DCT

2:19-cv-02100

Jackson Labs Tech Inc v. Orolia USA Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:19-cv-02100, D. Nev., 12/06/2019
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Nevada because Defendant Orolia conducts business and has substantial ongoing contacts within the state.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its RSR Transcoder™ product does not infringe Defendant’s patent related to Global Navigation Satellite System (GNSS) signal simulation, following pre-suit infringement accusations from the Defendant.
  • Technical Context: The technology at issue involves methods for simulating GNSS signals (such as GPS) to provide positioning and timing data in environments where direct satellite signals are weak or unavailable, a critical function for indoor navigation, testing, and military applications.
  • Key Procedural History: The complaint outlines a series of pre-suit communications initiated by Orolia, beginning with a July 24, 2019 letter accusing Jackson Labs of infringing the patent-in-suit. Orolia later provided a communication purporting to be a claim chart comparing method claim 1 of the patent to the accused product, which Jackson Labs disputed, leading to this declaratory judgment action.

Case Timeline

Date Event
2015-05-01 ’211 Patent Priority Date
2019-03-26 ’211 Patent Issue Date
2019-07-24 Orolia sends first letter to JLT alleging infringement
2019-10-04 JLT’s counsel responds to Orolia
2019-10-18 Orolia’s counsel sends letter with purported claim chart for Claim 1
2019-11-05 JLT’s counsel sends detailed response denying infringement
2019-11-26 Orolia’s counsel responds, asserting JLT’s claim scope arguments are "baseless"
2019-12-06 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 10,241,211 - "Methods Of Location Using GNSS Simulators and Devices Thereof"

  • Patent Identification: U.S. Patent No. 10,241,211, “Methods Of Location Using GNSS Simulators and Devices Thereof,” issued March 26, 2019 (the “’211 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section states that Global Navigation Satellite System (GNSS) signals are typically too weak to be received indoors or underground. Conventional solutions, such as radio frequency (RF) repeaters, are limited because they require expensive, low-loss coaxial cable and only report the location of the outdoor antenna, not the user's actual indoor position (’211 Patent, col. 1:10-24).
  • The Patented Solution: The invention proposes a system where an outdoor GNSS receiver captures a "live sky" satellite signal and decodes it to extract timing and ephemeris (satellite orbital) data. This information is converted into a digital format and sent over a standard communication network, like Ethernet or WiFi, to one or more indoor GNSS simulators. These simulators then use the digital data to generate and transmit a new, simulated GNSS signal that is synchronized with the live outdoor signal, providing accurate positioning information within a specific indoor "coverage area" (’211 Patent, Abstract; col. 2:26-39).
  • Technical Importance: This digital transmission method decouples the point of RF signal reception from the point of re-transmission, leveraging ubiquitous and cost-effective digital networks instead of specialized RF cabling to cover indoor spaces (’211 Patent, col. 2:26-33).

Key Claims at a Glance

  • The complaint identifies independent method claim 1 as being asserted by Orolia (Compl. ¶¶15, 17).
  • The essential elements of independent claim 1 include:
    • Receiving, by a GNSS simulator, a precision timing signal and ephemeris data from a GNSS receiver, where this data is received in a digital format over a communication network.
    • The GNSS receiver operates on a "first GNSS system."
    • Generating, by the simulator, a simulated GNSS signal based on the received data.
    • Transmitting the simulated GNSS signal over a coverage area.
    • The transmitted simulated signal is configured to operate on a "second GNSS system different from the first GNSS system."
  • The complaint notes that Orolia’s allegations may extend to other unspecified claims of the ’211 Patent (Compl. ¶17).

III. The Accused Instrumentality

Product Identification

  • The accused product is the Jackson Labs Technologies, Inc. (JLT) RSR Transcoder™ (Compl. ¶8).

Functionality and Market Context

  • The complaint describes the RSR Transcoder™ as a product that "allows retrofitting of legacy GPS equipment to next-generation GNSS, SAASM, M-Code, INS, and other PVT/PNT sources" (Compl. ¶8).
  • Based on this description, the device appears to function as an intermediary or translator, enabling older positioning, navigation, and timing (PNT) equipment to work with modern signal sources. The complaint does not provide further technical detail on the product's internal architecture or method of operation.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and therefore does not contain affirmative infringement allegations or a claim chart. Instead, it describes Orolia’s pre-suit allegations. The complaint states that on October 18, 2019, Orolia’s counsel provided a letter with a table "that purports to be a claim chart comparing method claim 1 of the '211 patent to JLT's RSR Transcoder™ device" (Compl. ¶15). This chart was not included with the complaint.

