DCT
2:15-cv-00041
Wetro LAN LLC v. ADTRAN Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wetro Lan LLC (Texas)
- Defendant: ADTRAN, Inc. (Delaware)
- Plaintiff’s Counsel: Austin Hansley PLLC.
- Case Identification: 2:15-cv-00041, E.D. Tex., 01/23/2015
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has transacted business and committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s wireless router products infringe a patent related to a hardware-based, non-user-configurable computer security apparatus.
- Technical Context: The technology concerns network security for small office/home office (SOHO) environments, specifically by filtering internet traffic based on predefined service types rather than complex, user-managed rules.
- Key Procedural History: The complaint was filed under the pleading standards of Federal Rule of Civil Procedure Form 18, which was in effect at the time but was abrogated in December 2015. This may provide context for the complaint's level of detail regarding infringement allegations. No other procedural events are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2000-03-07 | '918 Patent Priority Date |
| 2004-09-21 | '918 Patent Issue Date |
| 2015-01-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,795,918 - "Service Level Computer Security," issued September 21, 2004
The Invention Explained
- Problem Addressed: The patent identifies a need for a simple and effective security solution for home and small office computer users who were increasingly vulnerable to hackers due to the rise of "always-on" high-speed internet connections like DSL and cable modems ('918 Patent, col. 1:30-44). Existing firewalls were described as being overly complex, designed for corporate environments, and often implemented in software that could be disabled or compromised remotely ('918 Patent, col. 2:21-54).
- The Patented Solution: The invention proposes a physical hardware apparatus that sits between a public network (e.g., the Internet) and a private local network ('918 Patent, Fig. 1). This device uses a "packet analyzer" to inspect incoming data packets, but only examines limited "service level" information: the communication protocol, source port, and destination port ('918 Patent, col. 5:40-54). It then compares this information to a fixed, "non-user configurable" lookup table to decide whether to allow or block the packet, effectively permitting only a predefined set of internet services ('918 Patent, col. 3:11-22).
- Technical Importance: The technology aimed to provide a secure, "plug-and-play" hardware solution that was simple for non-technical users and secure against remote tampering, as its filtering rules were not intended to be alterable by the end-user ('918 Patent, col. 3:4-9).
Key Claims at a Glance
- The complaint asserts infringement of the '918 Patent, quoting what corresponds to independent claim 10 (Compl. ¶10).
- Essential elements of independent claim 10 include:
- A first communication interface for connecting to a public network.
- A packet analyzer that includes separate storage devices for protocol, source port, and destination port information extracted from a data packet.
- A lookup table device, coupled to the storage devices, that determines if a packet is authorized.
- A second communication interface for connecting to a private network.
- A limitation that the packet analyzer only permits packets for a "selected group of Internet services."
- A limitation that the "lookup table device is non-configurable by a computer user."
- A limitation that the "communication protocol information includes information about transport types."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "ADTRAN NetVanta 3200G Wireless Router and other similarly situated ADTRAN Wireless Routers" as the Accused Instrumentality (Compl. ¶11).
Functionality and Market Context
- The complaint does not provide specific details regarding the technical functionality or operation of the accused routers. It alleges in a conclusory manner that the products are used, sold, and offered for sale by the Defendant (Compl. ¶11). The complaint does not contain allegations regarding the product's commercial importance or market position.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
- Claim Chart Summary: The complaint does not provide a claim chart but makes a general allegation of infringement after quoting the language of claim 10. The following chart summarizes the infringement theory based on the complaint's structure.
'918 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer security apparatus comprising: a first communication interface coupled to a public network... | The ADTRAN NetVanta 3200G router is a computer security apparatus with an interface (e.g., a WAN port) for connecting to a public network. | ¶¶10-11 | col. 9:2-5 |
| a packet analyzer... including: a protocol storage device... a source port storage device... a destination port storage device... | The ADTRAN router contains a packet analyzer with hardware or software components that store protocol, source port, and destination port information from data packets. | ¶¶10-11 | col. 9:6-20 |
| a lookup table device... configured to determine... whether the first data packet should be authorized... | The ADTRAN router contains a lookup table (e.g., as part of its firewall or NAT functionality) that determines whether to pass or block packets based on their protocol and port information. | ¶¶10-11 | col. 9:21-26 |
| a second communication interface coupled to a private network... | The ADTRAN router has an interface (e.g., LAN ports) for connecting to a private network. | ¶¶10-11 | col. 9:27-29 |
| wherein the packet analyzer only permits data packets for a selected group of Internet services... | The ADTRAN router's firewall is configured to permit only a selected group of internet services. | ¶¶10-11 | col. 9:30-31 |
| and the lookup table device is non-configurable by a computer user... | The ADTRAN router's lookup table functionality is alleged to be non-configurable by a computer user. | ¶¶10-11 | col. 9:31-32 |
| and the communication protocol information includes information about transport types. | The protocol information used by the ADTRAN router includes transport types such as TCP and UDP. | ¶¶10-11 | col. 9:33-34 |
- Identified Points of Contention:
- Technical Question: A central question will be what evidence the Plaintiff can provide that the accused router's "lookup table device is non-configurable by a computer user." Standard commercial routers are typically designed with web-based user interfaces that allow for extensive configuration of firewall rules, port forwarding, and other security settings. The complaint does not allege any facts to suggest the accused ADTRAN routers deviate from this industry norm.
- Scope Questions: The case may turn on the construction of "non-configurable by a computer user." The viability of the infringement claim raises the question of whether this term can be interpreted to read on a commercially available router that is, in practice, highly configurable by its end-user.
V. Key Claim Terms for Construction
- The Term: "non-configurable by a computer user"
- Context and Importance: This term appears to be the primary point of novelty described in the patent and is the dispositive limitation in claim 10. Its definition is critical because most modern routers are, by design, user-configurable. The infringement analysis will likely depend entirely on whether the accused router's functionality can be said to meet this limitation. Practitioners may focus on this term because of the apparent factual mismatch between the claim requirement and the likely operation of a standard wireless router.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide a basis for a broader interpretation. A party might argue the term means the device is pre-configured to work securely "out of the box" without requiring user input, but the specification provides evidence to the contrary.
- Evidence for a Narrower Interpretation: The patent specification provides a specific definition, stating that "non-configurable generally means that the user does not have to adjust settings on the present device" ('918 Patent, col. 3:14-18). It further reinforces this by stating that the lookup table's "information can only be modified by having direct physical access to the hardware," thereby preventing a "remote intruder" from bypassing security ('918 Patent, col. 7:29-33). This evidence supports a narrow construction that would seem to exclude devices configurable via a software or web interface.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain allegations of induced or contributory infringement.
- Willful Infringement: The complaint does not allege willful infringement or plead any facts related to Defendant's knowledge of the '918 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of factual contradiction: can the accused ADTRAN wireless router, which is presumably a standard commercial product with a user-configurable administrative interface, satisfy the explicit claim limitation that its "lookup table device is non-configurable by a computer user"? The resolution of this apparent conflict between the claim language and the accused product's likely functionality will be central to the case.
- A second key question will be definitional scope: does the intrinsic evidence of the '918 patent—which defines "non-configurable" as requiring physical hardware access for modification—foreclose any interpretation that could cover a router configurable through a web interface? The construction of this term will likely be the dispositive legal issue in the dispute.