DCT

2:24-cv-00771

Woodbury Wireless LLC v. AT&T Enterprises LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00771, E.D. Tex., 09/20/2024
  • Venue Allegations: Plaintiff asserts venue is proper in the Eastern District of Texas because AT&T maintains regular and established places of business within the district—including numerous retail stores, an "AT&T Foundry," and an "AT&T 5G Innovation Studio"—and has committed alleged acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless telecommunications networks infringe a patent related to methods for managing simultaneous transmissions in Multiple-Input Multiple-Output (MIMO) systems to reduce interference.
  • Technical Context: The lawsuit concerns advanced wireless network management techniques, specifically how a network dynamically coordinates transmissions to multiple user devices to optimize performance and reliability in complex radio environments.
  • Key Procedural History: The asserted patent issued from a long chain of continuing applications, with the earliest priority date in 2006. The patent face notes a terminal disclaimer, which may limit the patent's term. The complaint cites other recent cases where AT&T has not contested venue in the Eastern District of Texas.

Case Timeline

Date Event
2006-02-28 Earliest Priority Date ('457 Patent)
2019-05-22 Application Filing Date ('457 Patent)
2024-06-18 Issue Date (U.S. Patent No. 12,015,457)
2024-09-20 Complaint Filing Date

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

U.S. Patent No. 12,015,457 - "MIMO Methods and Systems"

  • Issued: June 18, 2024

The Invention Explained

  • Problem Addressed: The patent describes a problem in wireless communications where conventional devices suffer reduced performance when communicating with multiple other wireless devices simultaneously due to mutual interference and changing environmental conditions (Compl. ¶¶23, 30; '457 Patent, col. 1:35-44). Prior art methods for adapting to interference were seen as ineffective (Compl. ¶30; '457 Patent, col. 10:48-52).
  • The Patented Solution: The invention is a method for a MIMO system to improve performance by dynamically selecting antennas and communication protocols. The system can form "MIMO physical sectors" by using overlapping directional antennas and can select an optimal combination to adapt to noise or changing conditions ('457 Patent, col. 1:56-65, col. 4:26-33). This allows the system to, for example, select different antennas or channels to reduce interference and maintain performance ('457 Patent, col. 9:5-14).
  • Technical Importance: The technology aims to provide more robust and higher-performance wireless communication by actively managing antenna configurations and radio resources in response to real-world, dynamic network conditions (Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶41).
  • The essential elements of Claim 1, a computer-implemented method, include:
    • Providing access to a MIMO-capable access point.
    • Selecting a channel based on channel characteristics.
    • Initiating a first and second transmission to two different wireless devices, such that the transmissions occur at least partially simultaneously.
    • Receiving measurement information back from the first and second wireless devices.
    • Altering at least one aspect of the first and second transmissions based on the received information to reduce interference.
    • Transmitting data to the first device, where the transmission occurs simultaneously with an "additional transmission from another" MIMO access point.
    • Receiving and acting on information from a third wireless device to alter a third transmission, which occurs over a different protocol (e.g., 802.11n) than the first two transmissions.
  • The complaint reserves the right to amend its infringement contentions (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

  • The "AT&T Wireless Networks," which provide "wireless coverage for 4G LTE, 5G, and '5G+' services" (Compl. ¶14). This includes the network infrastructure and services provided under the "AT&T" and "Cricket Wireless" brands (Compl. ¶14).

Functionality and Market Context

  • The complaint alleges that the accused networks are used to provide wireless telecommunications services throughout the United States, including within the Eastern District of Texas (Compl. ¶14). The complaint highlights AT&T's marketing of these networks for "increased data speeds, reliability, and a uniform user experience" (Compl. ¶29). To establish venue, the complaint includes a screenshot from AT&T's website showing a map of its numerous retail stores within the district. (Compl. p. 4). The complaint also points to an "AT&T Foundry" and "AT&T 5G Innovation Studio" in Plano, Texas, as places where AT&T designs, tests, and promotes services for its wireless networks (Compl. ¶¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least Claim 1 of the '457 patent but refers to an "exemplary Claim Chart...attached hereto as Exhibit B," which was not included with the public filing (Compl. ¶40). The following chart summarizes the infringement theory based on the complaint's narrative allegations and the language of Claim 1.

