DCT
1:25-cv-11609
Mesa Digital LLC v. Motorola Mobility LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Mesa Digital, LLC (New Mexico)
- Defendant: Motorola Mobility LLC (Delaware)
- Plaintiff’s Counsel: Ramey, LLP
- Case Identification: 2:23-cv-00836, N.D. Ill., 09/24/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Northern District of Illinois and has allegedly committed acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones infringe a patent related to handheld multimedia devices that incorporate multiple wireless communication technologies.
- Technical Context: The technology at issue concerns the architectural integration of various wireless transceivers—such as cellular, Wi-Fi, and Bluetooth—into a single handheld computing device.
- Key Procedural History: The patent-in-suit claims priority to provisional applications filed in 2000. No prior litigation or administrative proceedings involving the patent are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2000-06-27 | U.S. Patent No. 9,031,537 Priority Date |
| 2015-05-12 | U.S. Patent No. 9,031,537 Issues |
| 2025-09-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,031,537 - "Electronic wireless hand held multimedia device"
- Patent Identification: U.S. Patent No. 9,031,537, "Electronic wireless hand held multimedia device," issued May 12, 2015 (’537 Patent). (Compl. ¶6).
The Invention Explained
- Problem Addressed: The patent's background section, referencing the state of technology in 2000, states that Personal Digital Assistants (PDAs) and similar devices were not available that could connect to more than one type of wireless network for accessing multimedia data from sources like the Internet. (’537 Patent, col. 2:50-57). Specifically, devices lacked the inclusion of "more than one wireless transceiver module to enable remote access via 802.11, cellular, short/visible range (e.g., Bluetooth), infrared, and GPS resources." (’537 Patent, col. 2:57-63).
- The Patented Solution: The invention described is a handheld multimedia device architecture that integrates a microprocessor with "more than one wireless transceiver modules" to enable communications over a variety of standards, such as cellular, WLAN (802.11), and short-range protocols like Bluetooth. (’537 Patent, Abstract; Fig. 1(b)). This allows the device to retrieve, process, and display multimedia data from remote sources on a touch-sensitive screen. (’537 Patent, col. 4:38-48).
- Technical Importance: The patent describes combining what were previously disparate communication technologies into a single, portable device, an architectural concept foundational to the development of modern smartphones. (’537 Patent, col. 2:65-col. 3:23).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-37 of the ’537 Patent. (Compl. ¶8). Independent claim 1 is detailed in the complaint's infringement chart.
- Independent Claim 1 of the ’537 Patent recites the following essential elements:
- At least one of a wireless unit and a tuner unit supporting bi-directional data communications over cellular networks, wireless local area networks, and a direct short-range connection using Bluetooth, where the Bluetooth communication occurs "after accepting a passcode from a user."
- A touch-sensitive display screen configured to display video and text and to receive input via selection of a "soft button."
- A microprocessor configured to facilitate the operation of and communications by the device.
- The complaint asserts both independent and dependent claims. (Compl. ¶8).
III. The Accused Instrumentality
Product Identification
- The complaint generally accuses Defendant's "systems, products, and services," with Exhibit B specifically identifying the "Motorola Mobility LLC's moto e⁵ play" smartphone. (Compl. ¶8; Compl. Ex. B, p. 27).
Functionality and Market Context
- The complaint identifies the accused product as an electronic handheld multimedia device. (Compl. Ex. B, p. 27). A product image provided in the complaint shows a modern smartphone. (Compl. Ex. B, p. 27).
- The functionality relevant to the infringement allegations includes its multiple wireless communication capabilities, such as cellular (4G LTE, CDMA, UMTS), Wi-Fi (802.11 a/b/g/n), and Bluetooth 4.2 LE. (Compl. Ex. B, p. 28). The complaint also points to the device’s touch-sensitive display for user interaction and its use of a microprocessor (Qualcomm Snapdragon) to control operations. (Compl. Ex. B, p. 29-30). A screenshot of the YouTube application running on the device is provided as evidence of its multimedia and touch-screen capabilities. (Compl. Ex. B, p. 29).
- The complaint does not provide sufficient detail for analysis of the product's commercial importance or market positioning.
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint provides a claim chart in Exhibit B alleging infringement of at least Claim 1 of the ’537 Patent by the moto e⁵ play smartphone. (Compl. ¶9).
