Lab Technology LLC v. Telus Intl US Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Telus International (U.S.) Corp. (Washington)
  • Plaintiff’s Counsel: Private Wealth Law, Inc.
• Case Identification: 2:26-cv-00284, D. Nev., 02/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Nevada because Defendant maintains an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to technology for automatically refreshing a telephone's display with contextually relevant services based on factors like time or location.
• Technical Context: The technology at issue addresses user interface efficiency on telecommunication devices, aiming to proactively display applications or services a user is likely to need based on their current context, thereby reducing manual navigation.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,219,982 - “Apparatus and method for automatically refreshing a display of a telephone”

The patent-in-suit is U.S. Patent No. 9,219,982, issued on December 22, 2015 (the ’982 Patent).

The Invention Explained

• Problem Addressed: The patent's background describes the inefficiency users face when navigating through numerous menu displays on a telephone to find a desired service, even though they often access the same services repeatedly based on predictable contexts like the time of day or their physical location ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 1:29-44). The patent identifies a need for a telephone that can automatically display services likely to be used at a given time or location ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 2:4-8).
• The Patented Solution: The invention is a telephone system that automatically updates its display to show relevant communication services based on the user's current context ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, abstract). The system uses a "function selector" that selects a predefined "function" (e.g., "office worker on workday morning" or "shopper's role at a shopping mall") from a datastore based on inputs like time from a clock or location from a location server ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 2:38-45; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 2:58-67). The telephone's screen is then refreshed to display the communication services associated with that selected function, such as a traffic report service for a morning commute or a store directory for a mall ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 4:46-54; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 5:3-9).
• Technical Importance: This approach aims to create a more intelligent and proactive user interface that anticipates user needs, contrasting with the static, manual-navigation-based interfaces common at the time of the invention.

Key Claims at a Glance

• The complaint alleges infringement of "exemplary claims" without specifying them (Compl. ¶10). Independent claim 1 is representative of the apparatus claims.
• Independent Claim 1 elements:
  • A telephone comprising a display panel, a processor, and a datastore.
  • The datastore comprises at least one "function" containing information related to a "current location of the telephone" and a user.
  • The telephone is operable to connect to a communication network.
  • The function is associated with at least one communication service.
  • The processor is operable to connect to a "location server" to get the telephone's current location, select a function from the datastore based on that location, and refresh the screen to display the communication service associated with the selected function.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products. It refers to "Exemplary Defendant Products" that are identified in charts incorporated as Exhibit 2 (Compl. ¶7). This exhibit was not publicly filed with the complaint.

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It makes only conclusory allegations that the products "practice the technology claimed by the '982 Patent" (Compl. ¶15). Without access to the referenced Exhibit 2, the specific features and functions of the accused instrumentality cannot be determined from the complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts in Exhibit 2, which was not provided with the initial filing (Compl. ¶16). The complaint alleges that these charts demonstrate how the "Exemplary Defendant Products" practice the technology and satisfy all elements of the asserted claims (Compl. ¶¶15-16). As the specific allegations mapping claim elements to product features are contained within the missing exhibit, a claim chart summary cannot be constructed.

Identified Points of Contention

Based on the claim language and the nature of the parties, the infringement analysis may raise several technical and legal questions:

• Scope Questions: A central question may be whether the accused products, likely software or service platforms provided by Telus International, qualify as a "telephone" under the patent's claims. The defense may argue the term is limited to physical hardware like the mobile and residential phones described in the specification ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 1:41; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 1:59; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 8:36-58), while the plaintiff may argue it covers any system performing the claimed functionality.
• Technical Questions: The complaint provides no facts explaining how the accused products perform the claimed steps. A key factual dispute may be whether the accused products contain a "datastore" with a predefined "function" that is selected based on location to trigger a screen refresh, as required by the claim ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 8:25-37). The analysis will question what evidence shows that the accused system specifically "connect[s]... to a location server to obtain a current location" for the express purpose of selecting a function and refreshing the display with associated services.

V. Key Claim Terms for Construction

The Term: "telephone"

• Context and Importance: This term's construction appears central to the dispute. Defendant Telus International is primarily a digital services and IT consulting company, not a hardware manufacturer. Whether its accused software platforms or applications can be construed as a "telephone" will likely be a threshold issue for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims focus on a set of functional capabilities (connecting to a network, having a display, processing location data) rather than a specific physical form factor. Plaintiff may argue that any modern device, including a computer running an application that performs these functions, meets the definition.
  • Evidence for a Narrower Interpretation: The specification consistently refers to "telephone," "home phone," and "mobile phone" ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 1:16; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 1:41-61). Embodiments describe a "residential telephone" and an "office telephone" ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 8:38; [’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 8:59). This consistent usage could support a narrower construction limited to devices primarily designed for telecommunications.

The Term: "function"

• Context and Importance: Claim 1 requires selecting a "function" from a datastore. The definition of "function" is important to distinguish the claimed invention from a simple if-then rule. Practitioners may focus on this term because infringement will depend on whether the accused products use a stored, discrete data object corresponding to the patent's "function."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states a function "represents a given set of conditions associated with a user" such as time or location ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 2:19-22), which could be interpreted broadly to cover any logic that maps context to an outcome.
  • Evidence for a Narrower Interpretation: The specification provides concrete examples of functions as named roles or situations, such as "an office worker on weekday morning," a "hotel guest in evenings," or a "vehicle driver" ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 2:23-24). This suggests a "function" is a defined profile stored in a datastore ([’982](https://ai-lab.exparte.com/patent/9219982) Patent, col. 6:11-13), potentially requiring a more structured implementation than a simple conditional statement.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement, asserting that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes" (Compl. ¶13). It further alleges post-suit inducement based on the knowledge provided by the complaint and its attached claim charts (Compl. ¶14).

Willful Infringement

The complaint alleges that service of the complaint and its claim charts provides Defendant with "actual knowledge of infringement" (Compl. ¶12). The allegation of continued infringement despite this knowledge forms the basis for a claim of post-suit willfulness (Compl. ¶13). No facts supporting pre-suit knowledge are alleged.

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

The resolution of this case, based on the initial complaint, appears to hinge on two primary questions for the court:

1. A core issue will be one of definitional scope: Can the term "telephone," as used and described throughout the ’982 Patent, be construed to encompass the software, platforms, or digital services offered by Defendant, or is its meaning limited to the physical communication devices contemplated in the specification?
2. A critical evidentiary question will be one of technical implementation: Assuming the accused products fall within the scope of a "telephone," what evidence will Plaintiff present to demonstrate that they perform the specific architecture of the claims—namely, storing and selecting a discrete, context-based "function" from a "datastore" to dynamically refresh a user interface with associated services?