Headwater Research LLC v. Samsung Electronics America, Inc. et al, No. 2:23-cv-00103 (E.D. Tex. Mar. 5, 2024)

From the Opinion

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Before the Court is the Motion to Dismiss for Failure to State a Claim filed by Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. Dkt. No. 40. Samsung seeks to dismiss Plaintiff Headwater Research LLC’s Amended Complaint (Dkt. No. 31). Plaintiff opposed the Motion by filing a response and sur-reply. Dkt. Nos. 42, 44. For the reasons discussed below, the motion should be DENIED. I. BACKGROUND In their Amended Complaint, Plaintiff has alleged infringement of U.S. Patent Nos.