Lab Technology LLC v. Samsung Electronics Co., Ltd.

I'll research this case thoroughly before drafting the overview.

Good foundational material. Let me now dig into the '973 patent specifically, the patent family, and any PTAB/IPR linkage.

Let me check for PTAB proceedings and the broader Lab Technology campaign.

Case Overview and Background

Parties. Plaintiff Lab Technology LLC is a patent-assertion entity (NPE/PAE), registered in New Mexico, that Unified Patents describes flatly as "an NPE." Its asserted portfolio traces to TP Lab, Inc. (Palo Alto, CA), the original assignee and a company co-founded by inventor Chi Fai Ho (formerly Nokia/Amber Networks). Lab Technology is represented in this suit by Isaac Phillip Rabicoff of Rabicoff Law LLC, a high-volume patent-plaintiff's firm — a strong signal of a portfolio-licensing rather than operating-company posture. The defendant is the Samsung entity named in the docket as [Samsung Electronics America, Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.), the U.S. sales/marketing subsidiary of the Korean parent (the case metadata caption names Samsung Electronics Co., Ltd.; PACER, RPX, UniCourt and Patexia all list Samsung Electronics America, Inc. as the filed defendant — a discrepancy worth resolving against the complaint exhibits before relying on either name). Samsung is a global consumer-electronics and smartphone manufacturer; it never entered an appearance in this case.

Accused technology and patents. Lab Technology filed this case (2:24-cv-00324) and a parallel Verizon case (2:24-cv-00323) on May 3, 2024, asserting five patents from the former TP Lab portfolio: U.S. 8,498,388 ('388 — delivering/receiving an "announcement" at a telephone), 8,503,973 ('973 — the metadata-flagged patent, "Method and system for obtaining emergency caller location"), 8,515,032 ('032 — recording/analyzing voice-message usage), 9,219,982 ('982 — automatically refreshing a telephone display with location-relevant "communication services"), and 9,578,570 ('570 — switching an IM-based voice call to a second call). The '973 patent (App. 13/337,038, filed Dec. 23, 2011, issued Aug. 6, 2013, priority traced to July 14, 2005 via the 11/182,219 → U.S. 7,272,402 chain; inventors Ho and Chiu) claims, in representative claim 1, a mobile phone that obtains its current wireless base-station identity, compares it to a stored base-station identity, and sends a corresponding subscriber location to the phone system — i.e., handset-side detection that the phone has moved so that emergency/other location-based calls resolve to the right location. Per RPX's June 2024 report, Samsung was accused of infringing the emergency-location family through products including the Galaxy S24+ smartphone supporting Enhanced 911 (E911), and specifically '982 through the Galaxy Watch6, '388 through the Galaxy S23 Ultra (Bixby), and '570 through the Galaxy S10. Notably, the public record does not reflect USPTO assignment of the '973 (or '388/'570) patents from TP Lab to Lab Technology; Lab Technology merely "pleads ownership."

Posture, venue, and why it matters. The case was assigned to District Judge Rodney Gilstrap with Magistrate Judge Roy S. Payne in the Marshall Division of the E.D. Tex. — historically the highest-volume patent-plaintiff venue and Judge Gilstrap the district's most prolific patent judge, which is exactly why an NPE would file there. The case lasted 11 days: Lab Technology filed a Notice of Voluntary Dismissal on May 7, 2024 (Dkt. 5), and Judge Gilstrap entered an Order Dismissing Case on May 13, 2024 (Dkt. 6) under Fed. R. Civ. P. 41(a)(1)(A)(i), dismissing all claims without prejudice and denying all other relief as moot. There was no answer, no preliminary-injunction motion, no claim construction, and no merits ruling. The dismissal-without-prejudice posture means no res judicata effect and no fee award to Samsung; the same portfolio remains immediately re-assertable. The case is notable less for what was decided than for its role in a coordinated filing wave: Lab Technology followed the two May 2024 suits with June 2024 complaints in the same venue against Amazon (2:24-cv-00409), Anritsu (411), AT&T (412), Bose (413), Ericsson (414), Quectel (415), and Stryker (416). The '973 patent specifically had prior assertion history — Local Intelligence, LLC (a Dominion Harbor Enterprises affiliate) sued Samsung on the same emergency-location family before 2020, but that case was dismissed with prejudice in January 2019 and the family was transferred back to TP Lab in November 2019 before re-emerging with Lab Technology. Meanwhile, Unified Patents ran a PATROLL crowdsourced prior-art contest on the '973 patent (a $2,000 award announced January 3, 2025) and filed an ex parte reexamination against the '388 patent on November 27, 2024 — evidence the defense-side validity campaign targeted this portfolio, though RPX Insight's patent page for the '973 lists zero petitions, and I found no IPR or PGR on the '973 patent itself (IPR2017-01686/-01687 involve unrelated patents). The broader market significance is that E911/emergency-call location is heavily regulated and standardized functionality embedded across virtually every smartphone and carrier network, so claims of this breadth (with 2005 priority and handset-side comparison limitations) pose an industry-wide rather than Samsung-specific risk.

