Lab Technology LLC v. AT&T Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: AT&T, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00412, E.D. Tex., 06/04/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Eastern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified telecommunications products and services infringe a patent related to systems for mapping a user's voice identity across different networks based on time-based rules.
• Technical Context: The technology concerns dynamic call routing, allowing a single point of contact to intelligently forward calls to a user's various devices (e.g., office, mobile, home) depending on a pre-set schedule or other attributes.
• Key Procedural History: The asserted patent is a continuation-in-part of a prior application that issued as U.S. Patent No. 7,391,858. This lineage may be relevant for determining the effective priority date of the asserted claims and for analyzing the prosecution history.

Case Timeline

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

U.S. Patent No. 8,483,102 - System and method for mapping a voice identity across multiple telephony networks with time attributes, Issued July 9, 2013

The Invention Explained

• Problem Addressed: The patent addresses the problem of individuals being associated with multiple telephone numbers (e.g., corporate extension, mobile phone, home phone), which makes it difficult for callers to reach them efficiently and forces the user to manage multiple voicemail systems ('102 Patent, col. 1:26-43).
• The Patented Solution: The invention proposes a system where a user can establish a "voice identity mapping policy" that automatically routes incoming calls based on predefined rules ('102 Patent, Abstract). This policy links a "search voice identity" (the number or ID a caller uses) to a "target voice identity" (the device or service where the call should be sent). The routing is governed by "time attributes," such as the time of day or a specific date range, allowing for dynamic call forwarding ('102 Patent, Fig. 2; col. 4:6-20). A central "policy processor" consults a database of these policies to determine how to route each call ('102 Patent, Fig. 4a).
• Technical Importance: The technology aims to provide a unified and transparent method for managing reachability across disparate communication platforms, adapting to a user's schedule and location to improve communication efficiency ('102 Patent, col. 2:21-24).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '102 Patent Claims" (Compl. ¶11). Independent claim 1 is representative of the system claimed.
• Independent Claim 1 requires:
  • One or more phone systems with telephony switches for call routing.
  • A policy processor coupled to the switches.
  • A data storage holding a "voice identity mapping policy" that maps "search voice identities" to "target voice identities" based on "time attributes."
  • A requirement that the voice identity, search voice identity, and target voice identity "each comprises a username."
  • A process where the policy processor receives a voice identity, matches it, and sends a "target voice identity comprising the username" to the telephony switch, which then "routes the call using the username."
• The complaint does not specify which, if any, dependent claims are asserted.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, services, or methods by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in an "Exhibit 2" (Compl. ¶16). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint alleges that the unspecified "Exemplary Defendant Products practice the technology claimed by the '102 Patent" (Compl. ¶16). Given the defendant and the patent's subject matter, these products are presumably telecommunications services offered by AT&T that involve call routing or forwarding functionalities. The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functions or market position.

IV. Analysis of Infringement Allegations

The complaint references but does not include the claim charts from "Exhibit 2" that purportedly detail the infringement allegations (Compl. ¶17). The body of the complaint offers only a conclusory statement that the accused products "satisfy all elements of the Exemplary '102 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint. Due to the absence of the referenced exhibit and any element-by-element analysis in the complaint, a claim chart summary cannot be constructed.

Identified Points of Contention

• Scope Questions: A primary issue will be whether identifiers used in AT&T's network, such as telephone numbers or customer account IDs, meet the claim limitation of a "username." The interpretation of this term will be central to the infringement analysis.
• Technical Questions: A key factual question will be whether the architecture of AT&T's network can be mapped onto the patent's claimed structure of a distinct "policy processor," "data storage," and "telephony switches" that interact in the specific manner recited in the claims. Plaintiff will bear the burden of proving, through discovery, that AT&T's systems contain these discrete or equivalent components and that they operate by routing calls "using the username" as claimed.

V. Key Claim Terms for Construction

The Term

"username"

Context and Importance

This term appears in the final three limitations of independent claim 1 and appears to be a key differentiator of the claimed invention. The viability of the infringement case may depend on whether the identifiers used within AT&T's accused services (e.g., phone numbers) can be construed as a "username." Practitioners may focus on this term because its definition could either confine the claim scope to specific internet-era technologies or broaden it to cover conventional telephony identifiers.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification describes a "voice identity" generally as "a designation assigned to a specific user," such as "a telephone number or an extension number" ('102 Patent, col. 2:57-59). An argument could be made that "username" is used interchangeably with this broader concept of a user-specific identifier.
• Evidence for a Narrower Interpretation: The specification provides specific examples of what a username might be, including an identifier for a "voice over IP (VOIP) network," a "VOIP service based on instant message (IM) technologies," an "IM identity," an "email account identity," or an "employee's computer user identity" ('102 Patent, col. 10:54-62). This language could support a narrower construction limiting the term to identifiers associated with digital or internet-based communication systems, as distinct from traditional telephone numbers.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that AT&T induces infringement by distributing "product literature and website materials" that direct end users to use the accused products in a manner that allegedly infringes the '102 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on knowledge of infringement acquired upon service of the complaint and the accompanying claim charts (Compl. ¶13, 15). The complaint does not allege any pre-suit knowledge.

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

1. A core issue will be one of definitional scope: Can the claim term "username," which the patent specification repeatedly associates with VoIP, IM, and computer-based identities, be construed broadly enough to read on the types of identifiers (such as traditional phone numbers or account numbers) used in AT&T's accused telecommunications services?
2. A second issue will be an evidentiary and architectural question: Can the plaintiff, through discovery, produce evidence demonstrating that AT&T's large-scale, integrated network architecture contains the specific, discrete components of a "policy processor," a "data storage" for mapping policies, and "telephony switches" that interact in the precise sequence mandated by the patent's claims? The case may turn on whether AT&T's system can be mapped to this claimed structure or if its operation is technically distinct.