E Beacon LLC v. Greenlight Financial Technology Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Greenlight Financial Technology, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01357, D. Del., 11/06/2025
• Venue Allegations: Venue is asserted on the basis that Defendant is incorporated in Delaware and has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The patent addresses the challenge of locating nomadic VoIP users during 911 calls, a critical public safety issue that arose with the shift from traditional landlines to internet-based telephony.
• Key Procedural History: No prior litigation, licensing history, or other procedural events are mentioned in the complaint.

Case Timeline

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

• Patent Identification: U.S. Patent No. 8,515,386, “Emergency services for voice over IP telephony (E-VoIP),” issued August 20, 2013 (’386 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the unreliability of emergency services for VoIP systems, contrasting them with the fixed-location nature of traditional landlines (Plain Old Telephone System, or "POTS") (Compl. ¶9; ’386 Patent, col. 1:11-29). Because a VoIP phone can be used from any location with internet access, an emergency dispatcher relying on a static, registered address might send help to the wrong place, such as a user’s empty home when they are traveling (’386 Patent, col. 1:23-29).
• The Patented Solution: The invention is a system that determines the current physical location of a VoIP device using technologies like GPS or cellular network triangulation and automatically transmits those coordinates to an emergency call center (e.g., a Public Safety Answering Point, or "PSAP") when an emergency number is dialed (’386 Patent, Abstract; col. 2:36-45). The system is designed to periodically update its location data to ensure accuracy and can use cellular networks as a backup if the VoIP service is unavailable (’386 Patent, Fig. 1; col. 3:46-55).
• Technical Importance: This technology aimed to provide E911 (Enhanced 911) capabilities to the growing population of VoIP users, addressing a significant public safety gap by making mobile and nomadic callers locatable in an emergency (’386 Patent, col. 1:47-56).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" but incorporates the specific asserted claims by reference to an exhibit not attached to the publicly filed complaint (Compl. ¶11, ¶16).
• Independent claim 1 is representative of the patent's core inventive concept and includes the following essential elements:
  • A method for determining the physical location of a VoIP phone and transmitting it to an emergency services call center.
  • Making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT").
  • If an attempt is successful, storing the physical location.
  • Placing a call to the emergency services call center with the VoIP phone.
  • Automatically transmitting the physical location of the VoIP phone to the emergency services call center.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" but does not name specific products, instead incorporating them by reference to an external exhibit (Compl. ¶11, ¶16). The defendant is Greenlight Financial Technology, Inc.

Functionality and Market Context

• The complaint does not provide any description of the accused products' features, functions, or operation. It alleges that these products "practice the technology claimed by the '386 Patent" (Compl. ¶16). Publicly available information indicates the defendant operates in the financial technology sector, providing debit cards and associated mobile applications for families. The complaint does not explain how these financial products are alleged to perform the E-VoIP methods of the ’386 Patent.

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations, including claim charts comparing the asserted claims to the "Exemplary Defendant Products," are incorporated by reference from an external document, Exhibit 2, which was not provided with the filed complaint (Compl. ¶16-17). The complaint’s narrative theory is limited to the conclusory statement that the accused products "satisfy all elements of the Exemplary '386 Patent Claims" (Compl. ¶16). Without access to Exhibit 2, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: The primary points of contention will likely arise from the apparent mismatch between the patent’s subject matter (emergency VoIP telephony) and the defendant’s business (financial technology services).
  • Scope Questions: A central dispute may concern whether Defendant's financial products or services can be construed as a "VoIP phone" as contemplated by the patent. The patent's specification discusses conventional VoIP phones as well as software-based "soft phones" (’386 Patent, col. 7:41-43), which raises the question of how broadly that term can be interpreted.
  • Technical Questions: The complaint provides no facts explaining how the accused financial products allegedly perform the core functions recited in the claims, such as "placing a call to the emergency services call center" and "automatically transmitting the physical location of the VoIP phone to the emergency services call center" (’386 Patent, col. 12:32-37). A key factual question will be whether the accused products perform these specific telephony functions or merely use location data for unrelated purposes, such as transaction verification or parental controls.

V. Key Claim Terms for Construction

• The Term: "VoIP phone"

• Context and Importance: The applicability of the entire patent hinges on whether the accused instrumentality is a "VoIP phone." Given that the defendant offers financial technology products, not traditional telephony services, the construction of this term will be dispositive. Practitioners may focus on this term because its scope will determine whether the patent can be asserted outside the conventional telecommunications field.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the term is not limited to hardware devices, stating the system can be used with "soft phones," which are described as "a software based VoIP phone which uses the computer's internet connection" (’386 Patent, col. 7:41-44). This could support an argument that any software application with voice communication capabilities over the internet qualifies.
  • Evidence for a Narrower Interpretation: The patent’s background and detailed description consistently frame the invention in the context of replacing traditional telephone services and enabling calls to a PSAP (’386 Patent, col. 1:11-29; col. 2:39-42). This context may support a narrower construction limited to devices or applications whose function includes general-purpose voice calling and interfacing with the public telephone network.

• The Term: "placing a call to the emergency services call center"

• Context and Importance: This active step is a critical limitation in the asserted method claims. The infringement analysis will depend on whether the accused products are capable of, and in fact perform, the act of initiating a voice call to a 911 operator or PSAP.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not appear to define "placing a call" in a specialized way, which might support giving the term its plain and ordinary meaning. An argument could be made that any automated data transmission to an emergency service, even if not a traditional voice call, could fall within this scope.
  • Evidence for a Narrower Interpretation: The specification repeatedly discusses dialing "9-1-1" and connecting a "caller" to a "911 operator" for voice communication, strongly suggesting a conventional telephone call is intended (’386 Patent, col. 3:9-14; col. 4:9-12). The entire purpose of transmitting location coordinates is to supplement this voice call, which supports a construction requiring the initiation of a real-time voice link to a PSAP.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use its products in a manner that infringes the ’386 Patent (Compl. ¶14-15).
• Willful Infringement: The basis for willfulness is alleged post-suit knowledge. The complaint asserts that service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringement thereafter is willful (Compl. ¶13-14).

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

This case appears to present fundamental questions of technological and definitional scope, stemming from the assertion of a patent directed at emergency telephony against a defendant in the financial technology sector. The resolution of the dispute will likely depend on the court’s answers to the following questions:

• A core issue will be one of definitional scope: Can the term "VoIP phone", as used in a patent focused on 911 emergency calling, be construed to encompass a financial services mobile application that may have ancillary communication or location-tracking features?
• A key evidentiary question will be one of functional operation: Does the complaint and its (unprovided) exhibits contain evidence that the accused financial products actually perform the central claimed method step of "placing a call to the emergency services call center" and transmitting location data for that specific purpose, or is there a fundamental mismatch in the technology’s real-world function?