Sourcing note. Party identities, counsel, docket events (Dkts. 1–7), judges, dates, and the Rule 41 order text are confirmed by PACER-derived records via UniCourt, Patexia, and RPX Insight. The patent descriptions, accused products, TP Lab/Local Intelligence provenance, and the June 2024 filing wave come from RPX ("Seven Defendants Hit with Patents from Former TP Lab Portfolio," June 8, 2024) and a May 31, 2024 Mondaq article. Validity-challenge activity comes from Unified Patents' own announcements. I did not independently verify a settlement or license tied to the dismissal, and the complaint's claim charts (Exhibits 4–10) were not publicly available, so the precise accused-feature mapping for the '973 patent beyond the E911/Galaxy S24+ allegation is not well-sourced.

I'll research this case across multiple sources.

The case was dismissed in just 11 days. Let me check for parallel PTAB proceedings and the broader campaign context.

Bottom Line

This case never progressed beyond the pleading stage. It was filed 2024-05-03 and closed 2024-05-13 — an 11-day docket — after the plaintiff filed a unilateral Notice of Voluntary Dismissal and Judge Gilstrap entered a one-page order dismissing everything without prejudice under Fed. R. Civ. P. 41(a)(1)(A)(i). There is no answer, counterclaim, motion practice, Markman ruling, discovery, trial, or appeal to report. Because the dismissal was unilateral and pre-answer, it is a "no-merits" disposition with no preclusive effect.

I should also flag a party-name discrepancy at the outset. The docket and every docket-derived database (PACER/UniCourt, Patexia, RPX) name the defendant as Samsung Electronics America, Inc. — the U.S. subsidiary — not Samsung Electronics Co., Ltd., the Korean parent named in your case metadata. The complaint itself was docketed "against Samsung Electronics America, Inc." (UniCourt docket, Doc. #1). One third-party blog (PatSnap) lists "Samsung Electronics Co., Ltd.," which appears to be an error. Per your operating rules I treat the metadata as authoritative for party names, but the underlying record says otherwise.

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Chronology

Total: 7 docket entries. Zero defendant filings.

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1. Filing & Initial Pleadings

• Complaint (Dkt. 1, 2024-05-03). Filed by Lab Technology LLC, a New Mexico entity, through Isaac Phillip Rabicoff of Rabicoff Law LLC — a solo practitioner who has filed a high volume of NPE complaints in E.D. Tex. The complaint carried ten exhibits plus a civil cover sheet, consistent with an assertion of multiple patents and claim charts. (Patexia docket)

• Patents asserted — five, not one. Per RPX and the Mondaq analysis (2024-05-31), the five patents-in-suit were:

  • 8,498,388 — delivering/updating audio announcements via telecom devices (accused via Galaxy S23 Ultra / Bixby)
  • 8,503,973 — emergency caller location determination (the patent in your metadata; accused via Galaxy S24+ / E911)
  • 9,578,570 — switching an IM-based voice call to a second call (Galaxy S10; LTE→3G/2G handoff)
  • 9,219,982 — refreshing a phone display with a location-specific communication service (Galaxy Watch6)
  • 8,515,032 — voice messaging (storing/synchronizing audio messages with status)

  Accused products were five, per RPX Insight. (Mondaq, "Yet Another New Mexico Plaintiff Launches Patent Litigation," 2024-05-31)

• Provenance / chain of title. The patents trace to TP Lab, Inc., with named inventors Shin Cheung Simon Chiu and Chi Fai Ho (TP Lab founder/CEO, ex-Nokia). The '973 patent is part of a 12-patent emergency-caller-location family that was assigned to Local Intelligence, LLC (a Dominion Harbor affiliate) in August 2017 and transferred back to TP Lab in November 2019. Importantly, Mondaq noted that USPTO assignment records did not reflect transfer of the '388, '570, or '032 patents to Lab Technology as of late May 2024 — Lab Technology merely "pleads ownership." That is a latent standing/ownership defect worth flagging if the portfolio resurfaces.

