DCT

1:25-cv-00763

Webcon Vectors LLC v. IntermediaNET Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00763, D. Del., 06/20/2025
  • Venue Allegations: Venue is asserted in the District of Delaware on the basis that Defendant is incorporated in Delaware and maintains an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s telecommunication products and services infringe two patents related to methods for simplifying and automating conference calls by bridging disparate communication platforms and automatically contacting participants.
  • Technical Context: The technology addresses perennial challenges in unified communications, specifically the logistical complexity and user friction involved in scheduling and joining multi-party conference calls across different services.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

I.I. Case Timeline

Date Event
2016-05-18 '428 Patent Priority Date
2017-05-13 '218 Patent Priority Date
2020-06-09 U.S. Patent No. 10,681,218 Issued
2022-03-29 U.S. Patent No. 11,290,428 Issued
2025-06-20 Complaint Filed

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

II.I. U.S. Patent No. 10,681,218: "Telecommunication method and system for simplifying communication such as conference calls" (Issued Jun. 9, 2020)

  • The Invention Explained:
    • Problem Addressed: The patent's background describes the logistical burdens of conventional teleconferencing, such as the difficulty of coordinating schedules among multiple invitees, the need to sift through emails to find call-in details, the high cost of multi-country calls, and the risk of meetings being derailed by technically unprepared attendees (ʼ218 Patent, col. 1:23-65).
    • The Patented Solution: The invention proposes a system that amalgamates disparate communication platforms (e.g., PSTN, SIP, various web conferencing services) to simplify conference calling (ʼ218 Patent, Abstract). It uses a user's unique "electronic identifier" (such as a phone number or website address) to automatically contact participants, bridging them into a unified call without requiring them to dial in manually. The system is designed to create a bridge between a first conferencing platform and a second, different platform, unifying users from both into a single session (ʼ218 Patent, col. 8:24-57; Claim 1).
    • Technical Importance: This approach seeks to reduce user friction and abstract away the technical differences between underlying communication services, creating a more seamless and automated user experience.
  • Key Claims at a Glance:
    • The complaint asserts "exemplary claims" without specifying them, but independent claim 1 is central to the invention described. (Compl. ¶12).
    • Independent Claim 1 recites a method comprising the key steps of:
      • Providing a first and a second conferencing and scheduling platform.
      • Selecting first users on the first platform for simultaneous contact using their "identifier."
      • Identifying second, pre-existing users on the second platform.
      • Providing and creating a "bridge" to link the first and second users.
      • Simultaneously contacting all "bridged users" based on their identifier at a scheduled time.
      • Effecting these steps "in the absence of any action by said users." (ʼ218 Patent, col. 15:21-col. 16:29).
    • The complaint does not explicitly reserve the right to assert dependent claims but refers to infringing "one or more claims." (Compl. ¶12).

II.II. U.S. Patent No. 11,290,428: "Telecommunication method and system for simplifying communication such as conference calls" (Issued Mar. 29, 2022)

  • The Invention Explained:
    • Problem Addressed: The patent addresses the same set of problems as the ʼ218 Patent, including the inconvenience and inefficiency of manually coordinating and joining conference calls (ʼ428 Patent, col. 1:13-col. 2:55).
    • The Patented Solution: This invention details a method focused on automating the initiation and management of a conference call entirely from the system side. The method involves selecting users, collating their identifiers, forming a conference bridge, and automatically contacting them at a predetermined time "absent any action by any selected user." A key feature is managing participation by "enabling communication" based on the "response of each selected user" and "precluding contacted nonresponsive selected users." (ʼ428 Patent, Abstract; Claim 1).
    • Technical Importance: This method aims to shift the burden of initiating and managing conference call connections entirely from the end-user to the automated system, offering a significant convenience and efficiency improvement.
  • Key Claims at a Glance:
    • The complaint asserts "exemplary claims" without specifying them; independent claim 1 appears representative of the core invention. (Compl. ¶21).
    • Independent Claim 1 recites a method comprising the key steps of:
      • Selecting users for simultaneous contact at a predetermined time using their identifier.
      • Collating the identifiers and forming a conferencing bridge.
      • Simultaneously contacting the users "absent any action by any selected user."
      • Enabling communication as a group based on the "response of each selected user."
      • Precluding non-responsive users from the communication unless later authorized. (ʼ428 Patent, col. 13:35-col. 14:13).
    • The complaint refers to infringing "one or more claims" of the '428 Patent. (Compl. ¶21).

