Railware Inc v. Peninsula Corridor Joint Powers Board

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Railware, Inc. (New York)
  • Defendant: Peninsula Corridor Joint Powers Board d/b/a Caltrain (California)
  • Plaintiff’s Counsel: Robins Kaplan LLP
• Case Identification: 3:25-cv-05725, N.D. Cal., 07/08/2025
• Venue Allegations: Venue is alleged to be proper in the Northern District of California because Caltrain is a resident of the district and maintains a regular and established place of business, specifically its Central Equipment & Maintenance Facility (CEMOF) control center, within the district in San Jose.
• Core Dispute: Plaintiff alleges that Defendant’s centralized train traffic control systems infringe patents related to a safety technology that gives railway field workers control over removing electronic "blocks" used to protect their work zones on train tracks.
• Technical Context: The technology addresses the risk of human error by train dispatchers by requiring a unique code, provided to a worker on the tracks, to be returned to the central control system before a track's safety block can be lifted.
• Key Procedural History: The complaint alleges Caltrain had knowledge of the Asserted Patents due to, among other things, prior patent infringement lawsuits filed by Railware against other major railway operators, namely Amtrak and the Southeastern Pennsylvania Transportation Authority (SEPTA), with whom Caltrain has allegedly had business dealings and meetings regarding the accused technology.

Case Timeline

Date	Event
2013-10-21	Earliest Priority Date for all Asserted Patents
2016-12-13	U.S. Patent No. 9,517,782 Issues
2020-02-04	U.S. Reissue Patent No. RE47,835 Issues
2020-10-21	Alleged Date of Constructive Notice via Patent Marking
2022-06-15	Railware Files Suit Against Amtrak on Asserted Patents
2022-06-28	U.S. Reissue Patent No. RE49,115 Issues
2024-07-08	Railware Files Suit Against SEPTA on Asserted Patents
2025-05-15	Railware Sends Letter to Caltrain Alleging Infringement
2025-07-08	Complaint Filed

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

U.S. Patent No. 9,517,782 - "Tools for Railway Traffic Control"

• Patent Identification: U.S. Patent No. 9,517,782, "Tools for Railway Traffic Control," Issued December 13, 2016.

The Invention Explained

• Problem Addressed: The patent’s background section describes the significant safety risks faced by railway field workers. It notes that human error by a remote dispatcher using a centralized traffic control (CTC) system can lead to the premature or mistaken removal of a safety "block" from a section of track, resulting in serious injury or death to workers still present in that section (Compl. ¶¶30, 33-34; ’782 Patent, col. 2:27-37).
• The Patented Solution: The invention proposes a system where, after a dispatcher places a block, a "release code" is generated by the railway control apparatus and transmitted to a mobile device in the possession of the railway worker on the track. The block can only be removed after this unique code is received back from the worker’s device, effectively transferring the final authority for lifting the safety block from the remote dispatcher to the worker in the field (’782 Patent, Abstract; col. 6:10-17).
• Technical Importance: This architecture provides a critical safety check by ensuring the person most at risk—the field worker—is directly involved in and provides authorization for the action that re-opens a track to train traffic (Compl. ¶¶9, 34).

Key Claims at a Glance

• The complaint asserts independent claim 5 (Compl. ¶72).
• The essential elements of claim 5 are:
  • Configuring a railway field worker's mobile device with a user interface to display information received from a railway control apparatus and permit responses.
  • Providing a terminal user interface for a terminal user to request that the railway control apparatus place a block on track sections.
  • Generating a release code by the railway control apparatus and transmitting it to an electronic contact address accessible by the field worker.
  • Permitting the block to be removed by the railway control apparatus only upon receiving the release code from the user terminal in return.
• The complaint reserves the right to assert additional claims (’782 Patent, Compl. ¶73, n.44).

U.S. Reissue Patent No. RE47,835 - "Tools for Railway Traffic Control"

• Patent Identification: U.S. Reissue Patent No. RE47,835, "Tools for Railway Traffic Control," Issued February 4, 2020.

The Invention Explained

• Problem Addressed: Similar to the ’782 Patent, the ’835 Patent addresses the danger of dispatcher error in centralized railway control systems, which historically placed sole control for track blocking in the hands of a remote operator (’835 Patent, col. 2:27-37).
• The Patented Solution: The invention describes a method where a centralized control system provides a user interface for placing a block on a track. The system then generates a "removal code," determines the worker’s electronic contact address by "accessing a rail personnel contact database," transmits the code to that address, and permits block removal only after the code is entered back into the system (’835 Patent, col. 11:49-66; col. 12:15-24).
• Technical Importance: This method formalizes the process of securely linking a safety block to a specific worker by integrating a personnel database lookup, ensuring the release code is sent to the correct individual responsible for safety on that track section (Compl. ¶¶34, 39).

