CelluPlex LLC v. Motorola Moblity LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CelluPlex LLC (New Mexico)
  • Defendant: Motorola Mobility LLC (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:24-cv-09091, N.D. Ill., 09/27/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant has an established place of business in the District, has committed acts of patent infringement in the District, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that certain unspecified Motorola products infringe a patent related to technology for interfacing a cellular telephone with a wired telephone network.
• Technical Context: The technology at issue enables a cellular phone to act as a wireless conduit for a traditional wired phone system, allowing users to make and receive cellular calls on standard home or office telephones.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No other procedural events such as prior litigation or post-grant proceedings are mentioned.

Case Timeline

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

U.S. Patent No. 7,177,664 - “Bluetooth interface between cellular and wired telephone networks,” issued February 13, 2007

The Invention Explained

• Problem Addressed: The patent describes a common inconvenience for cellular phone users at home or in an office: they often prefer to use a conventional wired telephone but cannot receive calls made to their cellular number on that device. This forces them to locate their cellular phone to answer calls or retrieve it from a briefcase or charging cradle to make an outgoing call. (Compl., Ex. 1, ’664 Patent, col. 1:11-28).
• The Patented Solution: The invention is an "interconnect device" that forges a link between a cellular phone and a wired telephone system using a short-range radio protocol like Bluetooth. The device emulates a traditional telephone "trunk line," allowing a user to pick up any standard wired telephone on the network to make or receive calls that are routed through the nearby cellular phone and its network. (’664 Patent, Abstract; col. 2:34-46; Fig. 1). The system thereby leverages the convenience and features of a wired phone system for cellular communications. (’664 Patent, col. 2:25-39).
• Technical Importance: This approach unifies a user's communications, allowing them to use a single cellular number while taking advantage of the superior ergonomics, audio quality, and multi-user features of a wired telephone system when at a fixed location. (’664 Patent, col. 2:25-39).

Key Claims at a Glance

The complaint does not identify any specific claims asserted against the Defendant. It alleges infringement of "one or more claims" and refers to "Exemplary '664 Patent Claims" detailed in an exhibit that was not filed with the complaint. (Compl. ¶¶11, 13).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, methods, or services in its text. It refers to "Exemplary Defendant Products" that are identified in charts within Exhibit 2, an exhibit that was not provided with the publicly filed complaint. (Compl. ¶¶11, 13).

Functionality and Market Context

The complaint does not provide any description of the accused products' functionality or market position, stating only that they "practice the technology claimed by the '664 Patent." (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are not detailed in the body of the document. Instead, it states that "Exhibit 2 includes charts comparing the Exemplary '664 Patent Claims to the Exemplary Defendant Products" and that these charts demonstrate that the products "satisfy all elements" of the asserted claims (Compl. ¶¶13-14). As Exhibit 2 was not provided, a detailed analysis of the infringement theory is not possible based on the filed complaint. The complaint alleges direct infringement by Defendant for making, using, selling, and importing the accused products, and also by its employees for internally testing and using them (Compl. ¶¶11-12).

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as it fails to identify which specific claims of the ’664 Patent are being asserted. (Compl. ¶¶11, 13).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain factual allegations to support a claim for indirect infringement.
• Willful Infringement: The complaint does not contain factual allegations to support a claim for willful infringement, though the prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285. (Compl. ¶E.i).

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

Based on the sparse initial pleading, the primary questions in the early stages of this case will be procedural and foundational before turning to technical substance.

• A primary question will be one of specificity: Following discovery, which specific Motorola products will be accused, and what precise features of those products are alleged to map onto the patent's limitations for creating a bridge between a cellular device and a separate telephone system?
• A second core issue will be one of claim scope: Once the asserted claims are identified, a key question will be how broadly terms like "wired telephone network" and "interconnect device" are construed, and whether the accused technology, which may operate in a modern VoIP or software-based ecosystem, falls within the scope of claims written in the context of early-2000s hardware (e.g., PBX systems, POTS lines).