Litigation

Xifi Networks R&D, Inc. v. Samsung Electronics Co., Ltd. et al.

active

2:24-cv-01057-JRG

Filed
2024-12-17

Patents at issue (1)

Plaintiffs (1)

Defendants (2)

Summary

This active district court case, filed by Xifi Networks R&D, Inc. against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., is ongoing. Defendants' motion to stay proceedings pending Inter Partes Review (IPR) and Post-Grant Review (PGR) was denied, and trial is scheduled for October 19, 2026.

Case overview & background

Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.

This patent infringement litigation, Xifi Networks R&D, Inc. v. Samsung Electronics Co., Ltd. et al., case number 2:24-cv-01057-JRG, is currently active in the U.S. District Court for the Eastern District of Texas, Marshall Division, presided over by District Judge Rodney Gilstrap. The plaintiff, Xifi Networks R&D, Inc., appears to be a Non-Practicing Entity (NPE) or Patent Assertion Entity (PAE), as indicated by the fact that its late CEO, Sai Manapragada, was identified as the sole shareholder, sole director, and sole named inventor of the asserted patents. The defendants, Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., are global operating companies that manufacture and sell a wide range of consumer electronics.

Xifi Networks R&D, Inc. accuses Samsung of infringing its patents through Samsung electronic devices that implement Multi-Link Operation (MLO) functionality, as specified in the IEEE 802.11be (Wi-Fi 7) Draft Standard. The accused products include various Samsung smartphones (e.g., Galaxy S23, S24, S25 series, Galaxy Z Fold/Flip series), TVs, laptops (e.g., Galaxy Book 5 Pro 360, Galaxy Book 4 Edge), tablets, and wearable devices. The core technology at issue revolves around foundational wireless communication methods and systems for managing and allocating bandwidth across multiple wireless channels, often involving a "virtual MAC" layer to enable multi-link operations. While the initial prompt focused on U.S. Patent No. 11,974,143, Xifi has actually asserted a family of eleven patents in this case, all claiming priority to provisional applications filed in October 2013. U.S. Patent No. 11,974,143 generally relates to systems and methods for multi-link wireless communication, particularly for improving data transfer efficiency. Other asserted patents cover aspects such as evaluating data transfer characteristics across bandwidth portions (e.g., 12,003,976), selecting links for transmission based on characteristics (e.g., 12,015,933), simultaneous transmit and receive operations using virtual architecture (e.g., 12,114,177), aggregating bandwidth from multiple transceivers (e.g., 11,856,414), and making allocation decisions based on resource monitoring (e.g., 12,190,198).

The Eastern District of Texas is a notable venue for patent litigation, often characterized as a "rocket docket" with a history of plaintiff-friendly procedural rules, accelerated trial schedules, and a reputation for favorable verdicts for patentees, particularly against large technology companies. This case is particularly notable due to the assertion of patents covering foundational Wi-Fi 7 technology, indicating a potential industry impact. Furthermore, the court's denial of Samsung's motion to stay proceedings pending inter partes review (IPR) and post-grant review (PGR) is consistent with Judge Gilstrap's established practice of denying such motions before institution decisions, underscoring the district's preference for moving cases toward trial. Samsung had filed eight IPR petitions and three PGR petitions challenging the asserted patents. The recent, unexpected passing of Xifi's CEO and sole inventor also adds an unusual, albeit tragic, element to the case's background.

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, filed by Xifi Networks R&D, Inc. against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., is active in the U.S. District Court for the Eastern District of Texas.

Filing & Initial Pleadings

  • Complaint Filed: Xifi Networks R&D, Inc. initiated the lawsuit on December 17, 2024, asserting nine patents.
  • First Amended Complaint Filed: Xifi filed a First Amended Complaint on March 11, 2025, which remains the operative complaint and added two more patents, bringing the total to eleven patents from a single family.
  • Answer and Affirmative Defenses: Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. filed their Answer and Affirmative Defenses to the First Amended Complaint on June 9, 2025.

Pre-trial Motions of Substance

  • Motion to Stay Proceedings Pending IPR/PGR Denied: Samsung filed a motion to stay proceedings pending Inter Partes Review (IPR) and Post-Grant Review (PGR) petitions. This motion was denied by District Judge Rodney Gilstrap on March 12, 2026. The court noted that the case was approaching the Markman hearing, which weighed against a stay.
  • Motion to Stay Proceedings (Plaintiff): Plaintiff Xifi Networks R&D, Inc. filed an unopposed motion for a 30-day stay of all pending deadlines due to the sudden passing of Sai Manapragada, Xifi's CEO, sole shareholder, sole Director, and sole named inventor of the asserted patents. The motion indicated Mr. Manapragada passed away sometime between May 15 and early May 16, 2026.

Claim Construction (Markman)

  • The court's denial of Samsung's motion to stay indicated that the case was "approaching the Markman hearing," suggesting that claim construction is an upcoming or ongoing phase. No specific date or outcome for a Markman order has been publicly detailed yet.

Discovery Milestones

  • The parties are currently engaged in active discovery.
  • Infringement Contentions: Xifi served infringement contentions on March 26, 2025.
  • Invalidity Contentions: Samsung served invalidity contentions on June 18, 2025.
  • Fact Discovery Deadline: The deadline to complete fact discovery and file motions to compel discovery was May 22, 2026 (amended from May 18, 2026).
  • Expert Witness Disclosures: The deadline for the party with the burden of proof to serve disclosures for expert witnesses was May 22, 2026 (amended from May 18, 2026). Disclosures for rebuttal expert witnesses were due June 12, 2026 (amended from June 8, 2026).
  • Expert Discovery Deadline: The deadline to complete expert discovery is June 22, 2026.
  • Motions to Strike Expert Testimony: Motions to strike expert testimony (including Daubert Motions) are due by June 29, 2026.
  • Dispositive Motions: Responses to dispositive motions (including Daubert Motions) are due by July 13, 2026.

