Patent Armory v. Samsung: Voluntary Dismissal After 98 Days in E.D. Texas
Patent Armory, Inc. filed a patent infringement action against Samsung Electronics in the Eastern District of Texas, asserting three patents covering mobile communication devices with electromagnetic radiation sensors, phased array sound systems, and wireless communication sensor integration. The case closed just 98 days after filing, with Patent Armory voluntarily dismissing all claims with prejudice.
Three sensor and wireless patents, one swift exit in E.D. Texas
On May 5, 2023, Patent Armory, Inc. filed suit against Samsung Electronics Co., Ltd. in the United States District Court for the Eastern District of Texas (Case No. 2:23-cv-00199) before Judge Rodney Gilstrap. The complaint asserted infringement of three patents — US7130430B2, US8275413B1, and US8825112B1 — covering mobile communication devices with electromagnetic radiation sensors, phased array sound systems, and wireless communication devices with integrated electromagnetic radiation sensors.
The recorded basis of termination is Voluntary dismissal. The docket order states that Patent Armory filed a Notice of Voluntary Dismissal with Prejudice pursuant to Rule 41(a)(1)(A)(i), and the Court accepted and acknowledged that all claims against Samsung Electronics America, Inc. were dismissed with prejudice, with each party bearing its own costs, expenses, and attorneys' fees. The specific terms or context driving the dismissal are not disclosed in the available record.
The case concluded in just 98 days — before any publicly recorded claim construction or merits proceedings. The speed of resolution is consistent with early-stage pre-litigation negotiation or strategic reassessment by the plaintiff, though the specific circumstances are not disclosed in the available record. What remains unknown is whether any private arrangement between the parties preceded or accompanied the dismissal.
See Complete Case & Patent Analysis →Filing to Voluntary dismissal in 98 days
98 days — resolved well before any claim construction or trial proceedings
US7130430B2, US8275413B1 & US8825112B1 — Wireless Sensor & Audio Patents
Any company developing mobile devices, wireless communication hardware, IoT sensors, or phased array audio products should treat these three patents as live enforcement risk. The dismissal with prejudice resolves only Patent Armory's claims against Samsung — it creates no invalidity finding, no claim construction, and no safe harbour for third parties. R&D and product teams shipping products with electromagnetic radiation sensors or beam-forming audio should commission an FTO review before launch.
Official order — verbatim text
The court's order accepted Patent Armory's Rule 41(a)(1)(A)(i) notice and recorded the dismissal of all claims with prejudice, with costs to be borne by each party. No merits determination was made; the dismissal extinguishes Patent Armory's ability to re-assert these specific claims against Samsung, but leaves the three patents' validity and scope legally undecided as against third parties.
Voluntary dismissal: what the resolution means for both parties
Rule 41(a)(1)(A)(i) voluntary dismissal with prejudice
A Rule 41(a)(1)(A)(i) voluntary dismissal allows a plaintiff to dismiss its own action before the opposing party serves an answer or motion for summary judgment. Here, Patent Armory dismissed with prejudice, meaning the same claims against Samsung on these patents cannot be re-filed. The court accepted and acknowledged the dismissal, closing the case and denying all pending relief requests as moot.
Plaintiff-initiated exitClaims permanently extinguished — no re-filing permitted
A dismissal with prejudice is a final adjudication on the merits for claim-preclusion purposes. Patent Armory cannot reassert the three patents — US7130430B2, US8275413B1, and US8825112B1 — against Samsung in future litigation on the same claims. Whether any private resolution or licensing arrangement preceded this outcome is not disclosed in the available record.
No re-filing against SamsungSamsung obtains finality with no admitted liability
Samsung Electronics benefits from the with-prejudice dismissal: the three asserted patents cannot be re-litigated against it by Patent Armory on the same claims. The court's order confirms each party bears its own costs, expenses, and attorneys' fees, so Samsung faces no cost award obligation. No liability was admitted or adjudicated on the merits.
Finality, no liability findingThird parties retain exposure — patents remain in force
A voluntary dismissal with prejudice resolves only the dispute between Patent Armory and Samsung. The three asserted patents — covering wireless sensor integration and phased array sound — remain valid and enforceable against third parties. Companies developing mobile devices, wireless sensor systems, or phased array audio products should assess their exposure to this portfolio independently of this case's outcome.