• Answer / counterclaims: none. Samsung never entered an appearance and never answered. No IPR-based stay motion was filed, and no counterclaim for declaratory judgment of invalidity or non-infringement was ever filed.

2. Pre-Trial Motions of Substance

None. No motion to dismiss, no § 1404(a) transfer motion, no motion to stay pending IPR, no § 101 motion, no summary judgment motion. Samsung never appeared. The only non-pleading substance was the plaintiff's own dismissal notice.

3. Claim Construction (Markman)

None. The case was dismissed roughly two weeks after filing — long before the E.D. Tex. scheduling order would have set a Markman hearing (typically 9–12 months out in Judge Gilstrap's court). No claim terms were construed, no Phillips briefing occurred.

4. Discovery Milestones

None. No Rule 26(f) conference, no discovery plan, no infringement contentions, no invalidity contentions, no depositions. The case was closed before the deadline for the parties' Rule 26(f) report.

5. Trial, Verdict, and Post-Trial Motions

None. No trial, no verdict, no JMOL, no new-trial motion, and no fee motion under § 285 or 35 U.S.C. § 285 / Rule 54. The dismissal order expressly denied all pending requests for relief not explicitly granted as moot — confirming no injunction, damages, or fee request had matured.

6. Final Disposition

The operative text of the order (as reproduced from PACER by PatSnap):

"Before the Court is the Notice of Dismissal filed by Lab Technology LLC. (Dkt. No. 5.) In the Notice, Plaintiff represents that the above-captioned case is voluntarily dismissed WITHOUT PREJUDICE… pursuant to Rule 41(a)(1)(A)(i), all pending claims and causes of action in the above-captioned case are DISMISSED WITHOUT PREJUDICE. All pending requests for relief in the above-captioned case not explicitly granted herein are DENIED AS MOOT."

Effect:

• Because dismissal was effected by unilateral notice under Rule 41(a)(1)(A)(i) — which is self-executing and requires no court action — there is no res judicata or claim-preclusive effect. Lab Technology may refile the same claims against Samsung. The court's order is effectively ministerial confirmation.
• Samsung received no cost or fee award, having never appeared and having incurred minimal expense.
• No settlement was disclosed in the public record, and the record does not indicate whether a license accompanied the withdrawal.
• Posture: As of the 2024-05-13 close, and through the available public record, the case remains closed with no appeal and no refiling against Samsung identified. If it were refiled, the same five patents would be at issue.

7. Parallel PTAB / USPTO Proceedings and Their Effect

No IPR or PGR was ever filed on U.S. 8,503,973 by Samsung or anyone else that I could identify. Because the district court case died in 11 days, there was no IPR-driven stay, no Fintiv analysis, and no estoppel question. However, the portfolio drew third-party validity attacks outside the case:

• Unified Patents — ex parte reexamination of U.S. 8,498,388. Unified filed a request for ex parte reexamination, and on 2025-01-15 the Central Reexamination Unit granted it, finding substantial new questions of patentability on all challenged claims (control no. 90/019,749). This targeted a patent from the same asserted group (the '388 patent was asserted by Lab Technology against Amazon and Google in the follow-on campaign). (Unified Patents, 2025-01-15)
• Unified Patents PATROLL prior-art bounty on U.S. 8,503,973. On 2025-01-03, Unified announced $2,000 in awards to Dinesh Swami and Mani Manikandan for prior art on the '973 patent, describing it as "relat[ing] to methods and systems for accurately determining the location of a caller during an emergency call," and noting it had been asserted against Cisco, Microsoft, Stryker, Samsung, and Verizon. (Unified Patents, 2025-01-03) This is a crowdsourced prior-art harvesting step, not a filed PTAB proceeding — but it signals an intent to challenge the '973 patent, and any resulting petition would be filed in 2025–2026.
• No litigation effect here. Neither of the above touched 2:24-cv-00324, which was already closed by the time both occurred. Any future Samsung-filed IPR on the '973 patent would face the changed PTAB landscape: institution rates against NPEs fell sharply through 2025, and the USPTO's "settled expectations" discretionary-denial framework would weigh against challenging a patent that issued in August 2013 (i.e., well over a decade old). See Unified Patents, Patent Dispute Report: 2025 in Review (NPE institution rate fell to 33.6% in Q4 2025 from 64.6% in Q1 2025).

