Lab Technology LLC v. Greenlight Financial Technology Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Greenlight Financial Technology, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01356, D. Del., 11/06/2025
• Venue Allegations: Venue is asserted based on Defendant’s incorporation in Delaware and its established place of business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to methods for automatically refreshing a telephone's display with relevant communication services based on contextual information such as the user's location or the time of day.
• Technical Context: The technology addresses context-aware computing, where a device’s user interface dynamically adapts to present services or information relevant to a user’s current situation, a common feature in modern mobile applications.
• Key Procedural History: The patent-in-suit is a continuation of prior applications, with the earliest priority date extending back to 2006, which may be relevant to assessing the scope of the claims against the backdrop of technology from that era. The complaint does not mention any prior litigation or administrative proceedings involving the patent.

Case Timeline

Date	Event
2006-06-22	U.S. Patent No. 9,219,982 Priority Date
2015-12-22	U.S. Patent No. 9,219,982 Issues
2025-11-06	Complaint Filed

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

U.S. Patent No. 9,219,982 - "Apparatus and method for automatically refreshing a display of a telephone," Issued December 22, 2015

The Invention Explained

• Problem Addressed: The patent background describes the inefficiency users face when navigating through numerous menu displays on a telephone to find a desired service, particularly when they frequently access the same services at specific times or in certain locations (U.S. Patent No. 9,219,982, col. 1:29-41).
• The Patented Solution: The invention proposes a telephone that automatically updates its display to present commonly used communication services tailored to the user's current context. This is achieved through a "function" that represents a set of conditions (e.g., "office worker on weekday morning") and is associated with relevant services (’982 Patent, Abstract; col. 4:31-37). A "function selector" module uses contextual information, such as time from a clock or data from a location server, to select the appropriate function from a datastore and refresh the screen accordingly (’982 Patent, col. 6:6-19; Fig. 4-5).
• Technical Importance: This technology aimed to provide a more intuitive and efficient user interface by proactively anticipating user needs based on context, reducing the number of manual steps required to access services (’982 Patent, col. 2:4-9).

Key Claims at a Glance

The complaint does not specify which claims are asserted in its main body, instead referring to "Exemplary '982 Patent Claims" detailed in an attached exhibit that was not provided (Compl. ¶11, 16). For analytical purposes, independent claim 1 is presented below.

• Independent Claim 1:
  • A telephone comprising a display panel, a processor, and a datastore;
  • the datastore comprising at least one function with information relating to a current location of the telephone and a user;
  • the telephone being operable to connect to a communication network and the function being associated with at least one communication service;
  • wherein the processor is operable to connect to a location server to obtain a current location;
  • select a function from the datastore;
  • and refresh the screen to include the communication service associated with the selected function, based at least in part on the current location.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific products by name, referring only to "Exemplary Defendant Products" that are allegedly detailed in an unprovided claim chart exhibit (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market position. It alleges generally that the products "practice the technology claimed by the '982 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges infringement but incorporates its detailed theory by reference to an external exhibit, Exhibit 2, which was not provided (Compl. ¶16-17). The complaint asserts that these charts demonstrate that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). Without the referenced exhibit, a detailed claim chart summary cannot be constructed. No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the claim language and the general nature of the allegations, several points of contention may arise during litigation.

• Scope Questions: A potential issue is whether a software application running on a general-purpose smartphone can be considered a "telephone" in the manner claimed by the patent, which depicts the system in block diagrams as a self-contained apparatus (’982 Patent, Fig. 3, 4, 5).
• Technical Questions: The complaint's allegations raise the question of what specific software component within the accused products performs the role of the claimed "function selector" that actively "select[s] a function from the datastore" (’982 Patent, col. 8:32-33). A dispute may focus on whether the accused products perform this discrete selection step or use a different architecture for contextualizing the user interface.

V. Key Claim Terms for Construction

The Term: "function"

• Context and Importance: This term is central to the invention's logic, defining the link between a user's context and the services displayed. Its construction will likely dictate the breadth of the patent's coverage over different types of contextual triggers.
• Intrinsic Evidence for a Broader Interpretation: The specification defines a "function" broadly as representing "a given set of conditions associated with a user," including "variable, such as time, location, activity or the like," which could support an interpretation covering a wide range of dynamic user states (’982 Patent, col. 4:31-34).
• Intrinsic Evidence for a Narrower Interpretation: The patent primarily illustrates "functions" with discrete, role-based examples like "an office worker on weekday morning," "a hotel guest in evenings," or "a vehicle driver" (’982 Patent, col. 4:35-37). This language may support a narrower construction requiring a predefined user profile rather than a mere transient condition.

The Term: "function selector"

• Context and Importance: This is the active agent in the claimed invention, responsible for processing context and choosing the appropriate function. Infringement analysis may depend on whether the accused products have an identifiable module that meets the definition of this term.
• Intrinsic Evidence for a Broader Interpretation: The patent describes the "function selector" as "preferably a program or programming logic that selects a function based on information, such as time... or location," which could be read to encompass any software code that performs this task (’982 Patent, col. 6:6-9).
• Intrinsic Evidence for a Narrower Interpretation: The patent’s figures depict the "Function Selector" as a distinct architectural block within the telephone that connects to other components like a datastore and a clock or location server (’982 Patent, Fig. 3-5). This could support an argument that the term requires a discrete, modular software component, not merely diffuse logic within a larger application.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that the Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’982 Patent (Compl. ¶14-15).

Willful Infringement

The complaint does not use the term "willful," but it alleges that service of the complaint provides Defendant with "Actual Knowledge of Infringement" and that Defendant continues its allegedly infringing conduct despite this knowledge (Compl. ¶13-14). These allegations could form the basis for a claim of post-suit willful infringement.

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

• A core issue will be one of claim scope and evolving technology: can the term "telephone" and its associated components, as described in a patent with a 2006 priority date, be construed to read on a modern software application operating within the ecosystem of a general-purpose smartphone? The outcome may depend on whether the accused architecture is fundamentally different from the distinct "function selector" and "datastore" structure claimed in the patent.
• A key evidentiary question will be one of factual sufficiency: given the complaint's reliance on an unprovided exhibit, a central challenge for the plaintiff will be to produce concrete evidence demonstrating how the accused products' software architecture specifically maps to each element of the asserted claims, particularly the discrete steps of selecting a "function" from a "datastore" based on location data from a "location server."