IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

REDSTONE LOGICS LLC,

Plaintiff,

v.

SAMSUNG ELECTRONICS CO., LTD.

SAMSUNG ELECTRONICS AMERICA, 

INC.,

Defendants.

Civil Action No. 2:23-cv-00485

JURY TRIAL DEMANDED

DEFENDANTS SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG 

ELECTRONICS AMERICA, INC.’S ANSWER AND COUNTERCLAIMS TO

PLAINTIFF REDSTONE LOGICS LLC’S COMPLAINT

Defendants Samsung Electronics Co., Ltd. (“SEC”) and Samsung Electronics 

America, Inc. (“SEA”) (collectively, “Samsung”), by and through its undersigned counsel,

hereby answer the Complaint filed by Plaintiff Redstone Logics LLC (“Redstone”) in Civil 

Action No. 2:23-cv-485 (Dkt. No. 1). Samsung denies each and every allegation of the 

Complaint to the extent such allegation is not expressly admitted in the following paragraphs.

THE PARTIES

1. Samsung is without knowledge or information sufficient to form a belief 

as to the truth of the allegations in Paragraph 1 and therefore denies them.

2. Samsung admits that SEC is a corporation organized under the laws of 

South Korea. Samsung admits that SEC has a location at 129, Samsung-ro, Yeongtong-gu, 

Suwon-si, Gyeonggi-do, 443-742, Republic of Korea. Samsung denies the remaining allegations 

in Paragraph 2.

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3. Samsung admits that SEA is a corporation organized under the laws of the 

State of New York. Samsung admits that SEA has a location at 85 Challenger Road, Ridgefield 

Park, New Jersey 07660. Samsung admits that SEA has a location at 6625 Excellence Way, 

Plano, Texas 75023. Samsung admits that SEA is a wholly-owned subsidiary of SEC. Samsung 

admits that SEA distributes certain Samsung-branded consumer electronics products in the 

United States. Samsung denies any remaining allegations in Paragraph 3, and specifically denies 

that it has committed or is committing any act of patent infringement.

JURISDICTION AND VENUE

4. Samsung states that the allegations in Paragraph 4 contain legal 

conclusions that require no answer. To the extent an answer is required, Samsung admits that the 

Complaint purports to make claims under the patent laws of the United States, 35 U.S.C. §§ 1, et 

seq. Samsung admits, for purposes of this action only, that this Court has subject matter 

jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 1338(a). Samsung denies any and 

all remaining allegations in Paragraph 4.

5. Samsung states that the allegations in Paragraph 5 contain legal 

conclusions that require no answer. To the extent an answer is required, Samsung does not 

contest that, for purposes of this action only, the Court has personal jurisdiction over Samsung. 

Samsung denies that it has committed or is committing any act of patent infringement. Samsung 

denies any and all remaining allegations in Paragraph 5.

6. Samsung states that the allegations in Paragraph 6 contain legal 

conclusions that require no answer. To the extent an answer is required, Samsung does not 

contest that, for purposes of this case only, venue over Samsung properly lies in this District, but 

Samsung denies that venue is convenient in this District. Samsung denies the remaining 

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allegations in Paragraph 6, and specifically denies that it has committed or is committing any act 

of patent infringement.

COUNT ONE: ALLEGED INFRINGEMENT OF U.S. PATENT NO. 8,549,3391

7. Samsung restates and incorporates by reference its answers to Paragraphs 

1 through 6 as if fully set forth herein.

8. Samsung admits that, on its face, U.S. Patent No. 8,549,339 (“the ’339 

Patent”) is titled “Processor core communication in multi-core processor” and states that it issued 

on October 1, 2013. Samsung admits that what purports to be a copy of the ’339 Patent was 

attached to the Complaint as Exhibit 1. Samsung is without information sufficient to form a 

belief as to the truth of the remaining allegations in Paragraph 8, and on that basis denies them.

9. Samsung admits that it makes and sells Samsung Galaxy S23 

smartphones. Samsung denies that any Samsung products infringe, literally and/or under the 

doctrine of equivalents, any claim of the ’339 Patent. Samsung denies the remaining allegations 

of Paragraph 9.

10. Denied.

11. Denied.

12. Samsung admits that Exhibit 2 attached to the Complaint purports to be a 

claim chart relating to claim 1 of the ’339 Patent and Accused Products. Samsung denies that the 

Accused Products charted in Exhibit 2 or any other Samsung products satisfy all claim 

limitations of one or more claims of the ’339 Patent. Samsung denies the remaining allegations

of Paragraph 12.

1 To the extent that the headings in the Complaint can be construed as allegations, Samsung 

denies any and all allegations in the headings. 

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13. Denied.

14. Denied.

COUNT TWO: ALLEGED INFRINGEMENT OF U.S. PATENT NO. 9,253,925

15. Samsung restates and incorporates by reference its answers to Paragraphs 

1 through 14 as if fully set forth herein.

