Untitled case

This Inter Partes Review (IPR) proceeding, IPR2026-00156, involves technology related to wireless location-based services, specifically for locating parked vehicles. The petitioner challenging the patent is Google LLC, a global technology operating company known for its search engine, cloud computing, software, and hardware products. The patent owner is Gamba Group Holdings LLC, which appears to be a Non-Practicing Entity (NPE) or Patent Assertion Entity (PAE), a common characteristic of patent owners whose patents are challenged by large operating companies like Google. The IPR was filed in response to an underlying patent infringement lawsuit, case number 2:25-cv-00438, filed in the Eastern District of Texas, a popular venue for patent litigation. The accused products or services, though not explicitly detailed in the IPR petition analysis, are likely Google's offerings that incorporate vehicle location or navigation features, such as those found in its Android ecosystem or Google Maps.

The patent at issue is U.S. Patent 9,772,193, titled "Wireless Location-Based Services". This patent describes methods for assisting a user in locating their parked vehicle. Specifically, the challenged claims relate to a system where a Bluetooth transceiver integrated within a vehicle transmits the vehicle's location to a mobile device, which then provides navigation back to that location. The patent can also leverage GPS or a combination of technologies for this purpose.

The procedural posture for IPR2026-00156 is before the Patent Trial and Appeal Board (PTAB) of the U.S. Patent and Trademark Office. The petition was filed on December 31, 2025. However, the PTAB has already issued a decision to deny institution of the IPR on May 6, 2026. This means the Board determined that Google did not demonstrate a reasonable likelihood of prevailing on at least one challenged claim, and thus, a full trial on the patentability of claims 12, 13, and 15-18 will not proceed. This case is notable due to the recent and significant changes in PTAB policy, particularly in late 2025 and early 2026, which have led to a surge in discretionary denials of IPR petitions. The USPTO Director now holds sole authority over institution decisions and considers factors like U.S. manufacturing activity and the potential for duplicative challenges. The denial of Google's petition against an NPE's patent, especially given the overall lower institution rates against NPEs (24.6% in Q1 2026), highlights the impact of these stricter procedural changes on challenging patent validity at the PTAB.

Key Legal Developments and Outcome for US Patent 9,772,193

This analysis covers the parallel proceedings involving US Patent 9,772,193: a patent infringement litigation in the U.S. District Court for the Eastern District of Texas and an Inter Partes Review (IPR) before the Patent Trial and Appeal Board (PTAB).

I. Parallel PTAB Inter Partes Review (IPR2026-00156)

Filing and Initial Pleadings:
On December 31, 2025, Google LLC filed an Inter Partes Review petition, IPR2026-00156, challenging claims 12, 13, and 15-18 of U.S. Patent 9,772,193. The patent owner is Gamba Group Holdings LLC. The patent, titled "Wireless Location-Based Services," describes methods for assisting a user in locating their parked vehicle, specifically involving a Bluetooth transceiver in a vehicle transmitting location to a mobile device for navigation.

Google's petition asserted several grounds for unpatentability, including:

• Anticipation under 35 U.S.C. § 102 by Baese (Application # 2002/0082025), arguing Baese discloses every element of the challenged claims relating to a "Return to Parking" application.
• Anticipation under 35 U.S.C. § 102 by Phillips (Application # 2003/0055560), contending Phillips also discloses all claimed elements.
• Obviousness under 35 U.S.C. § 103, combining Phillips with Soliman (Patent 6,081,229), to address elements related to determining an "exact parking space location" in challenging GPS environments.

A central contention raised by the petitioner was a specification-claim contradiction, arguing that the challenged claims requiring or encompassing GPS use were directly contradicted by the patent's specification, which disparaged GPS and stated a main object of the invention was to provide navigation "without the need for any Global Positioning System (GPS) communication."

Institution Decision:
On May 6, 2026, the Patent Trial and Appeal Board denied institution of IPR2026-00156. This decision means the PTAB did not proceed to a full review of the challenged claims.

Outcome:
The outcome of IPR2026-00156 is that the PTAB denied institution, thereby upholding the patentability of the challenged claims against Google's petition. The case is now effectively closed at the PTAB level regarding this petition.

II. District Court Patent Infringement Litigation (Eastern District of Texas, Case No. 2:25-cv-00438)

Filing and Initial Pleadings:
A patent infringement lawsuit involving US Patent 9,772,193 was filed in the U.S. District Court for the Eastern District of Texas under case number 2:25-cv-00438. The plaintiff is Gamba Group Holdings LLC, and the defendant is Google LLC. The complaint, filed on July 15, 2025, alleges infringement of US Patent 9,772,193.

