DCT

1:25-cv-01939

Webcon Vectors LLC v. Avaya LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01939, D.N.J., 03/18/2025
  • Venue Allegations: Venue is asserted based on Defendant Avaya LLC maintaining an established place of business in the District of New Jersey.
  • Core Dispute: Plaintiff alleges that Defendant’s telecommunication products and systems infringe patents related to methods for simplifying and unifying communications between users on disparate conferencing platforms.
  • Technical Context: The technology concerns systems that automate conference call setup by using unique electronic identifiers for users, aiming to bridge different communication services (e.g., traditional phone lines, VoIP, specific applications) into a single, seamless call.
  • Key Procedural History: The U.S. Patent No. 10,681,218 is a continuation-in-part of the application that led to U.S. Patent No. 11,290,428, suggesting a shared technical disclosure. The complaint does not reference any other prior litigation, licensing, or administrative proceedings involving the patents-in-suit.

Case Timeline

Date Event
2016-05-18 Priority Date for U.S. Patent No. 11,290,428
2017-05-13 Priority Date for U.S. Patent No. 10,681,218
2020-06-09 U.S. Patent No. 10,681,218 Issued
2022-03-29 U.S. Patent No. 11,290,428 Issued
2025-03-18 Complaint Filed

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

U.S. Patent No. 10,681,218

  • Patent Identification: U.S. Patent No. 10,681,218, "Telecommunication method and system for simplifying communication such as conference calls," issued June 9, 2020.
  • The Invention Explained:
    • Problem Addressed: The patent's background describes the inefficiencies of conventional teleconferencing, such as the cumbersome process of scheduling and rescheduling, the difficulty of locating call-in details within numerous emails, and the technical challenges that can "effectively derail the conference call" ('218 Patent, col. 1:39-62).
    • The Patented Solution: The invention proposes a method where different teleconferencing platforms are unified. The system contacts users via their unique "electronic identifier" (e.g., email, Skype address, phone number) and automatically connects them at a scheduled time, bridging users from a first platform with users from a second, dissimilar platform ('218 Patent, col. 5:16-31). This process is designed to be managed by the system, making the user's role passive after the initial setup ('218 Patent, col. 15:28-33).
    • Technical Importance: The described technology seeks to abstract away the underlying complexity of different communication networks, allowing for a more streamlined and platform-agnostic user experience in initiating multi-party calls ('218 Patent, col. 4:47-62).
  • Key Claims at a Glance: The complaint does not identify any specific claims of the '218 Patent asserted against the Defendant. It states that "Exemplary '218 Patent Claims" are identified in an external document (Exhibit 3) not provided with the complaint (Compl. ¶12). Therefore, an analysis of the asserted claims is not possible from the complaint itself.

U.S. Patent No. 11,290,428

  • Patent Identification: U.S. Patent No. 11,290,428, "Telecommunication method and system for simplifying communication such as conference calls," issued March 29, 2022.
  • The Invention Explained:
    • Problem Addressed: The patent addresses similar problems as its continuation-in-part, the '218 Patent, including the privacy risks of systems that automatically extract conference details and the friction caused by requiring users to manually initiate connections ('428 Patent, col. 2:22-34).
    • The Patented Solution: The invention describes a method for simplifying communication by selecting users for simultaneous contact based on their electronic identifiers and forming a "conferencing bridge" ('428 Patent, col. 13:38-46). A key aspect is enabling communication "absent any action by any selected user," thereby creating a passive and automated connection experience ('428 Patent, col. 14:1-3).
    • Technical Importance: This approach prioritizes user convenience and privacy by allowing users to be connected automatically without revealing their specific contact details (like a private cell number) to a moderator or other participants ('428 Patent, col. 9:64-10:11).
  • Key Claims at a Glance: The complaint does not specify which claims of the '428 Patent are asserted. It refers to "Exemplary '428 Patent Claims" identified in an external document (Exhibit 4) that was not provided (Compl. ¶21). An analysis of the asserted claims is therefore not possible based on the complaint.

III. The Accused Instrumentality

  • Product Identification: The complaint does not name any of Avaya's specific products, methods, or services. It refers generally to "Exemplary Defendant Products" that are purportedly identified in external chart exhibits (Compl. ¶¶ 12, 21).
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It makes only the conclusory allegation that the accused products "practice the technology claimed" by the patents-in-suit (Compl. ¶¶ 17, 26).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 3 (for the '218 Patent) and Exhibit 4 (for the '428 Patent). As these exhibits were not provided, a detailed element-by-element analysis is not possible.

The narrative infringement theory is that Defendant's "Exemplary Defendant Products" directly infringe the "Exemplary... Patent Claims" because they "practice the technology claimed" and "satisfy all elements" of those claims (Compl. ¶¶ 12, 17, 21, 26). The complaint alleges infringement occurs through Defendant's acts of making, using, testing, selling, and offering the products for sale, as well as through internal use by its employees (Compl. ¶¶ 12-13, 21-22).

No probative visual evidence provided in complaint.

The complaint does not provide sufficient detail for analysis of specific points of contention regarding infringement.

V. Key Claim Terms for Construction

The complaint does not identify the specific independent or dependent claims asserted against the Defendant. Without identification of the asserted claims, an analysis of key terms for claim construction is not possible based on the provided document.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis for inducement is Defendant's distribution of "product literature and website materials" that allegedly instruct customers on how to use the accused products in a manner that infringes (Compl. ¶¶ 15, 24). The allegations state that Defendant has acted "knowingly, and intentionally" to induce infringement at least since being served with the complaint (Compl. ¶¶ 16, 25).
  • Willful Infringement: The complaint does not use the word "willful" but does request that the case be declared "exceptional" under 35 U.S.C. § 285, which can be a predicate for enhanced damages and attorneys' fees (Prayer for Relief ¶G.i.). The basis for alleging knowledge is exclusively post-suit, stating that the service of the complaint and its attached charts "constitutes actual knowledge of infringement" (Compl. ¶¶ 14, 23).

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

Given the high-level nature of the complaint, the litigation will likely focus first on clarifying the core allegations before moving to substantive technical disputes. The key questions raised by the filing are:

  1. Identification and Functionality: A threshold issue for the court will be the identification of the accused instrumentalities. The complaint's reliance on external, unprovided exhibits to name the accused products and describe their functionality leaves the central basis of the lawsuit undefined. Discovery will be required to determine which specific Avaya products are at issue and how they allegedly operate.
  2. Definitional Scope of "Bridging": Assuming specific products are identified, a central claim construction and infringement question will likely be the meaning of "bridging" dissimilar platforms. For example, Claim 1 of the '218 Patent requires "providing a bridge for bridging users of the first platform and the second platform." The case may turn on whether an integrated system that can natively handle various protocols (e.g., PSTN and SIP) meets this limitation, or if the claim requires connecting two truly separate, pre-existing conferencing systems.
  3. Novelty Over Prior Art: The patents-in-suit aim to solve well-known problems in teleconferencing. A key validity question will be whether the specific methods claimed, particularly the use of "electronic identifiers" for automated, platform-agnostic connection, are patentably distinct from prior art systems that also sought to automate conference call entry, such as by parsing calendar invitations or other electronic data.