DCT
0:25-cv-62546
Integral Wireless Technologies LLC v. MW Intl Ventures LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Integral Wireless Technologies LLC (Texas)
- Defendant: MW International Ventures LLC d/b/a Social Mobile (Florida)
- Plaintiff’s Counsel: Rozier Hardt McDonough, PLLC
- Case Identification: 2:25-cv-00644, E.D. Tex., 06/18/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business in the District, evidenced by the presence of employees, and has committed acts of patent infringement within the District.
- Core Dispute: Plaintiff alleges that Defendant’s portfolio of enterprise mobile devices, which are compatible with various wireless standards, infringes nine U.S. patents relating to foundational wireless communication technologies, including MIMO-OFDM systems, power-saving methods, and preamble structures.
- Technical Context: The patents-in-suit address core technical challenges in modern wireless communications, such as improving data throughput in multi-antenna systems (MIMO), reducing feedback overhead, and enhancing power efficiency, which are central to standards like Wi-Fi (802.11) and 5G cellular.
- Key Procedural History: An Inter Partes Review (IPR) Certificate for U.S. Patent No. 7,269,127, one of the patents-in-suit, indicates that claims 1-10 and 17 were cancelled. The complaint asserts claim 20 of this patent, which was not subject to the IPR cancellation.
Case Timeline
| Date | Event |
|---|---|
| 2001-10-04 | U.S. Patent No. 7,269,127 Priority Date |
| 2004-07-02 | U.S. Patent No. 7,738,595 & 7,822,141 Priority Date |
| 2004-07-21 | U.S. Patent No. 7,676,007 Priority Date |
| 2004-07-30 | U.S. Patent No. 8,139,544 Priority Date |
| 2004-11-24 | U.S. Patent No. 8,812,888 & 9,207,748 Priority Date |
| 2005-04-26 | U.S. Patent No. 7,949,068 Priority Date |
| 2007-09-11 | U.S. Patent No. 7,269,127 Issued |
| 2008-12-09 | U.S. Patent No. 8,976,714 Priority Date |
| 2010-03-09 | U.S. Patent No. 7,676,007 Issued |
| 2010-06-15 | U.S. Patent No. 7,738,595 Issued |
| 2010-10-26 | U.S. Patent No. 7,822,141 Issued |
| 2011-05-24 | U.S. Patent No. 7,949,068 Issued |
| 2012-03-20 | U.S. Patent No. 8,139,544 Issued |
| 2014-08-19 | U.S. Patent No. 8,812,888 Issued |
| 2014-07-18 | IPR proceeding (IPR2014-01185) filed for U.S. Patent No. 7,269,127 |
| 2015-03-10 | U.S. Patent No. 8,976,714 Issued |
| 2015-12-08 | U.S. Patent No. 9,207,748 Issued |
| 2018-06-28 | IPR Certificate issued for U.S. Patent No. 7,269,127, cancelling claims 1-10 and 17 |
| 2025-06-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,676,007 - System and Method for Interpolation Based Transmit Beamforming for MIMO-OFDM with Partial Feedback
The Invention Explained
- Problem Addressed: In multiple-input multiple-output (MIMO) systems using orthogonal frequency division multiplexing (OFDM), optimal performance requires the transmitter to have channel state information (in the form of "beamforming vectors") for every data subcarrier. In non-reciprocal channels, sending this information back from the receiver to the transmitter for all subcarriers consumes an excessive amount of feedback bandwidth (’007 Patent, col. 2:39-43).
- The Patented Solution: The invention reduces this feedback overhead by having the receiver send back beamforming vectors for only a subset of the subcarriers. The transmitter then computationally derives the beamforming vectors for the remaining subcarriers through interpolation, using the known correlation between adjacent subcarriers. The feedback also includes "interpolation information," such as phase rotation parameters, to minimize distortion introduced by the interpolation process (’007 Patent, Abstract; col. 2:44-58).
- Technical Importance: This method provided a technique to make advanced beamforming more practical for real-world wireless systems by significantly reducing the amount of feedback data required to maintain a high-quality link.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶37).
