Lab Technology LLC v. Sangoma Tech US Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Sangoma Technologies US Inc. (Delaware)
  • Plaintiff’s Counsel: Beusse Sanks; Rabicoff Law LLC
• Case Identification: 1:25-cv-22717, S.D. Fla., 06/16/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Southern District of Florida and allegedly committing acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that certain unidentified products of the Defendant infringe a patent related to methods for obtaining the location of a mobile phone user for emergency or other location-based services.
• Technical Context: The technology addresses the challenge of providing accurate location information for emergency services (like E911) in an era of mobile and nomadic communication systems, such as cellular and Voice over IP (VoIP), where a user is not tied to a fixed physical address.
• Key Procedural History: The patent-in-suit claims priority back to an application filed in 2005, establishing an early priority date for the claimed technology. The patent is also subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier-expiring, related patent.

Case Timeline

Date	Event
2005-07-14	Earliest Patent Priority Date
2011-12-23	Patent Application Filing Date
2013-08-06	Patent Issue Date
2025-06-16	Complaint Filing Date

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

U.S. Patent No. 8,503,973 - Method and system for obtaining emergency caller location, issued August 6, 2013

The Invention Explained

• Problem Addressed: The patent’s background section describes the inadequacy of traditional emergency call systems, which rely on the fixed location of a landline, to handle calls from mobile technologies like cellular and VoIP phones. With these newer services, a user’s physical location can change, creating a "fairly complex problem" for dispatching emergency services that depend on knowing where a call originates (’973 Patent, col. 2:23-29).
• The Patented Solution: The invention discloses systems and methods for determining a caller's location in a mobile environment. A core concept involves a mobile device obtaining an identifier for its current network connection (e.g., a "wireless base station identity") and comparing it to a previously stored identifier. If they do not match, it indicates the device has moved. The device then obtains a new subscriber location corresponding to the new network connection and sends this updated location to a phone system, which can then use it for emergency dispatch or other location-based services (’973 Patent, Abstract; col. 11:10-28). Figure 3 illustrates a key component of this architecture: a "subscriber location query system" that receives an identity and returns a location record (’973 Patent, Fig. 3).
• Technical Importance: The described methods provide a technical framework to solve the critical public safety gap that emerged as telecommunications shifted from fixed, address-based landlines to nomadic VoIP and mobile cellular systems (’973 Patent, col. 2:55-59).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, stating only that Defendant infringes "one or more claims" and referring to "Exemplary '973 Patent Claims" in an unprovided exhibit (Compl. ¶11). Independent claim 1 is a representative method claim.
• Independent Claim 1 recites a method with the following essential elements:
  • obtaining by the mobile phone a current wireless base station identity for a current wireless base station to which the mobile phone is coupled;
  • obtaining by the mobile phone a stored wireless base station identity;
  • determining by the mobile phone that the current wireless base station identity does not match the stored wireless base station identity;
  • obtaining by the mobile phone a subscriber location corresponding to the current base wireless station identity; and
  • sending the subscriber location by the mobile phone to the phone system.
• 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 or services. It refers generally to "Defendant products identified in the charts incorporated into this Count" as the "Exemplary Defendant Products" (Compl. ¶11). These charts are part of Exhibit 2, which was not filed with the complaint document.

Functionality and Market Context

• The complaint provides no specific details regarding the functionality or market position of the accused products. It alleges in a conclusory manner that the products "practice the technology claimed by the '973 Patent" and that all elements of the asserted claims are satisfied (Compl. ¶16). All factual support for this allegation is incorporated by reference from the unprovided Exhibit 2.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or detailed infringement allegations within its body, instead incorporating them by reference from "the attached claim charts" in Exhibit 2, which is not included in the provided court filing (Compl. ¶13, ¶16). Therefore, a detailed claim chart summary cannot be constructed.

The general infringement theory, based on the allegations and the representative claim, is that Defendant’s products constitute mobile phones or systems that perform the method of Claim 1. This involves detecting a change in location by comparing a current network identifier with a stored one, and upon detecting a mismatch, obtaining and transmitting an updated location to a phone system (Compl. ¶11; ’973 Patent, cl. 1).

The complaint references, but does not include, charts in Exhibit 2 that allegedly compare the patent claims to the accused products (Compl. ¶16). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Pleading Sufficiency: A threshold issue may be whether the complaint, by failing to identify any accused products or provide any factual allegations of infringement within its four corners and instead relying entirely on an external exhibit, meets the plausibility pleading standards required by federal court.
  • Scope Questions: The language "obtaining by the mobile phone" and "determining by the mobile phone" in Claim 1 raises the question of whether the claimed steps must be performed on the user's device itself. Infringement analysis will depend on whether the accused system performs these functions on the device or offloads them to a network server, which may not fall within the claim's scope.
  • Technical Questions: A key factual question will be whether the accused products actually perform the specific comparison recited in Claim 1—comparing a "current wireless base station identity" to a "stored wireless base station identity." The defense may argue its products use a different location-determination technology (e.g., GPS-based, Wi-Fi triangulation) that does not involve the claimed comparison of base station identifiers.

V. Key Claim Terms for Construction

• The Term: "wireless base station identity" (’973 Patent, cl. 1)
• Context and Importance: This term is the foundational piece of data used in the claimed method to detect a change in location. The outcome of the infringement analysis will likely depend on whether the specific network identifier(s) used by the accused products are encompassed by the court's construction of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses a variety of "subscriber access line" technologies, including not just radio networks but also copper loops and coaxial cables, and the "identity" that corresponds to them (’973 Patent, col. 4:13-16). A plaintiff may argue this context supports a broad interpretation of "identity" to cover various types of network-related identifiers beyond just traditional cellular base stations.
  • Evidence for a Narrower Interpretation: The claim language itself specifies a "wireless base station identity," and the term "base station" is a well-established term of art in cellular telecommunications. A defendant may argue this language limits the claim's scope to conventional cellular network identifiers (e.g., a Cell Global Identity) and excludes other types of wireless identifiers, such as a Wi-Fi network's SSID or a Bluetooth device address.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users" to use the products in an infringing manner (Compl. ¶14). The specific factual basis for this allegation is purportedly contained in the unprovided Exhibit 2.
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that Defendant has had "actual knowledge of infringement" from the moment of being served with the complaint and its accompanying claim charts (Compl. ¶13, ¶15). No allegations of pre-suit knowledge are made.

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

This case appears to be in its earliest stage, with the initial pleading presenting several fundamental questions that will shape the litigation.

1. A primary issue will be one of pleading sufficiency: Does a complaint that omits the identity of the accused products and the factual basis for infringement, instead incorporating them by reference to an external document, provide the "short and plain statement" required to survive a motion to dismiss?

2. A central dispute will be one of claim construction: Can the term "wireless base station identity," as used in the patent, be construed to cover the specific location-tracking technologies and network identifiers employed by Defendant's modern communication products?

3. The core evidentiary challenge for the Plaintiff will be one of operational proof: Assuming the case proceeds, can Plaintiff demonstrate that the accused products perform the precise sequence of steps recited in the claims—specifically, the determination of a location change via a comparison of a "current" and "stored" base station identity performed "by the mobile phone" itself?