedings in both district court and before the PTAB. The district court case, 2:25-cv-00334, is currently in the discovery phase, with a Markman hearing set for October 21, 2026, and a jury selection scheduled for April 19, 2027, before District Judge Robert W. Schroeder III and Magistrate Judge Roy S. Payne. [cite: 10 (previous search)] The Eastern District of Texas is a prominent venue for patent litigation, often favored by patent owners due to its reputation for efficiency and proclivity for finding patent validity and infringement. The non-institution of IPR2025-01551 by the PTAB due to procedural reasons means that Samsung's challenge to the validity of patent 8,554,671 will not proceed at the PTAB, potentially leaving the validity determination solely to the district court. While the specific procedural reason for the denial of institution for IPR2025-01551 is not publicly detailed, such denials often stem from the PTAB Director's discretionary authority, which in 2025 saw a trend of denials without extensive public reasoning, based on factors such as the stage of parallel district court litigation or "settled expectations."
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Key Legal Developments and Outcome in Paygeo LLC v. Samsung Electronics Co., Ltd. et al and Parallel IPR Proceedings
This case involves a patent infringement lawsuit filed by Paygeo LLC against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the Eastern District of Texas, as well as a related Inter Partes Review (IPR) proceeding at the Patent Trial and Appeal Board (PTAB) concerning U.S. Patent 8,554,671. The IPR was ultimately not instituted due to procedural reasons.
Parallel PTAB IPR Proceedings
IPR2025-01551 (U.S. Patent 8,554,671)
An Inter Partes Review petition, IPR2025-01551, was filed against U.S. Patent 8,554,671, one of the patents asserted by Paygeo LLC. The status of this IPR is "Not Instituted - Procedural." While the specific procedural reason for the denial of institution for IPR2025-01551 is not detailed in the available information, recent PTAB trends in 2025 and 2026 have seen discretionary denials based on factors such as "settled expectations," "real party in interest" issues, or "material error" during patent prosecution. The denial means the PTAB did not proceed to a full merits review of the patentability of the challenged claims.
District Court Litigation: Paygeo, LLC v. Samsung Electronics Co., Ltd. et al. (E.D. Tex. Case No. 2:25-cv-00334)
Filing & Initial Pleadings:
- Complaint Filed (2025-04-02): Paygeo, LLC initiated a patent infringement lawsuit against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the U.S. District Court for the Eastern District of Texas. The complaint asserted infringement of five U.S. Patents, including U.S. Patent No. 8,554,671. The case was assigned to Judge Robert W. Schroeder, III, and referred to Magistrate Judge Roy S. Payne.
- Answer to Complaint (2025-07-29): Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed their Answer to Paygeo's Complaint.
- Motion to Strike Affirmative Defenses (2025-08-20): Paygeo, LLC filed an "Opposed Motion to Strike Defendants' Affirmative Defenses" (Dkt. 33). This motion sought to strike Samsung's Fourteenth Defense, which included waiver, estoppel, acquiescence, laches, unclean hands, and/or implied license. Paygeo argued that laches is no longer a defense to patent infringement and that Samsung's assertion of lack of knowledge of the asserted patents contradicted several of these equitable defenses.
- Sur-Reply to Motion to Strike (2025-09-19): Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd. filed a Sur-Reply to Paygeo's Motion to Strike their affirmative defenses.
Pre-trial Motions of Substance:
- Extension of Time (2025-04-22): An order was granted for an extension of time for the Defendants to answer.
- Motion for Extension of Time (2025-09-18): Magistrate Judge Roy S. Payne signed an order granting a motion for an extension of time to file a response/reply related to a Motion for Judgment on the Pleadings pursuant to Federal Rule of Civil Procedure 12(c). Responses were due by September 19, 2025, and replies by October 3, 2025.
Discovery Milestones:
- Invalidity Contentions (2025-11-03): Defendants' Invalidity Contentions were served on November 3, 2025.
