DCT

0:25-cv-62665

Integral Wireless Tech LLC v. MW Intl Ventures LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:25-cv-62665, S.D. Fla., 12/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established and regular place of business in the district and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s enterprise mobility solutions, including servers and a wide range of mobile devices, infringe seven patents related to wireless power management, user behavior tracking, data coding, network data flow, and hierarchical data processing.
  • Technical Context: The asserted technologies span mobile device power saving, personalized online content delivery, and efficient data transmission and processing, which are foundational to modern enterprise and consumer mobile computing.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, licensing history, or other significant procedural events related to the asserted patents.

Case Timeline

Date Event
2004-12-20 U.S. Patent No. 10,033,716 Priority Date
2005-06-08 U.S. Patent No. 7,627,805 Priority Date
2006-03-16 U.S. Patent No. 8,073,866 Priority Date
2006-08-16 U.S. Patent No. 8,031,654 Priority Date
2007-02-21 U.S. Patent No. 7,707,213 Priority Date
2007-02-21 U.S. Patent No. 7,707,214 Priority Date
2008-07-07 U.S. Patent No. 8,156,360 Priority Date
2009-12-01 U.S. Patent No. 7,627,805 Issue Date
2010-04-27 U.S. Patent No. 7,707,213 Issue Date
2010-04-27 U.S. Patent No. 7,707,214 Issue Date
2011-10-04 U.S. Patent No. 8,031,654 Issue Date
2011-12-06 U.S. Patent No. 8,073,866 Issue Date
2012-04-10 U.S. Patent No. 8,156,360 Issue Date
2018-07-24 U.S. Patent No. 10,033,716 Issue Date
2025-07-18 NEXA announces acquisition of Sonim Technologies
2025-10-16 Social Mobile rebrands to NEXA
2025-12-24 Complaint Filing Date

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

U.S. Patent No. 8,156,360 - *"Systems and Methods for Waking Wireless LAN Devices"*

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of remotely "waking up" wireless computing devices from low-power sleep modes for administrative tasks like data backups or software updates, a problem that had been largely solved for wired networks but was complex in wireless environments. (’360 Patent, col. 1:25-2:2).
  • The Patented Solution: The invention describes a method where a device in a low-power state periodically activates its wireless network controller for a brief "monitor timeframe" to scan for a specific wake-up packet addressed to it. If the packet is found, the controller signals the device to wake to full power; if not, the controller powers down again to conserve energy until the next timeframe, avoiding the need to maintain a constant, power-draining connection to a wireless access point. (’360 Patent, Abstract; col. 3:1-15).
  • Technical Importance: This approach sought to extend the power management and remote administration capabilities of wired networks to the increasingly prevalent wireless device ecosystem, balancing battery conservation with network manageability. (’360 Patent, col. 2:54-67).

Key Claims at a Glance

  • The complaint asserts independent claim 8 and dependent claims 11 and 14. (Compl. ¶31).
  • The essential elements of independent claim 8 (an apparatus claim) include:
    • A controller configured to monitor a plurality of wireless channels for a wake-up packet addressed to a wireless device during a monitor timeframe.
    • The wake-up packet is configured to cause the device to transition from a first (lower) power mode to a second (higher) power mode.
    • The controller is configured to initiate this transition when the addressed wake-up packet is received before the monitor timeframe elapses.
    • The controller is configured to cease monitoring the channels if the packet is not received after the monitor timeframe has elapsed.
  • The complaint states it asserts "at least" these claims, reserving the right to assert others. (Compl. ¶31).

U.S. Patent No. 10,033,716 - *"Method and Device for Publishing Cross-Network User Behavioral Data"*