16. Samsung admits that, on its face, U.S. Patent No. 9,253,925 (“the ’925 

Patent”) is titled “Panel for enhancing thermal conduction in an electronic assembly” and states 

that it issued on February 2, 2016. Samsung admits that what purports to be a copy of the ’925 

Patent was attached to the Complaint as Exhibit 3. Samsung is without information sufficient to 

form a belief as to the truth of the remaining allegations in Paragraph 16, and on that basis denies 

them.

17. Samsung admits that it makes and sells Samsung Galaxy S22

smartphones. Samsung denies that any Samsung products infringe, literally and/or under the 

doctrine of equivalents, any claim of the ’925 Patent. Samsung denies the remaining allegations 

of Paragraph 17.

18. Denied.

19. Samsung admits that Exhibit 4 attached to the Complaint purports to be a 

claim chart relating to claim 3 of the ’925 Patent and Accused Products. Samsung denies that the 

Accused Products charted in Exhibit 4 or any other Samsung products satisfy all claim 

limitations of one or more claims of the ’925 Patent. Samsung denies the remaining allegations

of Paragraph 19.

20. Denied.

21. Denied.

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DEMAND FOR JURY TRIAL

22. Redstone’s demand for a trial by jury for any issues triable to a jury does 

not state any allegation to which Samsung is required to respond.

PRAYER FOR RELIEF

No response to the Prayer for Relief is necessary. To the extent a response is 

required, Samsung denies any allegations contained in the Prayer for Relief, and denies that 

Redstone is entitled to any of the requested relief.

AFFIRMATIVE DEFENSES

Without assuming any burden Samsung would not otherwise have, Samsung 

asserts the following defenses:

FIRST DEFENSE

(Failure to State a Claim)

Redstone’s Complaint fails to allege plausible facts in support of any claim for 

relief and fails to state any claim upon which relief may be granted.

SECOND DEFENSE

(Invalidity)

The asserted claims of the ’339 and ’925 Patents are invalid for failure to comply 

with one or more of the requirements of 35 U.S.C. §§ 101, 102, 103, and/or 112.

THIRD DEFENSE

(Non-infringement)

Samsung has not directly or indirectly infringed any valid claim of the ’339 and 

’925 Patents, either literally or under the doctrine of equivalents.

FOURTH DEFENSE

(Limitation on Damages Under Section 286)

Redstone’s claims for damages are barred to the extent Redstone seeks damages 

beyond the applicable statute of limitations, 35 U.S.C. § 286.

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FIFTH DEFENSE

(Limitation on Damages Under Section 287)

Redstone’s claims for damages prior to the date of notice to Samsung are barred 

to the extent Redstone has failed to comply with the requirements of 35 U.S.C. § 287.

SIXTH DEFENSE

(Prosecution History Estoppel)

Redstone’s claims are barred, in whole or in part, by the doctrine of prosecution 

history estoppel to the extent Redstone alleges infringement under the doctrine of equivalents.

SEVENTH DEFENSE

(Equitable Doctrines)

Redstone’s claims are barred, in whole or in part, by the equitable doctrines of 

laches, waiver, estoppel, acquiescence, and/or unclean hands.

EIGHTH DEFENSE

(License and Exhaustion)

Redstone’s claims are barred to the extent that Redstone has licensed or 

authorized, either expressly or impliedly, the alleged infringement, or has otherwise exhausted its 

rights and remedies as to the alleged infringement.

NINTH DEFENSE

(Lack of Standing)

Redstone’s claims fail to the extent it lacks standing to assert the ’339 and/or ’925

Patents.

TENTH DEFENSE

(Extraterritoriality)

Redstone’s claims for patent infringement are precluded in whole or in part to the 

extent that any accused functionality or acts are located or performed outside of the United 

States.

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ELEVENTH DEFENSE

(No Basis for Injunctive Relief)

Redstone cannot show that it is entitled to injunctive relief.

RESERVATION OF RIGHTS TO ASSERT

ADDITIONAL DEFENSES

Samsung has not knowingly or intentionally waived any applicable defenses, and 

it reserves the right to assert and rely upon other applicable defenses that may become available 

or apparent throughout the course of this action. Samsung reserves the right to amend or seek to 

amend its answer or affirmative defenses.

COUNTERCLAIMS 

Pursuant to Federal Rule of Civil Procedure 13, Samsung Electronics Co., Ltd. 

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

counterclaim against Redstone Logics LLC (“Redstone”) and, in support thereof, allege the 

following:

PARTIES

23. Counterclaim-Plaintiff SEC is a business entity organized under the laws 

of the Republic of Korea with a principal place of business at 129, Samsung-ro, Yeongtong-gu, 

Suwon-si, Gyeonggi-do, 443-742, Republic of Korea.

24. Counterclaim-Plaintiff SEA is a corporation organized and existing under 

the laws of New York, with a place of business at 85 Challenger Road, Ridgefield Park, New 

Jersey 07660.

