WebSock Global Strategies LLC v. Chanty Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: Chanty, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-00041, S.D.N.Y., 01/02/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Southern District of New York and has committed the alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that unspecified products from Defendant infringe a patent related to methods for achieving symmetrical, bi-directional communication between network nodes over standard protocols.
• Technical Context: The technology addresses the inherent asymmetry of client-server protocols like HTTP, proposing a method to reverse these roles to enable peer-to-peer communication, particularly across network firewalls or NAT devices.
• Key Procedural History: The patent-in-suit is a continuation of a prior application that issued as U.S. Patent No. 7,403,995, indicating a broader patent family that may be relevant to claim construction and prosecution history.

Case Timeline

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

• Patent Identification: U.S. Patent No. 7,756,983, “Symmetrical bi-directional communication,” issued July 13, 2010.

The Invention Explained

• Problem Addressed: The patent describes a "fundamental problem" in network communications where protocols like HTTP enforce rigid, asymmetric roles: a "client" must initiate all requests, and a "server" can only respond ('983 Patent, col. 2:5-12). This structure prevents a server from initiating a spontaneous communication to a client, an issue compounded by network hardware like NAT routers and firewalls that typically block unsolicited inbound connections to a private client ('983 Patent, col. 1:44-51, col. 2:48-51). The patent notes that "polling," where a client repeatedly asks a server if it has data, is an inefficient and bandwidth-intensive workaround ('983 Patent, col. 3:4-10).
• The Patented Solution: The invention enables symmetrical communication by first establishing a standard client-server connection (e.g., an HTTP session over a TCP/IP circuit) ('983 Patent, col. 5:16-22). The two nodes then "negotiate transactional role reversal" ('983 Patent, Abstract). Following this negotiation, the initial application-layer (HTTP) session is terminated, but the underlying transport-layer (TCP/IP) network connection is preserved ('983 Patent, col. 5:27-29; Fig. 9, step 512). A new HTTP session is then established over the existing connection, but with the roles "flipped"—the original server now acts as a client, and the original client acts as a server, allowing the original server to initiate requests ('983 Patent, col. 5:30-35; Fig. 9, step 514).
• Technical Importance: This method was designed to allow peer-to-peer style applications to function over the ubiquitous and firewall-friendly HTTP protocol without being limited by its inherent client-server asymmetry ('983 Patent, col. 3:20-24).

Key Claims at a Glance

• The complaint asserts "one or more claims" without specifying them (Compl. ¶11). Independent claim 1 is representative of the core inventive method.
• Essential elements of independent claim 1 include:
  • First and second network nodes engaging in an asymmetric HTTP transactional session with an underlying network connection, with one node acting as a client and the other as a server.
  • Terminating the asymmetric HTTP session while maintaining the underlying network connection.
  • The nodes negotiating a transactional role reversal.
  • The nodes further communicating under a reversed asymmetric transactional protocol where each node enacts the initial role of the other.
  • The session utilizing a network connection that traverses "hardware enforcing asymmetric communication."
• The complaint does not explicitly reserve the right to assert dependent claims, but its general allegation of infringing "one or more claims" leaves this possibility open (Compl. ¶11).

III. The Accused Instrumentality

The complaint does not identify any specific accused products, methods, or services by name. It refers generally to "Defendant products identified in the charts incorporated into this Count" (Compl. ¶11) and "Exemplary Defendant Products" (Compl. ¶13), but the referenced charts (Exhibit 2) were not attached to the publicly filed complaint. As such, the complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that claim charts in an unfiled "Exhibit 2" demonstrate that Defendant's products infringe the '983 Patent (Compl. ¶¶13-14). Without these charts, a detailed element-by-element analysis is not possible. The complaint's narrative theory is conclusory, stating that the accused products "practice the technology claimed" and "satisfy all elements" of the asserted claims (Compl. ¶13).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the claim language and the general nature of the dispute, the infringement analysis will likely raise several key questions once product details are available:
  • Scope Questions: Claim 1 requires terminating an HTTP session while "maintaining said underlying network connection." A central dispute may be whether the accused products perform this specific two-step process of tearing down an application-layer session while explicitly preserving and reusing the transport-layer connection, or if they achieve a similar result via a different, non-infringing mechanism (e.g., opening a second, independent connection).
  • Technical Questions: The claim requires the nodes to be "negotiating transactional role reversal." A key evidentiary question will be what proof Plaintiff can offer that the accused products perform an explicit negotiation protocol to flip client-server roles, as depicted in the patent (e.g., sending an "HTTP FLIP request") ('983 Patent, col. 10:61-62), versus merely having the capability to communicate in two directions.

V. Key Claim Terms for Construction

The Term: "negotiating transactional role reversal"

• Context and Importance: This phrase captures the essence of the inventive concept. The outcome of the case may depend on whether this term is construed to require a specific, explicit protocol exchange or if it can cover any process that results in reversed communication roles. Practitioners may focus on this term because it is the primary active step that distinguishes the claimed method from conventional bi-directional communication techniques.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The Summary of the Invention describes the concept generally as "negotiate transactional role reversal" without specifying the mechanism ('983 Patent, col. 3:30-31).
  • Evidence for a Narrower Interpretation: The detailed description and flowcharts depict a specific implementation involving an "HTTP FLIP request" sent from the client and an "ACCEPT" response from the server, suggesting a formal, multi-step negotiation process ('983 Patent, col. 10:61-62; Fig. 10, steps 534-540).

The Term: "hardware enforcing asymmetric communication"

• Context and Importance: This limitation defines the environment in which the invention is claimed to operate. Its construction will determine whether the claims are limited to specific network configurations.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The background section broadly discusses "Network Address Translation, or proxying" and "firewalls" as sources of asymmetry, suggesting the term could cover any standard NAT router or corporate firewall that blocks unsolicited inbound traffic ('983 Patent, col. 2:45-51).
  • Evidence for a Narrower Interpretation: The use of the word "hardware" could be argued to limit the claim to physical devices whose specific purpose is enforcement, potentially excluding software-based firewalls or general-purpose routers where asymmetry is a default behavior rather than an actively enforced policy.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead a separate count for indirect infringement and alleges no specific facts to support the knowledge and intent elements required for such a claim (e.g., there is no mention of user manuals or active encouragement of infringement by customers) (Compl. ¶11).
• Willful Infringement: The complaint does not explicitly allege willful infringement or plead facts showing Defendant had pre-suit knowledge of the '983 Patent. The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, which relates to awards of attorney fees and can be based on litigation misconduct or exceptionally weak positions, but this is distinct from a formal willfulness claim seeking enhanced damages under § 284 (Compl. Prayer ¶E(i)).

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

1. A threshold issue will be one of evidentiary sufficiency: As the complaint lacks specific factual allegations about the accused products, a primary question is whether Plaintiff can produce evidence to show that an identified product actually performs the claimed, specific sequence of terminating an application-layer session, maintaining the underlying network connection, and reusing that connection for a new, role-reversed session.
2. The case will likely turn on a question of definitional scope: Can the term "negotiating transactional role reversal," which the patent illustrates with a specific "FLIP request" protocol, be construed broadly enough to read on the accused products' method for enabling two-way communication, or will the accused method be found to be technically distinct and non-infringing?