Calibrate Networks LLC v. Docker Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Calibrate Networks LLC (New Mexico)
  • Defendant: Docker, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01574, D. Del., 12/30/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to methods for managing network communications, particularly for changing network addresses without disrupting connections.
• Technical Context: The patent addresses inefficiencies in traditional layered network architectures, proposing a streamlined method for processing data packets and managing device mobility.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,584,633 - "Method and system for managing network communications"

The Invention Explained

• Problem Addressed: The patent's background describes traditional network architectures as inefficient due to their layered structure. Processing data packets, or Protocol Data Units (PDUs), requires passing them through multiple stages, which involves performance-degrading data copies and task switching. Furthermore, changing the network address of a device—a critical function for mobility—is difficult and can destroy active connections. (’633 Patent, col. 1:19-64).
• The Patented Solution: The invention proposes a more efficient, "flattened" network architecture. It describes treating each PDU as a "serial tape" to be processed by a single, unified processor, thereby avoiding the need to pass the PDU between distinct layers (’633 Patent, col. 3:3-9). To solve the address-change problem, the patent discloses a method where a network process can be assigned a new address while its old address remains temporarily active. The process begins using the new address as its source, and over time, as routing tables update across the network, the old address is phased out without losing data or connections (’633 Patent, col. 5:46-6:1).
• Technical Importance: This approach aims to simplify network processing, reduce hardware complexity, and provide a seamless mechanism for renumbering network devices to support mobility and efficient routing. (’633 Patent, col. 1:56-61).

Key Claims at a Glance

• The complaint does not identify specific asserted claims but reserves the right to rely on the claims identified in a referenced, but unattached, exhibit (Compl. ¶11, ¶16). The first independent method claim is Claim 1.
• Claim 1 of the ’633 Patent includes the following essential elements:
  • Determining an address change is desired for an Inter-Process Communication (IPC) process that has an old address and a globally known application name.
  • Assigning a new address to the IPC process, where both the old and new addresses are "only known in a layer."
  • The IPC process then utilizes the new address as its source address in any new data flows it originates.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an incorporated exhibit, which was not filed with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges infringement but provides its substantive analysis in "Exhibit 2," which is referenced but was not included with the pleading (Compl. ¶16-17). The narrative allegations state that the "Exemplary Defendant Products practice the technology claimed by the '633 Patent" and "satisfy all elements of the Exemplary '633 Patent Claims" (Compl. ¶16). Without the exhibit, a detailed analysis of the infringement theory is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "Inter-Process Communication (IPC) process"

  • Context and Importance: This term defines the entity whose address is being changed and is central to Claim 1. The applicability of the patent to the accused technology will hinge on whether Defendant's systems employ what can be considered an "IPC process." Practitioners may focus on this term because its definition could either confine the patent to a specific network architecture or allow it to cover a broader range of modern distributed systems.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not appear to limit the term to a specific operating system or hardware context, referring generally to "Application Processes" that are members of a "DIF" (Distributed IPC Facility) (’633 Patent, col. 5:53-55). This could support an interpretation covering any software process communicating over a network.
    • Evidence for a Narrower Interpretation: The specification makes reference to a "Recursive Inter Network Architecture (RINA)" (’633 Patent, col. 5:42-43). This context may support a narrower construction limiting the term to processes operating within the specific, formal RINA framework described in academic and technical literature associated with the inventors.

• The Term: "only known in a layer"

  • Context and Importance: This limitation, which applies to both the old and new addresses, distinguishes them from the "globally" known application name. The infringement analysis will likely turn on whether the addresses used in the accused products (e.g., private IP addresses in a container network) meet this "layer-specific" requirement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: This could be interpreted to mean any address that is not globally unique or routable on the public internet, such as addresses used within a virtual private network, an overlay network, or other private address spaces.
    • Evidence for a Narrower Interpretation: The patent’s discussion of a recursive, multi-layer architecture could suggest a more formal definition, where an address is strictly confined to a single, defined protocol layer and is not visible to layers above or below it (’633 Patent, col. 3:17-48).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint alleges willfulness based on post-suit knowledge. It contends that the filing of the complaint and its associated (but unattached) claim charts provide Defendant with actual knowledge of infringement, and that any continued infringement thereafter is willful (Compl. ¶13-14). No allegations of pre-suit knowledge are made.

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

• A central threshold issue will be one of pleading sufficiency: given the complaint’s failure to identify any specific accused product or provide the claim charts it incorporates by reference, the initial phase of the case may focus on whether the allegations meet the plausibility standard required to proceed.
• Assuming the case moves forward, a core dispute will be one of technical applicability: can the patent’s method for changing an address for an "IPC process" within a recursive network architecture be mapped onto the functionality of modern containerization and cloud networking platforms, which were not explicitly described in the patent?
• A key legal question will concern claim scope: can claim terms rooted in a specific network theory, such as "Inter-Process Communication (IPC) process" and an address "only known in a layer," be construed broadly enough to encompass the fundamentally different architectures of the accused systems, or are they terms of art limited to the patent’s specific context?