Samsung Electronics Co, Ltd. v. Blaze Mobile, Inc.

Background

Samsung Electronics Co. and Samsung Electronics America, Inc. sued Blaze Mobile, Inc. and Michelle Fisher. The case concerns eight asserted patents, grouped as Advertising Patents, NFC Security Patents, and Mobile Payment Patents, along with Blaze’s non-patent claims.

The court stayed the case in August 2023 while the U.S. Patent and Trademark Office conducted ex parte reexaminations—proceedings addressing patent validity. Blaze moved to partially lift the stay for the Advertising Patents, two NFC Security Patents, and its non-patent claims. Blaze narrowed its request from lifting the entire stay to that partial request.

Court’s Analysis

The court applied three factors used to decide whether to continue a stay pending patent reexamination: the status of discovery and trial scheduling; whether the stay would simplify the case; and whether continuing the stay would unfairly prejudice the party opposing it.

The court found that the factors strongly favored partially lifting the stay. The Patent Office had completed reexamination of the asserted patents except for issuing the reexamination certificate for the ’612 Patent. The Patent Office had determined that the ’493, ’007, and ’259 Patents were invalid in their entirety, and Blaze had appealed those decisions to the Patent Trial and Appeal Board and the Federal Circuit.

The court concluded that continuing the complete stay would not greatly simplify the case because reexamination of most of the patents was finished. Resuming discovery and allowing dispositive motions could instead reduce the issues for trial. The court also found that discovery concerning the Advertising Patents and NFC Security Patents would not substantially overlap with discovery concerning the Mobile Payment Patents still on appeal because Blaze accused different products for the different patent categories.

The court further found that continuing the stay could prejudice Blaze because the case had been pending for more than four years and had been stayed for about half that time. The court noted that relevant witnesses could become unavailable and evidence could be lost. Although the case had been stayed before discovery began or a trial date was set, the court attributed that circumstance to Samsung’s requests for reexamination and its motion to stay the case.

Ruling

Judge Edward J. Davila granted Blaze’s motion and partially lifted the stay as to the Advertising Patents, the ’575 Patent, the ’771 Patent, and Blaze’s non-patent claims. The order did not lift the stay for the remaining matters. The court set an initial case-management conference for October 9, 2025, and required the parties to file a joint case-management conference statement by September 29, 2025.