ReadyComm LLC v. Ooma Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ReadyComm LLC (New Mexico)
  • Defendant: Ooma, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01394, 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 telecommunication products and services infringe a patent related to systems for managing a group of telephone devices by designating one as "active" for calls while others remain in "stand-by."
• Technical Context: The technology addresses methods for unifying multiple communication devices (e.g., landline, mobile, VoIP) under a single user identity, allowing for dynamic selection of which device is primary for making and receiving calls.
• Key Procedural History: The patent-in-suit is a continuation-in-part of a prior application, now issued as U.S. Patent No. 9,049,275. The complaint does not reference any prior litigation or administrative proceedings involving the patent-in-suit.

Case Timeline

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

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

U.S. Patent No. 9,179,011 - Telephone Communication System and Method of Using

The patent-in-suit, issued November 3, 2015, is referred to as the “’011 Patent”.

The Invention Explained

• Problem Addressed: The patent’s background section describes the increasing difficulty of contacting individuals who use multiple communication devices, such as home, work, and mobile phones, each with a distinct phone number. ('011 Patent, col. 1:22-32). It identifies the limitations of conventional call forwarding systems and notes the broader problem of exhausting the public supply of available 10-digit phone numbers. ('011 Patent, col. 1:45-54, col. 2:8-14).
• The Patented Solution: The invention proposes a system where a group of telephone devices are functionally linked. At any given time, one device is in an "activated mode," enabling it to make and receive calls, while the other devices in the group are in a "stand-by mode," rendering them incapable of placing or receiving calls. ('011 Patent, Abstract). The system includes a "switch" that allows a user to change which device is in the active mode, including "on-the-fly" during an ongoing call, thereby redirecting communication to the newly activated device. ('011 Patent, col. 4:35-41, Fig. 1A).
• Technical Importance: This approach seeks to provide a unified communication identity across multiple physical devices, improving user accessibility while allowing for dynamic control over which device is primary for communication. ('011 Patent, col. 2:39-44).

Key Claims at a Glance

• The complaint does not identify specific claims, instead referring to "Exemplary '011 Patent Claims" detailed in an external exhibit not attached to the publicly filed complaint (Compl. ¶11, ¶16). Independent Claim 1 is representative of the core patented system.
• Independent Claim 1 requires:
  • A group of at least two telephones configured for placement in either an "activated mode" or a "stand-by mode."
  • In "stand-by mode," a telephone is "incapable of placing or receiving a call unless switched to active mode."
  • Each telephone is associated with a "switch."
  • The switch is configured to activate one telephone, which places all other telephones in the group into "standby mode."
  • A standby telephone can be switched to active mode "during a telephone call."

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Defendant Products" that are identified in charts incorporated by reference but not attached to the complaint itself (Compl. ¶11). It further alleges infringement by "numerous other devices" without specification (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It generically alleges that Defendant makes, uses, offers for sale, sells, and/or imports infringing products (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations are contained entirely within "the claim charts of Exhibit 2," which was not filed with the complaint (Compl. ¶17). The complaint asserts in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '011 Patent" and "satisfy all elements of the Exemplary '011 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint. Lacking specific factual allegations or the referenced claim charts, a detailed infringement analysis based on the complaint is not possible.

Identified Points of Contention

Based on the patent’s claims and the general nature of VoIP technology, the dispute may center on several key technical and legal questions.

• Scope Questions: A primary issue may be whether the accused system creates a "stand-by mode" where a device is truly "incapable of placing or receiving a call," as required by Claim 1. Systems that allow for simultaneous ringing on multiple devices (e.g., a desk phone and a mobile app) may not align with the patent's described dichotomy, raising the question of whether a device that can announce an incoming call is "incapable" of receiving it.
• Technical Questions: A factual question will be what mechanism in the accused products constitutes the claimed "switch." The court may need to determine if Defendant’s products contain a feature that performs the claimed function of changing a device from an inert "stand-by" state to an "active" one, as opposed to implementing more conventional call routing or follow-me logic.

V. Key Claim Terms for Construction

"stand-by mode such that in stand-by mode a telephone is incapable of placing or receiving a call"

• Context and Importance: This term defines the core functionality of the non-active devices and is central to distinguishing the invention from prior art call forwarding or routing systems. Whether the accused products meet this "incapable" limitation will likely be a dispositive issue for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's objective is to centralize communication to one active device at a time. Language stating that in standby mode a phone "cannot make or receive calls" suggests a focus on the inability to complete a communication session, which a party could argue is met even if the device can still provide a notification of an attempted call. ('011 Patent, col. 2:62-63).
  • Evidence for a Narrower Interpretation: The specification also states that stand-by devices will alert users to an incoming call with a "second ringtone, different from the first ringtone" of the active device. ('011 Patent, col. 3:4-7). A party could argue that a device which audibly alerts a user to a specific incoming call is not "incapable of... receiving a call," suggesting the limitation requires a more complete functional disabling.

"switch"

• Context and Importance: This is the control element of the claimed system. Its construction will determine whether infringement requires a discrete, user-initiated action or if it can read on automated, software-based call management rules.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states 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. 4:50-54). This non-limiting list may support construing "switch" to cover a variety of hardware or software mechanisms that alter the system's state.
  • Evidence for a Narrower Interpretation: The patent’s detailed examples consistently describe the switch being activated by an explicit user action, such as entering a PIN on a keypad to "activate that phone." ('011 Patent, col. 6:17-19, col. 6:28-30). This focus on direct user intervention may support an interpretation that excludes passive or pre-configured system logic.

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 the products in a manner that infringes the ’011 Patent (Compl. ¶14-15).
• Willful Infringement: The complaint bases its willfulness allegation on post-suit knowledge. It pleads that the filing and service of the complaint provide Defendant with "actual knowledge" and that any subsequent infringement is therefore willful (Compl. ¶13-14). No facts suggesting pre-suit knowledge are alleged.

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

• A central issue will be one of technical operation: Does the architecture of the accused Ooma products map onto the specific active/stand-by modality required by the asserted claims, particularly the requirement that stand-by devices be "incapable" of placing or receiving calls? Or do the products utilize a different technical approach, such as simultaneous call presentation across multiple endpoints, that falls outside the claim scope?
• A second core issue will be one of definitional scope: Will the term "switch" be construed broadly to cover automated, rule-based software logic for call routing, or will it be limited to a discrete, user-initiated command that manually changes the priority status of a device within the system, as emphasized in the patent's examples?
• A threshold procedural question concerns pleading sufficiency: Given that the complaint delegates nearly all factual allegations of infringement to an external exhibit that was not filed, an initial point of contention may be whether the complaint, on its own, alleges sufficient facts to meet the plausibility standard required to proceed with a patent infringement claim.