Golden v. Samsung Electronics America, Inc.

Background

Larry Golden brought patent-infringement claims against Samsung Electronics America, Inc. involving United States Patent Nos. 9,096,189, 9,589,439, and 10,163,287. The patents share a specification and are titled “Multi Sensor Detection, Stall to Stop and Lock Disabling System.” The opinion describes them as addressing systems for detecting chemical, biological, or radiological hazards and disabling locks or preventing unauthorized access.

The opinion states that Golden had pursued related patent claims for more than ten years in multiple courts. In an earlier case against the United States involving Samsung and other cellphone manufacturers’ products, the Federal Court of Claims dismissed his claims with prejudice, and the Federal Circuit affirmed that dismissal. The opinion also describes other courts’ dismissals of related claims involving smartphone technologies and states that some of those decisions were affirmed.

The parties’ arguments

Samsung moved to dismiss. It argued that issue preclusion—which prevents a party from relitigating an issue already finally decided—barred Golden’s claims because he had previously asserted the same infringement theories involving Samsung products. Samsung also relied on the Kessler doctrine, which the opinion describes as protecting an adjudged non-infringer from repeated suits involving essentially the same devices after a final judgment. Samsung separately argued that Golden’s complaint was frivolous because it did not explain how Samsung’s products met key patent requirements for direct infringement or provide facts supporting induced or contributory infringement.

Golden opposed dismissal and filed a cross-motion for summary judgment. He argued that the earlier case did not allow him to litigate the infringement claims against Samsung on their merits because the earlier complaint had been dismissed for failing to plausibly allege infringement. He also argued that his allegations resembled those in another case in which the Federal Circuit reversed a dismissal and allowed another opportunity to plead.

Court’s analysis

The court concluded that Golden had received a full opportunity to litigate his claims concerning Samsung’s products in the earlier case. Because that case had been dismissed with prejudice and the dismissal had been affirmed, the court held that traditional preclusion principles barred this action. The court also held that the Kessler doctrine barred Golden’s attempt to assert the same infringement theories against newer Samsung products.

The court gave an alternative reason for dismissal. Golden alleged that Samsung infringed the patents through smartphone central processing units, global positioning system and web-browser functions, camera lenses, biometric unlocking, and remote unlocking technology. The court found these allegations wholly unsupported and implausible because they did not adequately connect those features to the patent requirements. The court compared the allegations to other broad and unspecific patent claims that had been dismissed without permission to amend.

Disposition

The court denied Golden’s cross-motion for summary judgment. It granted Samsung’s motion to dismiss the complaint without leave to amend and dismissed the case with prejudice. The order was signed by United States District Judge William H. Orrick.