Key Claims at a Glance

• The complaint asserts independent claim 19 (Compl. ¶135).
• The essential elements of claim 19 are:
  • Providing a user interface of a railway traffic control apparatus, including a "block placing part" to place a block on specified track sections.
  • Generating a removal code, determining an electronic contact address of the railway field worker by accessing a rail personnel contact database, and transmitting the removal code to that address.
  • Permitting the block to be removed only upon entry of the removal code by the centralized control operation.
• The complaint reserves the right to assert additional claims (’835 Patent, Compl. ¶136, n.79).

U.S. Reissue Patent No. RE49,115 - "Tools for Railway Traffic Control"

• Patent Identification: U.S. Reissue Patent No. RE49,115, "Tools for Railway Traffic Control," Issued June 28, 2022.

Technology Synopsis

This patent claims the railway control apparatus itself, comprising a processor and a memory storing instructions. The invention is the physical system configured to perform the safety method: receiving a track selection, transmitting a block signal to the corresponding track interlock, generating a secret code associated with the block, and transmitting that secret code to a remote user terminal (’115 Patent, col. 15:3-21).

Asserted Claims

Independent claim 20 is asserted (Compl. ¶199).

Accused Features

The complaint accuses Caltrain's RailwayNet/AIM systems, which allegedly comprise the claimed processor and memory, of infringing by being configured to perform the claimed safety functions (Compl. ¶¶201, 236-237).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Caltrain's Centralized Traffic Control (CTC) system, which it internally refers to as the "Rail Operations Control System" or "ROCS" (Compl. ¶59). The complaint identifies the specific platforms as the Westinghouse Air Brake Technologies Corporation's ("Wabtec") RailwayNet℠ and/or Advanced Information Management (“AIM”) platforms, which are alleged to include an "Enhanced Employee Protection System" ("EEPS") or EEPS-like functionality (Compl. ¶¶15, 64).

Functionality and Market Context

The system is operated from Caltrain’s Central Equipment & Maintenance Facility (CEMOF) in San Jose, which is described as the "nerve center" for directing and monitoring all train traffic on its corridor (Compl. ¶¶58, 95). A core feature of this system is its ability to protect track workers by applying a "block" to prevent train movement into a work zone (Compl. ¶100). The complaint alleges that Caltrain has implemented a safety process requiring a "specific electronic code," "release code," or "pin code" to be transmitted from the worker to the dispatcher before this protection can be removed (Compl. ¶¶84, 89, 115). A Caltrain safety briefing presentation slide included in the complaint describes a "new electronic process...that requires a specific electronic code to be transmitted to the dispatcher" (Compl. p. 26, ¶¶89, 91).

IV. Analysis of Infringement Allegations

'782 Patent Infringement Allegations

Claim Element (from Independent Claim 5)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
configuring a mobile user device of a railway field worker to provide a device user interface to display information received via a network...and to permit the railway field worker to respond to prompts displayed thereon	Caltrain provides mobile devices to its railway field workers, and its system uses a network to communicate information, such as a release code, to that device. Workers then respond to prompts to provide the code back to the dispatcher.	¶¶82, 88	col. 6:21-27
providing a terminal user interface on a terminal to permit a terminal user...to request the railway control apparatus to place a block on one or more specified track sections	Caltrain's dispatchers at its CEMOF control center use terminals with a user interface to place blocks on track sections to protect workers, a process Caltrain refers to as applying "track and time" authority or placing tracks in "foul time."	¶¶94, 96, 100, 104	col. 6:28-35
generating by the railway control apparatus a release code and transmitting the release code to an electronic contact address accessible by the railway field worker via operation of the user interface of the user terminal	The accused system's "back office" generates a "release code" or "pin code" and transmits it to the railway field worker's mobile device. The complaint references a Caltrain safety presentation confirming this process.	¶¶107, 109-110	col. 6:36-41
permitting the block to said one or more track sections to be removed by the railway control apparatus only upon receiving the release code from the user terminal in return	The accused system requires the dispatcher to receive and enter the "release code" or "pin code" from the worker in order to remove the block and release the track from "foul time."	¶¶114-115, 117	col. 6:42-46

'835 Patent Infringement Allegations

Claim Element (from Independent Claim 19)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing a user interface of the railway traffic control apparatus, including a block placing part to place a block on one or more specified track sections...to block railway traffic	Caltrain’s control centers provide dispatchers with a user interface that functions as a "block placing part" to establish working limits ("foul time") by applying a block, which is controlled via interlocks.	¶¶155, 161, 163	col. 12:15-24
generating a removal code, determining an electronic contact address of the railway field worker by accessing a rail personnel contact database...and transmitting the removal code...	The accused system's "back office" generates a removal code. To transmit it, the system must access a database of railway field workers' electronic contact information to know where to send the code.	¶¶168, 171-173	col. 12:25-31
permitting the block to said one or more track sections to be removed only upon entry of the removal code by said centralized control operation...	Caltrain’s system requires the entry of the removal code (referred to as a "release code" or "pin code") in order to lift the block and remove protection from the track. This is evidenced by a Caltrain safety briefing on "Redundant Safety Protections."	¶¶179-181	col. 12:32-36

