W&WSens Devices Inc. v. Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.

Summary

The United States District Court for the Eastern District of Texas grants Samsung’s motion to amend its invalidity contentions in a patent infringement action. Applying Federal Rule of Civil Procedure 16(b)(4), the Court finds that Samsung established good cause despite insufficient diligence because the proposed amendment was important and would cause minimal prejudice to Plaintiff.

Holdings

1. A party seeking to amend Invalidity Contentions after the scheduling-order deadline must demonstrate good cause under Federal Rule of Civil Procedure 16(b)(4), and the court must consider the explanation for the delay, the importance of the amendment, potential prejudice, and the availability of a continuance to cure prejudice.
2. Samsung showed good cause to amend its Invalidity Contentions despite its insufficient explanation for delay because the proposed amendment was important, caused minimal prejudice, and did not require a continuance.

Questions Presented

1. Whether Samsung demonstrated good cause under Federal Rule of Civil Procedure 16(b)(4) to amend its Invalidity Contentions after the scheduling-order deadline.
2. Whether the four good-cause factors—explanation for delay, importance of the amendment, potential prejudice, and availability of a continuance—supported granting leave to amend.

Disposition

other