E Beacon LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (DE)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00890, E.D. Tex., 11/03/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed acts of patent infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that certain unspecified Samsung products infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology addresses the challenge of locating mobile VoIP users during emergency calls, a critical function as telecommunications shift from fixed-line to internet-based systems.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term. The patent is also a continuation-in-part of a prior application that issued as U.S. Patent No. 7,933,580, suggesting a more developed prosecution history that could inform claim construction. The complaint's willfulness and inducement allegations are based on knowledge gained from the service of the complaint itself.

Case Timeline

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, issued August 20, 2013.

The Invention Explained

• Problem Addressed: The patent's background section notes that traditional emergency services for landlines reliably transmit a user's fixed address to a 911 operator. In contrast, VoIP phones are mobile and can be used in any location with internet access, meaning a pre-registered address may be incorrect and of no help to first responders if the user is traveling or unable to communicate their location verbally (’386 Patent, col. 1:11-44).
• The Patented Solution: The invention is a system that determines the current physical location of a VoIP device using technologies like GPS or cellular network triangulation. When an emergency number is dialed, the system automatically transmits these determined physical coordinates to the emergency services call center, enabling operators to locate the caller even if the phone is not at its registered address (’386 Patent, col. 2:32-44). The process involves detecting an emergency call, obtaining current or recently stored coordinates, and sending that data to the Public Safety Answering Point ("PSAP") (’386 Patent, Fig. 1).
• Technical Importance: This technology aims to provide mobile VoIP users with location-based emergency response capabilities comparable to those available on cellular networks, addressing a critical public safety gap created by the rise of nomadic internet telephony (’386 Patent, col. 1:47-57).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '386 Patent Claims" detailed in an unprovided exhibit (Compl. ¶11). Independent claim 1 is a representative method claim.
• Independent Claim 1:
  • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT")
  • if an attempt is successful, storing the physical location determined using the corresponding LDT
  • placing a call to the emergency services call center with the VoIP phone
  • 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 generally to "Exemplary Defendant Products" that are purportedly detailed in claim charts within an unprovided "Exhibit 2" (Compl. ¶¶11, 16).

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 '386 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts in an unprovided Exhibit 2 (Compl. ¶¶ 16-17). As this exhibit is not attached to the publicly filed complaint, a detailed element-by-element analysis of the infringement allegations is not possible. The complaint alleges that the "Exemplary Defendant Products" satisfy all elements of the exemplary asserted claims (Compl. ¶16).

Identified Points of Contention

Lacking specific allegations, any analysis is preliminary. However, disputes in this technology area frequently center on the following questions:

• Technical Questions: A primary question will be evidentiary: what specific location-determining technologies (e.g., Wi-Fi positioning, GPS, cell tower triangulation) do the accused products use, and do they constitute separate "location detection technologies" as required by the claim? Another question is whether the transmission of location data is "automatic" or if it requires user interaction that might fall outside the claim's scope.
• Scope Questions: The case may turn on how broadly the court construes "VoIP phone." Does this term, as used in the patent, cover modern smartphones that use Wi-Fi calling and other VoIP protocols, or is its scope limited to the dedicated VoIP devices contemplated at the time of invention?

V. Key Claim Terms for Construction

• The Term: "location detection technology ('LDT')" (from Claim 1)
• Context and Importance: The definition of LDT is central to infringement, as Claim 1 requires using a "plurality" of "separate" LDTs. A narrow definition could allow a defendant to argue its device uses a single, integrated location system, while a broad definition would make it easier for the plaintiff to show that different methods (e.g., GPS and Wi-Fi) used by the same device are distinct LDTs. Practitioners may focus on this term to determine if the accused products meet the "plurality" limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of LDTs, including "geolocation, location based service (LBS), GSM localization, triangulation, automatic location information (ALI) database correlation, coordinate information... GPS, CDMA and GSM technologies... Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies" (’386 Patent, col. 7:56-65). This extensive list could support a broad reading that encompasses nearly any electronic means of determining position.
  • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes GPS and cellular networks as the primary examples (’386 Patent, col. 2:49-54). A defendant may argue that the term should be limited to distinct network-based systems (like GPS, CDMA, and GSM) rather than different software-based techniques that might rely on the same underlying hardware.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant distributing "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint's theory of willfulness is based on post-suit conduct. It alleges that "service of this Complaint, in conjunction with the attached claim charts...constitutes actual knowledge" and that Defendant's infringement continued despite this knowledge (Compl. ¶¶13-14). Induced infringement is also alleged to have occurred "At least since being served by this Complaint" (Compl. ¶15).

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

1. An Evidentiary Question: A threshold issue, arising from the complaint's lack of specificity and its reliance on an unprovided exhibit, will be establishing the precise identity and technical operation of the "Exemplary Defendant Products." The viability of the infringement case depends entirely on evidence that is not yet on the public record.
2. A Question of Claim Scope: The case will likely hinge on the interpretation of "a plurality of... separate location detection technolog[ies]." The central question for the court will be whether the accused products' location-finding methods, once revealed, constitute two or more distinct "LDTs" under the patent's definition, or a single, multifaceted system.
3. A Question of Timing and Intent: Given that the willfulness and inducement allegations are predicated on knowledge from the complaint itself, a key issue will be whether Plaintiff can prove Defendant engaged in infringing conduct after being served and, if so, whether that conduct was sufficiently egregious to warrant enhanced damages.