DCT

2:25-cv-07267

E Beacon LLC v. Medical Guardian LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-07267, E.D. Pa., 12/23/2025
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of Pennsylvania because Defendant has an established place of business in the District.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephony.
  • Technical Context: The technology addresses the challenge of locating mobile VoIP users during emergency calls by using multiple location detection methods to automatically transmit a user's physical coordinates to 911 call centers.
  • Key Procedural History: The front page of the asserted patent indicates it is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in the family. The complaint itself does not mention any prior litigation, licensing history, or other proceedings.

Case Timeline

Date Event
2005-08-05 ’386 Patent Priority Date
2011-04-25 ’386 Patent Application Filing Date
2013-08-20 ’386 Patent Issue Date
2025-12-23 Complaint Filing Date

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

U.S. Patent No. 8,515,386 - Emergency services for voice over IP telephony (E-VoIP)

  • Patent Identification: U.S. Patent No. 8,515,386, “Emergency services for voice over IP telephony (E-VoIP),” issued August 20, 2013 (’386 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the unreliability of emergency services for VoIP telephone systems, which, unlike traditional landlines, are not tied to a fixed physical address. This creates a risk that if a VoIP user dials 9-1-1 and cannot verbally communicate their location, emergency responders could be dispatched to an incorrect, registered address instead of the user's actual location (’386 Patent, col. 1:24-44).
  • The Patented Solution: The invention proposes a system that automatically determines the physical location of a VoIP device using one or more location detection technologies, such as GPS or cellular network triangulation. When an emergency number is dialed, the system transmits the determined physical coordinates to the emergency call center, ensuring first responders are sent to the correct location even if the caller is incapacitated (’386 Patent, Abstract; col. 2:36-44). The system is designed to use multiple location detection methods and can fall back to a cellular network if the primary VoIP network is unavailable (’386 Patent, Fig. 1).
  • Technical Importance: The technology aimed to provide mobile VoIP users with E911 location services comparable in reliability to those available for traditional telephones, addressing a critical public safety gap for this emerging communication method (’386 Patent, col. 1:11-14).

Key Claims at a Glance

The complaint does not specify which claims of the ’386 Patent are asserted, instead referring to an unprovided exhibit containing claim charts (Compl. ¶11, ¶16). Independent claim 1 is representative of the patent's core method.

  • Independent Claim 1:
    • A method for determining the physical location of a VoIP phone and transmitting the physical location to an emergency services call center.
    • The method comprises making a plurality of attempts to determine the physical location of the VoIP phone, with each attempt using a separate location detection technology ("LDT").
    • If an attempt is successful, the method involves storing the determined physical location.
    • The method includes placing a call to the emergency services call center with the VoIP phone.
    • The method concludes by automatically transmitting the physical location of the VoIP phone to the emergency services call center.

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify any specific accused products by name. It refers to them generally as "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused products' functionality. It alleges in a conclusory manner that the products "practice the technology claimed by the '386 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s substantive infringement allegations appear to be contained entirely within "claim charts incorporated into this Count" located in an external document, Exhibit 2, which was not filed with the complaint (Compl. ¶11, ¶16-17). The complaint itself offers no specific factual allegations mapping claim elements to accused product features. The infringement theory is broadly stated as Defendant "making, using, offering to sell, selling and/or importing" infringing products (Compl. ¶11).

  • Identified Points of Contention: Based on the language of representative Claim 1 of the ’386 Patent, the infringement analysis may raise several key questions.
    • Scope Questions: The case may turn on the definition of "separate location detection technology." A central question could be whether using different algorithms on a single hardware radio (e.g., two different cellular triangulation methods) constitutes two "separate" technologies, or if the term requires distinct technological categories (e.g., GPS vs. Wi-Fi positioning).
    • Technical Questions: A factual dispute may arise over whether the accused products actually perform a "plurality of attempts" to determine location using different LDTs as required by the claim. The complaint provides no factual basis to assess this allegation.

V. Key Claim Terms for Construction

  • The Term: "separate location detection technology ('LDT')"
  • Context and Importance: This term appears in the core limitation of independent claim 1, which requires "making a plurality of attempts... each using a separate location detection technology." The breadth of this definition will be critical to the infringement analysis, as it dictates what combination of methods in an accused product would satisfy the claim. Practitioners may focus on this term because its interpretation will determine whether a product using, for example, multiple Wi-Fi-based location techniques alongside a single GPS check would infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of LDTs, including "GPS, CDMA and GSM technologies," as well as "Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies that can provide geolocation information" (’386 Patent, col. 8:58-65). This broad list may support an interpretation where different software-based methods qualify as "separate" technologies.
    • Evidence for a Narrower Interpretation: The patent’s description of a physical embodiment distinguishes between "a cellular module 120 and a GPS module 122" as distinct hardware components (’386 Patent, col. 6:11-13; Fig. 3). This could support a narrower construction requiring fundamentally different hardware or communication standards to be considered "separate."

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). The complaint references an unprovided Exhibit 2 for evidence supporting this allegation (Compl. ¶14).
  • Willful Infringement: The complaint does not explicitly allege willful infringement. However, it pleads facts that could support a claim for post-suit willfulness by alleging that service of the complaint constitutes "Actual Knowledge of Infringement" and that Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" the accused products despite this knowledge (Compl. ¶13-14).

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

The complaint as filed presents a generalized notice of infringement, with the specific factual and technical bases for its claims deferred to an unprovided exhibit. Consequently, the case will likely turn on the following fundamental questions:

  • A primary evidentiary question will be one of technical proof: What specific products are accused of infringement, and what evidence will Plaintiff produce to demonstrate that these products perform the claimed method, particularly the step of "making a plurality of attempts" to determine location using multiple, "separate" technologies?
  • A central legal issue will be one of definitional scope: How will the court construe the term "separate location detection technology"? The outcome of this claim construction will likely determine whether the functionality of the accused products, once revealed, falls within the scope of the patent claims.