1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

NARISTE NETWORKS PTY. LTD. 

Plaintiff, 

v. 

SAMSUNG ELECTRONICS CO., LTD. 

and SAMSUNG ELECTRONICS 

AMERICA, INC. 

Defendants. 

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Civil Action No. 2:23-cv-00031 

JURY TRIAL DEMANDED

PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Nariste Networks Pty. Ltd. (“Nariste” or “Plaintiff”) hereby submits this 

Complaint for patent infringement against Defendants Samsung Electronics Co., Ltd. (“SEC”), 

and Samsung Electronics America, Inc. (“SEA”) (collectively, “Defendant” or “Samsung”) and 

states as follows: 

I. NATURE OF THE ACTION 

1. This is an action for patent infringement arising under the patent laws of the United 

States, 35 U.S.C. § 1 et seq., including, for example, 35 U.S.C. §§ 271, 281, 283, 284, and 285. 

II. THE PARTIES 

2. Nariste is a Proprietary Limited Company organized under the laws of Australia 

with its principal place of business at 81-83 Campbell Street, Surry Hills, NSW 2010, Australia. 

3. On information and belief, defendant SEC is a corporation organized and existing 

under the laws of the republic of Korea, with its principal place of business at 129 Samsung-ro, 

Maetan-3dong, Yeongtong-gu Suwon-si, Gyeonggi-do 16677, Suwon-Shi, Korea. 

4. On information and belief, defendant SEA is a corporation organized and existing 

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under the laws of New York, with its principal place of business at 85 Challenger Road, Ridgefield 

Park, New Jersey, 07660, and maintains a regular and established place of business in this District, 

including for example at 6625 Excellence Way, Plano, Texas 75023; 1303 East Lookout Drive, 

Richardson, Texas 75082; 2800 Technology Drive, Suite 200, Plano, Texas 75074; and 2601 

Preston Road, Frisco, Texas 75034. Moreover, SEA indicated in early 2019 that it would be 

centralizing multiple offices in a location in this District at the Legacy Central office campus, 

located at 6225 Declaration Drive, Plano, Texas 75023.1 SEA is registered to do business in the 

state of Texas and may be served with process through its registered agent CT Corporation System, 

located at 1999 Bryan St., Suite 900, Dallas, Texas 75201. 

5. On information and belief, SEA is a wholly owned subsidiary of SEC. 

6. On information and belief, Samsung has authorized sellers and sales representatives 

that offer and sell products pertinent to this Complaint to consumers throughout the State of Texas, 

including in this Judicial District, such as: Best Buy, 422 West TX-281 Loop, Suite 100, 

Longview, Texas 75605; Best Buy, 308 E End Blvd S, Marshall, Texas 75670; AT&T, 1712 East 

Grand Avenue, Marshall, Texas 75670; TMobile, 1806 East End Boulevard North, Suite 100, 

Marshall, Texas 75670; TMobile, 900 East End Boulevard North, Suite 100, Marshall, Texas 

75670; Verizon authorized retailers, including Russell Cellular, 1111 East Grand Avenue, 

Marshall, Texas 75670; Victra, 1006 East End Boulevard North, Marshall, Texas 75670; and 

Cricket Wireless authorized retailer, 120 East End Boulevard South, Marshall, Texas 75670. 

7. Samsung sells, offers for sale, makes, uses, and/or imports cellular phones, tablets, 

and other mobile devices throughout the United States, including within this District that 

incorporate the infringing technologies. 

1 https://news.samsung.com/us/samsung-electronics-america-open-flagship-north-texas-campus/ (last visited Dec. 

30, 2022). 

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III. JURISDICTION AND VENUE 

8. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) 

because this action arises under the patent laws of the United States, 35 U.S.C. § 1 et seq., including 

35 U.S.C. § 271. 

9. This Court has personal jurisdiction over Samsung at least because Samsung 

conducts business in this Judicial District and in the State of Texas. 

10. This Court also has personal jurisdiction over Samsung at least because Samsung 

has committed acts of patent infringement and/or has induced acts of patent infringement by others 

in this Judicial District and in the State of Texas. Samsung has sold and offered for sale products 

that infringe Nariste’s patent rights and has induced others to use Samsung products to infringe 

Nariste’s patent rights. On information and belief, these products, including the Samsung cellular 

phones, tablets and other mobile products (defined below and collectively referred to herein as the 

“Infringing Products”) have been manufactured, offered for sale, sold, used, and/or imported in 

the United States, within the State of Texas and within this Judicial District. 

