IOENGINE, LLC filed IOENGINE, LLC v. Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., No. 2:26-cv-00866, in the Marshall Division of the Eastern District of Texas on September 22, 2026. IOENGINE demands a jury. Counsel on the complaint is Reichman Jorgensen Lehman & Feldberg LLP. The complaint does not identify an assigned district judge.

The core dispute

The complaint describes a 2004-era idea: a small portable device that keeps its own processor, memory, and data, and borrows the screen, controls, and sometimes the network connection of a larger device the patents call a terminal. The specification's name for the portable device is a tunneling client access point. Data can be shown through the terminal, the complaint says, without having to live on the terminal, and the portable device can reach remote servers by tunneling through the terminal.

IOENGINE alleges Samsung practices that architecture in four product categories, each with a different portable-device and terminal pairing. A smartwatch, fitness band, or earbud is the portable device, and a phone running the Galaxy Wearable app is the terminal. A portable SSD is the portable device, and a Windows or Mac computer is the terminal. A Galaxy phone is the portable device, and a vehicle infotainment system running Android Auto is the terminal. Those pairings are allegations in the complaint. They are not findings that any Samsung product practices a claim.

Snapshot

IOENGINE is a Delaware limited liability company with a principal place of business in Norwalk, Connecticut. The complaint says founder Scott McNulty is the sole named inventor and that IOENGINE owns the five patents. Samsung Electronics Co., Ltd. is pleaded as a Korean corporation that designs, manufactures, and sells the accused products and causes them to be imported into the United States. Samsung Electronics America, Inc. is pleaded as a New York corporation, a wholly owned U.S. operating subsidiary, with its United States headquarters at 6625 Excellence Way, Plano, Texas.

On venue, the complaint alleges that the Plano headquarters is a regular and established place of business for Samsung Electronics America, that U.S. marketing, sales, distribution, and support for the accused products are directed from there, and that employees there use the accused products in the claimed configurations by pairing, configuring, registering, and updating them, which it calls infringing use in the district. It alleges venue over Samsung Electronics Co., Ltd. under 28 U.S.C. 1391(c)(3) because that defendant is a foreign corporation. It also alleges that Samsung has litigated patent cases in the district before, as plaintiff and as defendant.

The five patents share a specification and claim priority to application 10/807,731, filed March 23, 2004. The complaint says the '006 and '969 patents claim the architecture in which the portable device reaches a network node through the terminal. It says the '819 patent claims the architecture in which the portable device uses its own network connection. It says the '374 and '786 patents claim both that own-connection architecture and a third in which the device does both.

Several public decisions bear on the asserted claims, and the complaint discusses none of them. In IOENGINE, LLC v. Ingenico Inc., 100 F.4th 1395 (Fed. Cir. May 3, 2024), the court affirmed the Board's IPR2019-00879 ruling that claims 1 and 2 of the '969 patent, among others, are unpatentable, and reversed the Board on claims 4 and 7; claim 10 was not among the claims the Board held unpatentable. The inter partes review certificate issued October 10, 2024. In Ingenico Inc. v. IOENGINE, LLC, 136 F.4th 1354 (Fed. Cir. May 7, 2025), the court affirmed a Delaware jury verdict that claim 3 of the '969 patent is invalid as anticipated and obvious over the DiskOnKey System, a USB drive M-Systems sold in the early 2000s with firmware-upgrade software. Claims 3, 4, and 10 all depend from claim 2.

The '819 patent has its own record. In IOENGINE, LLC v. Roku, Inc., No. 6:21-cv-01296 (W.D. Tex.), a jury found on April 19, 2024 that Roku did not infringe claims 187 and 192 of the '819 patent or the asserted claims of U.S. Patent 10,972,584, and the court entered judgment for Roku on May 20, 2024. The court denied IOENGINE's renewed motion for judgment as a matter of law or a new trial on July 28, 2026, and a notice of appeal was docketed on August 25, 2026. In a July 27, 2026 notice in that case, IOENGINE reported that the Patent Trial and Appeal Board had reversed, on July 22, 2026, the examiner's rejection of claims 184 through 192 of the '819 patent in an ex parte reexamination Roku requested. Claim 184 is the '819 claim asserted against Samsung.

