Lab Technology LLC v. ETA Transit Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: ETA Transit Inc. (Pennsylvania)
  • Plaintiff’s Counsel: Beusse Sanks; Rabicoff Law LLC
• Case Identification: 0:25-cv-60940, S.D. Fla., 05/12/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business within the Southern District of Florida and has committed the alleged acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for automatically refreshing a telephone's display with relevant communication services based on the device's current location or other contextual information.
• Technical Context: The technology addresses context-aware user interfaces for communication devices, aiming to simplify user interaction by proactively presenting services that are relevant to a user's specific situation, such as their location or the time of day.
• Key Procedural History: The patent-in-suit is a continuation of a series of prior applications. The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the asserted patent.

Case Timeline

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

U.S. Patent No. 9,219,982 - Apparatus and method for automatically refreshing a display of a telephone

• Patent Identification: U.S. Patent No. 9,219,982, "Apparatus and method for automatically refreshing a display of a telephone," issued December 22, 2015.

The Invention Explained

• Problem Addressed: The patent describes the problem of users having to navigate through numerous menu displays on a telephone to find a desired service, which can be inefficient, especially when users tend to access the same services under predictable circumstances, such as at certain times of day or in particular locations (’982 Patent, col. 1:28-44).
• The Patented Solution: The invention proposes a telephone apparatus that automatically updates its display to show a set of commonly used communication services based on a user's current context, which the patent terms a "function" (’982 Patent, col. 2:10-28). The apparatus includes a "function selector" that can use information like time from a clock (Fig. 4) or location from a location server (Fig. 5) to select the appropriate function from a datastore and refresh the screen with associated services, thereby anticipating the user's needs (’982 Patent, col. 6:7-19, 6:55-64).
• Technical Importance: This technology sought to improve the usability of networked telephones by making the user interface dynamic and context-sensitive, reducing the number of steps required for a user to access frequently needed services (’982 Patent, col. 2:4-7).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’982 patent without specifying them, referring to "Exemplary '982 Patent Claims" in an unattached exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative of the apparatus claims.
• The essential elements of independent claim 1 include:
  • A telephone comprising a display panel, a processor, and a datastore.
  • The datastore contains at least one "function" with information related to the telephone's current location and user.
  • The telephone can connect to a communication network and the function is associated with a communication service.
  • The processor is operable to connect to a "location server" to get the telephone's current location.
  • The processor selects a function from the datastore.
  • The processor refreshes the display screen to show the communication service associated with the selected function, based at least partly on the current location.

III. The Accused Instrumentality

Product Identification

• The complaint refers to "Exemplary Defendant Products" identified in charts within Exhibit 2, but Exhibit 2 was not filed with the complaint (Compl. ¶11). The specific accused products, methods, or services are not named in the main body of the complaint.

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '982 Patent" and "satisfy all elements of the Exemplary '982 Patent Claims" (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the specific technical functionality or market context of the accused products.

IV. Analysis of Infringement Allegations

The complaint states that Exhibit 2 contains claim charts comparing the asserted claims to the accused products, but this exhibit is not available for analysis (Compl. ¶16-17). The core infringement theory is that the accused products incorporate the claimed technology for refreshing a display based on context (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Based on the complaint and patent, the dispute may raise several questions.
  • Scope Questions: A central question may be whether the term "telephone" as used in the patent can be construed to read on the specific accused products sold by the Defendant. The definition of a "function," described in the patent as representing a "given set of conditions associated with a user" (e.g., "office worker on weekday morning"), will be critical in determining if the accused products' contextual logic falls within the claim scope (’982 Patent, col. 4:32-37).
  • Technical Questions: An evidentiary question will be what proof Plaintiff can provide that the accused products perform the claimed actions. For example, what evidence demonstrates that the products connect to a "location server," maintain a "datastore" of "functions," and use a "processor" to "select a function" in the manner required by the claims (’982 Patent, cl. 1).

V. Key Claim Terms for Construction

"telephone"

• Context and Importance: This term defines the scope of the claimed apparatus. The outcome of the infringement analysis depends on whether Defendant's accused products are properly classified as "telephones" under the patent's definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims require a device with a "display panel," a "processor," and the ability to "connect to a communication network," features common to many modern electronic devices (’982 Patent, cl. 1). The specification also refers to a "mobile phone" generally (’982 Patent, col. 7:55).
  • Evidence for a Narrower Interpretation: The patent’s title, abstract, and background consistently use the term "telephone." The background section lists traditional telecommunication services like "telephone services, conference services, voice messaging services," which could suggest a device primarily intended for telephony (’982 Patent, col. 1:20-23).

"function"

• Context and Importance: This term is central to the patent's inventive concept, linking a user's context to the services displayed. Practitioners may focus on this term because infringement will depend on showing that the accused products implement a corresponding "function."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a function broadly as representing "a given set of conditions associated with a user" which may be "static, such as user ID, or variable, such as time, location, activity or the like" (’982 Patent, col. 4:32-34). This could support an interpretation covering any context-based user profile or setting.
  • Evidence for a Narrower Interpretation: The patent provides specific, role-based examples of a "function," such as "an office worker on weekday morning," a "hotel guest in evenings," or a "vehicle driver" (’982 Patent, col. 4:35-37). A party could argue the term requires a pre-defined, user-centric profile rather than any programmatic response to a change in location or time.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product literature and website materials" that instruct and encourage end users to use the accused products in a manner that directly infringes the ’982 patent (Compl. ¶14-15).
• Willful Infringement: The complaint does not use the term "willful." It alleges "Actual Knowledge of Infringement," but bases this allegation on the "service of this Complaint" (Compl. ¶13). This allegation, if proven, could potentially support a claim for enhanced damages for infringement occurring only after the complaint was filed.

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

• A central issue will be one of evidentiary proof: Given the absence of detailed factual allegations in the pleading itself, a key question will be whether Plaintiff's discovery can produce technical evidence demonstrating that the accused products' internal software architecture performs the specific steps of selecting a "function" from a "datastore" based on data from a "location server," as required by the patent's claims.
• The case will also turn on claim construction: A core question will be one of definitional scope, particularly whether the term "function," described in the patent via user-centric roles like "shopper" or "parent," can be construed to cover the specific contextual algorithms implemented in Defendant's accused products.