Lab Technology LLC v. Trimble Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Trimble Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-01233, D. Colo., 04/17/2025
• Venue Allegations: Venue is predicated on Defendant maintaining an established place of business in the District of Colorado.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe patents related to systems for delivering dynamically updated audio announcements and for automatically refreshing a device's display with context-relevant services.
• Technical Context: The patents address dynamic content delivery and context-aware user interfaces on electronic devices, technologies central to modern mobile and smart device functionality.
• Key Procedural History: Both patents-in-suit claim priority to U.S. patent applications filed in 2006. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving these patents.

Case Timeline

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

U.S. Patent No. 8,498,388 - “Method and system for announcement,” Issued July 30, 2013

The Invention Explained

• Problem Addressed: The patent describes prior art methods for receiving audio announcements—such as dialing a telephone number, listening to a radio broadcast, or navigating a website—as inefficient and lacking timeliness (’388 Patent, col. 1:22-66).
• The Patented Solution: The invention proposes a system where a device ("announcer") receives a structured "announcement package" from a server. This package contains one or more discrete "announcement items," each with its own unique "item identity." By sending a subsequent package with items that have matching identities, the system can specifically update, replace, or add to the content on the device, ensuring the announcements are current without requiring the user to manually seek them out (’388 Patent, col. 2:6-20; col. 7:25-34). Figure 2 illustrates this process of receiving a new announcement package (220) to update an existing one (200).
• Technical Importance: This architecture enables a device to receive dynamic, targeted, "pushed" audio content that can be managed and updated efficiently over a network (’388 Patent, col. 2:18-20).

Key Claims at a Glance

• The complaint asserts exemplary claims from the ’388 Patent, reserving the right to assert others (Compl. ¶12). Independent claim 1 is representative:
• Claim 1 (Method):
  • Receiving a first announcement item by a telephone, the item comprising a first item identity and first audio data.
  • Receiving a second announcement item by the telephone, the item comprising a second item identity and second audio data.
  • Determining by the telephone if the second item identity matches the first item identity.
  • In response to a match, updating the first audio data with the second audio data by the telephone.

U.S. Patent No. 9,219,982 - “Apparatus and method for automatically refreshing a display of a telephone,” Issued December 22, 2015

The Invention Explained

• Problem Addressed: Users must often navigate through multiple menus on a telephone to access a desired service. This is inefficient, particularly when users tend to access specific services at predictable times or in particular locations (’982 Patent, col. 1:31-41).
• The Patented Solution: The patent discloses a telephone that automatically adapts its user interface based on the user's context. A "function selector" in the device uses information like time of day or location to select a predefined "function" from a datastore. This "function" represents a set of commonly used services (e.g., traffic and weather in the morning), and the device automatically refreshes its screen to display these relevant services, anticipating the user's needs (’982 Patent, col. 2:31-45; col. 6:35-43).
• Technical Importance: This technology aims to create a more intelligent, context-aware user experience by proactively presenting relevant options and reducing the need for manual navigation (’982 Patent, col. 2:4-8).

Key Claims at a Glance

• The complaint asserts exemplary claims from the ’982 Patent, reserving the right to assert others (Compl. ¶21). Independent claim 1 is representative:
• Claim 1 (Apparatus):
  • A telephone comprising a display panel, a processor, and a datastore.
  • The datastore comprises at least one "function" with information relating to a current location of the telephone and a user.
  • The processor is operable to connect to a location server to obtain the current location.
  • The processor is operable to select a function from the datastore.
  • The processor is operable to refresh a screen on the display panel to include at least one communication service associated with the selected function based on the current location.

III. The Accused Instrumentality

• Product Identification: The complaint does not identify specific products by name. It refers generally to "Exemplary Defendant Products" that are purportedly detailed in claim chart exhibits not attached to the complaint itself (Compl. ¶12, ¶21).
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. It makes only conclusory allegations that these products practice the technology claimed by the patents-in-suit (Compl. ¶17, ¶26).

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating by reference claim charts from Exhibits 3 and 4, which were not provided with the filed complaint (Compl. ¶18, ¶27). As such, a detailed claim-chart analysis is not possible. The narrative infringement theories are summarized below.