On marking, the complaint alleges that IOENGINE itself has not made or sold a product practicing the patents, and that its only license under the '006 and '969 patents is a May 2018 license to Interactive Media Corporation, which sells Kanguru-brand secure USB storage devices. The complaint says that license requires marking, and alleges on information and belief that Interactive Media has marked the Kanguru Defender line since May 2018 with "Pat." and a Kanguru partners web address that lists the '006 and '969 patents. It alleges no license, and no marking obligation, under the '374, '819, or '786 patents. From that record the complaint claims constructive notice of the '006 and '969 patents under 35 U.S.C. 287(a), and damages for infringement it alleges occurred up to six years before filing, within 35 U.S.C. 286.

  • March 23, 2004: priority application filed. The '006 patent issued December 28, 2010.
  • June 16, 2015: the '969 patent issued. May 2018: the complaint dates the Interactive Media license.
  • August 27, 2019 and October 15, 2019: the '374 and '819 patents issued. April 27, 2021: the '786 patent issued.
  • April 19, 2024: a Western District of Texas jury found Roku did not infringe '819 claims 187 and 192. May 3, 2024: the Federal Circuit affirmed that '969 claims 1 and 2, among others, are unpatentable and reversed the Board on claims 4 and 7. October 10, 2024: the IPR2019-00879 certificate issued.
  • May 7, 2025: the Federal Circuit affirmed a jury verdict that '969 claim 3 is invalid over the DiskOnKey System. July 22, 2026: IOENGINE reports that the Board reversed the reexamination rejection of '819 claims 184 through 192.
  • September 22, 2026: the Samsung complaint was filed.

Patents and asserted claims

The complaint asserts these claims. For the four patents it treats as expired, the counts use the past tense and stop the accused period at the expiration date the complaint pleads. Only the '006 count alleges continuing conduct and seeks an injunction.

  • U.S. Patent 7,861,006, issued December 28, 2010. Claim 1. Pleaded against portable drives and Galaxy smartphones, and pleaded as still in force.
  • U.S. Patent 9,059,969, issued June 16, 2015. Claims 4 and 10, which depend from claim 2 and, through it, from claim 1. Pleaded against earbuds, smartwatches, portable drives, and smartphones, through expiration the complaint dates as April 10, 2024.
  • U.S. Patent 10,397,374, issued August 27, 2019. Claims 1 and 3. Pleaded against smartwatches and smartphones, through expiration the complaint dates as March 23, 2024.
  • U.S. Patent 10,447,819, issued October 15, 2019. Claim 184. Pleaded against smartwatches and smartphones, through the same March 23, 2024 date.
  • U.S. Patent 10,992,786, issued April 27, 2021. Claims 1 and 20. Pleaded against smartphones and smartwatches, through expiration the complaint dates as April 13, 2024.

What the patents cover

The complaint's specification story, drawn from the shared written description, is that early portable computers were a bad compromise: bulky, small screens, and too much power just to keep data. The disclosed answer is not a better tiny screen. It is a pocket device that plugs into, or wirelessly joins, a terminal the user already knows, uses that terminal's interface, and keeps storage and processing on the portable device. The claim summaries below restate issued claim language. They are not findings that Samsung practices any claim.

U.S. Patent 7,861,006

U.S. Patent 7,861,006 covers a portable tunneling storage and processing apparatus that talks to a terminal over a universal serial bus conduit, stores program instructions, and uses the terminal's display and network while its own processor handles encrypted data and encrypted communications.

Claim 1 covers that apparatus in three blocks. The conduit connects the portable apparatus to a terminal that has a processor, an input, a display, and a network interface to a server, and the conduit is a USB conduit. The apparatus has its own processor and a memory with a unique identifier and stored instructions. A first set of those instructions, executed by the terminal's processor, lets the user work with the portable apparatus through the terminal's input and display and gives the apparatus access to the terminal's network interface. At least one instruction presents an interactive interface on the terminal display so the user can make the portable processor run instructions stored on the apparatus and can make the apparatus send a request to a server. At least one further instruction, executed by the portable processor in response to that interaction, runs a second set of instructions, shows that activity on the terminal display, and sends a server request. The apparatus is configured to communicate with the terminal and through the terminal's network interface with a server, and its processor is configured to store encrypted data, encrypt what it sends, and decrypt what it receives.