Patents still enforceable vs. othersFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Patent Armory, Inc. | Company | /Search in Eureka ↗ |
| Defendant | Samsung Electronics Co., Ltd. | Company | /Search in Eureka ↗ |
| Plaintiff counsel | Isaac Phillip Rabicoff | Attorney | Counsel for Patent Armory, Inc.Search in Eureka ↗ |
| Plaintiff law firm | Rabicoff Law LLC | Law Firm | Representing Patent Armory, Inc.Search in Eureka ↗ |
| Defendant counsel | Melissa Richards Smith | Attorney | Counsel for Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Defendant law firm | Gillam & Smith LLP | Law Firm | Representing Samsung Electronics Co., Ltd.Search in Eureka ↗ |
| Presiding judge | Judge Rodney Gilstrap | Judge | Texas Eastern District CourtSearch in Eureka ↗ |
R&D signals: wireless sensor and phased array audio IP
Forward-looking patent intelligence on the wireless sensor, electromagnetic radiation, and phased array audio technology domains touched by Patent Armory's assertions against Samsung.
Patent Armory's wireless and sensor patent assertion activity
Patent Armory has asserted patents covering electromagnetic radiation sensor integration in mobile devices and phased array audio. Tracking the full scope of its portfolio — including continuation applications and related family members of US7130430B2, US8275413B1, and US8825112B1 — can reveal whether additional claims or divisionals pose risk to wireless OEMs beyond the Samsung action.
NPE portfolio watchFiling trends in electromagnetic sensor integration for mobile devices
Patent filings in electromagnetic radiation sensor integration for mobile and wearable devices have grown alongside regulatory requirements for SAR measurement and 5G band management. Mapping recent filing activity in this domain — by Samsung, Qualcomm, Apple, and emerging IoT players — identifies which claim spaces are becoming crowded and where design-around opportunities exist.
Sensor IP filing trendsSamsung's defensive patent position in wireless sensor technology
Samsung Electronics maintains an extensive patent portfolio in mobile communication hardware, sensor integration, and audio processing. Analysing Samsung's own filings in phased array sound and electromagnetic sensor domains reveals its defensive IP depth and the likelihood that any future litigation would encounter cross-licensing or IPR counter-strategies.
Samsung defensive portfolioAdjacent claim space in phased array audio and sensor fusion
US8275413B1's phased array sound claims intersect with growing innovation in spatial audio, beam-forming microphones, and multi-sensor fusion for wearables and automotive. R&D teams can use patent landscape analysis to identify white-space claim territories — particularly around AI-driven sensor fusion and adaptive beam-forming — where new IP can be developed without overlapping existing assertions.
Phased array audio white spaceSimilar patent cases: wireless sensor and audio patents in E.D. Texas
Explore comparable infringement actions asserting wireless communication, electromagnetic sensor, and phased array audio patents in the Eastern District of Texas before Judge Gilstrap.
What this case signals for the wireless sensor IP landscape
A rapid voluntary exit in E.D. Texas against a major OEM raises portfolio and enforcement strategy questions worth tracking.
Early exits against major OEMs often signal licensing activity or portfolio reassessment
A 98-day voluntary dismissal with prejudice — before any claim construction — is consistent with early-stage resolution or a strategic decision not to proceed. Patent practitioners monitoring Patent Armory's enforcement activity should track subsequent filings against other defendants in the wireless sensor and mobile communication space.
With-prejudice dismissal bars re-litigation of these patents against Samsung
Companies sharing Samsung's technology profile — mobile devices with integrated electromagnetic radiation sensors or phased array sound — should note that these three patents remain active. The dismissal creates no precedent on claim scope or validity, leaving the patents' enforceability against other parties legally untested.
Patent v Samsung — key questions answered
Patent Armory asserted three patents: US7130430B2 (mobile communication device with electromagnetic radiation sensors), US8275413B1 (phased array sound system), and US8825112B1 (wireless communication device with integrated electromagnetic radiation sensors). All three claims were voluntarily dismissed with prejudice on August 11, 2023.
The recorded basis of termination is Voluntary dismissal. The docket order reflects a Rule 41(a)(1)(A)(i) voluntary dismissal with prejudice filed by Patent Armory, accepted by the court. All claims were dismissed with prejudice, each party bears its own costs, and the case was closed. The specific terms driving the dismissal are not disclosed in the available record.
No. The dismissal with prejudice bars Patent Armory from re-asserting these claims against Samsung only. All three patents — US7130430B2, US8275413B1, and US8825112B1 — remain in force and enforceable against third parties. No invalidity or non-infringement finding was made in this case.
Patent Armory was represented by Isaac Phillip Rabicoff of Rabicoff Law LLC. Samsung Electronics was represented by Melissa Richards Smith of Gillam & Smith LLP. The case was presided over by Judge Rodney Gilstrap in the Eastern District of Texas.
Under Rule 41(a)(1)(A)(i), a plaintiff may voluntarily dismiss its action before the defendant serves an answer or motion for summary judgment. When filed with prejudice, the dismissal operates as a final adjudication for claim-preclusion purposes — Patent Armory cannot re-file the same claims against Samsung. No merits finding on validity or infringement was made.
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