DCT

1:25-cv-01392

ReadyComm LLC v. Dialpad Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01392, D. Del., 11/17/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has committed acts of patent infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s communication products and services infringe a patent related to managing multiple telephone devices by designating one as "active" and others as "stand-by."
  • Technical Context: The technology addresses the challenge of users managing multiple communication devices (e.g., landline, mobile phone) by enabling a system where different devices can be selectively activated to make or receive calls associated with a group identity.
  • Key Procedural History: The patent-in-suit is a continuation-in-part of a prior application that issued as U.S. Patent No. 9,049,275.

Case Timeline

Date Event
2008-06-24 U.S. Patent No. 9,179,011 Priority Date
2015-11-03 U.S. Patent No. 9,179,011 Issues
2025-11-17 Complaint Filed

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

  • Patent Identification: U.S. Patent No. 9,179,011, "Telephone Communication System and Method of Using," issued November 3, 2015 (’011 Patent).

  • The Invention Explained:

    • Problem Addressed: The patent's background describes the increasing difficulty for individuals and groups to manage communications across numerous devices (home phone, mobile phone, work phone), leading to a proliferation of telephone numbers and challenges in staying reachable ('011 Patent, col. 1:21-32; col. 2:5-15). Traditional call forwarding was identified as having limitations, such as requiring each device to have its own distinct number and offering limited user control over which device is active ('011 Patent, col. 1:44-54).
    • The Patented Solution: The invention proposes a system comprising a group of telephones where only one device is in "active mode" at any given time, while the others are in "stand-by mode" ('011 Patent, Abstract). A device in stand-by mode is described as "incapable of making or receiving a call" until it is switched to active mode ('011 Patent, Abstract). The system includes a "switch" that allows a user to change which device is active, enabling "on-the-fly redirection" of calls, even during an incoming call that is ringing ('011 Patent, col. 5:1-6; col. 9:48-54). This allows multiple devices to be associated with a single persona or group identity while ensuring calls are routed only to the user's currently preferred device.
    • Technical Importance: This approach sought to unify a user's communication presence across multiple physical devices without relying on conventional call-forwarding logic, giving the user direct control over the single, currently-active endpoint for all communications. (Compl. ¶9; ’011 Patent, col. 2:38-44).

  • Key Claims at a Glance:

    • The complaint asserts infringement of "one or more claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is representative of the core system.
    • Independent Claim 1:
      • a group of N telephones where N is at least two, each configured to be placed in activated mode and alternatively in stand-by mode such that in stand-by mode a telephone is incapable of placing or receiving a call unless switched to active mode;
      • each of said N telephones associated with a switch;
      • said switch configured to activate one of said N telephones to be an active mode telephone such that all remaining N-1 telephones are on standby mode prior to making an outgoing call or taking an incoming call; and
      • at least one of said standby telephones configured such that it may be switched to active mode during a telephone call.
    • The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "one or more claims" of the patent (Compl. ¶11).

III. The Accused Instrumentality

  • Product Identification: The complaint accuses "Exemplary Defendant Products" without naming specific products, services, or methods (Compl. ¶11).
  • Functionality and Market Context: The complaint alleges that Defendant makes, uses, sells, and imports products that infringe the ’011 Patent (Compl. ¶11). Defendant Dialpad, Inc. is a provider of cloud-based business communication, VoIP, and contact center services. The complaint does not describe the specific functionality of the accused products, stating only that they "practice the technology claimed by the '011 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16, ¶17). However, Exhibit 2 was not filed with the public complaint. The complaint's narrative theory alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the patent’s claims and the nature of Defendant’s likely products (cloud-based communication services), several potential areas of dispute may arise.
    • Scope Questions: The claims are written in terms of discrete physical "telephones." A primary question will be whether Defendant’s software applications (e.g., desktop or mobile apps) and user accounts on a cloud platform constitute a "group of N telephones" as recited in the claims.
    • Technical Questions: A key technical question will concern the "active mode" and "stand-by mode" limitations. The patent specifies that a device in stand-by mode is "incapable of placing or receiving a call" ('011 Patent, col. 15:47-49). The infringement analysis may turn on whether the accused products implement a function that renders a device truly "incapable," or if they use a different mechanism, such as call routing rules or presence-state indicators, that does not meet this specific functional requirement. Another question is what component of Defendant's software-based system constitutes the claimed "switch."

V. Key Claim Terms for Construction

  • The Term: "stand-by mode"

    • Context and Importance: This term is central to the novelty of the invention, as it defines the state of all non-active devices in the group. The definition will be critical to determining infringement, as the accused products must render a device in "stand-by mode" incapable of certain functions. Practitioners may focus on whether this requires a device-level state change (e.g., disabling the communication hardware) or can be met by a network-level routing decision.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Narrower Interpretation: The claim itself provides a functional definition: "in stand-by mode a telephone is incapable of placing or receiving a call unless switched to active mode" ('011 Patent, col. 15:47-49). This language suggests a complete functional disability, which could be interpreted narrowly.
      • Evidence for a Broader Interpretation: The specification describes the system's effect on calls, where a call to a stand-by number is "redirected to the active mode telephone" ('011 Patent, col. 7:31-33). This could support an argument that "incapable" refers to the system-level outcome (the call does not connect to the stand-by device) rather than a hard-and-fast technical limitation on the device itself.

  • The Term: "switch"

    • Context and Importance: The "switch" is the mechanism for user control, allowing a change from stand-by to active mode. Identifying the corresponding feature in a modern, software-defined communication platform will be a key issue.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the "switch" can be of "numerous types, including, but not limited to a toggle switch, a Personal Identification Number (PIN), and/or a menu-type switch" ('011 Patent, col. 4:51-55). This broad list of examples, including software-based inputs like a PIN or menu, may support a construction that covers user interface elements in a software application.
      • Evidence for a Narrower Interpretation: The patent repeatedly associates the switch with a specific telephone device ("Each telephone device 106 contains a separate and distinct switch 114") ('011 Patent, col. 4:35-36). This could support a narrower construction requiring a distinct, identifiable switching component associated with each endpoint client or application instance, rather than a centralized, account-level setting.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct end users to use the accused products in a manner that infringes the ’011 Patent (Compl. ¶14).
  • Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that Defendant has had "actual knowledge" of its infringement at least since being served with the complaint and attached claim charts (Compl. ¶13, ¶15).

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

The resolution of this case will likely depend on the court’s interpretation of claim terms drafted for an era of distinct physical devices and their application to a modern, cloud-based software architecture.

  • A core issue will be one of technological mapping: how, if at all, does the claim language requiring a "group of N telephones," each with an associated "switch," apply to Defendant’s likely architecture of user accounts, software clients, and centralized cloud-based call routing logic?
  • A second dispositive issue will be one of functional definition: does the accused system's method of managing call routing to different user endpoints meet the specific claim requirement that a device in "stand-by mode" be rendered "incapable of placing or receiving a call," or is there a fundamental mismatch in technical operation?