11. This court also has personal jurisdiction over Samsung because Samsung has placed 

the Infringing Products into the stream of commerce, with the expectation that they will be 

purchased and used by customers in the State of Texas and in this Judicial District. On information 

and belief, customers in the State of Texas and in this District have purchased and used and 

continue to purchase and use the Infringing Products. Accordingly, Samsung’s conduct and 

connections with the State of Texas are such that it should reasonably have anticipated being 

brought into court here. 

12. Accordingly, Samsung has established minimum contacts with this forum such that 

the exercise of jurisdiction over Samsung would not offend traditional notions of fair play and 

substantial justice. 

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13. Venue is proper in this District as to SEC pursuant to 28 U.S.C. §§ 1391 and 

1400(b) because, among other things, being an alien corporation, SEC may be sued in any judicial 

district. Further, venue is proper in this District as to SEC pursuant to 28 U.S.C. §§ 1391 and 

1400(b) because SEC is a foreign company doing business in the United States through SEA, SEA 

and SEC are subject to personal jurisdiction in this District, have committed acts of patent 

infringement in this District, and have a regular and established place of business in this District. 

14. Venue is proper in this District as to SEA pursuant to 28 U.S.C. §§ 1391 and 

1400(b) because, among other things, SEA has committed acts of infringement in this judicial 

District and has a regular and established place of business in this District, including but not limited 

to regular and established places of business at 6625 Excellence Way, Plano, Texas 75023 and 

2601 Preston Road, Frisco, Texas 75034. 

15. Samsung has committed acts within this Judicial District giving rise to this action, 

and Samsung continues to conduct business in this District, including through the importation, 

sale, offer for sale and use of Infringing Products. 

16. Joinder of SEC and SEA is proper under 35 U.S.C. § 299 because Nariste asserts 

its right to relief against SEC and SEA jointly, severally, or in the alternative with respect to or 

arising out of the same transaction, occurrence, or series of transactions or occurrences relating to 

the making, using, importing into the United States, offering for sale, selling of the same accused 

products or processes, including Samsung cellular phones, tablets and other mobile products; and 

questions of fact common to SEC and SEA will arise in the action. 

IV. BACKGROUND 

17. This complaint arises from Samsung’s infringement of United States Patent No. 

RE48,206 (“Asserted Patent” or “‘206 Patent”). 

18. On September 15, 2020, the United States Patent and Trademark office duly and 

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legally issued the ‘206 Patent which is entitled “Reduced Power in Mobile GPS-Based 

Technologies.” The ‘206 Patent is valid and enforceable. 

19. The inventor of the ‘206 Patent is Dr. Robert Anderson Malaney. 

20. Nariste is the sole and exclusive owner of all rights, title, and interest in the ‘206 

Patent, including the sole and exclusive right to prosecute this action, to enforce the ‘206 Patent 

against infringers, to collect damages for past, present and future infringement of the ‘206 Patent, 

and to seek injunctive relief as appropriate under the law. Accordingly, Samsung’s infringement, 

as described below, has injured, and continues to injure Nariste. 

21. The ‘206 Patent generally relates to GPS acquisition and more particularly, to 

power conservation for GPS-enabled devices. 

22. Nariste focuses on the development of wireless technology that utilizes location 

information to enhance mobile application performance. The inventions of the ‘206 Patent grew 

out of research conducted by Dr. Malaney. Following the filing of the application that issued as 

the ‘206 Patent, Nariste undertook extensive field trials of its technology, proving the usefulness 

of the technology in acquiring location information that met certain technical requirements, whilst 

reducing mobile-battery usage. 

23. By 2010, GPS-equipped mobile phones had become standard, and providers of 

such phones had become aware of battery-power depletion issues due to on-board GPS chips. 

Accordingly, over time, the technology developed by Nariste was widely adopted by various 

mobile devices including those imported, used, manufactured, offered for sale, or sold by 

Samsung. 

