Samsung Electronics Co. Ltd. v. Massively Broadband LLC

Samsung Electronics Co. Ltd., a South Korean multinational technology conglomerate, found itself as the respondent in an Inter Partes Review (IPR) filed by Massively Broadband LLC at the Patent Trial and Appeal Board (PTAB). Samsung is a global leader in electronics, semiconductors, and telecommunications, widely known for its smartphones, televisions, and other consumer and enterprise technologies. Massively Broadband LLC, conversely, operates as a Patent Assertion Entity (PAE) or Non-Practicing Entity (NPE), a company that acquires patents not for product development but for monetization through licensing and litigation. This is evident from reports indicating the transfer of over 20 US patents from inventor Theodore S. Rappaport to Massively Broadband LLC, an entity established in Texas in February 2023, specifically for assertion purposes.

The IPR, numbered IPR2025-01605, targeted US Patent 10797783, which broadly relates to a "Wearable Computing Device." The IPR was initiated in response to an underlying patent infringement lawsuit filed by Massively Broadband LLC against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the U.S. District Court for the Eastern District of Texas (Case # 2:25-cv-00608). This district court case, presided over by Judge Rodney Gilstrap, alleges infringement of a dozen patents, including US 10797783, by Samsung's various wireless communication devices and related infrastructure components.

The procedural posture of this case is notable because the IPR was filed with the Patent Trial and Appeal Board, an administrative body offering a specialized forum for challenging patent validity outside of federal district court. However, the IPR was terminated as 'Not Instituted - Procedural' on February 3, 2026. This outcome signifies that the PTAB declined to proceed with a substantive review of the patent's validity, likely due to a procedural deficiency in Samsung's petition, a settlement between the parties, or other administrative grounds, rather than a decision on the merits of the prior art arguments. The case is noteworthy for illustrating the assertion patterns of NPEs like Massively Broadband LLC, the strategic use of IPRs by operating companies like Samsung to defend against such assertions, and the specific, non-merits based termination that prevented a full PTAB review of the patent's validity.

Legal Developments and Outcome for Samsung Electronics Co. Ltd. v. Massively Broadband LLC (IPR2025-01605) and Related Patent Infringement Litigation

This summary covers the Inter Partes Review (IPR) proceeding, IPR2025-01605, concerning U.S. Patent No. 10,797,783, and its related patent infringement litigation, Massively Broadband LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:25-cv-00608, in the U.S. District Court for the Eastern District of Texas.

I. Inter Partes Review (IPR2025-01605)

• Filing: Samsung Electronics Co. Ltd. filed IPR2025-01605 with the Patent Trial and Appeal Board (PTAB) on October 14, 2025, challenging U.S. Patent No. 10,797,783, owned by Massively Broadband LLC.
• Termination: The IPR was terminated on February 3, 2026, with the status "Not Instituted - Procedural." This indicates that the PTAB did not reach the merits of the patentability challenge, and institution was denied on procedural grounds.

II. Parallel Patent Infringement Litigation (Massively Broadband LLC v. Samsung Electronics Co., Ltd. et al., Case No. 2:25-cv-00608)

The patent at issue in the IPR, U.S. Patent No. 10,797,783, is one of several patents asserted in a co-pending infringement lawsuit.

• Filing & Initial Pleadings:
  • Complaint: On June 6, 2025, Massively Broadband LLC filed a patent infringement complaint against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. in the U.S. District Court for the Eastern District of Texas, Marshall Division, under Case No. 2:25-cv-00608. The complaint alleged infringement of multiple patents, including U.S. Patent No. 10,797,783, among others referred to as "Intelligent Wireless Broadband Relay Patents," "Smart Antenna Patents," and "Network Monitoring Patents."
  • Service & Extension to Respond: Samsung Electronics America, Inc. was served on June 9, 2025. Samsung Electronics Co., Ltd. agreed to waive service under the Hague Convention. On June 25, 2025, the defendants filed an unopposed motion for an extension of time to answer or otherwise respond to the complaint. The court granted this motion, extending the deadline for all defendants to September 29, 2025.
• Pre-trial Motions of Substance & Discovery:
  • E-Discovery Orders: The parties have engaged in discovery, evidenced by joint motions for extensions of time to file proposed E-Discovery Orders. Such motions were filed on November 12, 2025, and November 24, 2025, and subsequently granted by District Judge Rodney Gilstrap on November 13, 2025, and November 25, 2025, respectively.
  • Interrogatories: Samsung served Massively Broadband LLC with its First Set of Interrogatories (Nos. 1-18), requesting information on alleged infringement and pre-suit notice, among other topics.
• Claim Construction (Markman) Outcomes: As of the current date, public records do not indicate that a Markman hearing has occurred or that claim construction outcomes have been issued in this specific litigation.
• Trial Events, Verdict, and Post-trial Motions: The case is still in its early stages of discovery, and there have been no trial events, verdicts, or post-trial motions reported for this specific litigation.
• Settlement, Dismissal, Judgment, or Appeal: The litigation remains active in the U.S. District Court for the Eastern District of Texas. No final disposition by settlement, dismissal, or judgment has been reported.
• Effect of Parallel PTAB Proceedings: The IPR challenging U.S. Patent No. 10,797,783 (IPR2025-01605) was terminated as "Not Instituted - Procedural." Because the PTAB did not institute a review on the merits, this IPR proceeding had no impact on the validity of the patent in the district court litigation, and the litigation was not stayed as a result of the IPR.

The counsel of record representing Samsung Electronics Co. Ltd. in IPR2025-01605 against Massively Broadband LLC is not readily identifiable through public web searches. As this Inter Partes Review was terminated as 'Not Instituted - Procedural' on 2026-02-03, detailed attorney appearances or Power of Attorney filings for this specific case are not prominently available in general public search results.

While Samsung Electronics Co. Ltd. frequently engages various law firms for its patent litigation and IPR proceedings, including firms like DLA Piper LLP and O'Melveny & Myers LLP in other IPR cases, and Kirkland & Ellis LLP in another IPR, the specific attorneys who filed the petition for IPR2025-01605 are not publicly indexed or discoverable via web search at this time. It is possible that the filings are not publicly accessible through general search engines or that the case's early procedural termination limited the public dissemination of such details.

Based on available information, specific counsel of record directly representing Massively Broadband LLC as the Patent Owner in IPR2025-01605 could not be definitively identified from the provided search results, likely due to the case being terminated as 'Not Instituted - Procedural' on February 3, 2026.

However, in the related district court patent infringement case, Massively Broadband LLC v. Samsung Electronics Co., Ltd. et al. (Case No. 2:25-cv-00608, E.D. Tex.), where Massively Broadband LLC is the plaintiff, Rachel E. Ellenberger has filed an attorney appearance on behalf of Massively Broadband LLC.

Details for Rachel E. Ellenberger are as follows:

• Name: Rachel E. Ellenberger
• Role: Counsel (representing Massively Broadband LLC in a related patent infringement case)
• Firm: K&L Gates LLP
• Office Location: Pittsburgh, Pennsylvania.
• Relevant Patent Litigation Experience: Rachel Ellenberger is an associate in K&L Gates' Intellectual Property Litigation practice group. Her prior experience includes working as a student-attorney in a Civil Rights Clinic, representing clients on issues including intellectual property, and working as a paralegal before law school. Her listed popular topics of focus include arbitration.