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.

Case No. 2:23-cv-00485

JURY TRIAL DEMANDED

REDSTONE’S ANSWER TO DEFENDANTS’ COUNTERCLAIMS

Plaintiff Redstone Logics LLC (“Redstone”) hereby answers Samsung Electronics Co., 

Ltd. and Samsung Electronics America, Inc. (collectively “Defendants” or “Samsung”)

counterclaims as follows:

PARTIES

23. Admitted.

24. Admitted.

25. Admitted.

JURISDICTION AND VENUE

26. Admit that Defendants’ counterclaims arise under the patent laws of the United 

States and that Defendants seek certain declaratory relief. Deny that Defendants are 

entitled to any such relief. Deny any other allegations in this paragraph.

27. Admit that venue is proper in this district. Deny any other allegations in this 

paragraph.

Case 2:23-cv-00485-JRG Document 20 Filed 03/12/24 Page 1 of 5 PageID #: 113
2

BACKGROUND

28. Admitted.

29. Admit that Plaintiff’s allegations in its Complaint speak for themselves. Deny any 

other allegations in this paragraph.

30. Admit that there is a case or controversy between the parties concerning alleged 

infringement and validity of the Patents-in-Suit. Deny any other allegations in this 

paragraph.

COUNT I

Declaratory Judgment of Non-Infringement of U.S. Patent No. 8,549,339

31. Plaintiff realleges Paragraphs 23-30 as though fully set forth herein.

32. Denied.

33. Denied.

COUNT II

Declaratory Judgment of Non-Infringement of U.S. Patent No. 9,253,925

34. Plaintiff realleges Paragraphs 23-33 as though fully set forth herein.

35. Denied.

36. Denied.

COUNT III

Declaratory Judgment of Invalidity of U.S. Patent No. 8,549,339

37. Plaintiff realleges Paragraphs 23-36 as though fully set forth herein.

38. Denied.

39. Denied.

Case 2:23-cv-00485-JRG Document 20 Filed 03/12/24 Page 2 of 5 PageID #: 114
3

COUNT IV

Declaratory Judgment of Invalidity of U.S. Patent No. 9,253,925

40. Plaintiff realleges Paragraphs 23-39 as though fully set forth herein.

41. Denied.

42. Denied.

PRAYER FOR RELIEF

WHEREFORE, Redstone prays for the following relief with respect to Defendants’ 

counterclaims:

A. A judgment in favor of Plaintiff on all counterclaims asserted by Defendants;

B. An adjudication that Defendants are not entitled to any relief on its counterclaims, 

including, without limitation, any fine or damages; and

C. A dismissal with prejudice of Defendants’ counterclaims;

D. A judgment and order finding that this is an exceptional case within the meaning 

of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees against 

Defendants; 

E. Plaintiff’s costs of suit against Defendants; and

F. Any and all other relief as the Court may deem appropriate and just under the 

circumstances.

DEMAND FOR JURY TRIAL

Redstone demands a trial by jury on all issues so triable.

Case 2:23-cv-00485-JRG Document 20 Filed 03/12/24 Page 3 of 5 PageID #: 115
4

Dated: March 12, 2024 /s/ Reza Mirzaie 

RUSS AUGUST & KABAT

Reza Mirzaie, SBN 246953

Email: rmirzaie@raklaw.com 

Marc A. Fenster, SBN 181067

Email: mfenster@raklaw.com 

Neil A. Rubin, SBN 250761

Email: nrubin@raklaw.com 

Christian W. Conkle, SBN 306374

Email: cconkle@raklaw.com 

Jonathan Ma, SBN 312773

Email: jma@raklaw.com 

12424 Wilshire Boulevard, 12th Floor

Los Angeles, California 90025

Telephone: (310) 826-7474

Facsimile: (310) 826-6991

Attorneys for Plaintiff Redstone Logics LLC

Case 2:23-cv-00485-JRG Document 20 Filed 03/12/24 Page 4 of 5 PageID #: 116
CERTIFICATE OF SERVICE

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

being served today, March 12, 2024, with a copy of this document via the Court’s CM/ECF system.

/s/ Reza Mirzaie 

Reza Mirzaie

Case 2:23-cv-00485-JRG Document 20 Filed 03/12/24 Page 5 of 5 PageID #: 117