1:25-cv-22704
Lab Technology LLC v. 3CX USA Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lab Technology LLC (New Mexico)
- Defendant: 3CX USA Corp. (Florida)
- Plaintiff’s Counsel: Beusse Sanks; Rabicoff Law LLC
- Case Identification: 1:25-cv-22704, S.D. Fla., 06/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed acts of infringement in the district, and Plaintiff has suffered harm there.
- Core Dispute: Plaintiff alleges that Defendant’s telephony products infringe a patent related to systems and methods for mapping a single voice identity to multiple phone numbers based on time-based rules.
- Technical Context: The technology addresses call routing in complex telecommunications environments, aiming to make users with multiple devices (e.g., office phone, mobile phone, home phone) reachable through a single identifier.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2004-11-02 | ’102 Patent Priority Date |
| 2007-10-29 | ’102 Patent Application Filing Date |
| 2013-07-09 | ’102 Patent Issue Date |
| 2025-06-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,483,102 - "System and method for mapping a voice identity across multiple telephony networks with time attributes"
- Patent Identification: U.S. Patent No. 8,483,102, “System and method for mapping a voice identity across multiple telephony networks with time attributes,” issued July 9, 2013.
The Invention Explained
- Problem Addressed: The patent describes the inefficiency and confusion that arises when a person is associated with multiple telephone numbers (e.g., office, mobile, remote office). Callers must try several numbers to reach the user, and the user must check multiple voicemail systems, leading to lost time and potential miscommunication (’102 Patent, col. 1:26-43).
- The Patented Solution: The invention proposes a system where a user has a single "voice identity" that callers use. A central "policy processor" consults a "voice identity mapping policy" which contains rules for routing calls. These rules can be based on time attributes (e.g., time of day, day of the week) to forward the call to the user’s currently active phone, such as a mobile phone after business hours or on weekends (’102 Patent, Abstract; col. 4:6-21). Figure 2 illustrates the core data structure, mapping a "Search Voice Identity" (202) to a "Target Voice Identity" (204) based on "Time Attributes" (206).
- Technical Importance: The system aims to provide a transparent way for a caller to reach a user through a single identifier, abstracting away the complexity of the user’s multiple devices and locations (’102 Patent, col. 2:20-23).
Key Claims at a Glance
The complaint asserts infringement of one or more unspecified claims of the ’102 Patent (Compl. ¶11). Independent claim 1 is representative of the patented system:
- one or more phone systems for providing voice services via telephony switches;
- at least one policy processor coupled to the telephony switches; and
- at least one voice identity mapping policy stored in a data storage accessible to the policy processor, comprising:
- a plurality of search voice identities mapped to one or more target voice identities, applicable to a plurality of users, and
- time attributes indicating when the mapping policies are valid.
- The system operates such that the policy processor receives a voice identity, matches it to a search voice identity, maps it to a target voice identity according to the policy, and sends the target voice identity to the telephony switches to route the call.
- A key limitation requires that the voice identity, the search voice identity, and the target voice identity each "comprises a username."
III. The Accused Instrumentality
Product Identification
The complaint does not name specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in charts incorporated as Exhibit 2 (Compl. ¶¶11, 16). This exhibit was not filed with the complaint.
Functionality and Market Context
The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed in the ’102 Patent (Compl. ¶16). Without access to the specific product identifications or the infringement charts in Exhibit 2, the precise functionality accused of infringement cannot be described. The Defendant, 3CX USA Corp., is a known provider of IP PBX and unified communications software systems (Compl. ¶3).
IV. Analysis of Infringement Allegations
The complaint alleges that Defendant’s products satisfy all elements of the asserted claims but provides no specific factual allegations or narrative infringement theory in the body of the complaint (Compl. ¶16). Instead, it incorporates by reference "claim charts of Exhibit 2," which was not provided with the publicly filed document (Compl. ¶17). As a result, a detailed analysis of the infringement allegations is not possible.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The Term: "username"
Context and Importance: Claim 1 requires that the "voice identity," "given search voice identity," and "given target voice identity" each comprises a "username". The definition of this term will be critical to determining the scope of the claim, as it appears to be a central element of the identity being mapped. Practitioners may focus on this term because the infringement analysis will depend on whether the identifiers used in the accused 3CX system (e.g., phone numbers, SIP URIs, extension numbers) meet this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests "username" can be non-telephonic, stating it may comprise "an IM identity or an email account identity" or an "employee's computer user identity" (’102 Patent, col. 10:58-61). This could support an argument that any unique user identifier within a system qualifies.
- Evidence for a Narrower Interpretation: The overall context of the patent is telephony and call routing. A defendant may argue that, when read in light of the entire specification, "username" must be an identifier directly usable in a telephony context, rather than a more general-purpose computing or messaging ID. The patent’s abstract and summary focus on mapping identities to "telephone number[s]" (’102 Patent, Abstract; col. 2:27-28).
The Term: "policy processor"
Context and Importance: This is the core active component of the claimed system, responsible for matching identities and applying the mapping policy. The dispute will likely involve identifying which specific component of the accused 3CX architecture performs the functions of the "policy processor".
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "policy processor" in flexible terms, stating it can be "a software application executed in at least one of the phone systems' application server, a stand-alone computer..., or an application specific integrated circuit (ASIC)" (’102 Patent, col. 10:48-53). This supports a broad definition covering various software or hardware implementations.
- Evidence for a Narrower Interpretation: The claims require the "policy processor" to be "coupled to the telephony switches" and to perform a specific sequence of actions: receiving an identity, matching it, mapping it according to a policy with time attributes, and sending the result back to the switches (’102 Patent, col. 10:15-41). A defendant could argue that this functional definition requires a single, dedicated component that performs all recited steps, rather than a distributed set of software modules that collectively achieve the outcome.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '102 Patent" (Compl. ¶14).
- Willful Infringement: The complaint does not use the term "willful." However, it alleges that Defendant has "Actual Knowledge of Infringement" based on the service of the complaint itself (Compl. ¶13). This appears to lay the groundwork for a claim of post-filing willful infringement. The prayer for relief also requests that the case be declared "exceptional," which is often tied to findings of willfulness (Compl. p. 5, ¶E.i.).
VII. Analyst’s Conclusion: Key Questions for the Case
- Evidentiary Sufficiency: A threshold issue is the complaint's reliance on an unprovided exhibit for its core infringement allegations. The primary question will be whether the forthcoming infringement contentions provide sufficient evidence to demonstrate that the accused 3CX products perform the specific functions recited in the claims.
- Definitional Scope: The case may turn on claim construction, particularly whether the term "username" can be interpreted to read on the types of user identifiers (e.g., extension numbers, SIP addresses) employed in the accused system.
- Functional Mapping: A central technical question will be whether the architecture of the accused 3CX system contains a component or set of components that can be mapped to the claimed "policy processor" and whether that accused component performs the required function of routing calls based on policies that include "time attributes".