Identified Points of Contention

• Scope Questions: The complaint alleges that a worker provides a code to a dispatcher, who then enters it into the system (Compl. p. 26). A key question for the court will be whether this indirect, human-mediated process meets the claim requirement that the apparatus "receiv[es] the release code from the user terminal in return" ('782 Patent, cl. 5). The interpretation of this phrase may determine whether there is a mismatch between the claimed direct electronic return path and the alleged real-world operation.
• Technical Questions: The complaint alleges the accused system determines a worker’s contact address by "accessing a rail personnel contact database" ('835 Patent, cl. 19). The infringement analysis may turn on the degree of automation in this step. A central question will be whether the accused system performs an automated database query to retrieve the contact information, or if this is a manual action performed by the dispatcher outside of the claimed method's scope.

V. Key Claim Terms for Construction

• The Term: "...receiving the release code from the user terminal in return" (from claim 5 of the ’782 Patent).

• Context and Importance: This term is critical to the infringement analysis for the ’782 Patent. The dispute may center on whether "receiving...from the user terminal" requires a direct, machine-to-machine data transmission from the worker's device to the control apparatus, or if it can encompass a scenario where the worker verbally communicates the code to a dispatcher who then manually inputs it. Practitioners may focus on this term because the complaint's own evidence suggests a human dispatcher is in the loop (Compl. p. 26).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the removal code can be entered in various ways, including via a "voice or speech interface part" that processes a voice message from a worker, which could support an interpretation that does not require a direct data link from the terminal itself (’782 Patent, col. 3:17-25).
  • Evidence for a Narrower Interpretation: The specification also describes an embodiment where the code is returned by "activating the link in the message received by the railway field worker," suggesting a direct electronic action by the terminal (’782 Patent, col. 3:20-22). The phrase "from the user terminal" could be interpreted by a defendant to mean the data packet must originate at the terminal, not at the dispatcher’s console after a phone call.

• The Term: "...determining an electronic contact address of the railway field worker by accessing a rail personnel contact database..." (from claim 19 of the ’835 Patent).

• Context and Importance: This limitation requires an affirmative step of accessing a database to find the worker's contact information. Infringement will depend on whether Caltrain's accused system performs this step as part of the claimed method. The construction will determine if a manual lookup by a dispatcher satisfies the claim, or if an automated query by the system itself is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim uses the general term "accessing," which could be argued to cover any method of retrieving information from the database, whether automated by the system or initiated manually by its user.
  • Evidence for a Narrower Interpretation: The context of an automated, centralized control system suggests an integrated, automated function. The patent describes the system itself performing the steps of generating a code, determining an address, and transmitting, which may imply that the "accessing" step is also performed by the system's processor, not its human operator (’835 Patent, col. 12:25-31).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b), stating that Caltrain instructs its dispatchers and other users on how to operate the accused systems in a manner that directly infringes the Asserted Patents (Compl. ¶¶121, 185, 279).
• Willful Infringement: The complaint alleges willful infringement based on both pre- and post-suit knowledge. It asserts Caltrain knew or should have known of the patents due to: (1) constructive notice via Railware's product marking since at least October 21, 2020; (2) knowledge of prior lawsuits involving the same patents against Amtrak and SEPTA, entities with which Caltrain allegedly collaborates; (3) meetings with SEPTA and Wabtec discussing the accused technology; and (4) an actual notice letter sent to Caltrain on May 15, 2025 (Compl. ¶¶49-57, 122-128).

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

• A core issue will be one of operational equivalence: does the accused process, which appears to involve a worker verbally communicating a code to a dispatcher for manual entry, perform the same function in substantially the same way as the claimed method, which requires the control apparatus to "receiv[e] the release code from the user terminal"? The case may turn on whether this human-mediated step breaks the chain of causation required for direct infringement.
• A second central issue will be one of system integration: for the claims requiring the system to access a personnel database, what evidence will show that this is an automated function of the accused apparatus itself, rather than a separate, manual action performed by the human dispatcher? The degree of automation in the accused system's workflow will be a critical factual question.
• A key evidentiary question will be one of willfulness: what was the extent of Caltrain's knowledge of the Asserted Patents and the specific nature of the alleged infringement prior to receiving the notice letter, particularly through its documented interactions with previously-sued entities like SEPTA? The answer will determine Caltrain's exposure to enhanced damages.