24. On December 3, 2020, Nariste sent a letter to Samsung’s Director of Patent 

Acquisition and asked if Samsung would be interested in purchasing the patent. Nariste never 

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received a response to that letter from Samsung. 

25. Nariste has not licensed or otherwise authorized Samsung to make, use, offer for 

sale, sell, or import any products that embody the inventions of the ‘206 Patent. 

26. Samsung Galaxy phones include a GPS antenna to track real-time location data.2 A 

user can easily turn on and off the location service on the phone.3 A user can also improve location 

accuracy to get more accurate location services.4 Samsung provides instructions on “[h]ow to 

activate [] location and change settings for location permissions” on its website.5

27. GPS is used by the Android Operating System (“Android OS”) running on 

Samsung devices. Additionally, many applications running on Samsung devices use GPS. 

28. It is important to users of cellular phones, tablets, smart watches and other mobile 

devices (collectively, “Mobile Devices”) that the device consume power in an efficient manner. 

The users of Mobile Devices prefer a device that consumes less power in a given time period to a 

device that consumes more power in the same given time period. 

29. The users of Mobile Devices prefer a device that needs to be charged less frequently 

to a device that would have to be charged more frequently. 

30. The GPS system is one of the most power-intensive systems of a smart phone. 

Accordingly, an inefficient consumption of power by the GPS system in Samsung Mobile Devices 

is undesirable. For instance, keeping the GPS system in the Samsung Mobile Devices fully 

powered “on” at all times would prematurely drain the device battery, requiring the user to charge 

the device more frequently. On the other hand, having a GPS system in the Samsung Mobile 

2 https://www.samsung.com/latin_en/support/mobile-devices/how-to-activate-my-location-and-change-settings-forlocation-permissions (last visited Dec. 27, 2022). 3 Id. 

4 Id. 

5 Id. 

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Devices that is selectively turned on and off to use power more efficiently is preferred. 

31. A user can easily activate location services in Samsung Mobile Devices based on 

instructions provided by Samsung:6

32. Moreover, a user can change the settings for location information permissions in 

Samsung Mobile Devices using instructions provided by Samsung:7

6 https://www.samsung.com/latin_en/support/mobile-devices/how-to-activate-my-location-and-change-settings-forlocation-permissions/ (last visited Dec. 27, 2022). 7 Id. 

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33. Additionally, Samsung provides user instructions to improve location accuracy in 

Samsung Mobile Devices:8

34. Samsung’s Mobile Devices operate using the Android OS. 

35. The Android OS is developed and is made available by Google. 

8 Id. 

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36. Additional instructions and information regarding the operation of the Android OS 

on the Samsung Mobile Devices are provided by Google. 

37. For example, a user is provided with instructions on how to “[H]elp [his/her] phone 

get a more accurate location (Google Location Services a.k.a. Google Location Accuracy):9

38. When Google Location Accuracy is turned on, the Samsung Mobile Devices use 

GPS, Wi-fi, Mobile Networks, and Sensors (e.g., accelerometer) to get the most accurate 

location:10

9 https://support.google.com/accounts/answer/3467281?hl=en (last visited Dec. 27, 2022). 10 Id. 

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39. For example, on information and belief, the Android OS allows applications 

running on the Samsung Galaxy S20 to control power on (and off) functionality of GPS through 

several attributes, e.g., one being setting the required accuracy to control whether GPS is used or 

not:11

40. When Google Location Accuracy is off, GPS, Wi-Fi, network, and sensor data are 

11 https://developer.android.com/guide/topics/location/battery (last visited Dec. 30, 2022). 

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not used or collected by Google Location Accuracy.12 Moreover, for Android 12 and higher, a user 

can manage each application’s permission to access precise location.13

V. COUNT I: INFRINGEMENT OF THE ’206 PATENT 

41. Nariste incorporates each of the allegations of paragraphs 1–40 above. 

42. Samsung has directly infringed and continues to directly infringe the ‘206 Patent 

by, for example, making, using, offering to sell, selling, and/or importing into the United States, 

without authority, products that practice one or more claims of the ‘206 Patent. 

43. Samsung is not licensed or otherwise authorized to make, use, offer for sale, sell or 

import any products that embody the inventions of the ’206 Patent in the United States. 

