Missed Call LLC v. RingCentral Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Missed Call, LLC (Texas)
  • Defendant: RingCentral, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:23-cv-06728, N.D. Cal., 12/31/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Northern District of California, conducts substantial business in the forum, and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s telecommunication products and services infringe a patent related to providing users with an indication of why a telephone call was missed.
• Technical Context: The technology addresses methods for a communication device to analyze network signals to determine if a missed call was terminated by the caller or by a network timeout, thereby providing the user with context about the call's potential urgency.
• Key Procedural History: The complaint is the initial pleading in this matter. Plaintiff identifies itself as a non-practicing entity. The allegations of willfulness are based on knowledge of the patent as of the complaint's filing date, reserving the right to prove an earlier date of knowledge.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,531,872 - Communication Apparatus For Providing An Indication About A Missed Call, And Method Thereof (Issued Dec. 27, 2016)

The Invention Explained

• Problem Addressed: The patent's background describes a situation where a user receiving a missed call notification cannot tell if the call was short (e.g., the caller hung up quickly) or long (e.g., the caller let it ring until the network disconnected it). This ambiguity means the called user "may not recognize the importance of a missed call" (’872 Patent, col. 5:48-49).
• The Patented Solution: The invention is a communication apparatus that analyzes technical data from the network to solve this problem. When a call is missed, the apparatus is described as "extracting a cause value from a cause information element sent from a network" (’872 Patent, col. 7:37-40). This "cause value" specifies whether the call was terminated by the calling user (e.g., "NORMAL CLEARING") or by the network (e.g., "RECOVERY ON TIME EXPIRY"). The apparatus then provides a corresponding indication to the user, allowing them to infer if the call was more or less urgent (’872 Patent, col. 6:40-53; Fig. 2).
• Technical Importance: The claimed invention purports to provide users with more granular, actionable information about the context of a missed call than was available in prior systems, which only indicated that a call was missed without explaining why (’872 Patent, col. 5:11-18).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-13 (Compl. ¶9). Independent claim 1 is representative.
• The essential elements of independent claim 1 include:
  • A communication apparatus with receiving means, a control unit, and output means.
  • A processing means for extracting a "cause value" from a "cause information element" sent by a network regarding a missed call.
  • Wherein if the caller ends the call, the apparatus uses the cause value to output an indication that the call was "caused by the caller."
  • Wherein if the network ends the call, the apparatus uses the cause value to output an indication that the call was "caused by the network and was urgent."
• The complaint reserves the right to assert additional claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name. It broadly accuses "Defendant's products and services," and "systems, products, and services that facilitate providing of an indication of a missed telephone call" (Compl. ¶3, ¶9).

Functionality and Market Context

The complaint does not provide technical details on how RingCentral's products operate. It alleges that Defendant "maintains, operates, and administers" systems that perform the infringing methods (Compl. ¶9). The complaint further alleges that Defendant derives "substantial revenue" from its products and services in the judicial district but provides no specific market context (Compl. ¶6). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that "[s]upport for the allegations of infringement may be found in the following exemplary table included as Exhibit A" (Compl. ¶10). However, Exhibit A was not filed with the complaint. In lieu of a claim chart, the infringement theory is that RingCentral's systems, when providing missed call notifications to users, practice the methods recited in the claims of the ’872 patent (Compl. ¶9). The complaint does not provide specific factual allegations detailing how the accused systems meet each claim limitation.

• Identified Points of Contention:
  • Technical Questions: A primary question for the court will be evidentiary. The complaint does not specify what evidence demonstrates that RingCentral’s systems "extract a cause value contained in a cause information element sent from a network," a key technical step in the asserted claims (’872 Patent, col. 7:37-38). Another question is what evidence shows the accused systems provide an indication that a network-terminated call "was urgent," as explicitly required by claim 1 (’872 Patent, col. 7:56-57).
  • Scope Questions: The infringement analysis may raise the question of whether modern VoIP signaling protocols, presumably used by RingCentral, fall within the scope of the patent's term "cause information element," which the specification discusses in the context of established telecommunication standards like ISDN and GSM (’872 Patent, col. 6:57-64).

V. Key Claim Terms for Construction

• The Term: "cause value contained in a cause information element sent from a network"

  • Context and Importance: This term recites the specific piece of network data that enables the invention's functionality. The infringement analysis will depend heavily on whether the signaling data used in the accused system can be characterized as meeting this definition.
  • Intrinsic Evidence for a Broader Interpretation: A party could argue that the term should cover any data packet or signal sent by a network that functionally communicates the reason for a call's termination. The patent's reference to specific standards like "ITU-T recommendation Q.931" or "3GPP TS 24.008" could be presented as exemplary, not limiting (’872 Patent, col. 6:57-64).
  • Intrinsic Evidence for a Narrower Interpretation: A party could argue that the term is limited to the specific, standardized data structures formally known as a "cause information element" containing a "cause value" within the protocols explicitly mentioned in the specification. This interpretation would narrow the claim scope to systems implementing those particular legacy standards.

• The Term: "an indication that the missed received incoming call was caused by the network and was urgent"

  • Context and Importance: Claim 1 requires the apparatus to affirmatively indicate that a network-terminated missed call "was urgent." Whether the accused system provides such an indication will be a crucial point of dispute.
  • Intrinsic Evidence for a Broader Interpretation: A party may argue that this limitation is met by any differential treatment from which a user could infer urgency. The specification supports this by suggesting "a high indication of urgency, such as a particular image or the like," rather than requiring the literal word "urgent" (’872 Patent, col. 6:36-38).
  • Intrinsic Evidence for a Narrower Interpretation: A party could contend that the claim requires an explicit notification of urgency, not merely an indication of the cause of termination. The plain language of the claim requires an indication that the call "was urgent," suggesting that merely differentiating between a caller-ended and network-ended call is insufficient without the additional urgency component.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it alleges Defendant instructs customers on how to use its systems in an infringing manner (Compl. ¶11). For contributory infringement, it alleges there are "no substantial noninfringing uses for Defendant's products and services" (Compl. ¶12). These allegations are not supported by specific factual pleadings.
• Willful Infringement: The complaint pleads willful infringement based on Defendant's alleged knowledge of the ’872 patent "from at least the filing date of the lawsuit" (Compl. ¶11, fn. 1). This allegation appears to be aimed at potential enhancement of post-filing damages rather than asserting pre-suit knowledge.

VII. Analyst’s Conclusion: Key Questions for the Case

1. An Evidentiary Question of Technical Operation: The case will likely depend on whether Plaintiff can produce evidence that the accused RingCentral system performs the specific technical steps of the claims, particularly the requirement to "extract a cause value from a cause information element" as that term is construed by the court. The complaint itself provides no such evidence.
2. A Definitional Question of Scope: A core issue will be one of claim construction: can the term "cause information element," which is described in the patent with reference to specific telecommunication standards, be interpreted to cover the signaling protocols used in Defendant's modern VoIP platform?
3. A Functional Question of Urgency: The analysis will also turn on a key functional question: does the accused system provide "an indication that the missed...call...was urgent" as required by claim 1, or does it merely provide information from which a user might independently infer urgency? The answer will determine if a critical limitation of the claim is met.