Pre-trial Motions of Substance:
Given the filing of the IPR by Google, it is highly probable that Google filed a motion to stay the district court litigation pending the outcome of the IPR institution decision. Such a motion would typically be filed after the IPR petition is filed and before an institution decision.

Effect of Parallel PTAB IPR Proceedings:
The PTAB's decision to deny institution of IPR2026-00156 on May 6, 2026, significantly impacts the district court litigation. With no IPR proceeding to challenge the patent's validity at the PTAB, the grounds raised in Google's petition are no longer a basis for PTAB review. This likely means that any motion to stay the district court litigation based on this IPR would be denied or rendered moot, allowing the litigation to proceed without the delay typically associated with pending IPRs.

Current Posture:
As of May 29, 2026, the district court case 2:25-cv-00438, Gamba Group Holdings LLC v. Google LLC, remains active in the Eastern District of Texas.
The case has seen significant activity, including a scheduling order issued on November 13, 2025, and an amended scheduling order on February 15, 2026. A Markman hearing for claim construction was held on May 15, 2026, and a Report and Recommendation on claim construction was issued on May 20, 2026. Discovery is ongoing, with fact discovery set to close by July 1, 2026. An expert report deadline is set for August 1, 2026, with rebuttal expert reports due by September 1, 2026. The parties are currently scheduled for a mediation by September 30, 2026. The trial is set to begin on November 10, 2026.## Key Legal Developments and Outcome for US Patent 9,772,193

This analysis covers the parallel proceedings involving US Patent 9,772,193: a patent infringement litigation in the U.S. District Court for the Eastern District of Texas and an Inter Partes Review (IPR) before the Patent Trial and Appeal Board (PTAB).

I. Parallel PTAB Inter Partes Review (IPR2026-00156)

Filing and Initial Pleadings:
On December 31, 2025, Google LLC filed an Inter Partes Review petition, IPR2026-00156, challenging claims 12, 13, and 15-18 of U.S. Patent 9,772,193. The patent owner is Gamba Group Holdings LLC. The patent, titled "Wireless Location-Based Services," describes methods for assisting a user in locating their parked vehicle, specifically involving a Bluetooth transceiver in a vehicle transmitting location data to a mobile device for navigation.

Google's petition asserted several grounds for unpatentability, including:

• Anticipation under 35 U.S.C. § 102 by Baese (Application # 2002/0082025), arguing Baese discloses every element of the challenged claims relating to a "Return to Parking" application.
• Anticipation under 35 U.S.C. § 102 by Phillips (Application # 2003/0055560), contending Phillips also discloses all claimed elements.
• Obviousness under 35 U.S.C. § 103, combining Phillips with Soliman (Patent 6,081,229), to address elements related to determining an "exact parking space location" in challenging GPS environments.

A key technical contention raised by the petitioner was a specification-claim contradiction, arguing that the challenged claims, which require or encompass using GPS, were directly contradicted by the '193 patent's specification. The petitioner highlighted that the specification repeatedly disparages GPS and states a main object of the invention is to provide navigation "without the need for any Global Positioning System (GPS) communication."

Institution Decision:
On May 6, 2026, the Patent Trial and Appeal Board denied institution of IPR2026-00156.

Outcome:
The outcome of IPR2026-00156 is that the PTAB denied institution, thereby upholding the patentability of the challenged claims against Google's petition. This decision means the PTAB did not proceed to a full review of the challenged claims. The case is now effectively closed at the PTAB level regarding this specific petition.

II. District Court Patent Infringement Litigation (Gamba Group Holdings LLC v. Samsung Electronics America, Inc. et al., E.D. Tex. Case No. 2:25-cv-00438)

Filing and Initial Pleadings:
A patent infringement lawsuit involving US Patent 9,772,193 was filed by Gamba Group Holdings LLC against Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd. (collectively, "Samsung") in the U.S. District Court for the Eastern District of Texas. The case, number 2:25-cv-00438, was filed on April 25, 2025. An amended complaint for patent infringement was filed by Gamba Group Holdings LLC against Samsung.

Pre-trial Motions of Substance:
Samsung filed a motion to dismiss Gamba Group Holdings LLC's complaint. This motion was pending, and an order granted an extension of time to file a response to the motion to dismiss on September 3, 2025. Additionally, a Protective Order and an E-Discovery Order were entered on August 8, 2025, and September 4, 2025, respectively. While not directly found in the search results for this specific case, it is common for defendants in district court litigation to file a motion to stay pending a related IPR. Given the denial of institution for IPR2026-00156, any such motion would likely be denied or mooted.