- Claim 1 recites a communication apparatus with:
- A plurality of antennas and a transmitter configured to provide output signals on a plurality of subcarriers.
- The transmitter is configured to receive "limited feedback information" from a receiver, which includes "interpolation information" and "beamforming vectors for a subset of the subcarriers."
- The transmitter is configured to "derive beamforming vectors" for subcarriers not in the subset by performing an "interpolation" of the provided beamforming vectors.
- The interpolation is based on the "interpolation information," which "includes phase values."
U.S. Patent No. 7,738,595 - Multiple Input, Multiple Output Communications Systems
The Invention Explained
- Problem Addressed: In typical MIMO systems, multiple signals transmitted simultaneously can interfere with each other ("cross-talk"), and the signal-to-noise ratios for different data streams may be unequal, resulting in varied bit error rates and inefficient communication (’595 Patent, col. 1:25-34).
- The Patented Solution: The patent describes systems for optimizing transmitter and receiver weights to create substantially decoupled data streams. One method is a "unit magnitude decomposition" of the transmission channel matrix. This mathematical process decomposes the channel matrix into a "unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane," which has the effect of creating orthogonal signal paths with equivalent gain (’595 Patent, Abstract; col. 12:3-12).
- Technical Importance: This technique offered a method to transform a complex, interfering multi-antenna channel into a set of clean, parallel, and equal-strength channels, thereby improving the reliability and overall throughput of MIMO systems.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶64).
- Claim 1 recites a MIMO signal transmitter with:
- At least two vector multipliers for weighting input signals with a vector to form weighted signals.
- At least two antennas configured to transmit the weighted signals.
- Each vector is computed using a "unit magnitude decomposition of a transmission channel matrix."
- The decomposition includes decomposing a portion of the channel matrix into a "unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane."
U.S. Patent No. 7,822,141 - Multiple Input, Multiple Output Communications Systems
- Technology Synopsis: This patent relates to improving MIMO communication by iteratively adjusting transmitter weights. The process involves generating and transmitting forward signals, receiving reverse signals with receiver weights, and then choosing updated transmitter weights based on those receiver weights to achieve a target gain level (’141 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶90).
- Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform the claimed iterative method for determining and choosing updated transmitter weights (Compl. ¶91).
U.S. Patent No. 7,949,068 - Systems and Methods for Transmitter Diversity
- Technology Synopsis: The patent describes a method for transmitter diversity expansion where a set of "base data streams" is supplemented by "extension data streams." These extension streams are generated via a matrix multiplication of the base streams with a unitary matrix and are transmitted from separate antennas (’068 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 17 (Compl. ¶100).
- Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform the claimed method of generating and transmitting base and extension data streams (Compl. ¶101).
U.S. Patent No. 8,139,544 - Pilot Tone Processing Systems and Methods
- Technology Synopsis: The patent discloses a receiver system for processing pilot tones in a multi-antenna environment. The system separates data subcarriers and pilot subcarriers from two distinct signals based on channel estimates and then "match-filter combine[s]" the pilot subcarriers from each signal (’544 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 15 (Compl. ¶126).
- Accused Features: The complaint alleges that Defendant's 802.11n compatible devices include a receiver configured to perform the claimed steps of separating and combining pilot subcarriers (Compl. ¶127).
U.S. Patent No. 8,812,888 - Systems and Methods for Scanning for A Wake Up Packet Addressed to A Wireless Device
- Technology Synopsis: This patent describes a power-saving method for a wireless device. The device scans for a "wake-up packet" for a predetermined period and ceases scanning if the packet is not received within that time, allowing it to return to a low-power state (’888 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶152).
- Accused Features: The complaint alleges that Defendant's Bluetooth compatible devices perform this method of time-limited scanning for a wake-up packet (Compl. ¶153).
U.S. Patent No. 8,976,714 - Providing and Acquiring A System Information Message In A Wireless Network
- Technology Synopsis: The patent relates to how a user equipment (UE) in a wireless network acquires system information (SI). The UE receives "si-Windowlength" information in an initial message and uses it to calculate the specific downlink subframe in which the full SI message will be transmitted (’714 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶163).
