Kaleasy Tech LLC v. Avaya Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kaleasy Tech LLC (Texas)
  • Defendant: Avaya Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:19-cv-01170, D. Del., 06/23/2019
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and maintains a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Avaya Equinox Meetings system infringes a patent related to methods for aggregating and distributing user presence information within a communication group.
• Technical Context: The technology concerns unified communications systems, specifically the consolidation of individual user status information (e.g., "available," "busy") with group-level data for efficient distribution to group members.
• Key Procedural History: The complaint notes that Plaintiff is the current owner of the patent-in-suit, having acquired it from a previous assignee. No other significant procedural history is mentioned.

Case Timeline

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

U.S. Patent No. 7,899,479 - "METHOD, SYSTEM AND APPARATUSES FOR SHARING PRESENCE INFORMATION," issued March 1, 2011

The Invention Explained

• Problem Addressed: The patent describes a prior art inefficiency where group communication services and presence services were separate. To determine the status of all members in a group, a user would have to send individual requests to a presence server for each member, a process described as "lengthy and inconvenient." ('479 Patent, col. 1:56-65, col. 2:1-3).
• The Patented Solution: The invention proposes a centralized method to streamline this process. It describes a system where a single entity—such as a group server, a presence server, or a dedicated "presence information management apparatus"—acquires both the "basic group information" (e.g., member list, group name) and the individual "presence information" of group members. These two data types are then combined into a single "group presence information" package and sent to group members, providing a consolidated view of the group's status. ('479 Patent, Abstract; col. 4:54-56).
• Technical Importance: This method provides a more integrated approach to presence management in group-based communications, a foundational capability for modern enterprise collaboration and unified communication platforms. ('479 Patent, col. 2:65-68).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claim 3 (Compl. ¶¶13, 15). The right to assert additional claims is reserved (Compl. ¶35).
• Independent Claim 1 requires:
  • Acquiring, by one of a group server, a presence server, or a presence information management apparatus, "group presence information" that comprises both "basic group information" and "presence information" of at least one group member.
  • The "basic group information" (containing a group attribute, member list, and member attribute) comes from the group server, and the "presence information" comes from the presence server.
  • Sending the combined "group presence information" to a group member.

III. The Accused Instrumentality

Product Identification

The "Avaya Equinox Meetings" system is identified as the Accused Instrumentality (Compl. ¶17).

Functionality and Market Context

The complaint alleges the Accused Instrumentality is a system for sharing presence information, such as the status of individual team members (e.g., "available/busy/do not disturb/ away etc.") (Compl. ¶¶17-18). The system is alleged to include an "Avaya Multimedia Messaging module" acting as a group server, which stores group names and memberships, and an "Avaya Aura presence services server" acting as a presence server, which gathers individual status and identity information (Compl. ¶¶20, 22). The complaint also identifies a "conferencing server" as a group server (Compl. ¶21). The complaint does not provide detail regarding the product's market position. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference an exemplary claim chart (Exhibit B) that was not attached to the publicly filed document. The following summary is based on the narrative allegations in the complaint body.

'479 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: Claim 1 recites three distinct entities that may perform the claimed steps: a "group server", a "presence server", and a "presence information management apparatus". The complaint alleges that different components of the Avaya system, such as a "conferencing server" and an "Aura presence services server," fulfill the roles of the "group server" and "presence server" (Compl. ¶¶21, 22). A central issue may be whether the specific functions of the accused Avaya components align with the functional roles of the "group server" and "presence server" as described and defined within the patent specification ('479 Patent, col. 6:27-38).
  • Technical Questions: A key factual question may be how the accused system handles data. The claim recites "acquiring" and "sending" a singular "group presence information" object, which the patent specification suggests is formed by combining basic group data and individual presence data ('479 Patent, col. 4:54-56). The analysis may focus on whether the accused system actually creates such a combined data object before transmission, or if it provides separate data streams to a client device for subsequent assembly and display.

V. Key Claim Terms for Construction

• The Term: "group presence information"

• Context and Importance: This term defines the data object at the heart of the invention. The outcome of the case may depend on whether this term requires a specific, pre-combined data structure or can cover a looser aggregation of data.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim itself provides a definition, stating it "compris[es] basic group information and presence information of at least one group member" ('479 Patent, col. 16:1-3). A party could argue this "comprising" language does not mandate a specific format or a formal combination step prior to sending.
  • Evidence for a Narrower Interpretation: The patent's detailed description repeatedly uses the verb "combine" when describing the creation of this information. For example, a flowchart specifies a step where "The group server combines the basic group information and the presence information of the group members together" ('479 Patent, col. 4:54-56, Fig. 5). This suggests "group presence information" is a distinct entity resulting from an explicit combination process.

• The Term: "group server"

• Context and Importance: Practitioners may focus on this term because its definition is crucial for the architectural mapping of the accused system onto the claims. The complaint identifies both a "conferencing server" and a "Multimedia Messaging module" as the "group server" (Compl. ¶¶20, 21). The defense may challenge whether either component meets the patent's definition.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent teaches that the "group server" is the source of "basic group information" ('479 Patent, col. 16:4-6). This could be argued as a broad functional definition, encompassing any server component that manages group lists and attributes.
  • Evidence for a Narrower Interpretation: The specification describes specific architectures and interactions. In one embodiment, the "group server" subscribes to the "presence server" to receive presence information, and then combines it with its own basic group data ('479 Patent, col. 9:25-30, col. 9:57-64). A party could argue this defines the "group server" by its specific interactive role, not just by the data it holds.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant has had knowledge of the '479 Patent "at least as of the service of the present Complaint" (Compl. ¶30). This allegation forms the basis for a claim of post-filing willful infringement and a request for enhanced damages pursuant to 35 U.S.C. § 284 (Compl. Prayer for Relief ¶f). No pre-suit knowledge is alleged.

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

• A core issue will be one of architectural mapping: Can the complaint establish that the accused "Avaya Equinox Meetings" system, with its "conferencing server" and "Aura presence services server" components, embodies the specific "group server" and "presence server" architecture recited in the claims, or does the functionality of Avaya's components differ materially from the roles described in the patent?
• A key evidentiary question will be one of data handling and operation: Does the accused system create and transmit a single, combined "group presence information" data object as the patent's flowcharts and description appear to require, or does it operate by sending separate streams of group data and presence data to a client device for assembly, potentially falling outside the literal scope of the claims?