The Invention Explained

  • Problem Addressed: The patent describes the limitations of server-side user tracking for targeted advertising. Such systems could only collect behavioral data from a limited "network" of cooperating websites, resulting in an incomplete profile of a user's interests across the broader internet. (’716 Patent, col. 1:24-51).
  • The Patented Solution: The invention proposes a client-side solution where a "behavior watcher" program resides on the user's computer. This program monitors browsing activity across all websites, summarizes this behavior, and "publishes" it into a data structure (e.g., a cookie) on the client machine. When the user visits a partner website, that site's server can access and decode this comprehensive, client-side summary to deliver more accurately targeted advertising. (’716 Patent, Abstract; Fig. 1).
  • Technical Importance: This technology represented a shift from fragmented, server-side user profiling to a more holistic, client-side model, potentially enabling more precise ad targeting by capturing behavior across the entire web rather than within a single ad network's domain. (’716 Patent, col. 1:52-62).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claim 3. (Compl. ¶58).
  • The essential elements of independent claim 1 (a method claim performed by a server) include:
    • Receiving one or more memory structures from a client computer containing "published summarized cross-network user behavior data."
    • This data is described as having been collected from the user's interactions with multiple websites, summarized on the client computer, and published to the memory structures on the client computer.
    • Decoding the memory structures.
    • Determining a message or advertisement to send based on the decoded data.
    • Customizing the message/advertisement to be responsive to the summarized data.
    • Sending the customized message/advertisement to the user's browser.
  • The complaint states it asserts "at least" these claims. (Compl. ¶58).

U.S. Patent No. 8,073,866 - *"Method for Providing Content to an Internet User Based On the User's Demonstrated Content Preferences"*

  • Technology Synopsis: The patent describes a method for delivering personalized content. A server receives an encrypted summary of a user's navigation history from the user's computer, where the summary is organized according to a first categorization system. The server uses a "profile library" to map this summary to its own, distinct content categorization system, allowing it to identify the user's preferences and deliver matching content. (Compl. ¶65, 69).
  • Asserted Claims: At least claim 1 (independent method). (Compl. ¶68).
  • Accused Features: The "NEXA System," which is alleged to be a server system performing the claimed method. (Compl. ¶69).

U.S. Patent No. 7,627,805 - *"Data Coding with an Efficient LDPC Encoder"*

  • Technology Synopsis: The patent addresses improving data transmission efficiency through a method of Low-Density Parity-Check (LDPC) encoding. The invention generates a codeword for transmission from a "mother code parity check matrix" and a "macro matrix," a technique used for forward error correction in communication systems. (Compl. ¶92, 96).
  • Asserted Claims: At least claims 1, 2, and 3 (claim 1 is an independent method). (Compl. ¶95).
  • Accused Features: "NEXA 5G Devices and NEXA 802.11n/ac/ax Wi-Fi Devices," which allegedly perform data coding for transmission. (Compl. ¶96).

U.S. Patent No. 8,031,654 - *"Wireless Communication System, Apparatus for Supporting Data Flow and Methods Therefor"*

  • Technology Synopsis: This patent aims to improve the efficiency of TCP-based data transfers in wireless systems. It describes a method where a network entity, upon sending a data segment to a wireless unit, proactively allocates not only the necessary downlink resources but also pre-allocates sufficient uplink resources for the unit to transmit a stand-alone acknowledgement (ACK) segment back, streamlining the process. (Compl. ¶119, 123).
  • Asserted Claims: At least claims 5, 6, and 8 (claim 5 is an independent apparatus). (Compl. ¶122).
  • Accused Features: "NEXA 4G/5G Devices." (Compl. ¶123).

U.S. Patent No. 7,707,213 - *"Hierarchical Update Scheme for Extremum Location"*

  • Technology Synopsis: The patent discloses a method to improve data processing efficiency by organizing data into a hierarchical structure of partitions. Each level in the hierarchy stores "extrema" (e.g., minimum or maximum values) for the group of partitions in the level below it. This enables efficient updates, as a change to a single data value only requires recalculating extrema in the affected hierarchical path rather than reprocessing the entire dataset. (Compl. ¶146, 150).
  • Asserted Claims: At least claims 16, 17, and 20 (claim 16 is an independent method). (Compl. ¶149).
  • Accused Features: "NEXA HEVC Devices," which are alleged to perform methods for generating and updating data. (Compl. ¶150).

U.S. Patent No. 7,707,214 - *"Hierarchical Update Scheme for Extremum Location with Indirect Addressing"*

  • Technology Synopsis: Related to the ’213 patent, this invention also describes a hierarchical data structure for efficient identification and updating of extrema. This method focuses on using "indirect addressing," where the hierarchy stores indices pointing to the locations of the extrema within the data partitions, rather than storing the extrema values themselves. (Compl. ¶173, 177).
  • Asserted Claims: At least claims 15, 16, and 19 (claim 15 is an independent method). (Compl. ¶176).
  • Accused Features: "NEXA HEVC Devices." (Compl. ¶177).

