ReadyComm LLC v. Zoom Communications Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ReadyComm LLC (New Mexico)
  • Defendant: Zoom Communications Video, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-2606, D. Colo., 08/20/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Colorado because Defendant maintains an established place of business in the district and has committed the alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a communication system that manages a group of telephone devices by designating one as "active" for making and receiving calls while the others remain in a "stand-by" mode.
• Technical Context: The technology addresses the management of multiple communication devices (e.g., landline, cellular, computer) associated with a single user or group, aiming to unify communications and allow seamless redirection of calls between devices.
• Key Procedural History: The patent-in-suit is a continuation-in-part of a prior application, which establishes an earlier priority date. The complaint does not mention any other prior litigation, licensing history, or post-grant proceedings involving the patent.

Case Timeline

Date	Event
2008-06-24	’011 Patent Priority Date
2015-11-03	’011 Patent Issue Date
2025-08-20	Complaint Filing Date

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

U.S. Patent No. 9,179,011 - Telephone Communication System and Method of Using

• Patent Identification: U.S. Patent No. 9,179,011, “Telephone Communication System and Method of Using,” issued November 3, 2015 (’011 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the increasing difficulty of contacting a person who uses multiple communication devices, such as a home phone, mobile phone, and office phone (Compl. Ex. 1, ’011 Patent, col. 1:22-32). It notes that conventional solutions like call forwarding are complicated, often require each device to have a unique 10-digit number, and contribute to the exhaustion of available phone numbers (Compl. Ex. 1, ’011 Patent, col. 1:45-54; col. 2:5-15).
• The Patented Solution: The invention proposes a system where a group of telephone devices are linked. At any given time, only one device is in "active mode," capable of making or receiving calls, while the other devices are in "stand-by mode," where they cannot make or receive calls (Compl. Ex. 1, ’011 Patent, col. 2:58-64). A core feature is a "switch" that allows a user to change which device is active, enabling "on-the-fly redirection" of a call from one device to another (e.g., from a landline to a cellular phone) (Compl. Ex. 1, ’011 Patent, col. 5:1-6; col. 4:35-47).
• Technical Importance: This approach seeks to provide a unified communication identity for a user across multiple devices, simplifying how others can reach them while allowing the user flexibility in choosing which device to use for a call (Compl. Ex. 1, ’011 Patent, col. 2:38-44).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying which ones, instead referring to an incorporated but unattached exhibit (Compl. ¶11; ¶16). Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • A telephone communication system comprising a group of at least two telephones.
  • Each telephone is configured to be placed in either an "activated mode" or a "stand-by mode."
  • A telephone in "stand-by mode" is "incapable of placing or receiving a call unless switched to active mode."
  • Each telephone is associated with a "switch."
  • The switch is configured to activate one telephone, which places all other (N-1) telephones in "standby mode."
  • At least one stand-by telephone is configured to be switched to active mode "during a telephone call."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific products by name. It refers generally to "Exemplary Defendant Products" that are purportedly detailed in claim charts incorporated as Exhibit 2, which was not filed with the complaint (Compl. ¶11; ¶16).

Functionality and Market Context

The complaint does not provide any description of the functionality of the accused products. It makes the conclusory allegation that the products "practice the technology claimed by the '011 Patent" (Compl. ¶16). No information is provided regarding the products' market positioning or commercial importance.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided with the public filing (Compl. ¶17). Therefore, a detailed claim chart summary cannot be constructed. The complaint’s narrative theory of infringement is limited to the assertion that the unspecified "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent’s claims and the general nature of the defendant's business in unified communications, several points of contention may arise.
  • Scope Questions: A primary question may be whether the term "telephone," as used in the patent, can be construed to read on software-based communication clients (e.g., a desktop application and a mobile app) logged into the same user account. The patent’s specification frequently refers to distinct hardware like "landline telephone" and "cellular telephone" (Compl. Ex. 1, ’011 Patent, col. 6:3-5), which may suggest a narrower scope than that required to cover modern VoIP systems.
  • Technical Questions: A key technical dispute may center on whether the accused products implement the specific "active mode" / "stand-by mode" architecture required by the claims. Specifically, the analysis may focus on whether an accused device in a purported "stand-by mode" is truly "incapable of placing or receiving a call." If multiple clients logged into the same account can simultaneously receive an incoming call notification and provide the user an option to answer on any of them, this may not align with the claimed system where only one device is active and the others are disabled from receiving the call.

V. Key Claim Terms for Construction

The Term: "telephone"

• Context and Importance: The construction of this term is central to the scope of the patent. If limited to traditional telephony hardware, the patent may not cover software-based VoIP platforms. Practitioners may focus on this term to determine if the patent applies to the accused technology at all.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a telephone device can be a "computer, car telephone, etc. and equivalents thereof," which could support an argument that software clients are included (Compl. Ex. 1, ’011 Patent, col. 4:26-29).
  • Evidence for a Narrower Interpretation: The background and examples in the patent are heavily grounded in the context of traditional devices like "landline telephone" and "cellular telephone," each with its own 10-digit calling number or Electronic Serial Number (ESN) (Compl. Ex. 1, ’011 Patent, col. 1:25-28; col. 6:3-10). This context could support a narrower definition tied to conventional telephony networks.

The Term: "stand-by mode such that in stand-by mode a telephone is incapable of placing or receiving a call"

• Context and Importance: This term defines a critical functional limitation of the claimed system. The infringement analysis will depend heavily on whether the accused system places devices in a state that meets this "incapable" requirement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue that "incapable of... receiving a call" means only that the final audio/video stream cannot be established on that device, even if an initial notification is received.
  • Evidence for a Narrower Interpretation: The patent states that "A phone in standby mode cannot make or receive calls" (Compl. Ex. 1, ’011 Patent, col. 2:63-64). This absolute language could be interpreted to mean the device is completely disabled from participating in the call process, including receiving an actionable notification. If a "stand-by" device can still alert the user to a call and allow them to answer it, it may not be "incapable."

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users" to use the accused products in an infringing manner (Compl. ¶14).

Willful Infringement

The willfulness allegation is based on post-suit conduct. The complaint asserts that Defendant gained "actual knowledge of infringement" upon service of the complaint and that its continued infringement thereafter is willful (Compl. ¶13; ¶15).

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

• A core issue will be one of definitional scope: can the term "telephone," rooted in the patent's context of distinct hardware devices on traditional networks, be construed to cover software clients operating as part of a modern, unified communications platform?
• A key evidentiary question will be one of technical functionality: does the accused system's architecture map to the patent's strict "active/stand-by" model? The case may turn on whether the accused products render non-active devices truly "incapable" of receiving a call, as claimed, or if they employ a different, simultaneous-access model for managing multiple user endpoints.