RecepTrexx LLC v. Texas Instruments Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: RecepTrexx LLC (Delaware)
  • Defendant: Texas Instruments, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:23-cv-00213, E.D. Tex., 05/11/2023
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s wireless communication products infringe a patent related to methods for routing data in ad hoc wireless networks.
• Technical Context: The technology concerns ad hoc wireless networking, a method allowing devices to communicate directly without a central access point, which is critical for mobile, infrastructure-less communications.
• Key Procedural History: Plaintiff RecepTrexx LLC is the assignee of the patent-in-suit. The complaint alleges that Defendant’s knowledge of infringement began, at the latest, upon service of the complaint.

Case Timeline

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

U.S. Patent No. 6,909,706 - “Multicast wireless ad hoc packet routing”

• Patent Identification: U.S. Patent No. 6,909,706, “Multicast wireless ad hoc packet routing,” issued June 21, 2005.

The Invention Explained

• Problem Addressed: In mobile ad hoc networks, particularly for hierarchical organizations like military units, conventional routing protocols can be inefficient (Compl. ¶ 9; ’706 Patent, col. 2:41-55). These protocols often require extensive "route discovery" messages to build and maintain routing tables for all possible destinations, which consumes limited network bandwidth.
• The Patented Solution: The invention proposes a hybrid routing method to optimize communications. For nearby nodes (e.g., within two hops), the system uses "periodic update messages" (PUMs) to proactively establish and maintain routes without requiring a specific discovery request (’706 Patent, col. 4:19-46). For nodes that are further away (more than two hops), the system falls back on conventional on-demand route discovery protocols (’706 Patent, col. 5:4-10). This approach is designed to handle the majority of traffic (which is assumed to be local) efficiently while still enabling communication to distant nodes.
• Technical Importance: This tiered approach sought to balance the need for reliable connectivity with the need to conserve bandwidth in dynamic, mobile wireless environments.

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and "Exemplary '706 Patent Claims," without specifying particular claim numbers (Compl. ¶ 11). Independent claim 1 is representative of the core invention.
• Independent Claim 1: A method comprising the steps of:
  • providing at least a first, second, and third LAN radio, where the first and second are not in range of each other but both are in range of the third;
  • broadcasting a periodic update message from the first LAN radio comprising information that the second LAN radio is not within range of the first LAN radio;
  • receiving the periodic update message with the third LAN radio;
  • determining that the first and second LAN radios are within range of the third LAN radio; and
  • updating a database of the third LAN radio with route information to indicate a route between the first and second LAN radios through the third LAN radio.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers to "Exemplary Defendant Products" that are purportedly identified in an attached Exhibit 2 (Compl. ¶ 11). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context. It alleges in general terms that Defendant makes, uses, sells, and imports products that "practice the technology claimed by the '706 Patent" (Compl. ¶ 16).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within claim charts in an unprovided "Exhibit 2" (Compl. ¶¶ 16-17). As such, a detailed element-by-element analysis based on the complaint's text is not possible. The complaint asserts that these charts demonstrate that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶ 16). No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent and the nature of the defendant's business, the infringement analysis will likely raise several questions.
  • Scope Questions: A central question may be whether components sold by the Defendant, such as wireless transceivers or system-on-a-chip (SoC) devices, constitute a "LAN radio" as recited in the claims, or whether the claims are properly directed to a complete end-user system. This will determine whether the primary dispute is over direct or indirect infringement.
  • Technical Questions: A key evidentiary question will be whether the accused products, either as sold or as implemented by customers, perform the specific step of "broadcasting a periodic update message... comprising information that said second LAN radio is not within range of said first LAN radio" (’706 Patent, col. 6:55-58). The case may turn on whether any periodic network beaconing in the accused products meets this specific informational requirement.

V. Key Claim Terms for Construction

• The Term: "periodic update message"
• Context and Importance: This term is central to the claimed invention, as it is the mechanism for the efficient, two-hop routing strategy that distinguishes it from conventional protocols. The definition will be critical to determining whether the accused products perform the broadcasting step of claim 1.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves do not strictly limit the content of the message beyond requiring "information that said second LAN radio is not within range of said first LAN" (’706 Patent, col. 6:55-58). A party could argue this encompasses any periodic signal from which such a status could be inferred.
  • Evidence for a Narrower Interpretation: The specification describes the periodic update message (PUM) in more detail, stating it "contains the global positioning system (GPS) location of a given LAN radio and the corresponding RBIP [role-based IP address]" and "a list of roles/members who should be normally within range of his LAN but are not" (’706 Patent, col. 4:21-30). A party may argue that to qualify as a "periodic update message," a broadcast must contain this specific type of "missing neighbor" list, not just general status information.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '706 Patent" (Compl. ¶ 14). The knowledge element for inducement is alleged to be met "at least since being served by this Complaint" (Compl. ¶ 15).
• Willful Infringement: The complaint does not contain a formal count for willful infringement. However, it alleges that Defendant has "actual knowledge" of its infringement from the date of service of the complaint and "continues to make, use, test, sell, offer for sale, market, and/or import" infringing products despite this knowledge (Compl. ¶¶ 13-14).

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

1. A primary issue will be one of evidence and specificity: Given the complaint’s reliance on an unprovided exhibit, a key question is whether Plaintiff can produce evidence showing that Defendant's accused products—which are likely components—perform the specific method steps of the asserted claims, particularly the generation and broadcasting of a "periodic update message" with the specific content described in the patent.
2. The case will also involve a core question of claim scope and liability: Does the term "LAN radio" as used in the claims encompass a semiconductor component, or does it refer to a complete end-user device? The resolution of this question will determine whether Defendant faces liability for direct infringement or if the case is primarily about whether it induces infringement by its customers.