Trial Events

  • Trial Scheduled: Jury selection and trial are scheduled for October 19, 2026.
  • Pre-Trial Deadlines:
    • Plaintiff to disclose final infringement contentions, final asserted claims, final damages theories, and final equitable relief theories: 10 days before Jury Selection.
    • Defendant to disclose final invalidity theories, final prior art references/combinations, and final equitable defenses: 7 days before Jury Selection.

Parallel PTAB IPR/PGR Proceedings

  • IPR Petitions: Samsung filed eight IPR petitions challenging eight of the originally asserted patents on July 3 and July 10, 2025.
  • PGR Petitions: Samsung filed three PGR petitions challenging the remaining three patents (those eligible for PGR) on July 21, 2025.
  • Impact on Litigation: The district court denied Samsung's motion to stay proceedings pending these IPR/PGRs, noting that a trial in the district court would decide the validity of at least one patent ('591 patent) over two months before the Board's deadline to issue a final written decision in the parallel IPR. The court indicated it was unlikely to grant a stay and that institution would lead to inefficient use of resources due to overlap between district court and PTAB arguments.

Plaintiff representatives

Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Counsel of Record for Xifi Networks R&D, Inc.

Xifi Networks R&D, Inc. is represented by attorneys from the firm Garteiser Honea PLLC. The firm specializes in intellectual property litigation and frequently serves as lead counsel in high-stakes patent disputes. Its attorneys are known for their experience in federal and state courts, particularly in the Eastern District of Texas.

The following attorneys are identified as key personnel within Garteiser Honea PLLC and are likely to be involved in the plaintiff's representation, given the firm's role as counsel for Xifi Networks R&D, Inc. in related proceedings and their stated expertise:

  • Randall T. Garteiser
    • Role: Partner, likely Lead Counsel
    • Firm: Garteiser Honea PLLC. The firm's website indicates locations in East Texas and Northern California.
    • Experience: A trial attorney, Mr. Garteiser previously litigated at Quinn Emanuel. He has experience distilling complex technology for judges and juries and has handled disputes for clients involving smartphones, tablets, Chromebooks, dielectric fluids, and software. He clerked for the Honorable James Ware in the U.S. District Court for the Northern District of California. Mr. Garteiser is licensed in California and Texas and admitted to the U.S. Supreme Court and the U.S. Court of Appeals for the Federal Circuit. He has been involved in cases with significant jury verdicts, including a $240M verdict for StreamScale from Cloudera and a $37.5M verdict against TP-Link Meta in the Eastern District of Texas.
  • Christopher Honea
    • Role: Partner, likely Lead Counsel
    • Firm: Garteiser Honea PLLC. The firm's website indicates locations in East Texas and Northern California.
    • Experience: As a founding partner of Garteiser Honea, Mr. Honea is involved in complex intellectual property and business disputes. The firm highlights his involvement in securing substantial jury verdicts in patent litigation.
  • M. Scott Fuller
    • Role: Partner, likely Lead Counsel
    • Firm: Garteiser Honea PLLC. The firm's website indicates locations in East Texas and Northern California.
    • Experience: Mr. Fuller joined Garteiser Honea as a partner in 2018. Before that, he was a partner and co-chair of the Texas IP Litigation Practice Group at Locke Lord LLP, where he represented Fortune 500 clients in district courts across the country, including in California, Texas, and New York. His practice focuses on complex and high-stakes patent litigation disputes.

Defendant representatives

Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).

Based on the available web search results, the counsel representing the defendant(s), Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., in Xifi Networks R&D, Inc. v. Samsung Electronics Co., Ltd. et al. (2:24-cv-01057-JRG) includes attorneys from Quinn Emanuel Urquhart & Sullivan, LLP. While a comprehensive list of all attorneys who have formally entered an appearance for the defendants in this specific district court case could not be directly extracted from the provided snippets, the following individuals have a stated connection to Samsung's defense in this litigation:

  • Patrick T. Schmidt

    • Role: Counsel for Defendants (role not explicitly defined as lead, but "centrally involved" in the district court litigation).
    • Firm: Quinn Emanuel Urquhart & Sullivan, LLP, Los Angeles, CA. [cite: 3 from current step, and 6 from step 2]
    • Experience Note: Mr. Schmidt is a seasoned trial attorney in high-stakes commercial litigation and intellectual property disputes, including patent infringement. He has defended Google and YouTube in a patent-infringement case in the Eastern District of Texas, securing a jury verdict of non-infringement. He has also represented Samsung against Apple in federal district court regarding cellular and touchscreen technology patents. [cite: 3 from current step]
  • James M. Glass

    • Role: Lead Counsel for Petitioners (Samsung) in related Inter Partes Review (IPR) proceedings. His extensive patent litigation background suggests a significant role in the overall defense strategy for the district court case.
    • Firm: Quinn Emanuel Urquhart & Sullivan, LLP, New York, NY. [cite: 2, 4, 5 from current step]
    • Experience Note: Mr. Glass chairs Quinn Emanuel's Post-Grant patent practice and has been lead counsel in over 500 PTAB proceedings. His practice encompasses patent litigation in district courts and the ITC, where he has successfully argued numerous Markman and Summary Judgment motions and represented clients at trial. [cite: 2 from current step]

It is also a common practice in the Eastern District of Texas for parties to engage local counsel. While specific local counsel for Samsung in this particular case could not be definitively identified from the provided search results, firms like DLA Piper have a history of frequently representing Samsung in other patent infringement cases in the Eastern District of Texas. [cite: 2, 23, 24 from step 2]