- Accused Features: The complaint alleges that Defendant's 5G compatible devices perform the claimed method of receiving si-Windowlength information and using it to calculate and receive a subsequent SI message (Compl. ¶164).
U.S. Patent No. 9,207,748 - Systems and methods for a wireless device wake-up process including power-save and non-power-save modes
- Technology Synopsis: The patent describes a computer system that manages a wireless device's wake-up process. A controller triggers a "wake-up detection mode" for a pre-determined time period and exits that mode either when a wake-up packet is received (and the device transitions to a non-power-save mode) or when the time period expires (’748 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 8 (Compl. ¶189).
- Accused Features: The complaint alleges that Defendant's Bluetooth compatible devices provide a computer with a controller configured to perform this time-limited wake-up detection process (Compl. ¶190).
U.S. Patent No. 7,269,127 - Preamble Structures for Single-Input, Single-Output (SISO) and Multi-Input, Multi-Output (MIMO) Communication Systems
- Technology Synopsis: The patent describes specific preamble structures for communication systems. It details a method of forming a frame by combining data and training blocks, performing an inverse discrete fourier transform (IDFT), and inserting cyclic prefixes, where the length of the training block's cyclic prefix (G) is a specific fraction of the training block's length (N₁), such as G=N₁/4 (’127 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 20 (Compl. ¶199).
- Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform the claimed method of forming a frame structure with the specified training block and cyclic prefix relationships (Compl. ¶200).
III. The Accused Instrumentality
Product Identification
- The complaint names a range of products under the “RHINO Mobility” brand and the “Social Mobile” brand, including models such as the RHINO C10, RHINO C6, RHINO D2 5G, and Social Mobile One (Compl. ¶27).
Functionality and Market Context
- The accused products are identified as enterprise mobility devices compatible with various wireless communication standards, including 802.11ac, 802.11n, 5G, and Bluetooth (Compl. ¶27). The complaint alleges these devices are part of a portfolio of "off-the-shelf, Android Enterprise devices" marketed by Defendant, who is described as a "leading provider of enterprise mobility solutions" (Compl. ¶4, ¶5). Infringement is alleged to occur when these devices operate in compliance with the functionalities specified by these standards (Compl. ¶38, ¶65, ¶91, ¶101, ¶127, ¶153, ¶164, ¶190, ¶200).
IV. Analysis of Infringement Allegations
’007 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a communication apparatus, comprising: a plurality of antennas; and a transmitter coupled to the antennas and configured to provide to the antennas a plurality of output signals on a plurality of subcarriers... | Defendant’s 802.11ac compatible devices provide communication apparatuses with antennas and a transmitter that outputs signals on multiple subcarriers. | ¶38 | col. 3:1-14 |
| wherein: the transmitter is configured to provide the output signals in response to a plurality of input signals and limited feedback information; | The transmitter in the accused devices provides output signals in response to input signals and limited feedback information received from a receiver. | ¶38 | col. 2:44-48 |
| the limited feedback information includes interpolation information and beamforming vectors for a subset of the subcarriers; | The limited feedback information received by the accused devices includes interpolation information and beamforming vectors for a subset of the subcarriers. | ¶38 | col. 15:13-17 |
| the transmitter is configured to derive beamforming vectors for at least one subcarrier...not included in the subset based at least on an interpolation of the beamforming vectors for a subset of the subcarriers; | The transmitter in the accused devices is configured to derive the remaining beamforming vectors by interpolating the vectors received for the subset of subcarriers. | ¶38 | col. 15:18-24 |
| the interpolation information includes phase values. | The interpolation information used by the accused devices includes phase values. | ¶38 | col. 16:1-2 |
’595 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A MIMO signal transmitter, comprising: at least two vector multipliers, each vector multiplier configured to weight a respective input signal with a vector to form a weighted signal; and at least two antennas comprising a transmit array... | Defendant’s 802.11n compatible devices provide MIMO signal transmitters with vector multipliers to weight input signals and a transmit array to transmit the weighted signals. | ¶65 | col. 16:4-14 |
| wherein each vector is computed using a unit magnitude decomposition of a transmission channel matrix; | The vectors used for weighting are computed using a unit magnitude decomposition of the transmission channel matrix. | ¶65 | col. 11:50-54 |
| and wherein the unit magnitude decomposition includes decomposing at least a portion of the transmission channel matrix into a unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane. | This decomposition involves creating a unitary matrix whose eigenvalues are substantially on the unit circle of a complex plane. | ¶65 | col. 12:8-12 |
Identified Points of Contention
- For the ’007 Patent, a central technical question may be whether the feedback mechanism implemented in the accused 802.11ac devices constitutes "interpolation information" that "includes phase values" as required by the claim. The dispute may focus on whether the standard's feedback reduction scheme explicitly provides or implicitly allows for the derivation of phase values for the specific purpose of interpolation, or if it uses a fundamentally different, non-infringing technique.