U.S. Patent 9,059,969

U.S. Patent 9,059,969 covers a portable device that coordinates with program code on a terminal. The terminal code presents an interactive interface and provides a communications node on the terminal so the portable device can reach a network node through the terminal. The portable device has its own interface, processor, and memory, including code that provides a communications node on the portable device and code that runs when the user interacts with the terminal interface.

The complaint asserts claims 4 and 10, not claim 1. Both depend from claim 2, which depends from claim 1, so those parent limitations are still in the asserted claims. The IPR, the two Federal Circuit decisions on the '969 patent, and the '819 trial and reexamination are public-record context, set out in the snapshot above. The complaint does not discuss them. Claim 2 covers the claim 1 device in which the fourth program code, when executed by the portable-device processor, causes a communication to be sent to the network node. Claim 4 covers that device in which the communication facilitates sending encrypted communications from the network node back to the terminal. Claim 10 covers that device in which the network node includes a database and the communication facilitates synchronizing content on the portable device with content in that database.

The remaining asserted patents

U.S. Patent 10,397,374 covers a portable device that can communicate with a network made up of a network node and a terminal. The terminal presents a graphical interface the user manipulates to control the portable device, and code on the device can send a communication to the network node, including in response to that manipulation, and can affect the interface the terminal shows. Claim 1 covers that device, configured to communicate with the terminal and to communicate securely with the network node. Claim 3 covers the claim 1 device in which the responsive code sends a secure communication through the terminal's network interface to the network node. The complaint alleges claims 1 and 3 against smartwatches and Galaxy phones that, it says, reach servers on their own cellular or Wi-Fi connection and also through a paired terminal. It dates the accused period through March 23, 2024.

U.S. Patent 10,447,819 covers, in claim 184, a portable device with its own network interface that receives data content from a network node, a separate communications interface that sends a data-content stream to a terminal, a processor that streams that content for the terminal to present, and program code that puts an interactive interface on the terminal, talks to the network node, reacts to the user's manipulation of that interface by sending a communication out the device's own network interface, and processes received content for display on the terminal. The complaint alleges this claim against smartwatches, including LTE models it says can receive calls and messages without a phone, and against Galaxy phones connected to a vehicle running Android Auto. It dates the accused period through March 23, 2024.

U.S. Patent 10,992,786 covers a portable device with two communication interfaces, one to a terminal and one to a network node. Claim 1 covers the device where terminal code receives the user's manipulation of an interactive interface, changes that presentation, and sends a communication to the portable device, and where code on the portable device both carries on communications over its own network interface and, in response to the terminal, sends a further communication to the network node. Claim 20 covers the claim 1 device in which the terminal also has a network interface and the portable device is configured to transmit a communication through that terminal interface to a network node. The complaint alleges these claims against Galaxy phones on Android Auto and against smartwatches that pair to a phone over Bluetooth and also reach a network on their own. It dates the accused period through April 13, 2024.

What the complaint says about term

Google Patents lists the '006 patent as active, with a listed expiration of October 21, 2028. It lists the '969 patent as expired on April 10, 2024 and the '786 patent as expired on April 13, 2024. It lists the '374 and '819 patents as expired, with an anticipated expiration of March 23, 2024. Those Google listings are status labels, not a court finding. The complaint pleads the same April 10, 2024 and April 13, 2024 dates for the '969 and '786 patents, pleads March 23, 2024 for the '374 and '819 patents, and treats only the '006 patent as unexpired. The prayer asks for a permanent injunction on the '006 patent, and for a continuing royalty on that patent if an injunction is not granted. For the other four patents it asks for a judgment of past infringement and damages, not an injunction.

Accused products

The complaint defines four categories, plus the Samsung applications and servers those devices use. Smartwatch Accused Products include, without limitation, the Galaxy Watch, Galaxy Watch Active, Galaxy Watch Classic, Galaxy Watch Pro, Galaxy Watch Ultra, Galaxy Watch FE, and Galaxy Fit lines. The Galaxy Watch Ultra is the example the complaint analyzes. Earbud Accused Products include the Galaxy Buds, Buds Plus, Buds Live, Buds Pro, Buds2, Buds2 Pro, and Buds FE lines. The Galaxy Buds2 Pro is the example. Portable Drive Accused Products include the Portable SSD T5, T7, T7 Touch, T7 Shield, T9, and T5 EVO lines. The T7 is the example. Smartphone Accused Products include the Galaxy S, Note, Z Fold, Z Flip, and A lines. The Galaxy S23 Ultra is the example.

