DCT

5:25-cv-04595

Competitive Access Systems v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Eric M. Delangis (Huntsville, AL)
    • Defendant: Telecom Corp. (Delaware)
    • Plaintiff’s Counsel: Patent Analytics Firm
  • Case Identification: 5:25-cv-04595, N.D. Cal., 10/17/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California as Defendant maintains a principal place of business, conducts substantial business, and has committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s 5G network infrastructure, which implements functionalities for multi-access communication, infringes patents related to methods and devices for multipath communications.
  • Technical Context: The technology at issue involves methods for aggregating bandwidth and managing data traffic across multiple distinct communication paths, such as cellular and Wi-Fi networks, to enhance connection speed and reliability.
  • Key Procedural History: The patents-in-suit belong to a large family of applications stemming from a provisional application filed in 2002, indicating a long history of development and prosecution in the technical area of multipath data communication. No prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date Event
2002-10-15 Earliest Priority Date ('908, '641, '343 Patents)
2019-01-01 Accused 5G Network with ATSSS Functionality Launch (Alleged)
2020-12-15 U.S. Patent No. 10,868,908 Issues
2022-08-16 U.S. Patent No. 11,418,641 Issues
2023-02-14 U.S. Patent No. 11,582,343 Issues
2025-10-17 Complaint Filing Date

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

U.S. Patent No. 10,868,908 - "Devices and methods for multipath communications"

  • Patent Identification: U.S. Patent No. 10,868,908, "Devices and methods for multipath communications," issued December 15, 2020.

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of limited bandwidth and high cost associated with residential internet access in the early 2000s, where standard telephone lines (POTS) offered low data rates and emerging broadband technologies like DSL were expensive and required significant infrastructure upgrades (US 10,868,908 B2, col. 1:24-42).
  • The Patented Solution: The invention proposes a communications device, or "Residential Communications Gateway," that aggregates multiple communication paths, such as POTS lines and wireless connections, into a single, higher-bandwidth logical connection. This is achieved through a "multilink PPP bundle" which allows data to be split and transferred across the different paths simultaneously, effectively combining their individual capacities (US 10,868,908 B2, col. 11:12-24; Fig. 7).
  • Technical Importance: The technology provided a method to increase data throughput and connection reliability by bonding multiple lower-speed connections, a key strategy for enhancing internet performance before the widespread availability of single-line high-speed broadband (US 10,868,908 B2, col. 1:43-51).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claims 1 and 8 (Compl. ¶ 45, 52).
  • Independent Claim 1 (Server for multilink communication) includes these essential elements:
    • At least one server network interface.
    • One or more processors configured to:
    • Receive a first multilink packet with a request for multilink communication and information about a first network interface of a device.
    • Send a data packet including a multilink session identification to the device's first interface.
    • Receive a second multilink packet with the session identification and information about a second network interface of the device.
    • Send different groups of data packets to both the first and second network interfaces of the device.
  • Independent Claim 8 (Server for multilink communication) includes these essential elements:
    • At least one server network interface.
    • One or more processors configured to:
    • Receive one or more multilink packets with information about multiple network communication interfaces of a second device.
    • Split data from a data source into different groups of data packets during a multilink session.
    • Control a data server to send the different groups of data packets to the different network communication interfaces of the second device.
  • The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶ 60).

U.S. Patent No. 11,418,641 - "Devices and methods for multipath communications"

  • Patent Identification: U.S. Patent No. 11,418,641, "Devices and methods for multipath communications," issued August 16, 2022.