’537 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one of a wireless unit and a tuner unit supporting bi-directional data communications of data including video and text for the electronic wireless hand held multimedia device with remote data resources over cellular telecommunications networks, over wireless local area networks and over a direct wireless connection with electronic devices located within short range using Bluetooth communications after accepting a passcode from a user of the electronic wireless hand held multimedia device during the communications | The accused device supports communications over cellular networks (4G LTE, CDMA, etc.), wireless local area networks (Wi-Fi), and direct short-range connections via Bluetooth 4.2 LE, as detailed in a technical specifications table. (Compl. Ex. B, p. 28). | ¶9 | col. 6:56-7:7 |
| a touch sensitive display screen configured to display the data including video and text received by the electronic wireless hand held multimedia device by selecting a particular data represented by a soft button on the touch sensitive display screen of the electronic wireless hand held multimedia device | The accused device has a touch-sensitive display that shows video and text and allows user input via soft buttons, as shown in a screenshot of the YouTube application. (Compl. Ex. B, p. 29). | ¶9 | col. 5:44-48 |
| a microprocessor configured to facilitate operation of and communications by the electronic wireless hand held multimedia device | The accused device contains a Qualcomm® Snapdragon™ processor with a quad-core CPU and Adreno GPU, which facilitates its operation and communications. (Compl. Ex. B, p. 30). | ¶9 | col. 6:1-6 |
Identified Points of Contention
- Temporal Scope: The complaint's own infringement exhibit includes the statement: "The reference includes subject matter disclosed by the claims of the patent after the priority date." (Compl. Ex. B, p. 27). This suggests a potential dispute over whether the patent's disclosure from 2000 adequately supports the scope of claims needed to read on a modern smartphone, and it may foreshadow a validity challenge by the defendant based on intervening prior art.
- Scope Questions: A central question may be whether the claim limitation "accepting a passcode from a user" during Bluetooth communications is met by modern Bluetooth pairing protocols, which may involve automated security confirmations rather than manual passcode entry.
- Technical Questions: What evidence does the complaint provide that the accused product's integrated System-on-a-Chip (SoC) architecture constitutes "at least one of a wireless unit and a tuner unit" as that phrase would have been understood by a person of ordinary skill in the art at the time of the invention?
V. Key Claim Terms for Construction
- The Term: "accepting a passcode from a user ... during the communications"
- Context and Importance: This term appears in the limitation describing Bluetooth functionality in claim 1. Its construction is critical because the method of securing Bluetooth connections has evolved since 2000. Whether modern, often automated, pairing procedures fall within the scope of this term will be a central point of the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a "security module" in general terms, intended to enable "the use of pass codes, passwords and/or biometrics" and provide "communications security during hand held device communications." (’537 Patent, col. 8:15-19). This general language could support construing the term to cover a variety of security mechanisms, including modern pairing confirmations.
- Evidence for a Narrower Interpretation: The specific phrase "accepting a passcode from a user" could be construed to require a direct, manual entry of an alphanumeric code by the user for a given communication session. The absence of a specific embodiment detailing this process in the patent may lead a court to apply a narrower, plain-language meaning that excludes automated or one-time pairing events.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. (Compl. ¶¶10-11). For inducement, it alleges Defendant encouraged or instructed customers on how to use its products in an infringing manner. (Compl. ¶10). For contributory infringement, it alleges there are "no substantial noninfringing uses" for the products. (Compl. ¶11). The complaint does not provide specific factual support for these allegations beyond general statements.
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’537 Patent "from at least the filing date of the lawsuit." (Compl. ¶10). This allegation supports a claim for post-filing willfulness only.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of validity and temporal scope: given the patent’s 2000 priority date and 2015 issue date, can the claims be validly construed to cover technology in a modern smartphone? The plaintiff's own exhibit statement that the accused product "includes subject matter disclosed by the claims of the patent after the priority date" will place this question at the center of the dispute. (Compl. Ex. B, p. 27).
- A key question of claim construction will determine the scope of infringement: does the term "accepting a passcode," rooted in early-2000s security concepts, read on the automated and streamlined pairing procedures used by modern Bluetooth-enabled devices, or does it require a specific, manual user action that may not be present in the accused functionality?
- An evidentiary question will be one of technical and architectural equivalence: does the highly integrated System-on-a-Chip design of the accused smartphone correspond to the claimed "wireless unit and ... tuner unit," or is there a fundamental mismatch between the architecture claimed in the patent and the technology embodied in the accused product?