Trial Events and Final Disposition:
- Trial Scheduled (2027-04-19): A trial in the District Court Action is currently scheduled for April 19, 2027.
- Current Status: The case is currently active and open.
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
The counsel of record representing the petitioner(s) (plaintiff(s) in the context of initiating the IPR) in IPR2025-01551, Samsung Electronics Co., Ltd. et al., is primarily:
Joshua L. Goldberg
- Role: Lead Counsel (as indicated by "Goldberg, Joshua et al." in the PTAB document and his leadership role in PTAB practice).
- Firm: Finnegan, Henderson, Farabow, Garrett & Dunner, LLP.
- Office Location: Reston, VA.
- Relevant Patent Litigation Experience: Joshua Goldberg is a partner and former leader of Finnegan's PTAB trials section, specializing in inter partes review (IPR), covered business method (CBM), and post-grant review (PGR) proceedings before the Patent Trial and Appeal Board (PTAB) and appeals to the Federal Circuit. He has served as lead or backup counsel in over 350 IPRs and PGRs across various technologies, including consumer electronics, software, and semiconductors, and co-authors "The Practitioner's Guide to Trials Before the Patent Trial and Appeal Board".
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- Finnegan, Henderson, Farabow, Garrett & Dunner
- Charles H. Suh · of counsel
- Gerald F. Ivey · attorney
- Nicholas A. Cerulli · attorney
- Connor Michael McGregor · attorney
- Wyatt Lawrence Bazrod · attorney
- Christina Ji-Hye Yang · attorney
- Christopher T. Blackford · attorney
- Parmanand K. Sharma · attorney
- Benjamin R. Schlesinger · attorney
- Gillam & Smith
- Melissa Richards Smith · local counsel
- In-house counsel
- Tim Jezek · in-house
- Phillip Lee · in-house
- Matthew Bathon · in-house
The defendants, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., are represented by a team of attorneys from several law firms, as well as in-house counsel.
Outside Counsel:
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
- Charles H. Suh (Of Counsel) - Reston, VA office. He appeared pro hac vice on behalf of Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd.. Finnegan is a prominent intellectual property law firm, and Mr. Suh's appearance suggests a key role in the patent litigation.
- Gerald F. Ivey (Attorney) - Washington, D.C. office.
- Nicholas A. Cerulli (Attorney) -
- Connor Michael McGregor (Attorney) -
- Wyatt Lawrence Bazrod (Attorney) -
- Christina Ji-Hye Yang (Attorney) -
- Christopher T. Blackford (Attorney) - Washington, D.C. office.
- Parmanand K. Sharma (Attorney) -
- Benjamin R. Schlesinger (Attorney) - Atlanta, GA office.
Gillam & Smith, LLP
- Melissa Richards Smith (Attorney) - Tyler, TX office.. Gillam & Smith is a well-known local counsel firm in the Eastern District of Texas for patent litigation. Melissa Smith has represented Samsung in other Eastern District of Texas patent cases.
In-House Counsel for Samsung:
Samsung Electronics has a robust in-house legal team dedicated to managing patent litigation.
- Tim Jezek (Principal Legal Counsel, Samsung Electronics America) - Focuses on IP litigation and related policy issues. He has over two decades of litigation and intellectual property counseling experience.
- Phillip Lee (Principal Legal Counsel, Samsung Electronics US IP Center) - A veteran litigator with experience in patent litigation, patent prosecution, and licensing. He manages a docket of patent cases with outside counsel law firms, negotiates settlements, and advises on IP issues.
- Matthew Bathon (Principal Legal Counsel, Samsung Electronics) - Coordinates Samsung's International Trade Commission (ITC) and district court dockets.
It is worth noting that while IPR2025-01551 was not instituted, other IPRs related to Paygeo LLC's patents were filed by Samsung. In related IPR2025-01554 and IPR2025-01555, Joshua Goldberg is listed as petitioner's counsel, representing Samsung.