Estech Systems IP LLC v. Freshworks Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Estech Systems IP, LLC (Texas)
  • Defendant: Freshworks Inc. (Delaware)
  • Plaintiff’s Counsel: Williams Simons & Landis PLLC
• Case Identification: 5:24-cv-02525, N.D. Cal., 04/07/2025
• Venue Allegations: Venue is asserted based on Defendant's principal place of business being located within the Northern District of California.
• Core Dispute: Plaintiff alleges that Defendant’s VoIP and business communication products infringe two patents related to providing phone directory and voicemail functionalities across different network locations.
• Technical Context: The technology at issue involves Voice over IP (VoIP) systems that enable integrated communication features, such as shared directories and voicemail, for users in geographically separate offices connected over a wide-area network.
• Key Procedural History: The complaint notes that the asserted patents have been licensed over 20 times to industry participants including Cisco, Microsoft, and Avaya. Additionally, U.S. Patent No. 8,391,298 was the subject of an Inter Partes Review (IPR) proceeding (IPR2021-00574), which concluded with the cancellation of claims 1-12 and 17-19. The complaint asserts the surviving independent claim 13 of that patent, suggesting its patentability has been tested before the Patent Trial and Appeal Board.

Case Timeline

Date	Event
2001-02-01	Earliest Priority Date for ’699 and ’298 Patents
2006-10-17	U.S. Patent No. 7,123,699 Issued
2013-03-05	U.S. Patent No. 8,391,298 Issued
2021-03-05	IPR Filed Against ’298 Patent (IPR2021-00574)
2025-02-12	IPR Certificate Issued for ’298 Patent
2025-04-07	Complaint Filing Date

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

U.S. Patent No. 8,391,298 - "Phone Directory in a Voice Over IP Telephone System"

• Patent Identification: U.S. Patent No. 8,391,298, "Phone Directory in a Voice Over IP Telephone System," issued March 5, 2013.

The Invention Explained

• Problem Addressed: The patent addresses the challenge of providing unified telephone services across geographically separate offices, where traditional phone systems require either expensive dedicated circuits or maintain separate, non-integrated systems that limit information sharing like phone directories (’298 Patent, col. 1:45-54; ’699 Patent, col. 1:52-60, incorporated by reference).
• The Patented Solution: The invention describes a VoIP system that allows a user at one location (a "first LAN") to access and display a list of phone numbers and extensions stored on a server at a remote location (a "second LAN"). The user can scroll through this remote directory and initiate a call to a selected party, making inter-office communication seamless without needing a printed directory or operator assistance (’298 Patent, Abstract; Fig. 11).
• Technical Importance: This technology facilitates more efficient communication within a distributed enterprise by centralizing directory information and making it transparently accessible across a wide-area network.

Key Claims at a Glance

• The complaint asserts at least independent claim 13 (Compl. ¶¶ 28, 36).
• Essential elements of Claim 13 (a system claim) include:
  • A first IP telephone on a first LAN and second/third telephone extensions on a second LAN, with the LANs connected by a WAN.
  • A third LAN also coupled to the WAN.
  • Means for displaying on the first IP telephone a list of telephone destinations stored on a server in the second LAN.
  • Means for automatically dialing a selected destination from that list.
  • Means for displaying a list of available LANs (e.g., the second and third LANs).
  • Means for displaying the destination list in response to the user selecting a specific LAN from the list of LANs.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,123,699 - "Voice Mail in a Voice Over IP Telephone System"

• Patent Identification: U.S. Patent No. 7,123,699, "Voice Mail in a Voice Over IP Telephone System," issued October 17, 2006.

The Invention Explained

• Problem Addressed: In a multi-office environment, voicemail systems were often isolated to each location, preventing users from easily accessing or being notified of messages left in a different office's system. This created a disjointed user experience (’699 Patent, col. 1:52-60).
• The Patented Solution: The patent discloses a method where a voicemail message stored in a system on a first LAN triggers a "sensory indication" (e.g., an LED light) on a user's telecommunications device located on a second, remote LAN. This indication alerts the user to the remote message, which they can then access and listen to over the WAN as if it were stored locally (’699 Patent, Abstract; Fig. 10).
• Technical Importance: The invention created a geographically transparent voicemail system, unifying the user experience and improving workflow for employees spread across different locations.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶¶ 49, 56).
• Essential elements of Claim 1 (a method claim) include:
  • Storing a voice mail message in a voice mail system within a first LAN.
  • Coupling a second LAN to the first LAN over a WAN using a routable network protocol.
  • Providing a sensory indication on a telecommunications device within the second LAN to signal that the message is stored in the first LAN.
  • The device in the second LAN accessing the system in the first LAN to listen to the message.
• The complaint states that Estech does not allege infringement of any non-method claims of the ’699 patent (Compl. ¶56).

III. The Accused Instrumentality

• Product Identification: The "Accused Instrumentalities" are identified as "Freshworks Products and Services" (Compl. ¶25). This includes VoIP software and services such as the Freshcaller mobile and desktop apps, Freshdesk apps, the Freshworks Customer Service Suite, Freshcaller Cloud PBX, and the Freshworks Neo Platform (Compl. ¶21).
• Functionality and Market Context: The complaint alleges these products combine to form telecommunication and information handling systems that provide VoIP-based voice calling, voicemail storage and retrieval, and directory services to customers (Compl. ¶¶ 21, 23). The functionalities are allegedly delivered via a combination of user-facing applications (telephony devices) and backend infrastructure (servers, cloud PBX) that operate over data networks (Compl. ¶21). The complaint does not provide sufficient detail for analysis of the products' market context.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint references infringement chart exhibits that were not provided with the pleading; therefore, the infringement allegations are summarized below in prose.