44. Samsung has and continues to directly infringe one or more claims of the ’206 

Patent, including, for example, claim 37 of the ’206 Patent, either literally or under the doctrine of 

equivalents, by making, using, offering to sell, selling, and/or importing into the United States 

Samsung Mobile Devices without authority and in violation of 35 U.S.C. § 271. 

45. With respect to the ‘206 Patent, Samsung’s infringing products include any 

12 Id. 13 Id. 

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Samsung products with embedded GPS and WiFi capability including, for example, the following: 

(1) Samsung phones including, but not limited to, Samsung Galaxy S series (e.g., S9, S9+, S10, 

S10+, S10e, S20, S20+, S20 Ultra, S20 FE, S21, S21+, S21 Ultra, S21 FE, S22, S22+, S22 Ultra), 

Samsung Galaxy Z series (e.g., Fold4, Flip4, Fold3, Flip3, Fold2, Fold, Flip), Samsung Galaxy A 

series (e.g., A73, A72, A53, A52, A52s, A51, A50, A42, A33, A32, A23, A22, A20, A13, A12, 

A04, A04s, A04e, A03, A03S); (2) Samsung tablets including, but not limited to, Samsung Galaxy 

Tab A (e.g., A7, A7 Lite, A8, A10.1); Tab S (e.g., S4, S5e, S6, S6 Lite, S7, S7+, S7 FE, S8, S8 

Ultra, S8+); and (3) Samsung watches including, but not limited to, Samsung Galaxy Watch 

Active, Watch Active 2, Watch, Watch 3, Watch 4 and Watch 5, as well as any other Samsung 

products with a similar structure or functionality (collectively, the “Accused Products”). 

46. On information and belief, each of the Accused Products, includes the Android OS 

at the time it is manufactured, used, imported, offered for sale and/or sold in the United States. 

47. On information and belief, each of the Accused Products runs the Android OS when 

in use by a user. 

48. On information and belief, applications running on each of the Accused Products 

have access to the Android OS. 

49. On information and belief, the Accused Products come preloaded with a number of 

features and applications developed by Samsung. On information and belief, some of these features 

and application developed by Samsung use the device location information (collectively, 

“Samsung Location Apps”). 

50. On information and belief, the Samsung Location Apps include, but are not limited 

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to, “Samsung Internet,”14 “Samsung Health,”15 and “Samsung Find my Mobile.”16

51. The Samsung Location Apps running on the Accused Products receive location 

information from the Android OS running on the device. 

52. For example, the Samsung Galaxy S20 (“Galaxy S20”) includes a number of 

Samsung Location Apps including, but not limited to Bixby.17 

53. Another example of a Samsung Location App on the Galaxy S20 is the “Emergency 

Mode Features” which allows a user to share his/her location information with emergency 

contacts.18

14 https://developer.samsung.com/internet/privacy-policy-us.html (last visited Jan. 4, 2023); 

https://www.youtube.com/watch?v=YuGgGq4vcUA (last visited Jan. 4, 2023). 15 https://www.mainenewsonline.com/how-accurate-is-the-samsung-health-app/ (last visited Jan. 4, 2023). 16 https://www.youtube.com/watch?v=gFv1qwE2OmY (last visited Jan. 4, 2023). 17 https://downloadcenter.samsung.com/content/UM/202002/20200215055549358/UNL_STR_SM-G981U_SMG986U_SM-G988U_EN_UM_Q_10.0_021220_FINAL.pdf#page74 (hereinafter, “S20 User Manual”) (last visited 

Jan. 4, 2023) at 32. 

18 S20 User Manual at 52-53. 

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54. Another example of a Samsung Location App on the Galaxy S20 is the “Send SOS 

Messages” feature which allows a user to send a message with his/her location to designated 

contacts:19

55. Another example of a Samsung Location App on the Galaxy S20 is the feature 

which attaches a GPS location tag to pictures.20

19 S20 User Manual at 95. 

20 S20 User Manual at 61. 

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56. Another example of a Samsung Location App on the Galaxy S20 is a “Places” 

feature which allows a user to explore nearby business and venues using location services:21

57. Another example of a Samsung Location App on the Galaxy S20 is a “Smart Lock” 

feature which unlocks the device automatically upon detecting a “trusted location”:22

58. Another example of a Samsung Location App on the Galaxy S20 is the “Find my 

21 S20 User Manual at 101. 

22 S20 User Manual at 150. 

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Mobile” features which uses Google’s location service.23

59. On information and belief, the Accused Products come preloaded with a number of 

third-party applications. On information and belief, some of these preloaded third-party 

applications use the device location information (collectively, “Third Party Location Apps”). 

