The court held that requiring the parties to focus on specific claims and prior art is inappropriate at this stage, noting that claim construction does not begin until August 10, 2026.
Network-1 filed its initial complaint against Samsung on June 27, 2025. The operative Amended Complaint was filed on October 22, 2025.
Samsung filed its motion to focus claims on January 13, 2026. Samsung argued that Network-1’s assertion of 85 claims across six patents creates an unnecessary burden, particularly given Network-1's refusal to agree to any narrowing before claim construction.
Network-1 responded that an order at this time is premature because discovery is ongoing and the claim construction process does not begin until August 10, 2026.
Judge Gilstrap agreed with Samsung that the current assertion of claims makes for an unwieldy case and is likely too expansive to accommodate under the court’s usual claim construction process.
However, the judge held that Network-1’s point was well taken: the case is in its early stages, and the earliest claim construction-related deadline remains over three months away from the April 23, 2026 order.
The court expressed hope that the parties would engage in productive narrowing themselves without judicial intervention before claim construction begins.
The order notes that managed narrowing by the parties is preferable to court-ordered reduction undertaken without internal perspectives.
Samsung may reassert its arguments at a later date if narrowing fails to occur. Any subsequent motion to focus claims may be filed no sooner than 75 days from the date of this order.
The court has set the Markman hearing for December 14, 2026.