III. The Accused Instrumentality

Product Identification

The complaint names a wide array of products, categorized as the "NEXA System" (a server system) and various device families including "NEXA 5G Devices," "NEXA 4G/5G Devices," "NEXA 802.11n/ac/ax Wi-Fi Devices," "NEXA HEVC Devices," and "NEXA Bluetooth Devices" (Compl. ¶21). These categories encompass numerous specific mobile phones, tablets, and mobile hotspots marketed under the RHINO and Sonim brands. (Compl. ¶¶ 5, 21).

Functionality and Market Context

The accused products are part of an "enterprise mobility" portfolio. (Compl. ¶5). The NEXA System is identified as a server system that allegedly performs methods related to user data analysis and content delivery. (Compl. ¶¶ 59, 69). The various accused devices are alleged to be enterprise-grade mobile products that incorporate wireless communication standards (Bluetooth, Wi-Fi, 4G/5G), video coding standards (HEVC), and associated hardware and software for power management and data processing. (Compl. ¶¶ 5-6, 32, 96, 123, 150). Defendant NEXA is positioned as a provider of custom devices and IoT solutions for major companies in sectors such as healthcare, transportation, and retail. (Compl. ¶5).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'360 Patent Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
an apparatus comprising: a controller configured to monitor a plurality of wireless channels for a wake-up packet addressed to a wireless device during a monitor timeframe, The accused NEXA Bluetooth Devices allegedly provide an apparatus with a controller that monitors for wake-up packets. ¶32 col. 4:47-52
wherein the wake-up packet is configured to cause the wireless device to initiate a transition from operating in a first power mode to operating in a second power mode, The alleged wake-up packet is configured to cause a transition between power modes. ¶32 col. 4:53-56
wherein the controller is configured to initiate the transition from operating the wireless device in the first power mode to operating the wireless device in the second power mode when a wake-up packet addressed to the wireless device has been received before the monitor timeframe has elapsed, The controller allegedly initiates the power mode transition upon receiving the packet within the timeframe. ¶32 col. 4:57-62
and wherein the controller is configured to cease to monitor the plurality of wireless channels when a wake-up packet addressed to the wireless device has not been received after the monitor timeframe has elapsed. The controller allegedly ceases monitoring if the packet is not received after the timeframe elapses. ¶32 col. 4:63-67

'716 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving, by the server, one or more memory structures that include published summarized cross-network user behavior data from a client computer, wherein the published summarized cross-network user behavior data includes: collected cross-network user behavior data related to a user's interactions with a plurality of web sites on the client computer, the collected cross-network user behavior data being summarized on the client computer, and the summarized collected cross-network user behavior data published to the one or more memory structures on the client computer; The accused NEXA System, a server, allegedly receives memory structures containing user behavior data that was collected, summarized, and published on a client computer. ¶59 col. 12:53-64
decoding, by the server, the one or more memory structures; The NEXA System allegedly decodes the received memory structures. ¶59 col. 13:1-2
determining, by the server, at least one of a message or advertisement to send to a browser of the client computer based on the decoded one or more memory structures; The NEXA System allegedly determines a message or advertisement based on the decoded data. ¶59 col. 13:3-5
customizing, by the server, the at least one of the message or advertisement to be responsive to the summarized cross-network user behavior data; and The NEXA System allegedly customizes the message or advertisement to be responsive to the user data. ¶59 col. 13:6-8
sending, by the server, the customized at least one of the message or advertisement responsive to the summarized cross-network user behavior data. The NEXA System allegedly sends the customized message or advertisement. ¶59 col. 13:9-12

Identified Points of Contention

  • '360 Patent: The infringement allegation centers on the specific operational logic of the accused Bluetooth devices' low-power modes. A potential point of contention is whether the standard power-saving protocols used in these devices perform the specific, claimed sequence of monitoring for a defined "monitor timeframe" and then ceasing to monitor if no packet is received. This raises the question of what evidence the complaint provides that the accused devices' general power-saving cycles meet the specific functional requirements of the claim.
  • '716 Patent: The claim requires the accused server (the "NEXA System") to receive user behavior data that was previously collected, summarized, and published on the client computer across multiple web networks. A potential dispute may arise over the source and nature of the data processed by the NEXA System. The analysis raises the question of whether the complaint alleges facts to support that the accused system operates on data generated by a client-side "behavior watcher" as described in the patent, or if it relies on more conventional server-side data aggregation techniques.