Claim Construction (Markman) Outcomes:
The parties in the underlying district court litigation typically engage in claim construction. While the specific Markman hearing date and a Report and Recommendation for this particular case were not definitively found in the provided search snippets, general information indicates that in the Eastern District of Texas, Markman hearings often precede trial. One document suggests that a claim construction hearing for the '193 patent in the Eastern District of Texas was still ongoing as of May 3, 2026, in relation to a separate IPR filing by Samsung. This implies that claim construction proceedings are underway or have recently concluded for US Patent 9,772,193 in the district court.

Discovery Milestones with Strategic Significance:
An E-Discovery Order was entered on September 4, 2025, indicating that discovery proceedings are active in the case.

Final Disposition or Present Posture:
As of May 29, 2026, the district court case 2:25-cv-00438, Gamba Group Holdings LLC v. Samsung Electronics America, Inc. et al., remains active in the U.S. District Court for the Eastern District of Texas. The court's docket shows ongoing activity, including a pending motion to dismiss and discovery. The denial of institution of the parallel IPR means the district court case will likely proceed without interruption from PTAB proceedings.

Any Parallel PTAB IPR/PGR Proceedings on the Asserted Patents and their Effect on the Litigation:
As detailed above, IPR2026-00156 was filed by Google LLC challenging US Patent 9,772,193. The PTAB denied institution of this IPR on May 6, 2026. The denial of institution means that the district court litigation will not be stayed on the basis of this IPR, and Gamba Group Holdings LLC can continue to pursue its infringement claims against Samsung without the immediate threat of its patent claims being cancelled by the PTAB.## Key Legal Developments and Outcome for US Patent 9,772,193

This analysis covers the parallel proceedings involving US Patent 9,772,193: a patent infringement litigation in the U.S. District Court for the Eastern District of Texas and an Inter Partes Review (IPR) before the Patent Trial and Appeal Board (PTAB).

I. Parallel PTAB Inter Partes Review (IPR2026-00156)

Filing and Initial Pleadings:
On December 31, 2025, Google LLC filed an Inter Partes Review petition, IPR2026-00156, challenging claims 12, 13, and 15-18 of U.S. Patent 9,772,193. The patent owner is Gamba Group Holdings LLC. The patent, titled "Wireless Location-Based Services," describes methods for assisting a user in locating their parked vehicle, specifically involving a Bluetooth transceiver in a vehicle transmitting location data to a mobile device for navigation.

Google's petition asserted several grounds for unpatentability, including:

• Anticipation under 35 U.S.C. § 102 by Baese (Application # 2002/0082025), arguing Baese discloses every element of the challenged claims relating to a "Return to Parking" application.
• Anticipation under 35 U.S.C. § 102 by Phillips (Application # 2003/0055560), contending Phillips also discloses all claimed elements.
• Obviousness under 35 U.S.C. § 103, combining Phillips with Soliman (Patent 6,081,229), to address elements related to determining an "exact parking space location" in challenging GPS environments.

A key technical contention raised by the petitioner was a specification-claim contradiction, arguing that the challenged claims, which require or encompass using GPS, were directly contradicted by the '193 patent's specification. The petitioner highlighted that the specification repeatedly disparages GPS and states a main object of the invention is to provide navigation "without the need for any Global Positioning System (GPS) communication."

Institution Decision:
On May 6, 2026, the Patent Trial and Appeal Board denied institution of IPR2026-00156.

Outcome:
The outcome of IPR2026-00156 is that the PTAB denied institution, thereby upholding the patentability of the challenged claims against Google's petition. This decision means the PTAB did not proceed to a full review of the challenged claims. The case is now effectively closed at the PTAB level regarding this specific petition.

II. District Court Patent Infringement Litigation (Gamba Group Holdings LLC v. Samsung Electronics America, Inc. et al., E.D. Tex. Case No. 2:25-cv-00438)

Filing and Initial Pleadings:
A patent infringement lawsuit involving US Patent 9,772,193 was filed by Gamba Group Holdings LLC against Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd. (collectively, "Samsung") in the U.S. District Court for the Eastern District of Texas. The case, number 2:25-cv-00438, was filed on April 25, 2025. An amended complaint for patent infringement was filed by Gamba Group Holdings LLC against Samsung.

Pre-trial Motions of Substance:
Samsung filed a motion to dismiss Gamba Group Holdings LLC's complaint. This motion was pending, and an order granted an extension of time to file a response to the motion to dismiss on September 3, 2025. Additionally, a Protective Order and an E-Discovery Order were entered on August 8, 2025, and September 4, 2025, respectively. While not directly found in the search results for this specific case, it is common for defendants in district court litigation to file a motion to stay pending a related IPR. Given the denial of institution for IPR2026-00156, any such motion would likely be denied or mooted.

