Evolved Wireless v. Samsung — Federal Circuit Affirms No Infringement and Surviving Qualcomm License

Background

Evolved accused Samsung products of infringing reissue Patent No. RE46,679, concerning cellular-network handover technology. The district court held that products using Qualcomm chips were licensed, and a jury found the remaining accused products did not infringe while rejecting Samsung’s invalidity defense. Evolved sought a new infringement trial; Samsung cross-appealed the denial of its written-description motion.

The Court’s Holding

The Federal Circuit affirmed the district court across both the appeal and cross-appeal: Samsung retained partial summary judgment for Qualcomm-chip products covered by a surviving license, the jury’s no-infringement verdict stood, and Samsung did not obtain judgment that the asserted claims lacked written description.

Because Evolved chose a standards-based infringement theory, it had to show that every implementation of the relevant LTE standard practiced the claims. The panel found no basis for a new trial and held that the Qualcomm license survived termination of the broader agreement under the controlling amendment. On Samsung’s cross-appeal, substantial evidence—including expert testimony and what skilled artisans understood—supported the jury’s finding of written-description support.

Key Takeaways

• A standards-based infringement theory requires proof that every compliant implementation meets the patent claims.
• License amendments can preserve downstream coverage even after the broader agreement terminates.
• A party cannot recast an expert’s contextual trial testimony as a binding concession when the jury had evidence supporting the opposite conclusion.

Why It Matters

The nonprecedential decision ends this round with Samsung prevailing on infringement while leaving the patent claims intact. It is especially useful for disputes combining standard-essentiality theories with complex component-supplier licensing chains.