DCT
6:20-cv-01270
Celeritasworks LLC v. New Cell LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Celeritasworks, LLC (Kansas)
- Defendant: New-Cell, LLC dba Cellcom (Wisconsin)
- Plaintiff’s Counsel: Hovey Williams LLP
- Case Identification: 6:20-cv-01270, D. Kan., 10/05/2020
- Venue Allegations: Venue is based on Defendant's alleged business activities in the district, including providing cellular coverage to local customers and operating a website with the accused tool that is accessible to district residents.
- Core Dispute: Plaintiff alleges that Defendant’s website-based cellular coverage map tool infringes a patent related to geographic network management systems.
- Technical Context: The technology involves web-based systems that process geographic search requests to retrieve and display network data, such as telecommunications coverage, on a map for a user.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patent and its alleged infringement via a letter dated December 23, 2019, which may form the basis for the willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 1999-12-22 | U.S. Patent No. 6,343,290 Priority Date |
| 2002-01-29 | U.S. Patent No. 6,343,290 Issues |
| 2019-12-23 | Plaintiff sends notice letter to Defendant |
| 2020-10-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,343,290 - “Geographic Network Management System” (issued January 29, 2002)
The Invention Explained
- Problem Addressed: The patent describes the increasing difficulty of managing telecommunication networks and identifies a need for a system to "view, configure, and manage" network data in a way that is "useful and efficient for viewing, configuration, and management" (’290 Patent, col. 1:11-28).
- The Patented Solution: The invention is a multi-part system that allows a user to submit a geographic search query through a web browser. The system architecture, shown in Figure 4, includes a web server to handle user communications, a map server to "geocode" the search criteria and generate a map, and a database server to store and retrieve the underlying network and geospatial data (’290 Patent, Abstract; col. 7:24-44). This allows network information (e.g., cell sites, trouble tickets) to be displayed geographically on a map for a user (’290 Patent, col. 4:51-64).
- Technical Importance: The technology provided a method for network operators and customer service representatives to visualize complex, abstract network data in a user-friendly, geographical context through a web interface, an important capability for managing service quality (’290 Patent, col. 3:41-49).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a system claim) and 86 (a method claim) (’290 Patent, col. 26:36-53, 31:19-28; Compl. ¶8).
- Independent Claim 1 (System) requires:
- A "database server" configured to retrieve and transmit network and geospatial data.
- A "web server" configured to receive and transmit a search criteria, and to receive and transmit a map.
- A "map server" configured to receive the search criteria, "geocode" it, retrieve the corresponding data from the "database server", and generate the map.
- Independent Claim 86 (Method) requires the steps of:
- Receiving a search criteria.
- Determining a "geocode" for the search criteria.
- Obtaining network data and geospatial data within a search range of the "geocode".
- Transmitting the data for display with a map.
- The complaint alleges infringement of "at least" these two independent claims (Compl. ¶8).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant Cellcom's "coverage map tool" available on its website (Compl. ¶8).
Functionality and Market Context
- The complaint alleges the tool functions by receiving a search criterion, such as a zip code or address, from a user over a web server (Compl. ¶8).
- The tool then allegedly geocodes the search criterion, retrieves corresponding network and geospatial data, and generates a map that includes "color-coded network data overlaid on geospatial data" to show cellular coverage (Compl. ¶8). The complaint provides a screenshot of the accused tool displaying a coverage map for Kansas City, Missouri, which includes a legend indicating different levels of mobile data service (Compl. p. 3).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in Exhibit B, which was not provided with the filed complaint; therefore, this analysis is based on the narrative allegations.
