DCT

5:24-cv-02525

Estech Systems IP LLC v. Freshworks Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:24-cv-02525, N.D. Cal., 01/16/2026
  • Venue Allegations: Venue is based on Defendant’s principal place of business being located in the Northern District of California.
  • Core Dispute: Plaintiff alleges that Defendant’s Voice over IP (VoIP) software, servers, and related services infringe patents related to unified phone directories and remote voicemail access across wide-area networks.
  • Technical Context: The dispute centers on Voice over IP (VoIP) telephony, a foundational technology for modern business communications that allows voice calls to be transmitted over data networks.
  • Key Procedural History: This Second Amended Complaint was filed after the Court expressed "reservations" regarding the sufficiency of infringement allegations in prior pleadings. The complaint states that it seeks to clarify its theories, particularly concerning the network architecture limitations in the asserted claims. The complaint also notes that the asserted patents have been licensed over 20 times to industry participants, including Cisco Systems and Microsoft.

Case Timeline

Date Event
2001-02-01 Earliest Priority Date for ’699 Patent
2001-02-01 Earliest Priority Date for ’298 Patent
2006-10-17 ’699 Patent Issued
2013-03-05 ’298 Patent Issued
2026-01-16 Second Amended Complaint Filed

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

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 describes the limitations of traditional, geographically separated telephone systems, which lacked the ability to provide a unified, easily accessible phone directory across different office locations connected by a data network (’298 Patent, Background Information).
  • The Patented Solution: The invention provides a VoIP telephone system where a user at a device on a first local area network (LAN) can access and view a list of telephone extensions (a directory) that are stored on a server located in a second, remote LAN. The two LANs are connected by a wide area network (WAN), such as the internet. The user can then select an extension from the remote directory to initiate a call across the network (’298 Patent, Abstract; col. 2:45-56).
  • Technical Importance: This technology facilitated the creation of cohesive communication systems for businesses with multiple physical locations, making it simpler for employees to connect without needing separate, site-specific directories (Compl. ¶18).

Key Claims at a Glance

  • The complaint asserts at least independent claim 13 (Compl. ¶36).
  • The essential elements of Claim 13 include:
    • A telecommunications system with a first IP telephone on a first LAN and second/third telephone extensions on a second LAN.
    • A WAN coupling the first LAN to the second LAN, and a third LAN also coupled to the WAN.
    • The first IP telephone includes circuitry enabling a user to observe a list of the extensions from the second LAN, where the list is stored on a server in the second LAN and accessed across the WAN.
    • The first IP telephone also includes circuitry for selecting between observing the list from the second LAN or a list of extensions from the third LAN.
  • The complaint alleges infringement of other claims as well (Compl. ¶42).

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: The patent identifies challenges with traditional voicemail systems in a wide area network context, which were often either centralized and inconvenient to access remotely or were separate systems at each location with limited ability to share or transfer messages (’699 Patent, col. 1:51-59).
  • The Patented Solution: The invention is a method for providing a transparent remote voicemail experience. A voicemail message is stored in a system on a first LAN. A user on a second LAN receives a "sensory indication" (e.g., a blinking light on their phone) that a message is available. The user can then access the voicemail system on the first LAN, which establishes a connection over the WAN to stream the audio of the message to the user's remote device (’699 Patent, Abstract; Fig. 11).
  • Technical Importance: This approach unified the voicemail experience for users across geographically dispersed offices, making remote work and inter-office communication more seamless (Compl. ¶51).

Key Claims at a Glance

  • The complaint asserts at least independent method claim 1 (Compl. ¶59).
  • The essential steps of Claim 1 include:
    • Storing a voicemail message in a system within a first LAN.
    • Coupling a second LAN to the first LAN over a WAN.
    • Providing a sensory indication on a device in the second LAN 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 specifies that it does not allege infringement of any non-method claims of the ’699 Patent (Compl. ¶59).

III. The Accused Instrumentality

Product Identification

  • The "Accused Instrumentalities" are identified as "Freshworks Products and Services" (Compl. ¶25). This includes software telephony products like the Freshcaller mobile and desktop apps, Freshdesk apps, and the Freshworks Customer Service Suite, as well as backend services like the Freshcaller Cloud PBX and Freshworks Neo Platform (Compl. ¶21).

Functionality and Market Context

  • The accused products collectively provide a cloud-based VoIP communication platform for businesses, offering functionalities such as voice calling, voicemail, and directory services (Compl. ¶23). The complaint alleges these systems are implemented using a network architecture of distinct LANs (e.g., customer networks and Freshworks' server networks) connected via a WAN (the internet), through which directory and voicemail data are transmitted (Compl. ¶32, ¶35, ¶56).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint refers to infringement chart exhibits that were not provided. The following summary is based on the narrative allegations.