’298 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities create a telecommunications system that meets the elements of claim 13. The infringement theory appears to rely on mapping Freshworks' cloud-based services to the specific network topology of the claim. The complaint alleges the existence of "first, second, and third LANs" coupled by a WAN (Compl. ¶32). It further alleges that Freshworks' VoIP devices (the "first IP telephone") can display a list of telephone destinations stored on remote servers (the "second IP server") (Compl. ¶34(i)). The system is accused of having functionality to automatically call a selected destination, display lists of different directories or locations, and display the contact list for a selected location, which appear to map to the "means for" limitations of claim 13 (Compl. ¶34).

• Identified Points of Contention:
  • Architectural Questions: A primary question will be whether Freshworks' architecture, likely a cloud-based service model with distributed clients, can be characterized as the specific "first LAN," "second LAN," and "third LAN" structure required by the claim. The defense may argue a fundamental mismatch between the claimed legacy architecture and the accused cloud service.
  • Means-Plus-Function Scope: Claim 13 is a means-plus-function claim. Infringement will require the court to first identify the corresponding structures in the ’298 Patent specification that perform the claimed functions (e.g., "means for displaying") and then determine if the accused products contain identical or equivalent structures. The complaint's high-level allegations do not identify the specific accused software or hardware components that allegedly perform these functions.

’699 Patent Infringement Allegations

The infringement theory for claim 1 alleges that the Freshworks system performs the claimed method for remote voicemail access. The complaint asserts that the Accused Instrumentalities include VoIP servers that store voicemails (allegedly in a "first LAN") (Compl. ¶53) and VoIP telephony devices (allegedly on a "second LAN") that provide a "sensory indication" when a message is stored (Compl. ¶54). The system is accused of allowing a user at a device on the "second LAN" to establish a channel over a WAN to access and listen to the voicemail message stored on the server in the "first LAN" (Compl. ¶55).

• Identified Points of Contention:
  • Technical Questions: Similar to the ’298 Patent, a factual dispute may arise over whether the accused system possesses the distinct "first LAN" and "second LAN" topology as required by the claim, or if it operates as a unified cloud platform.
  • Scope Questions: The scope of "sensory indication" will be critical. The defense may argue the term, in the context of the patent, is limited to a physical indicator like an LED on a desk phone, while Plaintiff may argue it is broad enough to cover modern software-based alerts like mobile push notifications or application badges.

V. Key Claim Terms for Construction

’298 Patent

• The Term: "a third LAN coupled to the first and second LANs via the WAN" (Claim 13)
• Context and Importance: This limitation defines a specific three-part network topology. Practitioners may focus on this term because the infringement case depends on mapping the accused cloud architecture to this precise structure. If Freshworks' system is not found to have a "third LAN" as construed by the court, the infringement claim may fail.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a system connecting multiple distinct locations, such as a Dallas office (301), a Detroit office (302), and a telecommuter's home (303), over a WAN (201) (’298 Patent, Fig. 3, col. 3:20-40). Plaintiff may argue that any distinct network or sub-network accessible via the WAN constitutes a "LAN" for the purposes of the claim.
  • Evidence for a Narrower Interpretation: The patent's figures and descriptions consistently depict "LANs" as traditional, physically co-located office networks. The defense could argue the term should be limited to such conventional local area networks, and not read on a more abstract collection of individual clients connecting to a central service.

’699 Patent

• The Term: "sensory indication" (Claim 1)
• Context and Importance: This term is central to how a user is notified of a remote voicemail. Its construction will determine whether modern, software-based notifications (e.g., push notifications, on-screen alerts, emails) fall within the claim's scope, or if it is limited to a physical indicator on a dedicated phone.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that "other types of indications or alerts can be utilized to inform a user that a remote message has been received, other than an LED light on a telephone" (’699 Patent, col. 10:65-67). This explicit language may support a construction that is not limited to the primary embodiment.
  • Evidence for a Narrower Interpretation: The abstract exclusively mentions an "LED lamp," and the detailed description of the notification process repeatedly refers to illuminating a "VMB LED" (’699 Patent, Abstract; col. 10:48-52). A defendant may argue that these specific disclosures limit the scope of "sensory indication" to physical hardware indicators on a telephone.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for the ’298 Patent. Inducement is based on Freshworks allegedly advertising, promoting, and providing instructions that guide customers to use the accused products in an infringing manner (Compl. ¶39). Contributory infringement is based on allegations that the products contain special, non-staple features specifically designed to be used in an infringing way (Compl. ¶40).
• Willful Infringement: Willfulness is alleged for the ’298 Patent based on Freshworks' knowledge of the patent since at least the service of the original complaint (Compl. ¶42). The complaint further alleges willful blindness, asserting that Freshworks has a "policy or practice of not reviewing the patents of others" (Compl. ¶41).

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

• A central issue will be one of architectural mapping: can the specific multi-LAN network topologies recited in the patent claims (e.g., the "first, second, and third LANs" of ’298 Claim 13) be proven to exist within Freshworks' modern, cloud-based service architecture, or is there a fundamental mismatch between the claimed legacy structure and the accused system?
• A key evidentiary question will be one of structural equivalence for means-plus-function claims: For the ’298 patent, what specific software and hardware in the accused products perform the functions of the "means for" limitations in claim 13, and are those structures the same as or equivalent to the corresponding structures disclosed in the patent's specification?
• Finally, the case may turn on a question of definitional scope: can terms rooted in the context of early-2000s telephony, such as "sensory indication," be construed broadly enough to read on modern software-based notifications like application badges and push alerts, or will they be limited to the physical hardware embodiments described in the patents?