The pairings are specific. For watches, bands, and earbuds, the complaint alleges the wearable is the portable device and a phone, tablet, laptop, or desktop running Galaxy Wearable is the terminal. It alleges the app presents the interface used to pair the device, update firmware, and change settings, and that the wearable can reach Samsung's servers through the phone's Wi-Fi or cellular connection. Network-equipped watches are also alleged to reach those servers on their own radios. For the T7, the complaint alleges the drive is the portable device and a Windows or Mac computer is the terminal, connected by a USB Type-C cable Samsung ships with the drive. For phones, the complaint alleges the phone is the portable device and a vehicle head unit running Android Auto is the terminal: the phone supplies processing, storage, and the network connection, and the car supplies the display and controls. On the '969 patent the complaint also alleges a second phone configuration, in which the phone is the portable device and a computer running Phone Link is the terminal.

What the complaint alleges about the Portable SSD T7

Count I's lead chart is claim 1 of the '006 patent against the portable drives, with the T7 as the worked example. The complaint alleges each of the following. None of it is a finding.

The complaint alleges the T7 is the portable tunneling apparatus: a self-contained drive with its own processor, memory, and storage. It alleges the external conduit is a universal serial bus conduit, because Samsung ships the drive with USB Type-C cables and the drive connects to a personal computer over that port.

The complaint alleges the computer is the terminal: a processor, a keyboard and pointing device, a display, and a network interface that can reach Samsung's servers. It alleges the drive's memory stores the Samsung Portable SSD Software, which the user manual tells the user to launch from the drive in Windows Explorer or on the Mac desktop, for Security Mode and firmware update. The complaint quotes the manual's warning that formatting the drive deletes that software, and treats that warning as confirmation the software resides on the drive.

The complaint alleges that software, executed on the computer, lets the user operate the drive from the computer's keyboard, pointing device, and display, and uses the computer's network interface to reach Samsung's servers for firmware updates. It alleges the same interface is how the user causes the drive's processor to set a password, turn Security Mode on or off, and encrypt or decrypt stored data, and how the user causes the drive to request a firmware update from Samsung's server.

The complaint alleges that when the user starts a firmware update or a security operation, the drive executes the corresponding code, the progress appears in the software window on the computer, and the drive requests the update through the computer's network interface. It alleges the drive's processor stores encrypted data and encrypts and decrypts communications, pointing to Samsung's description of AES 256-bit hardware encryption and password protection, and alleging that because the encryption is on the drive, the processor encrypts data as it is written and decrypts data as it is read.

Parallel notes on the other categories

The complaint alleges Galaxy phones also meet claim 1 of the '006 patent, with the phone as the portable apparatus, a USB Type-C port as the conduit, and either a computer or a vehicle running Android Auto as the terminal. It alleges Android Auto presents the interface on the car display, and that user commands on that display cause the phone to run code and to reach servers.

On the '969 patent, the complaint's earbud chart alleges the Galaxy Buds2 Pro is the portable device and a Galaxy phone is the terminal. It alleges Galaxy Wearable, stored on the phone, presents the interface, and that code on the phone provides the communications node that passes traffic to the earbuds over Bluetooth and to Samsung's servers over the phone's Wi-Fi or cellular connection. It alleges the earbuds' Bluetooth radio is the external interface, and that pairing through the app lets the earbuds send messages to Samsung's servers through the phone, including for firmware updates and account registration. The complaint makes parallel allegations for watches paired through Galaxy Wearable, for the T7 reaching Samsung's servers through the computer, and for phones synced through Phone Link.

For claim 4, the complaint alleges that those server communications facilitate encrypted return traffic to the terminal, on information and belief using Transport Layer Security, when earbuds and watches pull updates through a phone, when a drive pulls firmware through a computer, and when a phone pulls messages and media through a computer. For claim 10, it alleges Samsung's servers are databases and that the communications synchronize content: settings and health data for earbuds and watches, firmware and management software for a portable drive, and photos, files, messages, and calendars for a phone linked to a computer.