’457 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A computer-implemented method, comprising: providing access to a multiple-input-multiple-output (MIMO)-capable access point... The complaint alleges that the AT&T Wireless Networks are MIMO-capable systems that provide wireless access to users. ¶¶14, 23, 41 col. 13:67-14:1
selecting at least one channel based on one or more channel characteristics, for initiating a first transmission to a first portable wireless device and initiating a second transmission to a second portable wireless device, such that at least a portion of the first transmission occurs simultaneously with at least a portion of the second transmission... The complaint alleges AT&T's networks perform the claimed steps, which would require selecting channels and managing simultaneous transmissions to multiple user devices. ¶¶23-25, 41 col. 14:2-12
receiving first information from the first portable wireless device that is based on a first measurement performed by the first portable wireless device... The complaint's theory requires that AT&T's networks receive feedback (e.g., signal quality metrics) from user devices. ¶¶27, 41 col. 14:13-16
altering at least one aspect of the first transmission, based on at least one of the first information or the second information, so as to reduce interference... The infringement theory requires that the networks actively alter transmission parameters (e.g., power, antenna configuration) in response to device feedback to mitigate interference. ¶¶24, 27, 41 col. 14:17-25
transmitting first data...such that the first transmission is transmitted simultaneously with an additional transmission from another multiple-input-multiple-output (MIMO)-capable access point to the first portable wireless device... The complaint's theory requires that the accused networks coordinate transmissions between different access points (e.g., cell towers) to the same user device. ¶¶23, 41 col. 14:31-37
transmitting third data in connection with the third transmission to the third portable wireless device, via a second wireless protocol including a 802.11n protocol, where the first wireless protocol includes another 802.11 protocol other than the 802.11n protocol. The infringement theory requires that the AT&T networks perform transmissions using multiple, distinct wireless protocols as specified in the claim. ¶¶41 col. 14:46-52

Identified Points of Contention

  • Technical Questions: A primary question will be whether the standard operations of AT&T's 4G/5G networks, which manage millions of users, practice the specific, multi-step feedback loop of "receiving measurement information" and then "altering" transmissions "so as to reduce interference" in the precise manner claimed. Does AT&T's network management constitute the claimed "altering," or does it operate on a different technical principle?
  • Scope Questions: Claim 1 recites coordinating a transmission with an "additional transmission from another multiple-input-multiple-output (MIMO)-capable access point." A key question will be whether AT&T's inter-cell coordination or carrier aggregation technologies meet this limitation as described in the patent.
  • Evidentiary Questions: The complaint does not specify which particular AT&T network management systems, algorithms, or standards (e.g., specific 3GPP releases) perform the claimed method. Discovery will be required to identify the specific software and hardware that allegedly practices each step.

V. Key Claim Terms for Construction

"altering at least one aspect of the first transmission...so as to reduce interference"

  • Context and Importance: This term is central to the invention's purported novelty over prior art interference management techniques. The case may turn on whether "altering" requires a specific type of change (e.g., selecting a new set of antennas, as described in embodiments) in direct response to specific device feedback, versus more general, system-wide network optimization. Practitioners may focus on this term because it defines the core feedback-and-response mechanism of the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad ("at least one aspect"). The specification discusses altering transmissions to improve various metrics like "throughput, data throughput, signal-to-noise ratio, reduced signal error," which could support a broad reading of the term's purpose ('457 Patent, col. 5:27-33).
    • Evidence for a Narrower Interpretation: The specification repeatedly links improved performance to the selection of an "optimal combination of antennas to form a MIMO physical sector" ('457 Patent, col. 9:5-9) or selecting a "different MIMO virtual sector" ('457 Patent, col. 5:10-14). A defendant may argue that "altering" should be limited to these specific disclosed actions of reconfiguring antenna sectors, not just any parameter tweak.

"an additional transmission from another multiple-input-multiple-output (MIMO)-capable access point"

  • Context and Importance: This limitation appears to require coordination between two distinct access points (e.g., cell towers) to serve a single device simultaneously. The infringement analysis will depend on whether this reads on modern network features like Coordinated Multi-Point (CoMP) or certain forms of carrier aggregation, or if the patent's disclosure implies a different structure.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "access point," which could be argued to cover a range of network nodes. The patent's focus is on improving performance, a goal shared by modern multi-cell coordination techniques.
    • Evidence for a Narrower Interpretation: The specification does not appear to provide extensive detail on the interaction between two separate access points. The claim language is found in the '457 patent, which issued in 2024, but the original priority document is from 2006. The meaning of "access point" and the nature of inter-AP coordination may be interpreted in light of the technology available at the time of invention.

VI. Other Allegations

  • Indirect Infringement: The complaint does not include specific counts or detailed factual allegations for indirect infringement.
  • Willful Infringement: The complaint alleges that AT&T has had "actual knowledge of the '457 patent at least as early as the date of service of this Complaint" (Compl. ¶42). This forms a basis for alleging post-suit willful infringement but does not allege pre-suit knowledge.

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

  1. A central issue will be one of technical specificity: Does the general interference management inherent in a modern 4G/5G network practice the specific, multi-step method of claim 1, which requires receiving discrete feedback from multiple devices and then "altering" transmissions in a particular way to "reduce interference," or is this a fundamental mismatch in operation?
  2. A key question of claim scope will be whether the limitation requiring simultaneous transmission "from another...access point" can be mapped onto AT&T's current network architecture, such as its implementation of inter-cell coordination or carrier aggregation technologies.
  3. An evidentiary question will be what specific network systems, software, and 3GPP or other standards implement the claimed method. The complaint's high-level allegations place the burden on discovery to uncover the technical evidence needed to connect the patent's claims to the complex, multi-layered operation of a national wireless network.