Jacobsen v. Samsung: Venue Transfer in Device Provisioning Patent Case
Updated on Dec. 8, 2025 | Written by Patsnap Team
Introduction
In a swift procedural ruling, the California Northern District Court transferred Krista Jacobsen’s patent infringement action against Samsung Electronics Co., Ltd. to the Eastern District of Texas. The case, filed May 7, 2025, and resolved just 15 days later, involved two patents covering automated device provisioning and service usage billing technologies—systems integral to modern smartphone activation and carrier billing processes.
This Jacobsen Samsung patent case analysis highlights how procedural maneuvering shapes technology patent disputes before substantive issues are addressed. For IP professionals tracking wireless technology patent infringement 2025 trends, this case offers insights into Northern District California patent cases and forum selection dynamics.
Case Summary
| Field | Details |
|---|---|
| Case Name | Krista Jacobsen v. Samsung Electronics Co., Ltd. |
| Case Number | 3:25-mc-80104 |
| Court | California Northern District Court (District Court) |
| Filing/Closure | May 7, 2025 – May 22, 2025 (15 days) |
| Outcome | Transferred to Eastern District of Texas per Rule 45(f) |
| Patents | US8588110B2, US8639811B2 |
| Products | Automated device provisioning and activation; Verifiable device assisted service usage billing with integrated accounting, mediation accounting, and multi-account |
| Plaintiff Counsel | Russ August & Kabat LLP (James Shrin Tsuei, Marc A. Fenster) |
| Defendant Counsel | Fish & Richardson P.C. (Leeron Kalay) |
| Termination Basis | Case Transferred |
Case Overview
The Parties
Plaintiff Krista Jacobsen brought this infringement action as an individual patent holder targeting telecommunications technologies.
Defendant Samsung Electronics Co., Ltd. ranks among the world’s largest consumer electronics manufacturers, facing substantial patent litigation exposure across its smartphone and connected device portfolios.
The Patents at Issue
Two U.S. patents formed the basis of this device provisioning patent infringement action:
US8588110B2 – Covers automated device provisioning and activation technology enabling smartphones to configure network settings and authenticate with carriers.
US8639811B2 – Addresses verifiable device assisted service usage billing with integrated accounting, mediation accounting, and multi-account functionality.
Research patent families on Patsnap Eureka IP for related provisioning technology portfolios.
Legal Representation
Plaintiff’s Counsel: James Shrin Tsuei and Marc A. Fenster of Russ August & Kabat LLP
Defendant’s Counsel: Leeron Kalay of Fish & Richardson P.C.
Litigation Timeline & Procedural History
| Date | Event |
|---|---|
| May 7, 2025 | Case filed in California Northern District Court |
| May 22, 2025 | Court grants unopposed transfer to E.D. Tex. |
Duration: 15 days
The rapid resolution reflects the procedural nature—a venue transfer under Federal Rule of Civil Procedure 45(f). Samsung did not oppose the transfer request.
Presiding Judge: Chief Judge James Donato granted the unopposed motion. The Eastern District of Texas remains a significant venue for patent litigation.
💡 Key Insight: Samsung’s decision not to oppose transfer may indicate coordination with existing Texas litigation or strategic preference for known procedural expectations.
The Verdict & Legal Analysis
Outcome
Per the court order: “Pursuant to Rule 45(f) and Jacobsen’s unopposed request, the matter is ordered transferred to the United States District Court for the Eastern District of Texas.”
No substantive rulings on patent validity, claim construction, or infringement were issued.
Basis of Termination: Case Transferred
Procedural Analysis
Rule 45(f) permits transfer of subpoena-related matters when the subject consents or exceptional circumstances exist. Factors typically influencing such venue decisions include:
⚖️ For Plaintiffs: Jury composition, judicial experience with patent cases, scheduling efficiency
⚖️ For Defendants: Consolidated defense strategy, procedural predictability, litigation cost considerations
Legal Significance
- Eastern District of Texas activity continues despite TC Heartland LLC v. Kraft Foods Group Brands LLC (2017) venue limitations
- Defendant non-opposition suggests strategic calculation rather than venue challenge
- Rule 45(f) mechanism provides distinct procedural pathway from traditional § 1404 transfers
Track litigation trends with Patsnap Eureka IP to monitor related assertions.
Strategic Observations
⚖️ For Patent Holders:
- Venue strategy merits early consideration in litigation planning
- Device provisioning patents continue generating assertion activity
⚖️ For Accused Infringers:
- Venue challenge cost-benefit analysis informs defense strategy
- Cross-matter coordination may influence forum decisions
🔬 For R&D Teams:
- Development documentation supports potential invalidity positions
- Freedom-to-operate (FTO) analysis should address device activation technologies
Industry & Competitive Implications
This case highlights ongoing patent exposure in the wireless device ecosystem. As 5G deployment accelerates and IoT devices proliferate, patents covering device-network authentication and usage tracking face increased scrutiny.
Samsung’s position as a leading Android OEM places it among companies facing assertions targeting standardized activation workflows.
📊 Observation: Device provisioning patents nearing term expiration often see increased monetization activity—a pattern relevant to portfolio valuation and licensing diligence.
Analyze patent landscapes on Patsnap Eureka IP for competitive intelligence in mobile technology sectors.
Key Takeaways
⚖️ For Patent Attorneys:
- Rule 45(f) transfers offer venue flexibility beyond traditional mechanisms
- Unopposed motions may resolve rapidly (here, 15 days)
- Monitor US8588110B2 and US8639811B2 for related proceedings
📊 For IP Professionals:
- Samsung faces continued device activation technology exposure
- Eastern District of Texas remains active in patent matters
- Track substantive developments via PACER
🔬 For R&D Teams:
- Automated provisioning and billing systems present litigation considerations
- FTO analysis should address these patent families
Start your patent research on Patsnap Eureka IP for portfolio analysis.
FAQ
What patents were involved in Jacobsen v. Samsung? US8588110B2 (automated device provisioning and activation) and US8639811B2 (verifiable device assisted service usage billing with integrated accounting, mediation accounting, and multi-account).
Why was this case transferred to Texas? The California Northern District Court granted Jacobsen’s unopposed Rule 45(f) motion transferring the matter to the Eastern District of Texas.
What is the current case status? The infringement action is now pending in the Eastern District of Texas. No rulings on patent validity or infringement have been issued.
Explore similar cases on Patsnap Eureka IP for patent litigation monitoring and IP portfolio analysis.
DISCLAIMER: This article is for informational and educational purposes only and does not constitute legal advice. The information presented is based on publicly available case data and should not be relied upon for legal decision-making. Readers should consult qualified legal counsel for advice regarding specific patent litigation matters. Case outcomes and procedural developments may change; verify current status through official court records.
