Vasu Holdings, LLC v. Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.

CourtDistrict Court, E.D. Texas
DecidedFebruary 5, 2026
Docket2:24-cv-00034
StatusUnknown

This text of Vasu Holdings, LLC v. Samsung Electronics Co., Ltd., Samsung Electronics America, Inc. (Vasu Holdings, LLC v. Samsung Electronics Co., Ltd., Samsung Electronics America, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vasu Holdings, LLC v. Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., (E.D. Tex. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

VASU HOLDINGS, LLC, § Plaintiff, § v. § § Case No. 2:24-cv-00034-JRG-RSP SAMSUNG ELECTRONICS CO., LTD., § SAMSUNG ELECTRONICS AMERICA, § INC., § Defendants. §

MEMORANDUM ORDER Before the Court is Samsung’s Daubert Motion and Motion to Strike Expert Testimony of Dr. Todor Cooklev. Dkt. No. 131. For the reasons discussed below, the Motion is DENIED. I. BACKGROUND Defendants seek to strike portions of the report of Plaintiff’s infringement expert, Dr. Cooklev. Dr. Cooklev’s report is relevant to the infringement determination for four asserted patents, U.S. Patent Nos. 8,886,181 (“the ʼ181 Patent”), 10,206,154 (“the ʼ154 Patent”), 10,368,281 (“the ʼ281 Patent”), and 10,419,996 (“the ʼ996 Patent”). Defendant’s Motion seeks to strike his expert report with respect to the ʼ181, ʼ281, and ʼ996 Patents. These patents teach different ways to switch between different wireless networks. For example, the ʼ181 Patent teaches a method of simultaneously establishing connection to a second, stronger, network without losing connection to the first. Similarly, the ʼ281, and ʼ996 Patents include timers to “wake up” the second antenna after a specified period of time, and if certain conditions are met. II. LEGAL STANDARD An expert witness may provide opinion testimony if “(a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case.” Fed. R. Evid. 702. Rule 702 requires a district court to make a preliminary determination, when requested, as to whether the requirements of the rule are satisfied with regard to a particular expert’s proposed

testimony. See Kumho Tire Co. v. Carmichael, 526 U.S. 137, 149 (1999); Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592-93 (1993). District courts are accorded broad discretion in making Rule 702 determinations of admissibility. Kumho Tire, 526 U.S. at 152 (“the trial judge must have considerable leeway in deciding in a particular case how to go about determining whether particular expert testimony is reliable”). Although the Fifth Circuit and other courts have identified various factors that the district court may consider in determining whether an expert’s testimony should be admitted, the nature of the factors that are appropriate for the court to consider is dictated by the ultimate inquiry—whether the expert’s testimony is sufficiently reliable and relevant to be helpful to the finder of fact and thus to warrant admission at trial. United States v. Valencia, 600 F.3d 389, 424 (5th Cir. 2010).

Importantly, in a jury trial setting, the Court’s role under Daubert is not to weigh the expert testimony to the point of supplanting the jury’s fact-finding role; instead, the Court’s role is limited to that of a gatekeeper, ensuring that the evidence in dispute is at least sufficiently reliable and relevant to the issue before the jury that it is appropriate for the jury’s consideration. See Micro Chem., Inc. v. Lextron, Inc., 317 F.3d 1387, 1391-92 (Fed. Cir. 2003) (applying Fifth Circuit law) (“When, as here, the parties’ experts rely on conflicting sets of facts, it is not the role of the trial court to evaluate the correctness of facts underlying one expert’s testimony.”); Pipitone v. Biomatrix, Inc., 288 F.3d 239, 249-50 (5th Cir. 2002) (“‘[t]he trial court’s role as gatekeeper [under Daubert] is not intended to serve as a replacement for the adversary system.’ . . . Thus, while exercising its role as a gate-keeper, a trial court must take care not to transform a Daubert hearing into a trial on the merits,” quoting Fed. R. Evid. 702 advisory committee note). As the Supreme Court explained in Daubert, 509 U.S. at 596, “Vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate

means of attacking shaky but admissible evidence.” See Mathis v. Exxon Corp., 302 F.3d 448, 461 (5th Cir. 2002). III. ANALYSIS In their Motion, Defendants first contend that Dr. Cooklev’s report improperly adds new infringement accusations through his identifications of new accused features. Dkt. No. 131 at 2. They argue that Dr. Cooklev’s report is untimely, like the infringement allegations rejected by the Court in Plaintiff’s June 18, 2025, Amended Infringement Contentions (Dkt. No. 100-1).1 Id. For example, Defendants contend that Dr. Cooklev’s report adds 68 accused “timers” to the 6 in the infringement contentions. Id. at 3. Defendants argue that this addition “flouts” EDTX Patent Rule 3-1(c), which requires plaintiffs to timely disclose infringement contentions. Id. at 10.

Defendants contend that Dr. Cooklev’s joint infringement opinions should be stricken because they lack evidentiary support and misstate the law. Id. at 10. Defendants argue that Dr. Cooklev’s joint infringement opinions do not cite any evidence, and are otherwise unrelated because different legal standards, entities, and timelines apply. Id. at 10-11. Defendants further argue that Dr. Cooklev’s report misstates the law on § 271(a) (direct infringement) with respect to third parties. Id. at 12-13. They contend that Dr. Cooklev misstates the law on third-party joint infringement, because he mistakenly identifies the end users, rather than third parties, as the beneficiaries. Id. They further reason that Dr. Cooklev fails to establish that defendants “direct and

1 In their Motion, Defendants concede that there is no overlap between the rejected amended infringement contentions and the new accused features in Dr. Cooklev’s report. Dkt. No. 131 at 10. control” the third parties in his demonstration that Defendant’s products are interoperable with mobile networks. Finally, Defendants argue that the portions of Dr. Cooklev’s report that provide claim scope make improper claim construction arguments. Defendants argue that Dr. Cooklev construes the

terms “sleep mode” and “active mode” to include limitations on power consumption. Id. at 15. They argue this is ultimately confusing to a jury. In response, Plaintiff points to specific disclosures in the infringement contentions that map to Dr. Cooklev’s report. They argue that infringement contentions need not disclose specific evidence or proof of infringement, unlike expert reports, which do require such specificity. They cite to ROY-G-BIV Corp. v. ABB, Ltd., and add that what expert reports cannot add are additional infringement theories. 63 F. Supp. 3d 690, 699 (E.D. Tex. 2014). Plaintiff argues that Dr. Cooklev’s report is proper because it merely adds support to the existing infringement theories, and does not advance any new theories Id. at 3. Plaintiff argues that it properly disclosed the evidentiary support for the joint infringement

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Related

Mathis v. Exxon Corporation
302 F.3d 448 (Fifth Circuit, 2002)
United States v. Valencia
600 F.3d 389 (Fifth Circuit, 2010)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
ROY-G-BIV Corp. v. ABB, Ltd.
63 F. Supp. 3d 690 (E.D. Texas, 2014)
Akamai Technologies, Inc. v. Limelight Networks, Inc.
797 F.3d 1020 (Federal Circuit, 2015)

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Bluebook (online)
Vasu Holdings, LLC v. Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/vasu-holdings-llc-v-samsung-electronics-co-ltd-samsung-electronics-txed-2026.