Hanger Solutions LLC v. Mediacom Communications Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hanger Solutions, LLC (Georgia)
  • Defendant: Mediacom Communications Corp (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 4:22-cv-00152, M.D. Ga., 09/28/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and the accused infringing activities occur within the State of Georgia.
• Core Dispute: Plaintiff alleges that Defendant’s website infrastructure and high-speed internet services infringe five patents related to network configuration management, domain name-based routing, and secure data communication.
• Technical Context: The patents-in-suit address foundational challenges in computer networking, such as efficient software configuration, IP address conservation, and on-demand key generation, which are core technologies for operating large-scale internet services.
• Key Procedural History: The complaint notes that Certificates of Correction were issued for U.S. Patent Nos. 6,772,227 and 6,868,160. No other significant procedural events are mentioned.

Case Timeline

Date	Event
1996-11-15	’098 Patent Priority Date
1998-01-29	’171 Patent Priority Date
1999-11-08	’160 Patent Priority Date
1999-11-08	Defendant Mediacom incorporated
2000-01-27	’623 Patent Priority Date
2000-08-01	’098 Patent Issue Date
2000-09-12	’171 Patent Issue Date
2002-05-16	’227 Patent Priority Date
2002-08-06	’623 Patent Issue Date
2004-08-03	’227 Patent Issue Date
2005-03-15	’160 Patent Issue Date
2007-06-05	’227 Patent Certificate of Correction Issued
2009-01-27	’160 Patent Certificate of Correction Issued
2022-09-28	Complaint Filing Date

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

U.S. Patent No. 6,098,098 - "System For Managing The Configuration Of Multiple Computer Devices"

The Invention Explained

• Problem Addressed: The patent describes the difficulty of maintaining proper and consistent software configurations across numerous computer devices in a network, especially after their initial setup. Conventional methods that require downloading entire configuration files for every update are inefficient and waste network bandwidth, particularly when the files are already present on the local device. (’098 Patent, col. 1:26–2:24).
• The Patented Solution: The invention proposes a centralized management system where a network file server stores "master" configuration information. Each "managed device" periodically connects to the server and compares data characterizing its local configuration (e.g., file version, size, date) with data characterizing the master configuration, without transferring the entire file. Only if this comparison reveals a difference are the updated components transferred from the server to the device, which then revises its own configuration. (’098 Patent, Abstract; col. 3:1-13).
• Technical Importance: This system enabled a bandwidth-efficient, centralized method for managing configurations of geographically dispersed devices, a crucial capability for scalable network systems like wireless messaging networks. (’098 Patent, col. 1:40-44).

Key Claims at a Glance

• The complaint asserts at least independent method claim 10. (Compl. ¶¶ 30-31).
• Essential elements of Claim 10 include:
  • providing a first computer storing a first set of configuration data and a second computer storing a second set of configuration data for the first computer.
  • establishing a network connection between the two computers.
  • comparing data characterizing the first and second sets of information to determine if they are different, performed without sending the second set of information to the first computer.
  • sending at least one component of the second set of information to the first computer only when the comparison determines they are different.
  • configuring the first computer using the sent information.

U.S. Patent No. 6,119,171 - "Domain Name Routing"

The Invention Explained

• Problem Addressed: The patent addresses the problem of IP address depletion in the rapidly growing Internet. It notes that existing solutions like Network Address Translation (NAT) were limited because they primarily supported communications initiated from a private network to the public internet, making it difficult for external entities to initiate contact with a specific host inside a private network. (’171 Patent, col.2:42-48).
• The Patented Solution: The invention discloses a "Domain Name Router" (DNR) that acts as a gateway for a private network. An external entity sends a data packet to the DNR's single global IP address. Critically, this packet contains embedded information representing the domain name of the specific target host within the private network. The DNR receives the packet, extracts the domain name, translates that name into a non-global, local IP address, and forwards the packet to the correct internal host. (’171 Patent, Abstract; col. 3:19-28).
• Technical Importance: This method allowed an organization to operate numerous internal hosts with private, non-unique IP addresses while remaining reachable from the global internet via a single (or few) global IP address, thereby conserving the scarce supply of public IP addresses. (’171 Patent, col. 3:4-14).

Key Claims at a Glance

• The complaint asserts at least independent method claim 1. (Compl. ¶¶ 41-42).
• Essential elements of Claim 1 include:
  • receiving a data unit that includes a destination address and a first set of information representing a first domain name.
  • The destination address corresponds to a set of two or more entities, while the domain name corresponds to a specific first entity within that set.
  • translating the first domain name to a first address that corresponds only to the first entity.
  • sending the data unit to the first entity using that first address.