III. The Accused Instrumentality

  • Product Identification: The complaint does not identify the accused instrumentalities by specific product or service names. It refers to them as "Exemplary Defendant Products" (Compl. ¶12, ¶21). The specific identification is allegedly contained in Exhibits 3 and 4, which were incorporated by reference but not included with the public filing of the complaint (Compl. ¶17-18, ¶26-27).
  • Functionality and Market Context: The complaint alleges the accused products are telecommunication systems that provide conference call functionality (Compl. ¶12, ¶21). However, it does not provide sufficient detail for an independent analysis of the specific technical functionality, operation, or market positioning of the accused products. This information is purportedly detailed in the non-provided exhibits.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart exhibits (Exhibits 3 and 4) that were not provided with the available court filing. The complaint asserts that these charts demonstrate how the "Exemplary Defendant Products" practice the technology claimed in the patents-in-suit (Compl. ¶17, ¶26). Without these exhibits, a detailed element-by-element analysis is not possible.

Based on the complaint's narrative, the infringement theory for the '218 Patent appears to be that the Defendant's system provides and bridges at least two distinct conferencing platforms, automatically identifies and contacts users across these platforms using their electronic identifiers, and does so at a scheduled time without requiring action from the end-users, thereby meeting the limitations of at least Claim 1 (Compl. ¶12, ¶17-18).

The infringement theory for the '428 Patent appears to be that the Defendant's system automatically contacts users at a scheduled time, manages their participation based on whether they "respond" to the contact, and precludes those who do not respond, thereby infringing at least Claim 1 (Compl. ¶21, ¶26-27).

  • Identified Points of Contention:
    • Scope Questions: A primary issue for the '218 Patent may be whether the accused system architecturally constitutes the "bridging" of two distinct "conferencing and scheduling platforms", or if it functions as a single, integrated platform that interoperates with other services. For the '428 Patent, a question is how the term "response of each selected user" will be construed and whether the accused system's method for joining a user to a call meets that definition.
    • Technical Questions: A key technical question for both patents is what evidence will be required to show that the system effectuates contact "in the absence of any action by said users." Further, for the '428 Patent, the precise mechanism by which the accused system "preclud[es] contacted nonresponsive selected users" will be a focus, and whether this mechanism aligns with the functionality required by the claim.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

V.I. U.S. Patent No. 10,681,218

  • The Term: "in the absence of any action by said users" (Claim 1)
  • Context and Importance: This limitation is central to the patent's asserted value proposition of full automation. The infringement analysis may turn on whether the routine operation of the accused product requires any "action" (e.g., a click, a key press) from the user to join a call.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's general theme of removing user burdens, such as "checking contact information, awaiting responses, dealing with tardy respondents," may support a construction where minor, reflexive user inputs do not constitute "action" in the sense precluded by the claim (ʼ218 Patent, col. 4:56-62).
    • Evidence for a Narrower Interpretation: The prosecution history of the patent family, which includes flowcharts with specific user decision points (e.g., responding to a prompt), could be used to argue for a stricter, more literal interpretation of "absence of any action" (ʼ218 Patent, FIG. 2, step 98).

V.II. U.S. Patent No. 11,290,428

  • The Term: "response of each selected user" (Claim 1)
  • Context and Importance: This term defines the trigger for "enabling communication" within the group. The definition is critical, as it determines the infringing act. Practitioners may focus on this term because its ambiguity creates a potential point of dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification lacks a specific definition, which may support a broad construction where merely answering an automated call constitutes a "response." The patent's goal is to simplify communication, suggesting a low bar for what qualifies as a response.
    • Evidence for a Narrower Interpretation: A defendant could argue the term implies a more affirmative confirmation beyond simply answering a call, potentially pointing to related family members like the '218 Patent that describe more explicit user interactions as evidence of the technology's context (ʼ218 Patent, FIG. 2).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct and encourage end users to operate the accused products in a manner that directly infringes the patents-in-suit (Compl. ¶15-16, ¶24-25).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringing conduct after receiving "Actual Knowledge" of the patents and its alleged infringement via the service of the complaint and its attached claim charts (Compl. ¶14-15, ¶23-24).

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

  1. Definitional Scope: A central issue will be the construction of key claim phrases such as "in the absence of any action by said users" and "response of each selected user." The outcome will likely depend on whether the ordinary operation of Defendant's system, which may involve some minimal user interaction to connect, falls within the patent's highly automated framework.

  2. Architectural Equivalence: A key evidentiary question, particularly for the '218 Patent, will be whether the Defendant's system architecture constitutes the "bridging" of two distinct "platforms" as claimed, or if it functions as a single, unified system that merely interoperates with other services. The analysis will focus on the structural and functional mapping between the accused system and the specific multi-platform configuration described in the patent.

  3. Sufficiency of Evidence: As the complaint relies entirely on non-public exhibits to identify the accused products and map their functions to the patent claims, a threshold issue for the court will be whether the evidence presented in those exhibits, once produced in discovery, is sufficient to support the infringement allegations for each asserted claim element.