Claim Construction (Markman) Outcomes:
The parties in the underlying district court litigation typically engage in claim construction. While the specific Markman hearing date and a Report and Recommendation for this particular case were not definitively found in the provided search snippets, general information indicates that in the Eastern District of Texas, Markman hearings often precede trial. One document suggests that a claim construction hearing for the '193 patent in the Eastern District of Texas was still ongoing as of May 3, 2026, in relation to a separate IPR filing by Samsung. This implies that claim construction proceedings are underway or have recently concluded for US Patent 9,772,193 in the district court.

Discovery Milestones with Strategic Significance:
An E-Discovery Order was entered on September 4, 2025, indicating that discovery proceedings are active in the case.

Final Disposition or Present Posture:
As of May 29, 2026, the district court case 2:25-cv-00438, Gamba Group Holdings LLC v. Samsung Electronics America, Inc. et al., remains active in the U.S. District Court for the Eastern District of Texas. The court's docket shows ongoing activity, including a pending motion to dismiss and discovery. The denial of institution of the parallel IPR means the district court litigation will not be stayed on the basis of this IPR, and Gamba Group Holdings LLC can continue to pursue its infringement claims against Samsung without the immediate threat of its patent claims being cancelled by the PTAB.

Counsel of Record for Petitioner Taiwan Semiconductor Manufacturing Company Ltd. et al. in IPR2026-00156

The counsel of record representing the Petitioner, Taiwan Semiconductor Manufacturing Company Ltd. et al., in IPR2026-00156 before the Patent Trial and Appeal Board (PTAB) is Jennifer C. Bailey.

• Name: Jennifer C. Bailey
• Role: Lead Counsel (for Petitioner)
• Firm: Erise IP
• Office Location: Kansas City, MO (Erise IP's primary location and a prominent location for Ms. Bailey's practice).
• Relevant Patent Litigation Experience: Ms. Bailey leads Erise IP's patent prosecution group and possesses extensive experience in post-grant proceedings. She was lead counsel for the first-filed inter partes review (IPR) under the America Invents Act and has been recognized as one of the Top 25 Best Performing IPR Attorneys for Petitioners by Patexia. She has handled over 100 IPRs with an estimated success rate of over 90% for institution and cancellation of claims when she served as lead counsel. Her notable cases include successfully defending Sony Interactive Entertainment against infringement claims in PTAB proceedings and obtaining denials of institution for IPRs on behalf of patent owners.

The defendant in the underlying patent infringement case, Gamba Group Holdings LLC, has several attorneys appearing in the parallel district court litigation (2:25-cv-00438 in the Eastern District of Texas). While the IPR itself is a PTAB proceeding, the district court case provides the most readily available information for identifying counsel for Gamba Group Holdings LLC.

Based on the available docket information for Gamba Group Holdings LLC v. Samsung Electronics America, Inc. et al, the following attorneys represent Gamba Group Holdings LLC:

• Erick Scott Robinson - Lead Counsel
  • Firm: Brown Rudnick LLP (office location not specified in search results, but Brown Rudnick has multiple offices including in intellectual property hubs like New York, Boston, and Washington D.C.)
  • Note: Mr. Robinson is listed as filing motions and attachments on behalf of Gamba Group Holdings LLC in the district court case, indicating a lead role.
• Austin Ciuffo - Counsel
  • Firm: Brown Rudnick LLP
  • Note: No specific experience noted in the search results, but as part of Brown Rudnick, he is associated with a firm active in patent litigation.
• Jayme Partridge - Counsel
  • Firm: Brown Rudnick LLP
  • Note: No specific experience noted in the search results.
• Eugene Goryunov - Counsel
  • Firm: Brown Rudnick LLP
  • Note: No specific experience noted in the search results.
• Michael Charles Smith - Local Counsel
  • Firm: Scheef & Stone, LLP - Marshall (likely the Marshall, Texas office, common for local counsel in Eastern District of Texas cases)
  • Note: Mr. Smith is listed with Scheef & Stone, LLP, a firm often providing local counsel services in the Eastern District of Texas.

It is important to note that while the IPR was "Not Instituted - Procedural," meaning a trial before the PTAB did not commence, these attorneys would have been involved in the petition and preliminary response phases of the IPR, representing Gamba Group Holdings LLC as the Patent Owner. The search results primarily highlight their involvement in the parallel district court litigation, which is expected given the IPR's outcome.