V. Key Claim Terms for Construction

'360 Patent: "monitor timeframe" (Claim 8)

  • The Term: "monitor timeframe"
  • Context and Importance: This term is critical because it defines the temporal window for the low-power monitoring activity. Its construction will determine whether the claim requires a specific, finite period of scanning, after which monitoring must cease. Infringement may turn on whether the accused devices operate with such a defined timeframe or utilize a more generalized, continuous, or event-driven power-saving cycle. Practitioners may focus on this term because it appears to add a specific functional limitation beyond merely "periodically" waking up.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to scanning "for a predetermined time period," which could support an argument that any programmed or periodic interval for monitoring qualifies. (’360 Patent, col. 3:6-7).
    • Evidence for a Narrower Interpretation: The flowchart in Figure 7 explicitly shows a "SET TIMER TO TIME T" step (S230), which may support an argument that the "timeframe" must be a discrete, timer-controlled duration after which a specific "cease to monitor" action is taken, as opposed to an indefinite or continuous low-power scanning state.

'716 Patent: "published summarized cross-network user behavior data" (Claim 1)

  • The Term: "published summarized cross-network user behavior data"
  • Context and Importance: This term defines the specific type of data that the accused server must receive to infringe. Its construction is central to the dispute, as it requires the data to originate from client-side summarization of behavior across multiple, unaffiliated web domains. The case may hinge on whether the data processed by the NEXA System meets this multi-part definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification notes that the data may be "published" to "cookies or similar memory structures," a common mechanism for transferring user data. (’716 Patent, col. 10:7-9). This could support an argument that receiving any aggregated user data via cookies falls within the claim scope.
    • Evidence for a Narrower Interpretation: The detailed description emphasizes a "behavior watching program resident in the client computer" that "observes user interest across different search engines, web sites and even browsers." (’716 Patent, col. 4:39-42). This may support a narrower construction requiring data generated by a specific client-side software agent performing active, comprehensive monitoring and summarization, distinguishing it from the simple server-side aggregation of standard cookies set by different websites.

VI. Other Allegations

  • Indirect Infringement: For all seven asserted patents, the complaint alleges induced infringement. The allegations are based on Defendant providing user manuals, software releases, and device support guides that allegedly instruct customers and end-users on how to use the Accused Products in an infringing manner. (Compl. ¶¶ 22, 36-38, 59, 73-75). Contributory infringement is also alleged for all patents. (e.g., Compl. ¶¶ 41-45).
  • Willful Infringement: The complaint alleges willful infringement for all seven patents. The basis for willfulness is articulated on two grounds: (1) an alleged pre-suit "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (e.g., Compl. ¶33); and (2) alleged post-suit willfulness based on Defendant having "actual knowledge" of the patents from the date it received the complaint. (e.g., Compl. ¶34).

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

  • A central issue will be one of technical specificity: for patents covering specific methods in power management (’360), data coding (’805), and data structuring (’213, ’214), the case will likely examine whether the accused devices' implementation of broad industry standards (e.g., Bluetooth Low Energy, 5G LDPC, HEVC) performs the particular, and potentially narrower, sequence of steps required by the asserted claims.
  • A key evidentiary question will concern the locus of data processing: for the ad-tech patents (’716, ’866), the dispute may turn on demonstrating the origin and flow of user data. A core question is whether the accused "NEXA System" operates on user behavior data that is actively monitored, summarized, and published on the client device across disparate web networks, as the patents describe, or if it relies on data collected through more conventional server-side techniques.
  • A primary strategic question will be how the assertion of seven patents across at least five distinct technological fields will shape the litigation, suggesting a broad portfolio-level dispute rather than a focused conflict over a single inventive concept.