Points of contention

The complaint uses the same two nouns, portable device and terminal, for different products depending on the pairing. A Galaxy phone is the terminal when it runs Galaxy Wearable beside an earbud or a watch, and it is the portable device when it is attached to a car running Android Auto or to a computer running Phone Link. Expect claim construction to test whether one product can switch roles that way under a single specification.

A second fight is functional. Claims 4 and 10 require program code on the terminal that provides a communications node, and program code on the portable device that coordinates with it. The complaint alleges Galaxy Wearable, the Portable SSD Software, Android Auto, and Phone Link are those nodes because they route traffic between the portable device and Samsung's servers. Whether that software is the claimed node, or only a settings app and a network stack, is a question the complaint poses and does not decide.

Claim terms

Terminal is doing a lot of work. The complaint cites the specification for a broad reading: an access terminal "may be any number of computing devices such as servers, workstations, desktop computers, laptops, portable digital assistants (PDAs), and/or the like," and "[t]he type of AT used is not important" so long as it can engage the portable device and give the user an operating environment. Other passages the complaint quotes describe the solution as plugging into "any existing and available desktop or laptop computer" so the user can keep "traditional large user interfaces." A broader reading reaches phones and car head units. A narrower reading asks whether a terminal has to be the large, familiar computer the problem statement was trying to borrow.

Communications node on the terminal is the '969 hook. Claim 1, which claims 4 and 10 incorporate, describes that node by function: program code which, when executed by the terminal processor, provides a communications node on the terminal to facilitate communications to the portable device and to a communications network node through the terminal's network interface. The complaint also cites the specification's description of tunneling as "the equivalent of a plug-n-play virtual private network (VPN)." A broader reading treats any bridging software that passes traffic as the node. A narrower reading asks whether the node has to be the secure tunnel the specification describes, rather than ordinary Bluetooth pairing plus the phone's existing internet connection.

Manuals, apps, and the prayer

The counts allege direct infringement under 35 U.S.C. 271(a), literally or under the doctrine of equivalents. They do not plead a separate inducement count under 271(b) or a contributory count under 271(c), and they do not allege pre-suit knowledge or willfulness. What they do allege is that Samsung's manuals and apps tell users to set the products up in the accused pairings: the T7 manual tells the user to launch the software from the drive, Galaxy Wearable is how Samsung tells users to connect a watch or earbuds to a phone, and Android Auto is how a phone is paired to a vehicle display.

The prayer asks for a judgment that Samsung has infringed and continues to infringe the '006 patent and has infringed the other four, for an injunction directed at the '006 patent, for damages of at least a reasonable royalty under 35 U.S.C. 284, and for a declaration that the case is exceptional under 35 U.S.C. 285 with an award of costs and reasonable attorneys' fees. The exceptional-case request sits in the prayer. It is not a pleaded willfulness count.

Why it matters

The suit takes a single 2004 tunneling specification and aims it at four current Samsung categories: watches and bands, earbuds, portable SSDs, and phones. The only patent the complaint treats as still in force is the '006 patent, and the injunction request is limited to that patent. The other four counts are damages cases the complaint itself dates as closed in March or April 2024, inside the six-year window of 35 U.S.C. 286. The family's record cuts both ways. On the '969 patent, claims 1 and 2, the base of both asserted claims, were held unpatentable and claim 3 was held invalid over the DiskOnKey System, while the Federal Circuit reversed the Board on claim 4. On the '819 patent, a jury found Roku did not infringe two other claims, and IOENGINE reports that the Board reversed a reexamination rejection covering asserted claim 184. Construction of terminal and communications node is likely to decide how far a pocket-device-to-PC disclosure reaches a wearable-to-phone stack and a phone-to-car stack.

What to watch next

Watch Samsung's answer and any early Rule 12 or venue challenge to the Plano headquarters theory. Watch claim-construction proposals on terminal and communications node, including whether a Galaxy phone can be a terminal in one count and a portable device in another. Watch how IOENGINE treats the four patents it pleads as expired when it serves infringement contentions and when it presses the '006 injunction.