In its filings, Samsung said it's been offering Apple a licence since November 2010 and "Apple has never been willing to take a licence on any terms."
Steve Dowling, a spokesman for Apple, didn't immediately respond to requests for comment.
Apple has for two years claimed Samsung "slavishly copied" the iPhone, while Samsung contends that Apple entered the mobile-phone market without paying royalties to the companies that built the industry.
Neither has been able to get a significant victory against the other outside the US. Apple was forced to apologise in the UK for accusing Samsung of copying the patented design of the iPad; the judge who ordered the apology has since left the bench and been hired by Samsung in its unrelated patent fight with Ericsson, according to an ITC notice posted in that case.
Apple's biggest victory over Samsung was a $US1 billion infringement verdict by a California jury in August, the fifth biggest in US history. US District Judge Lucy Koh in San Jose, California, on March 1 ordered a new trial on damages for a portion of the award, while upholding $US598.9 million of the verdict.
Koh earlier rejected Samsung's request for a new trial on liability as well as Apple's bid for an order to block sales of the Samsung products that were part of the trial.
Samsung, with 140,000 patents worldwide on items including light-emitting diodes (LED) and televisions, has been the second- biggest recipient of US patents since 2006 and now tops the list of applicants in Europe.
It filed its trade complaint in June 2011 as a counter strike against Apple's accusations that handsets running on Google's Android operating system copied the look and feel of the iPhone.
Apple has its own case against Samsung at the trade agency. A final decision in that dispute is scheduled to be released on August 1.
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