ZTE has secured a preliminary victory in a standard essential patent (SEP) licensing lawsuit filed by Samsung Electronics. The U.S. District Court for the Northern District of California granted ZTE's motion to dismiss the case on grounds of lack of personal jurisdiction, while granting Samsung an opportunity to amend its complaint.

District Judge Araceli Martínez-Olguin issued the ruling on January 30, 2026, ordering it unsealed on February 11. Building upon a prior procedural ruling by a magistrate judge, Judge Martínez-Olguin determined that Samsung failed to demonstrate sufficient U.S. connections for ZTE. The judge noted that the alleged patent licensing negotiations occurred solely between ZTE (China) and Samsung Electronics (South Korea), with ZTE not engaging in relevant conduct through any U.S. entity. Merely mentioning or asserting U.S. patents during negotiations does not satisfy the “purpose-directed” jurisdictional requirement.

Regarding jurisdiction, Samsung advanced multiple arguments to support court jurisdiction: ZTE accused Samsung of infringing U.S. patents during negotiations; past contracts between the parties elected California and New York law; ZTE retained U.S. law firms for patent enforcement; and ZTE had engaged in licensing discussions with U.S. companies like Apple.

ZTE countered in its motion that Samsung's lawsuit was “unnecessary and frivolous,” asserting that Samsung's own low offer was the primary cause of the negotiations' collapse. Furthermore, ZTE argued that most of the alleged infringing acts occurred in China and South Korea, and that U.S. courts should not intervene.

Judge Martínez-Olguin rejected each of Samsung's arguments. Regarding the hiring of U.S. law firms, the judge noted that the precedent cited by Samsung only applies to patent infringement cases initiated by U.S. entities, which differs from the circumstances of this case. Concerning licensing discussions with companies like Apple, Samsung did not assert that ZTE had actually reached any licensing agreements; merely “unsuccessful licensing discussions” are insufficient to establish jurisdiction. Regarding the contract's choice-of-law clause, the judge explicitly stated that there is “no legal basis” to extend it as a basis for jurisdiction, and other courts have reached contrary determinations. Regarding the securities case precedent cited by Samsung, the judge found it markedly distinct from the present case: that case involved stronger privacy rights concerning secretly recorded phone conversations, whereas the disputed patent negotiation records in this case lack similar rights attributes, as users voluntarily submitted the relevant technical information.

This ruling temporarily blocks Samsung's lawsuit, initiated in February 2025, at the jurisdictional stage. This lawsuit is one of a series filed by Samsung Electronics and its affiliates against ZTE for violating fair, reasonable, and non-discriminatory (FRAND) licensing commitments. Concurrent cases are also being heard in the UK and Germany. Samsung alleges ZTE engaged in monopolistic practices, breached contracts, and violated California state law regarding 4G and 5G standard-essential patent licensing. The complaint also notes that ZTE pleaded guilty in 2017 to violating U.S. sanctions against Iran and North Korea, resulting in an $1.19 billion fine. Additionally, some of its products were banned from sale in the U.S. in 2022 by the Federal Communications Commission on national security grounds.

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