U.S. Patent No. 6,430,623 - "Domain Name Routing"

• Technology Synopsis: A continuation of the '171 patent, the '623 patent focuses on a method for enabling communication with an entity inside a private network, where the communication is initiated from outside the private network. The method uses a unique identifier (e.g., a URL) below the application layer to identify the specific target entity, which does not itself have a globally unique address. (Compl. ¶53; ’623 Patent, col. 13:25-40).
• Asserted Claims: At least independent claim 1. (Compl. ¶52).
• Accused Features: The complaint alleges that Defendant's Website Infrastructure provides a method for communicating with entities (e.g., domains on web servers) in its private network (e.g., a DMZ) by using a unique identifier (e.g., a URL) with protocols like TLS. (Compl. ¶53).

U.S. Patent No. 6,772,227 - "Communicating Between Address Spaces"

• Technology Synopsis: This patent describes a method for routing a message from a first address space (e.g., public internet) to a second address space (e.g., a private network). A message is received containing both a destination network address (for an intermediate entity) and a separate identification of the final target entity, which is not routable in the first address space. The system uses this identification to determine the target's address within the second space. (’227 Patent, col. 13:51-67).
• Asserted Claims: At least independent claim 1. (Compl. ¶63).
• Accused Features: The complaint accuses Defendant's Website Infrastructure of receiving messages (packets) that include a destination network address and an identification of a second entity (e.g., a subdomain like sso.mediacomcable.com) to determine a destination address on a private subnet (e.g., a DMZ). (Compl. ¶64).

U.S. Patent No. 6,868,160 - "System And Method For Providing Secure Sharing Of Electronic Data"

• Technology Synopsis: This patent discloses a system for generating public-private encryption key pairs algorithmically and on-demand, without requiring a central authority to store and manage keys or certificates. The system uses one or more unique attributes of an individual (e.g., a phone number or PIN) as input to generate the keys. (’160 Patent, Abstract).
• Asserted Claims: At least independent claim 8. (Compl. ¶74).
• Accused Features: The complaint alleges Defendant's Website Infrastructure infringes by providing a service that receives a key generation request (e.g., via a TLS handshake), uses a unique attribute associated with a user's device (allegedly via ECDHE protocol), generates a public/private key pair, and provides it to the device. (Compl. ¶75).

III. The Accused Instrumentality

Product Identification

• The "Mediacom Website Infrastructure," which encompasses the websites "mediacom.com" and "mediacomcable.com", along with related internal systems, architecture, and infrastructure. (Compl. ¶20).

Functionality and Market Context

• The complaint alleges this infrastructure is used to advertise, sell, and support Mediacom's "Xtream high speed internet access services" for its customers. (Compl. ¶21). The technical functionalities accused of infringement include methods for managing computer configurations, routing data based on domain names between public and private networks, and generating cryptographic keys for secure communications, allegedly using protocols such as TLS and ECDHE. (Compl. ¶¶ 31, 42, 53, 64, 75).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'098 Patent Infringement Allegations

Claim Element (from Independent Claim 10)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing at least one first computer storing first information for configuring said first computer;	Defendant's Website Infrastructure provides a first computer that stores a first set of data for configuring itself.	¶31	col. 2:57-63
providing a second computer storing second information for configuring said first computer;	The infrastructure provides a second computer that stores a second set of data for configuring the first computer.	¶31	col. 2:60-64
comparing data characterizing said first information with data characterizing said second information...to determine if said first and second information is different from each other when said first and second computers are connected without sending said second information to said first computer;	The infrastructure compares the first set of data with the second set of data to determine if the data sets are different, without sending the second set of data to the first computer.	¶31	col. 6:53-65
sending at least one component of said second information from said second computer to said first computer when said first and second information are determined different from each other by said comparing means;	The infrastructure sends at least one component of the second set of data to the first computer when the comparison determines the data sets are different.	¶31	col. 7:1-6
and configuring said first computer in accordance with said sent second information.	The infrastructure configures the first computer in accordance with the second set of data.	¶31	col. 8:1-4

• Identified Points of Contention:
  • Scope Questions: A primary issue is whether the routine process of deploying software updates to servers in Mediacom's infrastructure constitutes the specific method claimed. The analysis will focus on whether the term "comparing data characterizing" the information, as taught by the patent to conserve bandwidth, can be read to cover modern, automated deployment scripts, which may or may not perform such a preliminary comparison before transferring files.
  • Technical Questions: What evidence demonstrates that the accused infrastructure performs a comparison "without sending the second set of data"? Proving this negative limitation will be a key evidentiary burden for the plaintiff. The court will need to examine the actual data flows in Mediacom's system to determine if a characterization/metadata comparison occurs separately from and prior to a full data transfer.

