Lab Technology LLC v. MSS Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: MSS Electronics, Inc. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:26-cv-00374, S.D.N.Y., 01/15/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is incorporated in New York, has an established place of business in the district, and has committed acts of alleged infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified "Exemplary Defendant Products" infringe a patent related to automatically refreshing a telephone's display with relevant services based on the user's context, such as time or location.
• Technical Context: The technology at issue concerns context-aware user interfaces for electronic devices, which aim to personalize and streamline the user experience by proactively presenting relevant information or services.
• Key Procedural History: The patent-in-suit is a continuation of a chain of applications with an earliest priority date of June 22, 2006, suggesting an extended period of prosecution and development for the claimed technology.

Case Timeline

Date	Event
2006-06-22	U.S. Patent No. 9,219,982 Priority Date
2015-06-04	U.S. Patent No. 9,219,982 Application Filing Date
2015-12-22	U.S. Patent No. 9,219,982 Issue Date
2026-01-15	Complaint Filing Date

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*

• Issued: December 22, 2015.

The Invention Explained

• Problem Addressed: The patent describes the inefficiency users face when navigating through numerous menu displays on a telephone to find a desired service, particularly when they tend to use the same services at predictable times or in specific locations (ʼ982 Patent, col. 1:29-45).
• The Patented Solution: The invention proposes a telephone that automatically updates its display to show "commonly used communication services" that are relevant to a user's current context. This is achieved by selecting a "function," defined as a set of conditions like time or location (e.g., "office worker on weekday morning"), and then refreshing the screen to display services associated with that function (ʼ982 Patent, col. 2:19-38; Fig. 3). The system can use inputs from a clock or a location server to select the appropriate function from a datastore (ʼ982 Patent, col. 6:35-43, 6:55-63).
• Technical Importance: This approach aims to reduce user effort and streamline interaction with a device by proactively presenting contextually relevant options, anticipating user needs without manual navigation (ʼ982 Patent, col. 1:50-57).

Key Claims at a Glance

• The complaint does not specify which claims it asserts, referring only to "Exemplary '982 Patent Claims" detailed in an unprovided exhibit (Compl. ¶11, ¶16). Independent claim 1 is the broadest apparatus claim.
• 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 function is associated with at least one "communication service."
  • The processor is operable to connect to a "location server" to obtain the telephone's 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.
• The complaint does not explicitly reserve the right to assert other claims, but its general language suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers to "Exemplary Defendant Products" that are purportedly identified in claim charts attached as Exhibit 2; however, this exhibit was not provided with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused product's specific functionality or market position, as all such details are deferred to the unprovided Exhibit 2 (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts in Exhibit 2, which is not included with the filed document (Compl. ¶16-17). The narrative theory asserts that the "Exemplary Defendant Products" practice the technology of the ’982 Patent and satisfy all elements of the asserted claims (Compl. ¶16). The complaint also alleges that Defendant provides "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether the term "function," as described in the patent as a discrete set of conditions (e.g., "office worker on weekday morning") (ʼ982 Patent, col. 4:35-36, 4:41-43), can be construed to cover modern, algorithmically-driven, context-aware features in operating systems that do not rely on pre-defined, stored profiles.
• Technical Questions: The infringement analysis may focus on whether the accused products perform the specific two-step process recited in claim 1: first, using location information to "select a function from the datastore," and second, using that selected function to "refresh a screen" with an associated service (ʼ982 Patent, col. 8:51-64). The question is whether the accused products implement this specific architecture or use a more direct method, such as having a location-aware widget that directly queries for and displays local information without an intermediate "function" selection step.

V. Key Claim Terms for Construction

Term: "function" (from Claim 1)

• Context and Importance: This term is the core of the claimed invention. Its construction will likely determine whether the claims read on modern smartphone interfaces that provide context-aware suggestions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines "function" broadly 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" (ʼ982 Patent, col. 4:31-34). This language could support an interpretation that covers any software module that acts on variable user context.
  • Evidence for a Narrower Interpretation: The patent's examples consistently describe functions as discrete, named roles or situations, such as "an office worker on workday mornings," "a shopper's role at a shopping mall," or a "seasonal event or holiday" (ʼ982 Patent, col. 4:41-43, 5:3-4, 5:14-15). This could support a narrower construction requiring a stored, pre-defined profile or state rather than a dynamic, algorithmic determination.

Term: "select a function from the datastore" (from Claim 1)

• Context and Importance: This phrase defines a key step in the claimed process. The dispute may turn on whether an accused device performs an explicit selection of a defined data object ("function") from storage ("datastore"), or if it uses a different computational process.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not narrowly define "datastore" or the "selection" process, which could allow the terms to cover a wide range of memory structures and software logic that uses location as an input to alter device behavior.
  • Evidence for a Narrower Interpretation: The architecture depicted, particularly in Figures 4 and 5, shows a "Function Selector" (453, 553) that connects to a "Datastore" (460, 560) containing distinct "Function" objects (452, 552). This could support an argument that the claims require a specific architecture where discrete "function" profiles are stored and retrieved, as opposed to being generated dynamically by an algorithm.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct customers and end users to use the accused products in a manner that infringes the ’982 Patent (Compl. ¶14-15).

Willful Infringement

The complaint does not include a formal count for willful infringement. However, it asserts that the filing and service of the complaint provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶13). This allegation serves as a basis for potential claims of post-suit willful infringement and enhanced damages. The prayer for relief also requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. Prayer for Relief ¶ E.i).

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

• A core issue will be one of definitional scope: can the patent’s central concept of a "function"—described with examples of discrete user profiles like "office worker" or "shopper"—be construed to encompass the dynamic, algorithm-driven, context-aware suggestion features common in modern mobile operating systems?
• A second key issue will be one of architectural equivalence: does the accused technology perform the specific sequence required by the claims—using location to explicitly "select a function from the datastore," which then dictates the content to be displayed—or does it achieve a similar result through a fundamentally different software architecture that does not map onto the claim elements?
• An immediate procedural question will be the sufficiency of the pleadings: the complaint's complete reliance on an unprovided exhibit to identify the accused products and articulate its infringement theory may be subject to challenge under federal pleading standards.