’298 Patent Infringement Allegations

Claim Element (from Independent Claim 13) Alleged Infringing Functionality Complaint Citation Patent Citation
a first IP telephone coupled to a first IP server within a first LAN Accused VoIP telephony devices (e.g., Freshcaller app) connected to a customer's LAN, which includes a firewall alleged to be the "first IP server." ¶33, ¶38 col. 2:57-65
second and third telephone extensions coupled to a second IP server within a second LAN Freshworks' servers, located within a "second LAN," store telecommunication extensions. ¶35, ¶37 col. 2:57-65
a WAN coupling the first LAN to the second LAN The internet or a virtual private network (VPN) connects the customer's LAN to Freshworks' server LAN. ¶39 col. 2:45-48
a third LAN coupled to the first and second LANs via the WAN The accused systems are alleged to use a multi-LAN architecture including first, second, and third LANs coupled with a WAN. ¶32 col. 2:45-48
the first IP telephone including first circuitry for enabling a user to observe a list of the second and third telephone extensions The accused VoIP devices have a means to display a list of telephone destinations stored on the remote Freshworks server. ¶34 col. 9:56-67
the first IP telephone including second circuitry for selecting between observing the list... [from the] second LAN or observing a list... [from the] third LAN The accused VoIP devices provide a means to display at least two different directories or types of directories. ¶34 col. 9:56-67

Identified Points of Contention:

  • Architectural Questions: A central dispute will likely be whether Freshworks' modern, cloud-based architecture maps onto the "first LAN", "second LAN", and "third LAN" structure recited in the claim. The complaint’s clarification that the LANs are "physically separate" but communicatively coupled suggests this is a known area of dispute (Compl. ¶37).
  • Scope Questions: The complaint’s assertion that a customer's firewall can be the claimed "first IP server" raises a significant claim construction question (Compl. ¶38). The case may turn on whether a security device like a firewall can be considered a "server" in the context of a patent describing multimedia telephony servers.

’699 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
storing a voice mail message... in a voice mail system within a first LAN Accused VoIP servers store voicemail messages within what is alleged to be a "first LAN" (e.g., Freshworks' server network). ¶56 col. 10:1-3
coupling a second LAN to the first LAN over a WAN The accused architecture connects customer networks ("second LAN") to Freshworks' server network ("first LAN") over the internet ("WAN"). ¶55, ¶58 col. 1:41-47
providing a sensory indication on a telecommunications device within the second LAN Accused VoIP devices provide users with a notification (e.g., on-screen alert, icon badge) indicating a new voicemail is stored remotely. ¶57 col. 10:39-41
the telecommunications device accessing the voice mail system within the first LAN to listen to the voice message Accused VoIP devices allow a user to establish a connection across the WAN to the remote server to stream and listen to the stored voicemail. ¶57, ¶58 col. 11:1-20

Identified Points of Contention:

  • Technical Questions: As with the ’298 Patent, the primary issue is one of architectural mapping. Does a cloud service model, where clients on various user networks connect to a centralized service, constitute the distinct "first LAN" and "second LAN" structure required by the claim? The complaint acknowledges the court's prior "reservations" on the "first LAN" limitation (Compl. ¶60).

V. Key Claim Terms for Construction

  • Term: "IP server" (’298 Patent)

    • Context and Importance: Plaintiff’s infringement theory for the ’298 Patent depends on construing this term broadly enough to read on a customer's firewall (Compl. ¶38). Practitioners may focus on this term because its construction could be dispositive of infringement for that patent.
    • Intrinsic Evidence for a Broader Interpretation: The term is not explicitly defined in the patent, which may support an argument that it should be given its ordinary meaning, potentially encompassing any network device that provides a service.
    • Intrinsic Evidence for a Narrower Interpretation: The specification consistently depicts the "IP server" (e.g., element 101) as an "IP multimedia server" that is a core component of the telephony system, distinct from other network elements like hubs or routers (’298 Patent, Fig. 1; col. 2:62-63). This context suggests a more specialized function than that of a generic firewall.

  • Term: "first LAN" / "second LAN" (’298 and ’699 Patents)

    • Context and Importance: The asserted claims in both patents are structurally dependent on the existence of and interaction between at least two distinct LANs. The infringement cases hinge on successfully mapping the accused cloud-based architecture to this claimed network topology.
    • Intrinsic Evidence for a Broader Interpretation: The patents describe the LANs as being coupled by a WAN, which could be a "public WAN, such as the Internet, a private data network, an intranet, or a Virtual Private Network" (’699 Patent, col. 3:19-23). This suggests the patent contemplates various logical, not just physical, network arrangements.
    • Intrinsic Evidence for a Narrower Interpretation: The exemplary embodiments in both patents depict geographically distinct office networks (e.g., "Dallas" and "Detroit"), each containing its own servers, hubs, and workstations (’298 Patent, Fig. 3). This may support an argument that a "LAN" refers to a complete, self-contained local network, rather than just the client-side of a cloud-client architecture.

VI. Other Allegations

  • Indirect Infringement: For the ’298 Patent, the complaint alleges induced infringement based on Freshworks providing instructions and advertising that guide customers to use the accused products in an infringing manner, with knowledge of the patent since at least the filing of the original complaint (Compl. ¶42). Contributory infringement is also alleged, on the basis that the accused products have special features for providing remote directory access that are a material part of the invention and not suitable for substantial non-infringing use (Compl. ¶43).
  • Willful Infringement: The complaint alleges willful infringement of the ’298 Patent based on Freshworks’ alleged knowledge since the original complaint was served (Compl. ¶45). It further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶44).

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

  • A core issue will be one of architectural mapping: Can Plaintiff successfully argue that the Defendant's modern, cloud-centric service architecture, where customer devices act as clients to a centralized platform, constitutes the distinct, peer-like "LAN-WAN-LAN" network topology described in the patents' claims and specifications?
  • A key question of definitional scope for the '298 patent will be whether the term "IP server" can be construed to read on a network security device like a customer's firewall, or if the patent’s context limits the term to a multimedia server performing core telephony functions.
  • A central procedural question will be whether the clarifications in this Second Amended Complaint are sufficient to overcome the Court's previously expressed "reservations" and allow the infringement claims to proceed past the pleading stage.