8. Related Litigation Context (Strategically Relevant)

• Prior assertion of the '973 patent family against Samsung. The same emergency-location family (via Local Intelligence, LLC, a Dominion Harbor affiliate) was previously asserted against Samsung in E.D. Tex., and that case was dismissed with prejudice in January 2019. That prior dismissal is notable: it may bear on the scope of any release or covenant not to sue, and it explains why the 2024 complaint focused on newer products (Galaxy S24+, Galaxy Watch6) rather than smartphones alone. (Mondaq, 2024-05-31)
• Local Intelligence v. HTC (N.D. Cal.). HTC moved to dismiss the '982 and related claims under Alice. Judge Edward J. Davila denied the motion, concluding the "specific improvement to user interfaces claimed here is also not an abstract idea" — a § 101 holding that survives as useful cover for the '982 patent's eligibility.
• Local Intelligence v. LGE (D. Del.). Voluntarily dismissed with prejudice before an answer.
• The wider 2024–2025 campaign. Simultaneously with the Samsung suit, Lab Technology filed 2:24-cv-00323 against Verizon. After dismissing Samsung, it filed a wave in E.D. Tex. on 2024-06-03/04: Amazon (2:24-cv-00409, closed 2024-07-07 per Unified Patents), Anritsu (00411), AT&T (00412), Bose (00413), Ericsson (00414), Quectel (00415), and Stryker (00416), asserting overlapping subsets of four of the five patents. (RPX Empower, 2024-06-08) The Samsung dismissal, in other words, was the opening move in a coordinated multi-defendant campaign, and Samsung was the first defendant dropped.

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Caveats on the Record

• The docket consists of seven entries; there is no opinion, no hearing transcript, and no merits document. Anything beyond the complaint and the dismissal order would be speculation.
• I could not verify why Lab Technology dismissed — the record shows no motion, no settlement filing, and no public statement. Given the 11-day timeline and the immediately following seven-defendant wave, the most defensible reading is procedural sequencing (e.g., refiling with a different defendant entity, venue strategy, or correcting a pleading defect such as the assignment-records gap for the '388/'570/'032 patents) rather than a merits-based retreat. I am labeling that inference, not reporting it as fact.
• No IPR was filed on the '973 patent as of the sources available; the '388 ex parte reexamination (90/019,749) is the one confirmed post-grant attack I found in this family. A search of the PTAB Patent Trial & Appeal Board Trial Statistics / Unified Patents portal would be the definitive check for any 2026-filed petition I did not surface.

I'll search several angles to find press coverage of this case.

Let me search additional angles for actual press coverage.

Press and Media Coverage of Lab Technology v. Samsung

Bottom line: this case generated no mainstream or legal-industry press coverage. I searched the case caption, the parties, the case number, and the asserted patent numbers (including '973 specifically) across the outlets you named — Reuters, Bloomberg Law, Law360, Ars Technica, The Verge, IPWatchdog, Patently-O, EFF Deeplinks, and JD Supra — and found nothing. There is no article anywhere in the mainstream or trade legal press reporting on the filing, the 11-day dismissal, or any settlement, damages figure, or executive statement. That is unsurprising: an 11-day, never-served, Rule 41(a)(1) dismissal of a single NPE complaint produces no docket event worth a reporter's time, and Samsung never appeared to comment. What coverage exists is limited to (a) patent-analytics/trade newsletters that logged the case as a data point, and (b) the defense-side advocacy post from Unified Patents discussed below. No outlet reported a damages demand, a settlement term, or a market-impact figure, because none was disclosed in the record.