No probative visual evidence provided in complaint.

• ’388 Patent Infringement Allegations: The complaint alleges that the "Exemplary Defendant Products" directly infringe the ’388 Patent by practicing the claimed technology (Compl. ¶17). The core of this theory, inferred from the patent's focus, is that the accused products receive and process structured data packages containing discrete, identifiable items, and that they update their content based on matching identifiers in subsequently received packages.
• ’982 Patent Infringement Allegations: The complaint alleges that the "Exemplary Defendant Products" directly infringe the ’982 Patent by practicing the claimed technology (Compl. ¶26). The implicit theory is that the accused products contain a feature that automatically changes or refreshes the user interface to display a set of services based on contextual information, such as the device's location.
• Identified Points of Contention:
  • Technical Questions: A primary factual question for both patents will be whether the internal software architecture and data-handling methods of the accused products operate in the specific manner required by the claims. For the ’388 Patent, this involves how data is structured, identified, and updated. For the ’982 Patent, this involves whether UI changes are driven by a "function selector" retrieving a predefined "function" from a "datastore" based on location, as claimed.
  • Scope Questions: For the ’982 Patent, the litigation may focus on the scope of the term "function". A question for the court may be whether a dynamic list of suggested applications or shortcuts, if present in the accused products, constitutes a "function" as described and claimed in the patent.

V. Key Claim Terms for Construction

• Term from ’388 Patent: "updating the first audio data with the second audio data" (Claim 1)

  • Context and Importance: This phrase defines the core infringing act of modifying content. The scope of "updating" is central to whether the accused product's behavior meets the claim limitation. Practitioners may focus on this term to determine if it requires a direct one-to-one replacement or if it can encompass broader actions like appending or deleting.
  • Intrinsic Evidence for a Broader Interpretation: The specification suggests "update" is a broad concept, stating that the "content of the announcement package can be replaced, deleted, or added" (’388 Patent, col. 2:16-17).
  • Intrinsic Evidence for a Narrower Interpretation: The claim language itself—"updating the first audio data with the second audio data"—could be argued to mean a direct substitution. Furthermore, dependent claim 3 explicitly recites "adding... a new announcement item," suggesting that the term "updating" in independent claim 1 may have been intended to mean something other than "adding."

• Term from ’982 Patent: "function" (Claim 1)

  • Context and Importance: This term is the conceptual linchpin of the asserted claim, defining the bundle of services that are contextually presented. The case may turn on whether the accused product's UI behavior is based on such a construct.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes a "function" in broad, role-based terms, such as "an office worker on weekday morning, a hotel guest in evenings, or a vehicle driver," suggesting a conceptual grouping of services tied to a user's context (’982 Patent, col. 4:31-35).
  • Intrinsic Evidence for a Narrower Interpretation: The specification consistently links a "function" to a "commonly used communication service" (’982 Patent, col. 4:38-40) and depicts it as a discrete, stored entity (Fig. 2, item 152; Fig. 3, items 352, 354). An accused infringer may argue that a dynamically generated list of shortcuts or a "most recently used" menu is not a pre-defined, stored "function" as required by the claim.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes both the ’388 and ’982 Patents (Compl. ¶15, ¶24).
• Willful Infringement: The complaint pleads post-filing willfulness. It alleges that the filing and service of the complaint provide Defendant with "actual knowledge" of the patents and its infringement, and that any subsequent infringement is therefore willful (Compl. ¶14, ¶16, ¶23, ¶25).

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

1. Evidentiary Sufficiency: The complaint's reliance on non-proffered exhibits creates a significant evidentiary gap at the pleading stage. A threshold question for the case is whether discovery will uncover evidence that the accused products' internal operations and data structures align with the specific mechanisms recited in the asserted claims.
2. Definitional Scope: The dispute over the ’982 Patent may turn on a question of definitional scope: can the term "function", which the patent describes as a stored entity associated with a user context, be construed to cover the specific method of UI adaptation used in the accused products?
3. Mechanism of Action: For the ’388 Patent, a key question will be one of technical mechanism: do the accused products employ a data-update protocol that relies on matching a specific "item identity" to "update" data as claimed, or do they use a more generic data synchronization method that falls outside the claim's functional requirements?