E Beacon LLC v. Saferwatch LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: SaferWatch LLC (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01358, D. Del., 11/06/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the District, and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology addresses the public safety challenge of automatically determining and transmitting the physical location of a nomadic VoIP phone user to emergency services (e.g., 911), a problem not present with traditional, fixed-location landlines.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier, related patent. No other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2005-08-05	’386 Patent Priority Date
2011-04-25	’386 Patent Application Date
2013-08-20	’386 Patent Issue Date
2025-11-06	Complaint Filing Date

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

U.S. Patent No. 8,515,386 - Emergency services for voice over IP telephony (E-VoIP)

• 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 providing emergency services for VoIP telephone systems. Unlike traditional landlines with fixed, known addresses, a VoIP phone can be used in any location with internet access, making it difficult for a 911 operator to automatically identify a caller's physical location during an emergency (’386 Patent, col. 1:11-29).
• The Patented Solution: The invention is a system that equips a VoIP device with location-finding capabilities, such as GPS or cellular network triangulation. The system periodically attempts to determine its own physical coordinates and stores them (’386 Patent, col. 2:46-58). When an emergency number like 9-1-1 is dialed, the system automatically transmits these stored physical coordinates to the emergency call center, enabling dispatchers to locate the caller even if the user is unable to state their location verbally (’386 Patent, col. 3:5-12; Fig. 1).
• Technical Importance: This technology aims to provide nomadic VoIP users with the same level of automatic location identification for emergency services that had long been standard for traditional telephone networks, addressing a critical public safety gap created by the shift to internet-based telephony (’386 Patent, col. 1:30-44).

Key Claims at a Glance

The complaint asserts infringement of "one or more claims," referencing "Exemplary '386 Patent Claims" in an attached exhibit not provided with the complaint (Compl. ¶11). Claim 1 is the first independent claim.

• Independent Claim 1:
  • 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 phone's location, with each attempt using a separate location detection technology ("LDT").
  • If an attempt is successful, storing the physical location determined by that LDT.
  • Placing a call to the emergency services call center with the VoIP phone.
  • Automatically transmitting the stored physical location to the emergency services call center.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products, referring to them generally as "Exemplary Defendant Products" (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not describe the specific functionality or operation of the accused products. It alleges, through incorporation of an unprovided exhibit, that the "Exemplary Defendant Products practice the technology claimed by the '386 Patent" (Compl. ¶16). The complaint provides no details regarding the products' market context or commercial positioning.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16-17). As this exhibit was not provided, a detailed element-by-element analysis is not possible. The narrative infringement theory alleges that Defendant’s products "satisfy all elements of the Exemplary '386 Patent Claims" (Compl. ¶16). The complaint alleges direct infringement by Defendant through its own testing and use of the products, as well as through making, using, and selling them (Compl. ¶11-12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Factual Questions: A primary question will be identifying the "Exemplary Defendant Products" and determining their precise technical operation. The complaint's lack of specificity raises the question of what evidence Plaintiff will present to show that these unidentified products perform each of the claimed steps, such as using a "plurality" of distinct "location detection technologies."
  • Scope Questions: The dispute may turn on whether the accused products' method of determining location falls within the scope of the claims. For example, a key issue could be whether the accused system makes a "plurality of attempts" using "separate" technologies as required by Claim 1, or if it uses a single, hybrid location-finding method.

V. Key Claim Terms for Construction

The Term: "location detection technology ('LDT')" (Claim 1)

• Context and Importance: This term defines the universe of technologies covered by the patent. Its construction will be critical to determining infringement, as the definition will dictate whether the technologies used by the accused products (e.g., GPS, cellular triangulation, Wi-Fi positioning) qualify as distinct "LDTs" under the claim. Practitioners may focus on this term because its breadth is central to the infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of examples, including "geolocation, location based service (LBS), GSM localization, triangulation... GPS, CDMA and GSM technologies... Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies" (’386 Patent, col. 13:58-64). This broad list of varied technologies may support an interpretation that covers any means of determining a device's physical location.
  • Evidence for a Narrower Interpretation: A defendant may argue that the term should be limited to the primary technologies described in the patent's detailed embodiments, namely GPS and cellular network-based methods (’386 Patent, col. 2:49-51). The requirement in Claim 1 that each of the "plurality of attempts" use a "separate" LDT may also support a narrower reading where technologies must be fundamentally distinct in their operational principles.

The Term: "making a plurality of attempts" (Claim 1)

• Context and Importance: This phrase is central to the claimed method. The infringement analysis will depend on whether the accused system's actions constitute a "plurality of attempts." For example, if a device simultaneously queries multiple location sources, the parties may dispute whether this constitutes a single "attempt" using a hybrid method or a "plurality of attempts" under the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The general description of the process in Figure 4 shows parallel paths for different LDTs (e.g., GPS, CDMA, GSM), which could be read as separate, simultaneous attempts occurring within a single "Location Detection Cycle" (’386 Patent, Fig. 4).
  • Evidence for a Narrower Interpretation: Dependent claims specify making a "further attempt" after a first one is unsuccessful (e.g., Claim 6). This language could suggest that the "plurality of attempts" must be sequential or iterative, rather than a single, multi-faceted query, potentially narrowing the scope of the independent claim.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in a manner that infringes the ’386 Patent (Compl. ¶14).
• Willful Infringement: The basis for willfulness is entirely post-suit knowledge. The complaint alleges that service of the complaint itself provides "actual knowledge of infringement" and that Defendant's continued alleged infringement thereafter is willful (Compl. ¶13-14). No allegations of pre-suit knowledge are made.

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

1. A threshold evidentiary question will be one of specification: What are the accused "Exemplary Defendant Products," and what are their specific functionalities? The current complaint's failure to identify any product by name or describe its operation creates a significant factual ambiguity that must be resolved before any substantive infringement analysis can occur.
2. A core issue will be one of claim scope: How will the court construe the term "a plurality of attempts, each using a separate location detection technology"? The case may depend on whether the accused system's method for determining location—whether it be a single, fused-data process or sequential/parallel queries—is found to meet this multi-part limitation as defined by the patent.