The Invention Explained

  • Problem Addressed: Similar to the '908 Patent, this patent addresses the need to overcome the bandwidth limitations of single communication links by aggregating multiple paths (US 11,418,641 B2, col. 1:24-42).
  • The Patented Solution: The invention describes a method for a communications device to increase its data bandwidth by establishing a "multilink connection." This involves sending a request to a remote communications device for it to participate, receiving packets from that remote device over a separate path, and aggregating the data from the original connection and the new path (US 11,418,641 B2, col. 17:1-20). The patent discloses using this method to aggregate bandwidth from multiple remote devices, potentially coordinated through a central office or server (US 11,418,641 B2, Fig. 8).
  • Technical Importance: This approach provides a framework for dynamically creating and managing higher-bandwidth connections by leveraging available capacity from multiple network endpoints, enabling more robust data-intensive applications like video streaming (US 11,418,641 B2, col. 2:1-4).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶ 65).
  • Independent Claim 1 (Method for increasing bandwidth) includes these essential elements:
    • A first device sending a multilink request to a second device to join a multilink connection.
    • The first device being connected to a first network via the second device.
    • The first device being connected to a second network via a third device.
    • When the multilink request is accepted, the first device concurrently receives first data from the first network and second data over a wireless connection from the third device.
  • The complaint reserves the right to assert additional claims (Compl. ¶ 75).

U.S. Patent No. 11,582,343 - "Devices and methods for multipath communications"

  • Patent Identification: U.S. Patent No. 11,582,343, "Devices and methods for multipath communications," issued February 14, 2023.
  • Technology Synopsis: This patent, part of the same family, also discloses methods for broadband communication over multiple paths. It focuses on a communications device that establishes connections to first and second networks via distinct devices and concurrently receives data from both to achieve an aggregated bandwidth (US 11,582,343 B2, col. 17:1-20).
  • Asserted Claims: The complaint asserts infringement of at least independent claim 12 (Compl. ¶ 81).
  • Accused Features: The complaint alleges that Defendant’s 5G network components, by managing multi-access PDU sessions according to the 3GPP TS 23.501 standard, infringe the '343 patent (Compl. ¶¶ 82-88).

III. The Accused Instrumentality

Product Identification

  • Defendant’s 5G System (5GS) network infrastructure and services (Compl. ¶ 2).

Functionality and Market Context

  • The complaint alleges that the accused instrumentality operates in compliance with the 3GPP Technical Specification (TS) 23.501 for the 5G System architecture (Compl., Ex. DD). Specifically, the complaint identifies the support for Access Traffic Steering, Switching, and Splitting (ATSSS) and Multi-Access PDU (MA PDU) Sessions as infringing functionalities (Compl. ¶ 30). These features allow a user device (UE) to establish and maintain a single communication session simultaneously over both a 3GPP access network (e.g., 5G cellular) and a non-3GPP access network (e.g., Wi-Fi) (3GPP TS 23.501, 5.32.1).
  • The 5G Core Network, through functions like the Session Management Function (SMF) and User Plane Function (UPF), manages these MA PDU sessions. This includes establishing user plane resources on both access networks and applying rules to steer, switch, or split data traffic across the two paths to optimize performance and maintain session continuity (3GPP TS 23.501, 5.32, 5.32.2). The complaint includes Figure 4.2.10-1 from the standard, which depicts a non-roaming architecture for ATSSS support (Compl. ¶ 31; 3GPP TS 23.501, Fig. 4.2.10-1).
  • The complaint asserts that ATSSS is a commercially important feature of modern 5G networks, marketed as providing enhanced reliability and seamless connectivity for end-users (Compl. ¶ 32).

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,868,908 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A server for multilink communication with a device... The 5G Core Network, including the Session Management Function (SMF) and associated network functions, which manages Multi-Access PDU Sessions for a UE. ¶46 col. 6:30-35
receive a first multilink packet...comprised of a request for a multilink communication and first information associated with first network communication interface of the device... The SMF receives a PDU Session Establishment Request from the UE, indicating a "MA PDU Request" and information related to the first access network (e.g., 3GPP access). ¶47 col. 6:36-41
sending a data packet including the multilink session identification to the first network communication interface of the device; The SMF responds to the UE, establishing the MA PDU Session and assigning a unique PDU Session ID, which serves as the multilink session identification. ¶48 col. 6:42-45
receive a second multilink packet...comprised of the multilink session identification and second information associated with a second network communication interface of the device... The SMF receives subsequent signaling from the UE to establish user-plane resources on the second access network (e.g., non-3GPP access) for the same MA PDU Session, identified by the PDU Session ID. ¶49 col. 6:46-51
send different groups of data packets...to the first network communication interface of the device and to the second network communication interface of the device... The User Plane Function (UPF), under control of the SMF, splits downlink traffic for the MA PDU Session and forwards different packets to the UE over both the 3GPP and non-3GPP access network paths simultaneously. ¶50 col. 6:52-58
  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the term "server" as used in the patent, which illustrates a "Class 5 Office" and modem bank architecture, can be construed to read on the distributed, service-based architecture of the 5G Core, specifically the SMF and UPF network functions. Similarly, a dispute may arise over whether control plane signaling messages in the 5G system, such as a PDU Session Establishment Request, constitute the "multilink packets" contemplated by the patent.
    • Technical Questions: The infringement analysis may raise the question of whether the sequence of events in establishing an ATSSS session precisely matches the step-by-step process recited in Claim 1. For instance, what evidence does the complaint provide that establishing resources on the second access path constitutes "receiving a second multilink packet" from the device, as opposed to a network-initiated procedure?

