WebSock Global Strategies LLC v. Rocketchat Tech Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: Rocket.Chat Technologies Corp. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.
• Case Identification: 1:24-cv-00995, D. Del., 08/30/2024
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business in the District of Delaware and allegedly committing acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s communication products infringe a patent related to methods for achieving symmetrical, bi-directional communication over inherently asymmetrical protocols like HTTP.
• Technical Context: The technology addresses limitations in traditional client-server web protocols, aiming to enable peer-to-peer style interactions, a foundational requirement for modern real-time messaging and data-streaming applications.
• Key Procedural History: The asserted patent is a continuation of an earlier application that issued as U.S. Patent No. 7,403,995 and is subject to a terminal disclaimer. No other prior litigation or administrative proceedings are mentioned in the complaint.

Case Timeline

Date	Event
2003-01-08	'983 Patent Priority Date
2008-04-24	'983 Patent Application Filing Date
2010-07-13	'983 Patent Issue Date
2024-08-30	Complaint Filing Date

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

U.S. Patent No. 7,756,983 - "Symmetrical bi-directional communication"

• Issued: July 13, 2010

The Invention Explained

• Problem Addressed: The patent addresses the inherent asymmetry of the HyperText Transfer Protocol (HTTP), where communication is strictly limited to a client initiating a request and a server responding ('983 Patent, col. 2:10-13). This architecture prevents a server from spontaneously sending data to a client, a significant hurdle for peer-to-peer applications, especially when one node is behind a firewall or Network Address Translator (NAT) that blocks unsolicited inbound connections ('983 Patent, col. 2:45-52).
• The Patented Solution: The invention discloses a method to reverse the client and server roles over an established network connection. After an initial client-server session is created, the nodes "negotiate" a role reversal. The original HTTP session is then terminated, but the underlying network transport connection (e.g., a TCP/IP socket) is preserved. A new HTTP session is created over this preserved connection, but with the roles "flipped," allowing the original server to now act as a client and initiate requests to the original client, which now acts as a server ('983 Patent, col. 9:12-38; FIG. 9).
• Technical Importance: This approach provided a pathway to achieve stateful, peer-to-peer communication using the ubiquitous and firewall-friendly HTTP, bypassing the protocol's native client-server limitations without resorting to inefficient polling techniques ('983 Patent, col. 3:4-16, col. 3:17-24).

Key Claims at a Glance

The complaint does not identify specific asserted claims but refers to "Exemplary '983 Patent Claims" in a non-proffered exhibit (Compl. ¶11). Independent claim 1 is representative of the core invention:

• First and second network nodes engaging in an asymmetric HTTP transactional session with an underlying network connection, with each node having distinct initial roles (HTTP server or client).
• Terminating the asymmetric HTTP transactional session while maintaining the underlying network connection.
• The first and second network nodes negotiating a transactional role reversal.
• The nodes further communicating under a reversed asymmetric transactional protocol where each node enacts the initial role of the other.
• The session uses a network connection traversing hardware that enforces asymmetric communication (e.g., a NAT or firewall).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products. It refers generally to "Defendant products identified in the charts incorporated into this Count" and "Exemplary Defendant Products" (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint provides no technical description of the accused products' functionality. It makes the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '983 Patent" and "satisfy all elements of the Exemplary '983 Patent Claims" (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes one or more claims of the '983 Patent (Compl. ¶11). However, it does not provide a narrative infringement theory or include the referenced claim charts (Exhibit 2) that purportedly compare the claims to the accused products (Compl. ¶13-14). The infringement allegations are therefore entirely conclusory.

• Identified Points of Contention: Given the technology, the dispute may focus on several key technical and legal questions:
  • Technical Questions: A central factual question will be whether the accused products' communication protocol actually performs the specific sequence recited in the claims. For example, does the protocol establish an initial HTTP session, terminate it while preserving the underlying socket, and then establish a second, role-reversed session on that same socket? Modern real-time communication protocols (e.g., WebSockets) often achieve bi-directional communication through a different mechanism, such as upgrading an initial HTTP connection to a different, symmetrical protocol, which may or may not map to the patent's claimed steps.
  • Scope Questions: The interpretation of "negotiating transactional role reversal" will be critical. The court will need to determine if this requires a discrete, explicit handshake for the purpose of reversing roles, as depicted in the patent's embodiments ('983 Patent, FIG. 9, block 504), or if it can be construed more broadly to cover any protocol initiation that results in bi-directional capability.

V. Key Claim Terms for Construction

The Term: "negotiating transactional role reversal" (Claim 1)

• Context and Importance: This term is the lynchpin of the inventive concept. Its construction will determine whether the claim reads on a wide range of modern bi-directional protocols or is limited to the specific "flip" mechanism described in the patent. Practitioners may focus on this term because the defendant will likely argue its technology establishes a bi-directional channel from the outset without a distinct "reversal" step.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism of negotiation, which may support an interpretation covering any process by which two nodes agree to communicate symmetrically after an initial asymmetric connection.
  • Evidence for a Narrower Interpretation: The specification provides a detailed flowchart showing a specific "HTTP FLIP REQUEST" sent from the client to the server to initiate the reversal ('983 Patent, col. 9:60-62; FIG. 9, block 504). This specific embodiment could be used to argue that "negotiating" requires an explicit, client-initiated request to "flip" an established session, rather than a more general protocol handshake.

The Term: "terminating said asymmetric HTTP transactional session while maintaining said underlying network connection" (Claim 1)

• Context and Importance: This element defines the core technical action of the invention. The dispute will likely hinge on what constitutes "terminating" an HTTP session.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The language could be argued to cover any process where the rules of the initial, strictly asymmetric HTTP interaction cease to apply, even if some session parameters are carried over.
  • Evidence for a Narrower Interpretation: The specification describes a process where the "existing HTTP layer session" is terminated to be replaced by a "new HTTP layer session" with reversed roles, all while the "underlying TCP/IP network connection" is preserved ('983 Patent, col. 9:48-55; FIG. 9, block 512, 514). This suggests a distinct destruction and recreation of the application-layer session, not merely a modification of its state.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific factual allegations to support claims of induced or contributory infringement, such as knowledge of the patent and specific intent to encourage infringement by customers. It makes a passing reference to infringement by customers (Compl. ¶11).
• Willful Infringement: The complaint does not allege willful infringement. While the prayer for relief requests a declaration that the case is "exceptional" for the purpose of recovering attorneys' fees, it does not plead the facts typically associated with a willfulness claim, such as pre-suit knowledge of the patent and objectively reckless conduct (Compl. Prayer ¶ E.i).

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

1. A Core Evidentiary Question: The primary issue will be factual: Does the accused product's communication protocol operate in the manner specifically claimed by the '983 Patent? The case will depend on evidence showing whether the accused system performs the discrete steps of creating an initial HTTP session, explicitly terminating only that session while preserving the underlying connection, and then creating a new, role-reversed session on the preserved connection.
2. A Definitional Scope Question: The outcome will likely turn on claim construction, particularly the meaning of "negotiating transactional role reversal." The central question for the court will be whether this phrase is limited to the explicit "flip request" mechanism shown in the patent's detailed description or if it can be interpreted more broadly to encompass modern protocol handshakes (like a WebSocket upgrade) that establish bi-directional communication channels.
3. A Question of Pleading Sufficiency: The complaint's lack of specific factual allegations mapping product features to claim elements, and its reliance on an unfiled exhibit, may itself become an early focus of the litigation through a motion to dismiss.