The complaint alleges that Orolia’s position is that the RSR Transcoder™ "meets every limitation of a least independent claim 1" (Compl. ¶14). JLT disputes this, and the pre-suit correspondence reportedly identified "several reasons" for its non-infringement position (Compl. ¶17).

Identified Points of Contention

  • Scope Questions: The complaint explicitly notes that a central dispute involves the scope of the terms "communication network" and "coverage area". Orolia’s counsel allegedly characterized JLT’s attempts to limit the scope of these terms as "baseless" (Compl. ¶18). This suggests a core disagreement over whether the RSR Transcoder's architecture and signal output fall within the boundaries of these claim limitations as defined by the patent. For example, a question for the court may be whether a direct, wired connection between components constitutes a "communication network" or if a signal output to a single piece of equipment constitutes transmission over a "coverage area."
  • Technical Questions: A key technical question will be whether the RSR Transcoder’s alleged function of "retrofitting" legacy equipment by translating signals from different sources performs the specific steps of Claim 1. This includes whether the device receives data from a "first GNSS system" and transmits a new, simulated signal for a "second GNSS system" in the manner claimed by the patent.

V. Key Claim Terms for Construction

The complaint indicates that the following terms from claim 1 are central to the parties' dispute (Compl. ¶18).

  • The Term: "communication network"

    • Context and Importance: This term is critical because the patent’s asserted novelty lies in replacing specialized RF cables with a digital network. JLT may argue its product does not use such a network, while Orolia may advocate for a broad definition. Practitioners may focus on this term because the nature of the data link between the signal-receiving and signal-transmitting functions is a core element of the claimed invention.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification provides examples such as "Internet, Ethernet, WiFi" and states the network can use "TCP/IP over Ethernet and industry standard protocols," but adds that "other types and/or numbers of communication networks may be utilized" (’211 Patent, col. 2:27-28; col. 6:35-40). This could support an interpretation that includes any means of digital communication between components.
      • Evidence for a Narrower Interpretation: The problem solved by the invention is the avoidance of "low-loss coaxial cable" over distances between an outdoor antenna and an indoor space (’211 Patent, col. 1:20-24). The patent figures depict the network (18) as a distinct element connecting physically separate devices (14, 16). This context could support an interpretation that excludes short, internal buses within a single integrated device.

  • The Term: "coverage area"

    • Context and Importance: This term defines the scope of the simulated signal's transmission. The dispute will likely concern whether the RSR Transcoder’s output constitutes transmission "over a coverage area." If the device outputs its signal via a direct cable to a single device, JLT may argue this limitation is not met.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not explicitly define a minimum size for the "coverage area." Orolia could argue that any region where the simulated signal is present and can be received, regardless of size or whether it is broadcast wirelessly, meets the limitation.
      • Evidence for a Narrower Interpretation: The summary and detailed description repeatedly refer to covering "large indoor spaces" and enabling positioning "in an indoor location" (’211 Patent, col. 2:32-33; col. 7:56-58). This context, which emphasizes providing a signal within a physical space for reception by potentially mobile user devices, could support an interpretation that requires a wireless, broadcast-like transmission into a physical volume, rather than a point-to-point wired output.

VI. Other Allegations

  • Indirect Infringement: The complaint states that JLT’s pre-suit correspondence identified reasons why it does not have liability for contributory infringement or inducement (Compl. ¶17). The complaint does not, however, provide the specific facts Orolia may have alleged to support such claims.
  • Willful Infringement: While not alleged by the plaintiff in this DJ action, the complaint establishes a basis upon which Orolia could found a willfulness claim. The series of communications beginning with the July 24, 2019 letter from Orolia’s General Counsel provides clear evidence of JLT’s pre-suit knowledge of the ’211 Patent and Orolia’s specific allegations of infringement (Compl. ¶¶10-12).

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

The resolution of this declaratory judgment action will likely depend on the court's interpretation of claim scope and its application to the accused product's technology. The central questions raised by the complaint are:

  • A core issue will be one of definitional scope: can the terms "communication network" and "coverage area", which are described in the patent in the context of bridging distances to provide signals in large indoor spaces, be construed to read on the internal architecture and signal output of JLT’s RSR Transcoder™ device?
  • A key evidentiary question will be one of technical correspondence: does the RSR Transcoder’s function of "retrofitting" legacy equipment by translating between signal types constitute the patented method of receiving decoded data from a "first GNSS system" over a network and generating and transmitting a simulated signal for a "second GNSS system," or is there a fundamental mismatch in technical operation?