Trade and analytics coverage. The only genuine reporting that discusses this case directly is RPX, which on 2024-06-08 reported that Lab Technology "began litigating patents apparently received from TP Lab, Inc. with separate suits filed against Samsung and Verizon" and noted pointedly that "[o]ne of those two cases already dismissed (without prejudice)" before the plaintiff rolled out seven more complaints against Amazon, Anritsu, AT&T, Bose, Ericsson, Quectel, and Stryker — treating the Samsung exit as the opening beat of a coordinated campaign rather than a litigation outcome. Mondaq published the one substantive analysis (2024-05-31), explicitly flagging the Samsung case by docket number and mapping each asserted patent to accused products. Both pieces are covered in the existing sections above, so I won't repeat the product/patent mapping here — but note that neither outlet attached any legal significance to the dismissal itself, and neither reported a settlement, license, or payment. Both framed the story around the portfolio's provenance (TP Lab → Local Intelligence/Dominion Harbor → back to TP Lab → Lab Technology) and the ownership-records gap, not around anything Samsung did.

The one piece of coverage aimed at the '973 patent's Samsung assertion comes from Unified Patents, the defensive aggregator, which on 2025-01-03 announced $2,000 in PATROLL crowd-sourced prior-art awards to Dinesh Swami and Mani Manikandan on U.S. 8,503,973, expressly describing it as "asserted by Lab Technology, LLC, an NPE" and listing the targets as "Cisco, Microsoft, Stryker, Samsung, and Verizon." Unified's PATROLL contest page shows the contest ran from 2024-06-06 to 2024-08-30 and states the patent "has been asserted against Samsung, Verizon, and Stryker." This is advocacy/defense-industry messaging rather than neutral journalism — Unified is soliciting invalidity evidence, and its characterization of the plaintiff as "an NPE" is a position, not a finding. Notably, the Samsung suit was already dismissed a month before the contest even opened, so Unified's "asserted against Samsung" framing reflects the portfolio's residual threat profile, not live litigation.

Caveat on the analytics-vendor "articles." The only other web content that reads like press coverage of this case is machine-generated litigation summaries from PatSnap Eureka, which restate the docket, reproduce the Rule 41 order verbatim, and add speculative "strategic takeaways." These are product-marketing pages, not reporting, and I would not treat them as independent confirmation of anything — one of them is the apparent origin of the "Samsung Electronics Co., Ltd." defendant name in your metadata (it lists that entity, while PACER, UniCourt, Patexia, and RPX all say Samsung Electronics America, Inc.). PatSnap has similar pages on Lab Technology's follow-on '973 suits against Sangoma (S.D. Fla., dismissed 2025), Cisco (W.D. Tex.), and Everbridge (D. Del.), and an AI-generated complaint analysis exists for the parallel Verizon case discussing the '973 claim-scope question (device-side vs. network-side base-station comparison) — none of which is press, but which collectively show the '973 patent being re-asserted repeatedly after Samsung was dropped. Nothing in any of these sources reports a settlement, payment, or admission by Samsung in 2:24-cv-00324.

Sources

• 2:24-cv-00324 | Lab Technology LLC v. Samsung Electronics America, Inc. | RPX Insight
• Lab Technology LLC v. Samsung Electronics — Telecom Patent Dismissal | PatSnap - Your Agentic AI Partner
• Lab Technology LLC v. Samsung Electronics America, Inc. - This case was last updated from U
• Lab Technology LLC v. Samsung Electronics America, Inc. > Documents
• 단독 삼성전자 뒤통수 친 前부사장…美 특허침해 소송 2차戰 결말은? - 서울와이어
• Seven Defendants Hit with Patents from Former TP Lab Portfolio - News | RPX Empower
• Yet Another New Mexico Plaintiff Launches Patent Litigation - ARTICLE
• Lab Technology LLC v. TELUS International (U.S.) Corp. (2:26-cv-00127), Nevada District Court
• Docket updates for Lab Technology LLC v. Lumen Technologies, Inc., 7:25-cv-00172 - Docket updates for Lab Technology LLC v
• 2:24-cv-00409 | Lab Technology LLC v. Amazon.Com, Inc., | RPX Empower
• 4:25-cv-00610 | Lab Technology LLC v. u-blox America, Inc. | RPX Empower
• Lab Technology LLC v. Solera Holdings, LLC

I'll research the counsel of record for the plaintiff in this case.

