IP Law Daily, PATENT—E.D. Tex.: Induced infringement claims against Samsung dismissed in Google Maps dispute, (Jun 12, 2025)

By Kevin M. Finson, J.D.

Patent claims for induced infringement failed because there was no plausible allegation of an act of direct infringement by the party alleged to have been induced to infringe.

Samsung Electronics showed that a patentee failed to allege it induced infringement by Google and end users of its products, the U.S. District Court in Marshall has held. The patentee’s theory of induced infringement did not establish an act of direct infringement by any third party, nor did it allege that Samsung knew a third party would infringe the asserted patents (Mullen Industries LLC v. Samsung Electronics Co., Ltd., No. 2:24-cv-00049-JRG (E.D. Tex. Jun. 11, 2025)).

Mullen Industries, LLC (Mullen) brought suit against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (collectively, Samsung) for direct and indirect infringement of some nine patents both directly by Samsung’s testing of electronic devices and indirectly by providing instructions for users to open and use the Google Maps app on Samsung’s products. Samsung moved to dismiss in part, specifically arguing that Mullen had failed to state a claim for direct infringement of U.S. Patents Nos. 9,204,283 (the ’283 patent) and 8,374,575 (the ’575 patent) and for induced infringement of U.S. Patents Nos. 11,096,039 (the ’039 patent) and 11,246,024 (the ’024 patent).

Direct infringement. Samsung argued that Mullen’s allegations that it performed all of the “user steps” of the ’283 and ’575 patents during product testing were not sufficiently specific. The court found that these allegations were not mere boilerplate but were based on Samsung’s own statements about its testing process. They were sufficient for the pleading stage, even if they lacked the detail which would be required at the summary judgment stage or at trial.

Samsung also argued that it did not complete the “server steps” of those same patent claims, which were instead performed on servers belonging to non-party Google. The court found that Mullen had alleged, at least with respect to Samsung’s SmartThings Find and Samsung Find products, that Samsung performed both the user and server steps itself, without the involvement of a third party.

Induced infringement. The court found that Mullen’s theory of induced infringement was not plausible. The allegations that Samsung provided instructions to users in how to open and use Google Maps on Samsung devices did not establish that either Google itself or the end users infringed, or that Samsung knew that Google’s acts on Google’s own servers constituted infringement.

The court granted the motion to dismiss as to the induced infringement claims related to Google Maps and denied it in all other respects.

The Case is No. 2:24-cv-00049-JRG.

Judge: Gilstrap, R.

Attorneys: Peter F. Snell (Glovsky and Popeo, P.C.) for Mullen Industries LLC. Marc J. Pensabene (O'Melveny & Myers LLP) for Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.

Companies: Mullen Industries LLC; Samsung Electronics Co., Ltd.; Samsung Electronics America, Inc.

Cases: Patent TechnologyInternet TexasNews