Webcon Vectors LLC v. Livestorm Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Webcon Vectors LLC (Delaware)
  • Defendant: LiveStorm Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00764, D. Del., 06/20/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant has an established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s telecommunication products infringe a patent related to methods for simplifying and automating conference calls.
• Technical Context: The technology concerns systems for initiating multi-party communications, such as conference calls, by automatically contacting participants rather than requiring them to manually dial in.
• Key Procedural History: The complaint is the initial pleading in this litigation. No prior litigation, administrative proceedings, or licensing activities are mentioned.

Case Timeline

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

U.S. Patent No. 11,290,428 - Telecommunication method and system for simplifying communication such as conference calls

The Invention Explained

• Problem Addressed: The patent's background section identifies inefficiencies in traditional teleconferencing, such as the cumbersome process of coordinating schedules, locating call-in numbers and access codes, and the potential for privacy compromises when systems automatically parse user data (Compl. ¶9; ’428 Patent, col. 1:13-31, col. 2:22-28).
• The Patented Solution: The invention describes a system where a host initiates a conference call by selecting participants' "electronic identifiers" (e.g., phone numbers, email addresses, social media handles). The system then automatically and simultaneously contacts all participants at a scheduled time and connects them to a conference bridge, eliminating the need for users to dial in manually. A key aspect is user privacy, as the system can operate without revealing a participant's contact identifier to the host or other attendees, and the user can change their designated identifier up until the time of the call (’428 Patent, Abstract; col. 4:51-64).
• Technical Importance: This system aims to reduce the logistical friction of setting up conference calls and enhance user privacy by shifting the burden of connection from the participants to a centralized, automated platform (’428 Patent, col. 4:26-34).

Key Claims at a Glance

• The complaint asserts infringement of one or more claims, including at least one independent claim (Compl. ¶11). The patent contains one independent method claim, Claim 1.
• Independent Claim 1 recites a method with the following key steps:
  • Selecting a plurality of users for simultaneous contact at a predetermined time via their electronic identifiers.
  • Collating the identifiers of all selected users.
  • Forming a conferencing bridge where each user's identifier is on the bridge in advance of contacting them, without any action from the users.
  • Simultaneously contacting the bridged identifiers at the predetermined time, absent any action by any selected user.
  • Enabling communication between the contacted users while "maintaining anonymity of the electronic identifier."
  • Precluding non-responsive users from joining the communication unless subsequently authorized.
• The complaint states that "numerous other devices that infringe the claims" may be asserted, suggesting a reservation of rights to assert dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" made, used, sold, or imported by LiveStorm Inc. (Compl. ¶11).

Functionality and Market Context

The complaint does not provide specific technical details about the accused products' operation. It alleges that these products are used for telecommunication and that they "practice the technology claimed by the '428 Patent" (Compl. ¶16). The specific products and their functionalities are detailed in claim charts attached as Exhibit 2, which was incorporated by reference but not filed with the complaint itself (Compl. ¶16-17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe the ’428 Patent but incorporates its specific infringement theories in an external exhibit not provided with the pleading (Compl. ¶16-17). As a result, a detailed element-by-element comparison is not possible based on the available document. The infringement theory is broadly that the accused products provide a teleconferencing service that satisfies all elements of the asserted claims (Compl. ¶16).

• Identified Points of Contention: Based on the language of independent Claim 1, the infringement analysis may focus on several technical and legal questions:
  • Scope Questions: A central dispute may concern the meaning of initiating contact "absent any action by any selected user." The question for the court could be whether this phrase precludes any user interaction, such as clicking an "accept" button or pressing a key to join, or if it only precludes the traditional, more burdensome actions of finding a number and dialing in with a code.
  • Technical Questions: A key factual question will be whether the accused system's architecture aligns with the claim's specific sequence of operations. For example, does the system "form a conferencing bridge where the identifier of each selected user is on said bridge" before it initiates contact, as the claim requires? Another factual issue may be how the accused system achieves the claimed "maintaining anonymity of the electronic identifier" and whether that functionality matches the patent's description.

V. Key Claim Terms for Construction

• The Term: "absent any action by any selected user"

• Context and Importance: This term appears twice in Claim 1 and is central to the invention's automated, user-passive nature. Its construction will be critical for determining infringement, as most communication systems require some minimal user response to establish a connection. Practitioners may focus on this term because its interpretation could either broadly cover modern "one-click-join" systems or be limited to systems requiring literally zero user input after the initial scheduling.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent repeatedly frames its objective as overcoming the "burden" and "colossal waste of valuable professional time" associated with traditional dial-in protocols (’428 Patent, col. 1:29-31, col. 4:51-54). A party could argue "action" should be interpreted in this context to mean the substantive steps of looking up information and manually dialing, not a simple confirmatory response.
  • Evidence for a Narrower Interpretation: The claim's use of the absolute phrase "any action" could support a very strict interpretation. Furthermore, the patent's own figures depict scenarios where a user may be prompted to respond to a notification or press a key to join a call, which could be construed as an "action" (’428 Patent, FIG. 2, steps 98, 110).

• The Term: "maintaining anonymity of the electronic identifier"

• Context and Importance: This term relates to the patent's asserted privacy benefits. The dispute will likely center on what level and type of "anonymity" are required to meet this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the goal is to prevent the host or other users from knowing a participant's direct contact details, stating "key phone numbers, i.e. cell, home, satellite never have to be known to any other user or host/moderator" (’428 Patent, col. 8:46-49). This may support an interpretation where anonymity simply means shielding the contact identifier from other human participants.
  • Evidence for a Narrower Interpretation: A party could argue this limitation requires a specific technical implementation. The specification notes that identifiers "may be scrambled by a suitable algorithm well known in the art and stored as such," suggesting that mere non-display might be insufficient and that an affirmative technical step to obscure the data is required (’428 Patent, col. 8:53-56).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct and encourage customers to use the products in a manner that infringes the ’428 Patent (Compl. ¶14-15).
• Willful Infringement: The complaint alleges that service of the complaint itself provides Defendant with "Actual Knowledge of Infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14). This forms a basis for a claim of post-filing willfulness.

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

1. A core issue will be one of definitional scope: can the claim limitation "absent any action by any selected user" be construed to read on modern teleconferencing systems that require a simple user response (e.g., a single click or key press) to join a call, or is it strictly limited to systems that require no responsive user interaction whatsoever?
2. A key evidentiary question will be one of operational correspondence: what evidence will discovery yield about the precise architecture and operating sequence of the accused products? Specifically, does the accused system pre-populate a conference bridge with user identifiers before initiating contact and technically implement a method for "maintaining anonymity" in a way that aligns with the requirements of Claim 1?