Counsel of Record for the Plaintiff — Lab Technology LLC

Bottom line

There was exactly one attorney of record for the plaintiff in Lab Technology LLC v. Samsung Electronics America, Inc., 2:24-cv-00324 (E.D. Tex.): Isaac Phillip Rabicoff, appearing pro se as counsel through his own firm, Rabicoff Law LLC. No co-counsel, no local counsel, no of-counsel, and no in-house attorney ever appeared for Lab Technology. Because Samsung never entered an appearance, there is no defense-side counsel of record in this case at all. The entire docket (7 entries) is public — nothing is sealed, so I can state the appearance record with confidence rather than inference.

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Counsel table — Plaintiff Lab Technology LLC

Documents bearing Rabicoff's signature in this case: Dkt. 1 (Complaint, 2024-05-03), Dkt. 2 (Notice of Attorney Appearance, 2024-05-03), Dkt. 3 (Rule 7.1(a)(1) Disclosure Statement, 2024-05-03), Dkt. 4 (AO 120 form), and Dkt. 5 (Notice of Voluntary Dismissal, 2024-05-07). (Patexia document list; UniCourt docket)

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Explicit negatives (no invention, no gaps left ambiguous)

• No local counsel. E.D. Tex. Local Rule AT-2 generally requires non-resident counsel to designate local counsel, but Rabicoff is himself admitted to the E.D. Tex. bar, so no local-counsel appearance was needed and none was filed. This is consistent with the pattern in Lab Technology's other E.D. Tex. campaign suits, where Rabicoff likewise appears alone (e.g., Lab Technology v. AT&T, 2:24-cv-00830, Dkt. 2).
• No second Rabicoff Law attorney. Rabicoff Law's roster includes other registered attorneys who appear with him in other matters — most consistently Kenneth A. Matuszewski (USPTO Reg. No. 74,791), who is listed as backup counsel on several Rabicoff Law PTAB powers of attorney. Matuszewski did not appear in 2:24-cv-00324, and I am not attributing him to this case. I found no evidence of any other attorney of record here.
• No sealed/withheld filings. Unlike many NPE complaints where claim charts are filed under seal, nothing on this seven-entry docket was sealed — the reason the complaint body's accused-product mapping is thin (Exhibits 4–10 were filed but are not reproduced in public docket mirrors) is docket-mirror limitation, not a sealing order.
• No in-house counsel of record for Lab Technology. Consistent with its NPE posture (the Rule 7.1 disclosure identifies a New Mexico LLC), no corporate counsel entered an appearance.

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Caveat and cross-reference

• The party-name discrepancy flagged in the earlier sections persists on the counsel point in only one direction: PatSnap's counsel table lists "Plaintiff counsel: Isaac Phillip Rabicoff / Rabicoff Law LLC" alongside a defendant listed as Samsung Electronics Co., Ltd. (PatSnap), while every PACER-derived source names the defendant as Samsung Electronics America, Inc. This does not affect the plaintiff's counsel identification, which is uniform across PACER, UniCourt, Patexia and PatSnap.
• I could not locate a firm-website case page, Law360 entry, or Reuters Legal item specifically naming counsel for this 11-day case; the identification rests on the PACER-derived dockets and the signature blocks. That is direct record evidence, not inference.
• If the portfolio is refiled against Samsung, expect the same single-attorney representation unless Rabicoff adds local or co-counsel — no appearance by any other attorney in this case gives any basis to name one.

I'll research this directly, focusing on whether any defendant-side appearance exists on the docket.

Docket confirms only plaintiff's counsel. Let me stress-test that conclusion with additional searches, including the parallel case and Samsung's historical representation in this patent family.

Confirmed: the docket shows no defense appearance. Let me verify the historical Samsung representation in the earlier Local Intelligence case and double-check the Samsung docket for any late-filed appearance.

Bottom Line

There is no counsel of record for the defendant in this case. None. Zero defense-side attorneys appeared.

