It's a different situation. Samsung is a big company, whereas the lightbulb vendors are fly-by-night resellers/contract manufacturers that don't care about patents. The patent holder goes after the biggest fish because Target is less likely to disappear than JKLM Filament Light Bulb Importing Ltd.
It seems the statute disagrees with me, but it seems wrong to sue the retailer. Sort of like safe-harbor provisions for copyright violations. I don't think it's practical to expect retailers to vet the functionality of an item against active patents and then audit the wholesaler's patent license portfolio for compliance. More practical would be a takedown system where the patent holder could notify the retailer of infringement, and the wholesaler would have the opportunity to respond, again like how things are handled with copyright. (Not that the process there is without flaws)