'171 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving a data unit, said data unit includes a destination address and a first set of information representing a first domain name...	The Website Infrastructure receives a data unit (e.g., data packet) that includes a destination address (e.g., IP address 68.66.66.193) and information representing a domain name (e.g., mediacomcable.com).	¶42	col. 3:30-36
...said destination address corresponds to each entity in a set of two or more entities, said domain name corresponds to a first entity in said set of entities;	The destination address is alleged to correspond to multiple entities (e.g., www.mediacomcable.com and sso.mediacomcable.com), while the domain name corresponds to a first entity (e.g., a WWW server).	¶42	col. 3:4-14
translating said first domain name to a first address, said first address corresponds to said first entity and does not correspond to any other entity in said set of entities;	The infrastructure translates the first domain name to a first address (e.g., using a DMZ) that corresponds to the first entity and not others in the set.	¶42	col. 13:36-40
and sending said data unit to said first entity using said first address.	The infrastructure sends the data unit to the first entity using that first address (e.g., via a TLS connection).	¶42	col. 13:36-40

• Identified Points of Contention:
  • Scope Questions: Does the term "entity," as used in the claim, refer to physically distinct servers, or can it be interpreted more broadly to mean different virtual hosts or services running on the same hardware? The viability of the infringement theory may depend on whether a single IP address is shown to serve multiple truly distinct "entities."
  • Technical Questions: The complaint's reference to TLS (Compl. ¶42) suggests a potential reliance on the Server Name Indication (SNI) protocol, where a client indicates the hostname it is trying to reach during the TLS handshake. A key technical question will be whether using SNI to direct traffic behind a single IP address constitutes the claimed steps of "receiving a data unit" with embedded domain name information and "translating" that name to an address.

V. Key Claim Terms for Construction

For the '098 Patent:

• The Term: "data characterizing said... information"
• Context and Importance: This term is the linchpin of the patent's claimed efficiency. Infringement will likely depend on whether this term is construed to mean specific metadata (like file versions or checksums) as opposed to merely the file's existence or name. Practitioners may focus on this term because it distinguishes the invention from simply overwriting files with new versions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines "computer file related information" to include a wide array of metadata, such as "file names, file creation date, last file modification data, file size, file type, file check codes, and file versions," suggesting the term could cover any of these characteristics. (’098 Patent, col. 4:26-32).
  • Evidence for a Narrower Interpretation: The overall purpose described is to "minimize network bandwidth usage." (’098 Patent, col. 2:23-24). A party might argue this purpose implies the "data characterizing" must be substantially smaller than the information itself and sufficient to determine if a transfer is needed, potentially excluding simple name-based checks.

For the '171 Patent:

• The Term: "translating said first domain name to a first address"
• Context and Importance: This is the core functional step of the claimed routing method. The outcome of the case may depend on whether this term is construed to cover modern, standard practices like SNI-based routing or if it is limited to the specific "Domain Name Router" (DNR) embodiment described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract broadly describes the process as the DNR "extracts the destination's domain name from the data, translates that domain name to a local address and sends the data to the destination," which could support an interpretation covering any process that uses a domain name to select a local IP address. (’171 Patent, Abstract).
  • Evidence for a Narrower Interpretation: The patent repeatedly describes a specific hardware component, the "Domain Name Router" or "DNR," as performing the invention. (’171 Patent, col. 3:15-18). A defendant could argue that "translating" must be performed by a device analogous to the disclosed DNR and its specific table look-up function (as shown in Fig. 11), not by a general-purpose web server handling a TLS handshake.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement, such as allegations that Defendant instructed others to infringe or provided components with knowledge of their infringing use. The counts are directed to Defendant's own alleged direct infringement.
• Willful Infringement: The complaint does not contain an explicit count for willful infringement or allege that Defendant had pre-suit knowledge of the patents-in-suit. The prayer for relief includes a request for a declaration of an exceptional case and attorneys' fees, but the factual allegations to support such a finding are not detailed in the body of the complaint. (Compl. ¶79.C).

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

• A key evidentiary question will be one of technical implementation: Can Plaintiff produce evidence that Mediacom’s modern, large-scale infrastructure operates using the specific, and now relatively dated, methods detailed in the patents? For example, does its configuration management system rely on comparing metadata to avoid bandwidth use as in the ’098 patent, or does it use different techniques? Similarly, does its use of TLS/SNI for routing traffic to virtual hosts map onto the specific "Domain Name Router" architecture of the '171 patent family?
• A core issue will be one of definitional scope: The case will likely turn on the construction of foundational networking terms like "translating," "entity," and "data characterizing." The central legal battle may be whether these terms, as understood in the context of the patents' 1990s-era disclosures, can be construed broadly enough to read on the functionality of common, standardized Internet protocols and infrastructure that are now ubiquitous, or if such an interpretation would improperly extend the claims beyond their original scope.