25. Upon information and belief, Counterclaim-Defendant Redstone is a 

limited liability company organized under the laws of the State of Texas, with an address at 2150 

S. Central Expressway, Suite 200, McKinney, TX 75070.

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JURISDICTION AND VENUE

26. Samsung asserts counterclaims seeking declaratory judgments of noninfringement and invalidity of U.S. Patents No. 8,549,339 (the “’339 Patent”) and 9,253,925 (the

“’925 Patent”) (collectively, “the Asserted Patents”). This Court has subject matter jurisdiction 

over these counterclaims pursuant to 28 U.S.C. §§ 1331, 1338(a), 2201, and 2202.

27. Venue is proper in the Eastern District of Texas, although not the most 

convenient venue, under 28 U.S.C. §§ 1391 and 1400, as a result of Redstone having filed this 

action in this District. By filing its Complaint in this District, Redstone has consented to personal 

jurisdiction and venue.

BACKGROUND

28. On October 17, 2023, Redstone filed suit against Samsung, claiming 

infringement of the Asserted Patents.

29. In its Complaint, Redstone alleges that it is the owner of both of the 

Asserted Patents. Complaint (Dkt. No. 1) ¶¶ 8 and 16.

30. An actual, substantial, and justiciable controversy, within the meaning of 

28 U.S.C. §§ 2201 and 2202, exists between Redstone and Samsung concerning the infringement 

and validity of the Asserted Patents. This controversy is of sufficient immediacy and reality to 

warrant the issuance of a declaratory judgment.

COUNT ONE

(Declaratory Judgment of Non-Infringement of the ’339 Patent)

31. Samsung incorporates by reference the admissions, denials, and 

allegations set forth in the preceding paragraphs of this Answer as if fully set forth herein.

32. Samsung has not infringed and is not infringing, directly or indirectly, any 

claim of the ’339 Patent. 

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33. Samsung is entitled to a declaratory judgment that it does not infringe, 

directly or indirectly, any claim of the ’339 Patent. 

COUNT TWO

(Declaratory Judgment of Non-Infringement of the ’925 Patent)

34. Samsung incorporates by reference the admissions, denials, and 

allegations set forth in the preceding paragraphs of this Answer as if fully set forth herein.

35. Samsung has not infringed and is not infringing, directly or indirectly, any 

claim of the ’925 Patent. 

36. Samsung is entitled to a declaratory judgment that it does not infringe, 

directly or indirectly, any claim of the ’925 Patent.

COUNT THREE

(Declaratory Judgment of Invalidity of the ’339 Patent)

37. Samsung incorporates by reference the admissions, denials, and 

allegations set forth in the preceding paragraphs of this Answer as if fully set forth herein.

38. The claims of the ’339 Patent are invalid for failure to comply with one or 

more requirements of patentability, including 35 U.S.C. §§ 101, 102, 103, and/or 112. 

39. Samsung is entitled to a declaratory judgment that the claims of the ’339

Patent are invalid. 

COUNT FOUR

(Declaratory Judgment of Invalidity of the ’925 Patent)

40. Samsung incorporates by reference the admissions, denials, and 

allegations set forth in the preceding paragraphs of this Answer as if fully set forth herein.

41. The claims of the ’925 Patent are invalid for failure to comply with one or 

more requirements of patentability, including 35 U.S.C. §§ 101, 102, 103, and/or 112. 

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42. Samsung is entitled to a declaratory judgment that the claims of the ’925

Patent are invalid.

DEMAND FOR JURY TRIAL

Samsung demands a jury trial on all issues that may be so tried.

REQUEST FOR RELIEF

WHEREFORE, Samsung prays for the following judgment and relief:

A. That Redstone take nothing by reason of its Complaint, that Redstone’s 

Complaint be dismissed in its entirety with prejudice, and that judgment be rendered in favor of 

Samsung and against Redstone;

B. A declaration that Samsung has not infringed and is not infringing the 

’339 Patent;

C. A declaration that Samsung has not infringed and is not infringing the 

’925 Patent;

D. A declaration that the claims of the ’339 Patent are invalid;

E. A declaration that the claims of the ’925 Patent are invalid;

F. A finding that this case is exceptional under 35 U.S.C. § 285 and an award 

to Samsung of its attorneys’ fees in this action;

G. An award to Samsung of its costs and expenses in this action; and

H. All other and further relief as the Court deems proper and just be granted. 

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Dated: February 8, 2024 By: /s/ Melissa R. Smith

Melissa R. Smith

GILLAM & SMITH LLP

303 S. Washington Ave.

Marshall, TX 75670

(903) 934-8450

melissa@gillamsmithlaw.com

Richard L. Rainey

COVINGTON & BURLING LLP

One CityCenter

850 Tenth Street, NW

Washington, DC 20001-4956

(202) 662-6000

rrainey@cov.com

Attorneys for Defendants Samsung Electronics 

Co., Ltd. and Samsung Electronics America, Inc.

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CERTIFICATE OF SERVICE

I certify that counsel of record who are deemed to have consented to electronic 

service are being served today, February 8, 2024, with a copy of this document via the Court’s

CM/ECF system per Local Rule CV-5(a)(3).

/s/ Melissa R. Smith

Melissa R. Smith

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