- For the ’595 Patent, the infringement analysis may turn on the precise mathematical definition of "unit magnitude decomposition." A key point of contention could be whether the signal processing algorithms used in the accused 802.11n devices perform a matrix decomposition that results in a "unitary matrix with eigenvalues that lie substantially on a unit circle," as the claim requires. The interpretation of "substantially" could be a focal point for claim construction and expert testimony.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
For the ’007 Patent
- The Term: "interpolation information"
- Context and Importance: This term is central to the claimed invention, distinguishing it from systems that simply use a smaller set of feedback vectors without a defined interpolation scheme. Practitioners may focus on this term because the infringement allegation depends on whether the data sent back in the 802.11ac protocol contains information that fits this definition, particularly the requirement that it "includes phase values."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses the feedback of "parameters for interpolation" generally, which could support a construction that is not limited to a single, explicit data field (’007 Patent, col. 4:8-12).
- Evidence for a Narrower Interpretation: The claim language itself links "interpolation information" directly to "phase values." The abstract also refers to "additional parameters for phase rotation," suggesting that this is a specific and necessary component of the claimed information, potentially narrowing its scope to explicit phase data (’007 Patent, Abstract).
For the ’595 Patent
- The Term: "unit magnitude decomposition"
- Context and Importance: This is a specific mathematical operation that defines the core of the claimed transmitter. The infringement analysis will depend entirely on whether the algorithms implemented in the accused devices fall within the technical scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself defines the term by its outcome: decomposing the channel matrix into a "unitary matrix with eigenvalues that lie substantially on a unit circle." The use of "substantially" may support a construction that is not rigidly tied to a single mathematical formula and allows for minor deviations.
- Evidence for a Narrower Interpretation: The specification describes the process in the context of specific matrix operations, such as QR decomposition ("H=QR"), which could be argued to limit the term to that specific class of mathematical procedures (’595 Patent, col. 12:3-4).
VI. Other Allegations
Indirect Infringement
- The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is primarily based on allegations that Defendant provides instructions, user manuals, advertising, and technical support that direct and encourage end-users to operate the Accused Products in their normal, infringing modes (Compl. ¶41-44, ¶68-71).
Willful Infringement
- Willfulness is alleged for multiple patents based on two theories. First, the complaint alleges Defendant was willfully blind to Plaintiff's patent rights due to a "policy or practice of not reviewing the patents of others." Second, it alleges actual knowledge of the patents and infringement "since at least the time of receiving the original complaint" (Compl. ¶39-40, ¶66-67).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of algorithmic correspondence: do the signal processing and power management functions, as implemented in standard-compliant 802.11ac, 802.11n, 5G, and Bluetooth chipsets within the accused products, perform the specific, and in some cases mathematically-defined, steps required by the asserted claims, or do they achieve similar outcomes through technically distinct methods?
- A key evidentiary question will be one of proof of practice: beyond alleging compliance with technical standards, what evidence will be presented to demonstrate that the accused devices actually practice the claimed inventions? This may require moving the analysis from high-level standards documents to the specific implementation choices made in the hardware and software of the accused products.
- A third question will be one of definitional scope, particularly for claim terms rooted in mathematics such as "unit magnitude decomposition" (’595 patent) and functional data types like "interpolation information" (’007 patent). The case may turn on whether the court construes these terms narrowly to specific algorithms and data structures described in the patents, or more broadly to cover the functional equivalents allegedly used in the accused devices.