V. Key Claim Terms for Construction

  • The Term: "multilink packet"

  • Context and Importance: This term appears in the steps for establishing the multi-path connection in claim 1 of the '908 patent. The Plaintiff's infringement theory appears to depend on mapping this term to 5G network signaling messages. Practitioners may focus on this term because its construction will determine whether the claim's specific sequence of receiving request packets applies to the accused 5G session establishment procedures.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification does not appear to provide an explicit definition of "multilink packet," which may support an argument for giving the term its plain and ordinary meaning in the context of a request to establish a multi-path communication link.
    • Evidence for a Narrower Interpretation: The patent repeatedly references and illustrates a "MULTILINK PPP BUNDLE" (US 10,868,908 B2, Fig. 7; col. 11:18-20). A defendant may argue this context limits the scope of "multilink packet" to packets specifically used in establishing a Point-to-Point Protocol (PPP) multilink session, which is distinct from the NAS signaling used in 5G.

  • The Term: "server"

  • Context and Importance: The asserted claims are directed to a "server." The infringement case requires mapping this element to the accused 5G Core Network functions. The definition of "server" will be critical to determining if the claims read on a modern, disaggregated network architecture.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent describes the server-side functionality in terms of its role in a client-server relationship (e.g., receiving requests, sending data) without necessarily limiting its physical architecture (US 10,868,908 B2, col. 11:4-14). This could support a construction covering any network-side entity or collection of entities that performs the claimed functions.
    • Evidence for a Narrower Interpretation: The embodiments and figures refer to "Softswitch, SIP proxy server and registrar" and a "Class 5 Office," which were specific, more centralized hardware and software configurations at the time of invention (US 10,868,908 B2, Fig. 2). A defendant may argue these examples imply a more traditional, monolithic server structure than the distributed SMF/UPF functions in a 5G network.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant encourages and instructs its customers and partners to use the infringing ATSSS functionalities of its 5G network through marketing materials, technical documentation, and user guides (Compl. ¶ 92). It is also alleged that Defendant contributes to infringement by providing the core network infrastructure (e.g., SMF and UPF) that is a material part of the invention and not a staple article of commerce (Compl. ¶ 95).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents-in-suit. This knowledge is asserted based on Defendant's position as a major implementer of telecommunications standards and its presumed awareness of the foundational patent landscape in multipath communications, as well as actual notice provided by the filing of this lawsuit (Compl. ¶¶ 98-99).

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

  • A core issue will be one of definitional scope: can terms from the patent's early-2000s technological context, such as "server" and "multilink packet" (conceived in a world of dial-up modems and PPP), be construed broadly enough to cover the architecturally distinct and functionally disaggregated components of a modern 5G Core network, like the SMF/UPF and their associated NAS signaling protocols?
  • A key evidentiary question will be one of operational equivalence: does the standardized 5G procedure for establishing a Multi-Access PDU Session—which involves complex interactions between the UE, RAN, AMF, and SMF—perform substantially the same steps, in substantially the same way, as the specific sequence of receiving and sending packets recited in the asserted claims, or are there fundamental differences in the technical operation?
  • A third question will revolve around priority and obviousness: given the long history of the patent family dating back to 2002, the court will likely need to examine whether the asserted claims are entitled to the early priority date and, if so, whether the accused 5G standard functionalities represent non-obvious advancements over prior art that existed at that time.