DCT

6:20-cv-01302

Celeritasworks LLC v. T-Mobile USA Inc

Key Events

Complaint

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Celeritasworks, LLC (Kansas)
- Defendant: T-Mobile USA, Inc. (Delaware)
- Plaintiff’s Counsel: Hovey Williams LLP
Case Identification: Celeritasworks, LLC v. T-Mobile USA, Inc., 6:20-cv-01302, D. Kan., 10/29/2020
Venue Allegations: Plaintiff alleges venue is proper in the District of Kansas because Defendant T-Mobile has a regular and established place of business within the district, including a retail location in Wichita, and has committed acts of infringement in the district by operating its website, which is accessible to residents.
Core Dispute: Plaintiff alleges that Defendant’s online cellular coverage map tool infringes a patent related to geographic network management systems.
Technical Context: The technology concerns systems that integrate telecommunications network data with geospatial data to provide interactive, web-based maps for network management and customer information.
Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent-in-suit and its alleged infringement via a letter dated December 16, 2019, which Defendant's in-house counsel acknowledged on January 14, 2020. This pre-suit notice forms 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
2019-12-16	Plaintiff sends notice letter to Defendant
2020-01-14	Defendant acknowledges receipt of notice letter
2020-10-29	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 addresses the increasing difficulty of managing telecommunication networks, noting that service providers need a system to "view, configure, and manage wireline and wireless networks" and provide network data to users in a useful context (’290 Patent, col. 1:11-28).
The Patented Solution: The invention is a system comprising three primary server components: a web server, a database server, and a map server (’290 Patent, Abstract). A user interacts with the system via a browser, sending a search criterion (e.g., an address) to the web server. The map server then "geocodes" this criterion, retrieves corresponding network data (e.g., cell site status) and geospatial data (e.g., street layouts) from the database server, and generates a map that visually integrates both data types for display to the user (’290 Patent, Fig. 4; col. 7:22-8:6).
Technical Importance: The system aimed to provide a "geographical representation of a telecommunications network through a graphical interface for a user," allowing for more efficient network monitoring, configuration, and management (’290 Patent, col. 3:13-16).

Key Claims at a Glance

The complaint asserts independent claims 1 and 86 (Compl. ¶9).
Independent Claim 1 (System Claim):
- a database server configured to retrieve and to transmit network data and geospatial data;
- a web server configured to receive a search criteria, to transmit the search criteria, to receive a map, and to transmit the map; and
- 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 comprising the network data and the geospatial data.
Independent Claim 86 (Method Claim):
- 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 network data and the geospatial data for display with a map.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is T-Mobile’s "coverage map tool" available on its public website (Compl. ¶9).

Functionality and Market Context

The complaint alleges that the accused tool allows a user to input a search criterion, such as a zip code or address, into a web interface (Compl. ¶9). In response, the system geocodes the location and generates an interactive map that displays "color-coded network data overlaid on geospatial data" (Compl. ¶9). A screenshot from T-Mobile’s website shows a map of Kansas City for zip code 64108 with pink-colored network coverage data overlaid on the geospatial street map (Compl. ¶9). This tool serves the important commercial function of informing potential and existing customers about the geographic extent and quality of T-Mobile's cellular network coverage.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit B to illustrate infringement but does not attach the exhibit (Compl. ¶10). The narrative allegations in the complaint, however, track the language of the asserted claims. The complaint alleges that T-Mobile’s coverage map tool performs the patented method and embodies the patented system by:

Receiving a search criteria (such as a zip code or address) over a web server;
Geocoding the search criteria to a specific geographic location;
Retrieving network data (i.e., T-Mobile's coverage information) and geospatial data (i.e., street maps) corresponding to the geocoded location; and
Generating a map that includes both the network data and geospatial data (Compl. ¶9).

Identified Points of Contention:
- Scope Questions: A central question for system claim 1 may be whether T-Mobile’s infrastructure comprises the distinct "web server", "database server", and "map server" architecture recited in the claim. The defense may argue that modern, distributed web architectures do not map cleanly onto the patent's more delineated three-server model.
- Technical Questions: What evidence supports the allegation that the data displayed by T-Mobile's tool—primarily cellular coverage strength—qualifies as "network data" as defined by the patent? The patent provides a broad definition that includes "equipment data, performance data, including trouble ticket data, event data, [and] alarm data" (’290 Patent, col. 3:20-24), raising the question of whether T-Mobile's more limited data set meets this claimed element.

V. Key Claim Terms for Construction

The Term: "map server" (Claim 1)
Context and Importance: This term is a structural pillar of independent claim 1. Its definition is critical for determining if T-Mobile’s system architecture infringes. Practitioners may focus on this term because the accused system may integrate the functions of a "map server" and "web server" into a single logical or physical unit, creating a dispute over whether a distinct element is present.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may support an interpretation that the term should be given its plain and ordinary meaning to one of skill in the art at the time, potentially covering any server component that performs the recited mapping functions, regardless of its integration with other components.
- Evidence for a Narrower Interpretation: The patent’s figures, particularly Figure 4, depict the "map server" (410) as a distinct block, separate from the "web server" (402) and "database server" (404) (’290 Patent, Fig. 4). This could support a narrower construction requiring a structurally or at least logically separate component.
The Term: "network data" (Claims 1, 86)
Context and Importance: This term appears in both asserted independent claims and is fundamental to the infringement allegation, as the complaint alleges T-Mobile's display of "color-coded network data" is an infringing act (Compl. ¶9). The dispute will likely center on whether T-Mobile's displayed coverage information falls within the scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that "network data comprises equipment data, performance data, including trouble ticket data, event data, alarm data, customer service data, and/or configuration data" (’290 Patent, col. 3:20-24). The use of "comprises" and "and/or" suggests this is a non-exhaustive list, which could support a construction that includes other types of network-related information, such as coverage strength.
- Evidence for a Narrower Interpretation: The specification consistently provides examples of "network data" that are related to network performance and management (e.g., trouble tickets, event/alarm data, cell site status) (’290 Patent, col. 3:20-32; col. 4:7-12). This context may support an argument that the term is limited to such detailed operational data, as opposed to the more general marketing-oriented coverage data shown in the complaint's screenshot.

VI. Other Allegations

Willful Infringement: The complaint alleges that T-Mobile has willfully infringed the ’290 Patent (Compl. ¶15). This allegation is based on T-Mobile having received notice of the patent and the alleged infringement via a letter dated December 16, 2019, which T-Mobile's counsel acknowledged on January 14, 2020 (Compl. ¶12). The allegation asserts T-Mobile acted despite an objectively high likelihood that its actions constituted infringement.

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

A central issue will be one of architectural mapping: does T-Mobile's modern, web-based system embody the distinct "web server", "database server", and "map server" architecture required by system claim 1, or are these functions sufficiently integrated to fall outside the claim's literal scope?
The case will also turn on a key definitional question: can the term "network data", which the patent illustrates with examples like trouble tickets and performance statistics, be construed broadly enough to read on the generalized cellular coverage information displayed by T-Mobile's accused tool?
Finally, a significant question will be one of willfulness: given the explicit pre-suit notice alleged in the complaint, the court will need to determine whether T-Mobile’s continued operation of its coverage map tool after receiving the notice constitutes the type of egregious conduct that warrants enhanced damages.