’290 Patent Infringement Allegations (Claim 1 - System)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a database server configured to retrieve and to transmit network data and geospatial data; | The system "retrieved network data and geospatial data," which implies the function of a database server. | ¶8 | col. 7:31-33 |
| a web server configured to receive a search criteria, to transmit the search criteria, to receive a map, and to transmit the map; and | The tool "received a search criteria...over a web server" and "generated a map" for display, implying the claimed web server functionality. | ¶8 | col. 7:45-49 |
| a map server configured to receive the search criteria from the web server, to geocode the search criteria, to retrieve network data and geospatial data from the database server corresponding to the geocode, and to generate the map...the network data... | The tool "geocoded the search criteria," "retrieved network data and geospatial data corresponding to the geocoded search criteria," and "generated a map including the network data and geospatial data." | ¶8 | col. 7:50-58 |
’290 Patent Infringement Allegations (Claim 86 - Method)
| Claim Element (from Independent Claim 86) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a search criteria; | The tool "received a search criteria (such as a zip code or other address) over a web server". | ¶8 | col. 16:63-65 |
| determining a geocode for the search criteria; | The system "geocoded the search criteria". | ¶8 | col. 16:3-7 |
| obtaining network data and geospatial data within a search range of the geocode; | The system "retrieved network data and geospatial data corresponding to the geocoded search criteria". | ¶8 | col. 16:3-7 |
| transmitting the network data and the geospatial data for display with a map. | The system "generated a map including the network data and geospatial data." A screenshot of the accused 'Coverage Map' tool shows a map of Kansas City for zip code 64108 with a legend for voice, messaging, and mobile data coverage (Compl. p. 3). | ¶8 | col. 16:5-7 |
Identified Points of Contention
- Scope Questions: A primary question will be whether the defendant’s system, likely built with modern web service technologies, contains the distinct "web server", "database server", and "map server" components as claimed. The defense may argue that its architecture is integrated in a way that does not meet the claim’s requirement for these separate logical or physical components.
- Technical Questions: What evidence will the plaintiff produce to demonstrate that the accused tool performs the specific step of "geocoding" as understood in the context of the patent, beyond simply mapping a zip code to a general area? For the system claim (Claim 1), the plaintiff must also prove that the defendant "made and used" a system with all the claimed server components in the United States (Compl. ¶8).
V. Key Claim Terms for Construction
- The Term: "web server", "database server", "map server"
- Context and Importance: The construction of the term "server" and its variants is central to the dispute. A narrow construction requiring physically or structurally distinct components, as arguably suggested by the patent’s block diagrams (e.g., ’290 Patent, FIG. 4), could make it difficult for the plaintiff to prove infringement against a modern, integrated, or cloud-based web application. Practitioners may focus on this term because the architectural assumptions of 1999 may not map directly onto current web service design.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional definition, stating a "server" means "software and/or hardware that may be implemented as one or more components" and that the claimed servers are "logical components that are scalable and that may be implemented as software and/or hardware individually, as a single component, or as multiple components" (’290 Patent, col. 7:38-44).
- Evidence for a Narrower Interpretation: The figures consistently depict the "web server", "database server", and "map server" as separate, labeled boxes connected by lines, which could be argued to teach a system of distinct, communicating modules rather than a single, monolithic software application (’290 Patent, FIG. 4).
VI. Other Allegations
Willful Infringement
- The complaint alleges that the defendant has willfully infringed the ’290 Patent "with full notice and knowledge thereof" (Compl. ¶14). This allegation is based on a letter plaintiff’s counsel allegedly sent to the defendant on December 23, 2019, putting the defendant on notice of the patent and its alleged infringement (Compl. ¶11).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: can the claimed system—comprising distinct "web server", "database server", and "map server" components as patented in the dot-com era—be construed to read on the defendant's potentially integrated, modern web service architecture? The outcome of this claim construction battle will significantly influence the infringement analysis.
- A key evidentiary question will be one of willfulness: given the plaintiff's allegation of a pre-suit notice letter, the court will need to determine if the defendant's continued operation of the accused tool after December 23, 2019, rises to the level of objectively reckless conduct required to support a finding of willful infringement and potential enhanced damages.