This is the rare instance where the correct answer is an absence. Case 2:24-cv-00324 consists of seven docket entries, all plaintiff-side, and closes 11 days after filing. Samsung never answered, never filed a corporate disclosure statement, never moved for an extension of time, and never entered an appearance — so no lead counsel, no local counsel, and no in-house counsel exists to name. The attorney/law-firm field for the defendant is empty in every docket-derived database I checked:

Because an attorney's notice of appearance is a non-sealed, publicly docketed event that cannot be filed invisibly, and because the docket is only seven entries long with a verified termination date, the absence is affirmative and reliable, not a records gap. The docket's last three entries (Dkt. 5 notice of dismissal, Dkt. 6 dismissal order, Dkt. 7 AO 120 mailed to the USPTO Director) were all entered before any Rule 26(f) conference or responsive-pleading deadline could mature — E.D. Tex. Local Rule CV-12 gives 21 days to respond, which would have fallen on or about May 24, 2024, eleven days after the case was already closed.

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Why this matters, and the trap to avoid

Two sets of Samsung-family counsel exist in public records that a less careful search would wrongly attribute to this case. I'm flagging both explicitly so they are not mistaken for counsel of record here:

⚠️ Trap 1 — the parallel Verizon case had real defense counsel (but these lawyers are not Samsung's)

Lab Technology filed 2:24-cv-00323 against Cellco Partnership d/b/a Verizon Wireless the same day. Unlike Samsung, Verizon did appear, and its counsel of record were:

Sources: PACER Monitor docket, 2:24-cv-00323 (Dkts. 11–12 appearances filed 07/26/2024); RPX Insight. Note the contrast: the Verizon docket shows plaintiff also added Benjamin Charles Deming (DNL Zito) (Dkt. 8, 07/10/2024) — a second plaintiff firm that never appeared in the Samsung case either. The Verizon case ran 216 days and closed 12/04/2024. These names are useful only as a template for the defense-side staffing pattern Lab Technology's parallel suits drew; none of them is counsel of record against Samsung in 2:24-cv-00324.

⚠️ Trap 2 — Samsung's actual counsel in the earlier case on the same '973 patent family

The same emergency-location family was previously asserted against both Samsung entities by Local Intelligence, LLC (case filed August 2017 in E.D. Tex.; dismissed with prejudice January 2019). In that case Samsung did appear, and its counsel of record were:

Source: PlainSite docket, Local Intelligence, LLC v. Samsung Electronics America, Inc., E.D. Tex.. That docket also shows the case got as far as a Rule 26(f) conference, scheduling conference (04/24/2018), discovery/E-discovery orders, protective order, and a Markman hearing set for 11/29/2018 — the full litigation apparatus that 2:24-cv-00324 never reached. These five attorneys are not counsel of record in 2:24-cv-00324; their names appear here only because they are the best available evidence of the defense team Samsung historically retained against this exact patent family in this exact court. I did not verify their current firm affiliations, and I'd caution against asserting them without a fresh firm-directory check.

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Caveats and verification gaps

• No sealing issue. The no-appearance finding does not rest on sealed filings — attorney appearances are public by rule, and the entire docket (Dkts. 1–7) is public.
• Party-name discrepancy compounds the counsel question. Your case metadata names Samsung Electronics Co., Ltd. (the Korean parent); the docket, complaint caption, UniCourt, Patexia, RPX and PACER Monitor all name Samsung Electronics America, Inc. (the U.S. subsidiary). This matters for counsel identification: in the 2017 Local Intelligence case both entities were named and both were represented by the same team (all appearances run "on behalf of SAMSUNG ELECTRONICS AMERICA, INC., Samsung Electronics Co., Ltd."). If the '973 claims were re-asserted against the parent alone, the defense team would likely differ on service and admission issues. I could not resolve the discrepancy; the complaint exhibits that might clarify the named defendant (Exhibits 4–10, the claim charts) were not publicly filed.
• What I could not check. I did not run a PACER attorney report or the E.D. Tex. "Attorney query" for this case number, and I did not locate a Law360 or Reuters Legal docket note naming Samsung counsel. My search hit its step limit before completing a firm-affiliation confirmation for Smith, Kennerly, Patel, Pade and Kidokoro. Those are the two definitive follow-ups.
• One inference, labeled as such: given the 11-day lifecycle and the immediately following seven-defendant filing wave (Amazon, Anritsu, AT&T, Bose, Ericsson, Quectel, Stryker in June 2024), the most defensible reading is that Lab Technology withdrew against Samsung before Samsung had any occasion to retain counsel — i.e., the absence of defense counsel is a symptom of a strategic refiling decision, not of a settlement that would normally generate at least a conditional appearance. The public record discloses no settlement, license, or standstill agreement tied to the dismissal.