60. For example, one of the Third Party Location Apps is Google Maps.24

61. On information and belief, the accused Samsung Phones include Google Maps, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

62. On information and belief, the accused Samsung Tablets include Google Maps, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

63. On information and belief, the accused Samsung Watches include Google Maps, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

64. Another example of the Third Party Location Apps is Google Chrome.25

23 S20 User Manual at 151. 

24 See, e.g., S20 User Manual at 112. 25 See, e.g., S20 User Manual at 111. 

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65. On information and belief, the accused Samsung Phones include Google Chrome, 

as manufactured, used, imported, offered for sale and/or sold in the United States. 

66. On information and belief, the accused Samsung Tablets include Google Chrome, 

as manufactured, used, imported, offered for sale and/or sold in the United States. 

67. On information and belief, the accused Samsung Watches include Google Chrome, 

as manufactured, used, imported, offered for sale and/or sold in the United States. 

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68. Another example of the Third Party Location Apps is Instagram. 

26

27

69. On information and belief, the accused Samsung Phones include Instagram, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

70. On information and belief, the accused Samsung Tablets include Instagram, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

71. On information and belief, the accused Samsung Watches include Instagram, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

26 https://help.instagram.com/171821142968851 (last visited Jan. 5, 2023). 27 https://www.newsnationnow.com/business/tech/is-instagrams-precise-location-feature-tracking-you (last visited 

Jan. 5, 2023). 

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72. Another example of the Third Party Location Apps is Facebook.28

73. On information and belief, the accused Samsung Phones include Facebook, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

74. On information and belief, the accused Samsung Tablets include Facebook, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

75. On information and belief, the accused Samsung Watches include Facebook, as 

manufactured, used, imported, offered for sale and/or sold in the United States. 

76. On information and belief, the Samsung Location Apps and the Third Party 

28 https://www.facebook.com/help/337244676357509 (last visited Jan. 5, 2023). 

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Location Apps in the Samsung Mobile Devices use the Android Framework Location APIs.29 The 

Android Framework Location APIs then hook into the next lower layer on the Android stack 

referred to as the Application Framework. The LocationManager software within this Application 

Framework controls the power to a number of sensors in the Samsung Mobile Devices including 

the GPS. The LocationManager allows applications to obtain periodic updates of the device’s 

geographical location, or to be notified when the device enters the proximity of a given 

geographical location.30

77. Fused Location Provider API (hereinafter, “Fused-Location”) is provided as a 

wrapper around the Framework Location APIs via a service module preloaded on Android Devices 

and referred to as Google Play Services. 

78. On information and belief, the Accused Products as manufactured, used, imported, 

offered for sale and/or sold in the United States include Google Play Services. 

79. On information and belief, Samsung has pre-loaded Fused-Location directly on a 

29 The Android Framework Location APIs are available, for example, at 

https://android.googlesource.com/platform/frameworks/base/+/refs/heads/master/location/java/android/location (last 

visited Jan. 5, 2023). 

30 https://developer.android.com/reference/android/location/LocationManager (last visited Jan. 5, 2023). 

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number of the Accused Products including, for example, the Samsung Galaxy S series (e.g., S9,31 

S10,32 S20 Ultra,33 S20 FE,34 S2135) and Samsung Galaxy Z series (e.g., Flip36). 

80. For example, Samsung Galaxy S20 infringes representative claim 37 of the ‘206 

Patent. On information and belief, the remaining Accused Products infringe representative claim 

37 of the ‘206 Patent at least for the same reasons and in the same manner. 

81. Claim 37 of the ‘206 Patent claims a method of acquiring a position on a mobile 

wireless communication device for a wireless communications network, said mobile wireless 

communication device possessing wireless communications capability for said wireless 

communications network and an embedded GPS module for GPS capability, said GPS referring 

to GPS-based techniques, said method comprising: determining when said embedded GPS module 

should be powered on, said embedded GPS module then being powered on, said when said 

embedded GPS module should be powered on being dependent on at least one of a current radio 

position and a position error of said mobile device determined from the wireless communications 

network, said wireless communications network being different from said GPS. 

