Lab Technology LLC v. Lifestation Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: LifeStation, Inc. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-09284, S.D.N.Y., 11/06/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the district and having committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for automatically refreshing a telephone's display with relevant services based on contextual information such as the user's location or the time of day.
• Technical Context: The technology at issue addresses context-aware user interfaces, which dynamically adapt to a user's environment to provide more relevant information and services with less manual navigation.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2006-06-22	U.S. Patent No. 9,219,982 Priority Date
2015-12-22	U.S. Patent No. 9,219,982 Issues
2025-11-06	Complaint Filed

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

• Patent Identification: U.S. Patent No. 9,219,982, "Apparatus and method for automatically refreshing a display of a telephone," issued December 22, 2015.

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

The Invention Explained

• Problem Addressed: The patent describes the inefficiency users face when navigating through numerous menu displays on a telephone to access a desired service, particularly when they tend to use specific services at certain times or in certain locations (Compl. ¶9; ’982 Patent, col. 1:28-40).
• 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. This is achieved through a "function," which represents a set of conditions like time or location (e.g., "office worker on weekday morning"). A "function selector" module determines the current context (e.g., by checking a clock or a location server) and selects the appropriate function from a datastore, causing the display to refresh with services associated with that function, such as traffic information for a morning commute (’982 Patent, col. 2:11-29; Fig. 4-5).
• Technical Importance: This approach sought to reduce user interaction friction by making device interfaces predictive and responsive to the user's environment, a foundational concept for modern smart devices (’982 Patent, col. 2:4-7).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims without specifying them, incorporating by reference an attached but unprovided claim chart exhibit (Compl. ¶11, ¶16). 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" with information relating to a current location of the telephone and a user.
  • The function is associated with at least one communication service.
  • The processor is operable to connect the telephone to a "location server" to obtain a current location.
  • The processor selects a function from the datastore.
  • The processor refreshes a screen on the display panel to include the communication service associated with the selected function "based at least in part on the current location of the telephone."
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint refers to "Exemplary Defendant Products" but does not identify any specific products by name (Compl. ¶11).

Functionality and Market Context

• The complaint does not describe the functionality of the accused products. It alleges that claim charts comparing the "Exemplary '982 Patent Claims" to the "Exemplary Defendant Products" are included in an attached Exhibit 2, which was not provided with the complaint itself (Compl. ¶16). Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality's specific features or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's products infringe the ’982 Patent, stating that the products "practice the technology claimed" and "satisfy all elements" of the asserted claims (Compl. ¶16). However, it incorporates the substantive infringement allegations by reference to an external claim chart exhibit (Exhibit 2), which is not included in the provided document (Compl. ¶16). The narrative theory is that the "Exemplary Defendant Products" perform the patented method of refreshing a display based on context.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Based on the language of claim 1 of the ’982 Patent and the general nature of the dispute, several points of contention may arise.
  • Scope Questions: A central question may be whether the accused products' software architecture includes a component that meets the definition of a "location server" as a distinct entity from which the telephone "obtains" its location. Further, the scope of the term "function" as a predefined set of conditions associated with a service may be disputed.
  • Technical Questions: The complaint does not provide evidence regarding how the accused products determine and use location or other contextual data. A key technical question will be whether the accused products actually "refresh a screen... based at least in part on the current location" in a manner that maps onto the claim's specific steps, or if they use a technically distinct method to present context-aware information.

V. Key Claim Terms for Construction

The Term: "function"

• Context and Importance: This term is the core of the invention, linking a user's context to the services displayed. Its construction will be critical to determining infringement, as the plaintiff will likely argue for a broad definition covering any contextual profile, while the defendant may argue for a narrower definition limited to the patent's specific examples.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines a function as representing "a given set of conditions associated with a user," which "may be static, such as user ID, or variable, such as time, location, activity or the like" (’982 Patent, col. 4:31-34). This language suggests a broad scope.
  • Evidence for a Narrower Interpretation: The patent provides specific, structured examples of functions, such as an "office worker on workday mornings" associated with a "voice message service, a collaboration service, or a conferencing service" (’982 Patent, col. 4:41-48). A defendant may argue these examples limit the term to pre-configured, role-based profiles.

The Term: "location server"

• Context and Importance: This is a specific structural element recited in claim 1. Whether the accused products contain an equivalent structure will be a key infringement question. Practitioners may focus on this term because modern devices often determine location using internal GPS hardware and local software, which may not fit the claim's requirement of connecting to an external "server" to "obtain" a location.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not narrowly define "location server." A plaintiff could argue it covers any source of location data external to the telephone's core processor, including GPS satellites or cell tower triangulation services.
  • Evidence for a Narrower Interpretation: The specification depicts the "location server" (570) as a distinct network component that the "function selector" (553) on the telephone connects to, suggesting a client-server relationship (’982 Patent, Fig. 5; col. 6:60-62). A defendant may argue this requires a networked server in the traditional sense, not merely passive signal reception.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). Specific details are allegedly provided in the unattached Exhibit 2 (Compl. ¶14).

Willful Infringement

• The complaint alleges willfulness based on knowledge obtained from the service of the complaint itself. It asserts that "at least since being served by this Complaint," Defendant has had "actual knowledge" and continued to infringe (Compl. ¶13, ¶15). This frames the allegation as post-suit willfulness.

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

• A core issue will be one of definitional scope: Can the term "function," described in the patent as a discrete profile (e.g., "hotel guest in evenings"), be construed to cover the more fluid, algorithm-driven contextual suggestions common in modern devices?
• A key evidentiary question will be one of architectural equivalence: Does the accused product's mechanism for determining location rely on a component that meets the claim limitation of a "location server"? The case may turn on whether an internal GPS chip or a distributed network of cell towers constitutes a "location server" that the device "connects to" in the manner required by the claims.
• A significant procedural question will be one of pleading sufficiency: Given that the complaint's substantive infringement allegations are contained entirely within an unprovided external exhibit, the initial stages of the case may focus on whether the complaint itself provides sufficient notice of the infringement theory as required by federal pleading standards.