IP Law Daily, PATENT—E.D. Tex.: Samsung ordered to pay prejudgment and post-judgment interest for infringing wireless network efficiency patents, (Jul 22, 2026)

By Carolin Dennis, B.Sc., LL.B., LL.M.

The district court issued post-trial rulings on prejudgment and post-judgment interest, and supplemental damages for Samsung’s patent infringement of four wireless network efficiency patents.

The federal district court in Texas, granted-in-part and denied-in-part the patent owner’s motion for supplemental damages and interest. The district court found that the patent owner was entitled to prejudgment interest, post-judgment interest, and supplemental damages for post-verdict sales of the accused products in light of Samsung’s non-opposition to the request. The district court, however, denied the motion as to supplemental damages for products not more than colorably different from the accused products (Collision Communications, Inc. v. Samsung Electronics Co., Ltd., No. 2:23-cv-00587-JRG (E.D. Tex. Jul. 16, 2026)).

Collision Communications, Inc. (Collision) is a non-practicing entity holding certain wireless communication patents. Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., (collectively, Samsung) are global manufacturers of smartphones and other consumer electronics. Collision filed a suit against Samsung on December 12, 2023, alleging infringement of six U.S. patents. However, the case proceeded to trial on October 3, 2025, with Collision asserting infringement of four wireless network efficiency patents. Samsung denied infringement and challenged the validity of all asserted claims. The jury found infringement of all asserted claims and that none of the asserted claims were invalid. The jury concluded that Samsung had infringed each of the four asserted patents, that Samsung’s infringement was wilful and awarded damages in the form of a reasonable royalty in the amount of $445,494,160.00, structured as a running royalty. The court entered its Final Judgment based on the verdict on November 12, 2025. Collision then filed a motion for supplemental damages, prejudgment, and post-judgment interest.

Prejudgment interest. Collision sought an award of prejudgment interest at the prime rate, compounded quarterly as the running royalty accrues. However, Samsung argued that Collision must be denied prejudgment interest because Collision waited many years to bring its case, and because an award of nearly half a billion dollars already would make Collision more than “whole” for Samsung’s alleged infringement. Samsung also asserted that in the event the district court finds Collision is entitled to prejudgment interest that such interest should be set at the T-Bill rate. The district court did not find that Collision “delayed” in bringing suit to such a degree as would undercut its entitlement to prejudgment interest. Further, it was unpersuaded by Samsung’s argument that the jury verdict already made Collision “whole” because the jury verdict did not account for the “foregone use of money between the time of infringement and the date of judgment.” Such foregone use of money is a necessary part of fully compensating Collision. Thus, the district court concluded that such prejudgment interest should be set at the five-year T-Bill rate, compounded quarterly as the running royalty accrues.

Supplemental damages. Collision sought a supplemental damages rate of 0.234% for infringing sales occurring between the verdict and December 12, 2025 (the expiration date for U.S. Patent No. 7,463,703), and a rate of 0.085% of revenue (based only one the U.S. Patent No. 7,593,492) for remaining sales from December 13, 2025, to the present. Samsung did not oppose Collision’s request for supplemental damages of post-verdict sales. Accordingly, this portion of Collision’s motion was granted.

Next, Collision also requested supplemental damages “on products that are ‘not more than colorably different’ from the products at issue in the case.” Collision asserted that the district court must “enter judgment determining that not-colorably-different-products incur the same effective royalty rate” presented above of 0.234% for sales prior to December 12, 2025, and a rate of 0.085% for subsequent sales. However, Collision did not make any attempt in the motion to state what these products would be, other than mentioning the Galaxy S24, a product released in January 2024 and upon which Collision did not take discovery and which was not included in its experts’ reports. Additionally, Samsung noted that, the single example product Collision lists is the Galaxy S24, a product that was released in January 2024, only a month after this case was filed and well within the time that Collision could have sought to add these products to the case, collect discovery on these products, and include them in their infringement contentions. Therefore, the district court found that it must not apply the jury’s royalty rate to these products that were not before the jury or part of the trial, especially where Collision’s single exemplar is a product that could have been but was not included in this case. Accordingly, this portion of Collision’s motion was denied.

Post-judgment interest. Lastly, Collision sought post-judgement interest set at the lawful federal rate under the statute, calculated from the date of entry of judgment, at the one-year T-bill rate, compounded annually. Collision requested that this amount apply to the entire amount of the judgment, including attorney’s fees, costs, supplemental damages, and prejudgment interest. Samsung did not oppose Collision’s request for post-judgment interest. Accordingly, the district court found that Collision was entitled to post-judgement interest at statutory rate, per 28 U.S.C. § 1961.

The Case is No. 2:23-cv-00587-JRG.

Judge: Gilstrap, R.

Attorneys: Bradley Wayne Caldwell (Caldwell Cassady & Curry, PC) for Collision Communications, Inc. Gregory F. Laufer (Wharton & Garrison LLP) for Samsung Electronics Co., Ltd.

Companies: Collision Communications, Inc.; Samsung Electronics Co., Ltd.

Cases: Patent TechnologyInternet TexasNews