Headwater Research Llc V. Samsung Electronics America, Inc. Et Al

Case Background

On July 8, 2022, Plaintiff  Headwater Research LLC filed a patent infringement lawsuit in the United States District Court, Texas Eastern (Case number: 2:22cv422). This case was assigned to District Judge Rodney Gilstrap and referred to Magistrate Judge Roy S. Payne.

Cause

Headwater Research LLC filed a patent infringement lawsuit against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. The case involved Samsung’s unauthorized use of Headwater’s patented wireless communication technologies. These innovations optimized data usage, reduced power consumption, and improved connectivity in mobile devices.

Dr. Gregory Raleigh, Headwater’s founder, originally developed the patented technology. During a collaboration with Sprint, Headwater shared these innovations with Samsung under confidentiality agreements. However, Samsung allegedly incorporated them into its devices without authorization or licensing. This led to the legal dispute over patent infringement and intellectual property rights.

Injuries

Samsung’s unauthorized use of the patented technology caused significant financial harm to Headwater Research LLC. By incorporating the technology without permission, Samsung profited while Headwater lost revenue and market share. The sale and distribution of infringing mobile devices, including smartphones and tablets, further deprived Headwater of potential licensing fees.

Headwater sought to recover damages, including past and future royalties. The lawsuit also aimed to hold Samsung accountable for willful patent infringement, justifying enhanced damages under patent law.

Damages

Headwater argued that Samsung’s patent infringement was willful and sought increased financial penalties.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s): Headwater Research LLC
    • Counsel for Plaintiff: Adam S. Hoffman | Amy Elizabeth Hayden  | Andrea Leigh Fair  | Benjamin T. Wang  | Brian D. Ledahl  | James A. Milkey  | James N. Pickens  | James Shrin Tsuei  | Jason Wietholter  | Kristopher Ryan Davis  | Neil Alan Rubin  | Paul Anthony Kroeger  | Philip X. Wang  | Reza Mirzaie  | Ryan Lundquist  | Marc A. Fenster  
  • Defendant(s): Samsung Electronics America, Inc. |  Samsung Electronics Co., Ltd.
    • Counsel for Defendants: Ruffin B. Cordell | Andrew Thompson (Tom) Gorham | Andria R. Crisler | Benjamin K. Thompson | Christopher O. Green | Grant K. Schmidt | Harry Lee Gillam, Jr. | James Travis Underwood | Jared Hartzman | John W. Thornburgh | John-Paul Robert Fryckman | Jon Bentley Hyland | Katherine Reardon | Lance Lin Yang | Leonard Davis | Meghana Thadani | Melissa Richards Smith | Michael J. McKeon | Nicholas Gallo | Noah C. Graubart | Sara Christina Fish | Sean S. Pak | Steffen Lake | Thad C. Kodish | Theodore Druce Kwong | Thomas Howard Reger, II

Claims

Headwater claimed that Samsung directly infringed multiple patents by manufacturing, selling, and distributing devices with the protected wireless technology. The lawsuit also alleged induced patent infringement, as Samsung encouraged others to use the technology through sales and distribution.

Headwater demanded monetary compensation, including reasonable royalty damages. It also requested a permanent injunction to prevent further unauthorized use of its intellectual property.

Defense

Samsung denied all patent infringement allegations. The company argued that it never used or misappropriated Headwater’s patented technology. It also claimed that the asserted patents were invalid due to lack of novelty and obviousness under U.S. patent laws.

Samsung contended that legal doctrines such as laches, equitable estoppel, waiver, and unclean hands barred Headwater’s claims. The company stated that Headwater delayed enforcing its rights or engaged in unfair conduct. Samsung further argued that it had an implied or express license or a covenant not to sue, which prevented the lawsuit.

The company also claimed that Headwater failed to meet legal requirements for damages, including proper marking of patented products. Samsung invoked prosecution history estoppel, which limited Headwater’s ability to expand patent claims beyond what was originally granted. Samsung requested the court to dismiss the case with prejudice, declare the patents invalid, and award it legal costs, including attorneys’ fees.

Jury Verdict

On January 17,2025, the jury ruled in favor of Samsung. It found that Headwater Research LLC failed to prove, by a preponderance of the evidence, that Samsung committed patent infringement on any of the asserted claims.

Court Documents:

Documents are available for purchase upon request at jurimatic@exlitem.com