82. Samsung Galaxy S20 implements a method of acquiring a position on a mobile 

wireless communication device for a wireless communications network, said mobile wireless 

communication device possessing wireless communications capability for said wireless 

communications network and an embedded GPS module for GPS capability, said GPS referring 

to GPS-based techniques.37

31 https://docs.samsungknox.com/CCMode/G960F_Q.pdf (last visited Jan. 5, 2023). 32 https://docs.samsungknox.com/CCMode/G973U_Q.pdf (last visited Jan. 5, 2023). 33 https://docs.samsungknox.com/CCMode/G988U_Q.pdf (last visited Jan. 5, 2023). 34 https://docs.samsungknox.com/CCMode/G781B_R.pdf (last visited Jan. 5, 2023). 35 https://docs.samsungknox.com/CCMode/G998N_5G_R.pdf (last visited Jan. 5, 2023). 36 https://docs.samsungknox.com/CCMode/SCG04_Q.pdf (last visited Jan. 5, 2023). 37 https://www.samsung.com/au/smartphones/galaxy-s20/specs/ (last visited Dec. 30, 2022). 

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83. The location services on the Samsung Galaxy S20 use a combination of GPS, 

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mobile network and Wi-fi to determine device location.38

84. The Samsung Location Apps and the Third Party Location Apps running on the 

Samsung Galaxy S20 use the determined device location information. 

85. Samsung Galaxy S20 determines when said embedded GPS module should be 

powered on, and said embedded GPS module is then powered on. 

86. On information and belief, the Android OS allows applications running on the 

Samsung Galaxy S20 (e.g., Samsung Location Apps and the Third Party Location Apps) to control 

power on (and off) functionality of GPS through several attributes, e.g., one being setting the 

required accuracy to control whether GPS is used or not: 

38 S20 User Manual at 156-157. 

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39

40

87. On information and belief, when said embedded GPS module of the Samsung 

Galaxy S20 should be powered on is dependent on at least one of a current radio position and a 

position error of said mobile device determined from the wireless communications network, said 

wireless communications network being different from said GPS. 

39 https://developer.android.com/guide/topics/location/battery (last visited Dec. 30, 2022). 40

https://developers.google.com/android/reference/com/google/android/gms/location/Priority#PRIORITY_HIGH_AC

CURACY (last visited Jan. 6, 2023). 

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88. For instance, the Android OS running on the Samsung Galaxy S20 allows an 

application to acquire a current radio position. 

41

89. The Android OS running on the Samsung Galaxy S20 also allows an application to 

independently get the position error (e.g., through getAccuracy()). 

41

https://developers.google.com/android/reference/com/google/android/gms/awareness/snapshot/LocationResult?hl=e

n (last visited Dec. 30, 2022). 

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42

90. The Android OS running on the Samsung Galaxy S20 also allows an application to 

independently set the required error of the position location (e.g., through setAccuracy()). 

43

91. The Android OS running on the Samsung Galaxy S20 also allows applications to 

use only wireless communication networks (e.g., Wifi and/or cellular signal and not GPS) for 

42 https://developer.android.com/reference/android/location/Location#getAccuracy() (last visited Dec. 30, 2022). 43 https://developer.android.com/reference/android/location/Criteria#setAccuracy(int) (last visited Dec. 30, 2022). 

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positioning.44 

92. Samsung has and continues to directly infringe the ‘206 Patent, either literally or 

under the doctrine of equivalents, without authority and in violation of 35 U.S.C. § 271, by making, 

using, offering to sell, selling, and/or importing into the United States the Accused Products that 

satisfy each and every limitation of one or more claims of the ‘206 Patent. 

93. Samsung had actual notice of the ‘206 Patent and its infringement of the same at 

least as of December 3, 2020, when it received a first letter from Nariste regarding the same. 

94. Samsung had actual notice of the ‘206 Patent and its infringement of the same at 

least as of January 26, 2023, when it received a second letter from Nariste regarding the same. 

95. Samsung had actual notice of the ‘206 Patent and its infringement of the same at 

least as of the filing date of this Complaint. 

44 https://developer.android.com/guide/topics/location/battery (last visited Dec. 30, 2022). 

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28 

96. Samsung instructs the users to choose location services during device set up for the 

Accused Products as is shown, for example, in the Samsung Galaxy S20 User Manual:45

97. In the User Manual, Samsung tells users that some applications require that location 

services be turned on for full functionality.46

98. In the User Manual, Samsung provide instructions for users to configure 

permissions for applications to access the device location information.47

45 S20 User Manual at 12. 

46 S20 User Manual at 156. 47 S20 User Manual at 156. 

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99. In the User Manual, Samsung provides instructions on how to obtain a list of 

applications that have requested the user’s location:48

100. Samsung advertises the Samsung Locations Apps and encourages users to use the 

Samsung Location Apps. 

101. Samsung advertises the Third Party Location Apps and encourages users to use the 

Third Party Location Apps. 

102. Samsung provides instructions to users and encourages users to download 

applications from the Google Play Store.49 

48 S20 User Manual at 156. 

49 https://www.samsung.com/au/support/mobile-devices/how-to-install-apps-from-the-google-play-store/ (last 

visited Jan. 5, 2023) 

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103. The Google Play Store includes a number of applications that use location services 

as described above, including, for example, Life360,50 SnapChat,51 PokemonGo,52 FourSquare,53

and others (collectively, “Google Play Location Apps”). 

104. Accordingly, Samsung advertises the infringing features, has published instructions 

regarding the use of the infringing features, and encourages customers to use the infringing features 

by providing instructions and encouraging them to use the Samsung Location Apps, Third Party 

Locations Apps, and the Google Play Location Apps. With respect to this induced infringement, 

at least the end users of the Accused Products are direct infringers that directly infringe the claims 

of the ‘206 Patent pursuant to Samsung’s instructions and advertisement. 

JURY DEMAND 

105. Nariste hereby demands a trial by jury on all issues so triable. 

PRAYER FOR RELIEF 

WHEREFORE, Nariste requests entry of judgment in its favor and against Samsung as 

follows: 

a) A declaration that Samsung has directly infringed one or more claims of the Asserted 

Patent, either literally or under the doctrine of equivalents; 

b) A declaration that Samsung has induced infringement and/or is inducing infringement of 

one or more claims of the Asserted Patent, either literally or under the doctrine of 

equivalents; 

c) An award of damages pursuant to 35 U.S.C. § 284 adequate to compensate Nariste for 

50 https://play.google.com/store/search?q=life360&c=apps&hl=en_US&gl=US (last visited Jan. 5, 2023). 51 https://play.google.com/store/apps/details?id=com.snapchat.android&hl=en_US&gl=US (last visited Jan. 5, 

2023). 

52 https://play.google.com/store/apps/details?id=com.nianticlabs.pokemongo&hl=en_US&gl=US (last visited Jan. 5, 

2023). 

53 https://play.google.com/store/apps/details?id=com.joelapenna.foursquared&hl=en_US&gl=US (last visited Jan. 5, 

2023). 

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Samsung’s infringement of the Asserted Patent in an amount according to proof at trial 

(together with prejudgment and post-judgment interest), but no less than a reasonable 

royalty; 

d) An award of costs and expenses pursuant to 35 U.S.C. § 284 or as otherwise permitted by 

law; and 

e) Such other and further relief, whether legal, equitable, or otherwise, to which Nariste may 

be entitled or which this Court may order. 

 

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Dated: January 27, 2023 Respectfully submitted,

/s/ Amir Alavi 

Amir Alavi 

Texas Bar No. 00793239 

aalavi@aatriallaw.com 

Masood Anjom 

Texas Bar No. 24055107 

manjom@aatriallaw.com 

Scott Clark 

Texas Bar No. 24007003 

sclark@aatriallaw.com 

Michael McBride 

Texas Bar No. 24065700 

mmcbride@aatriallaw.com 

ALAVI & ANAIPAKOS PLLC 

3417 Mercer Street, Suite C 

Houston, Texas 77027 

Telephone: (713) 751-2362 

Facsimile: (713) 751-2341 

Counsel for Plaintiff Nariste Networks Pty. 

Ltd. 

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