Nodal Tech LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nodal Technologies LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd (Republic of Korea) & Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:24-cv-01051, E.D. Tex., 12/16/2024
• Venue Allegations: Venue is alleged to be proper for Samsung Electronics Co., Ltd. as a foreign corporation and for Samsung Electronics America, Inc. because it has allegedly committed acts of infringement and maintains a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s base station equipment supporting 4G and 5G cellular technology infringes a patent related to managing a node's affiliation with multiple clusters in an ad hoc wireless network.
• Technical Context: The technology concerns methods for improving the reliability and flexibility of wireless networks by allowing a single device to connect to multiple network access points simultaneously.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,711,409 - Node Belonging To Multiple Clusters In An Ad Hoc Wireless Network

• Patent Identification: U.S. Patent No. 6,711,409, "Node Belonging To Multiple Clusters In An Ad Hoc Wireless Network", issued March 23, 2004.

The Invention Explained

• Problem Addressed: The patent describes a problem in prior art ad hoc wireless networks where a mobile station could only affiliate with a single "cluster head" (i.e., access point) at a time (U.S. Patent 6,711,409, col. 2:22-24). The unexpected loss of that single cluster head, particularly in military or emergency scenarios, could sever the station's network connection, potentially leading to "catastrophic results" (’409 Patent, col. 2:35-37).
• The Patented Solution: The invention proposes a method allowing a mobile station to affiliate with multiple cluster heads concurrently ('409 Patent, col. 5:13-16). A station can identify and evaluate multiple potential cluster heads, establish independent communication links with a subset of them, and thereby create redundant communication paths to the network ('409 Patent, col. 3:40-51). This "multiple-cluster membership" improves network survivability and allows for smoother transitions as a station moves through the network ('409 Patent, col. 6:25-34).
• Technical Importance: This approach aimed to increase the reliability and robustness of mobile ad hoc networks by eliminating the single point of failure inherent in single-cluster affiliation schemes ('409 Patent, col. 6:43-46).

Key Claims at a Glance

• The complaint asserts independent claim 2 (Compl. ¶12).
• The essential elements of independent claim 2 are:
  • A method for configuring a network of stations, comprising:
  • determining a communication state between a station and the cluster head stations of plural clusters;
  • assigning said station to each of the plural clusters for which a prescribed communication state has been determined;
  • setting the station to be in independent communication with each of those plural cluster head stations;
  • wherein all communications for other network stations not assigned to the station's clusters are routed via at least one of the station's assigned cluster heads and the other station's assigned cluster head.
• The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "at least claim 2" (Compl. ¶12).

III. The Accused Instrumentality

Product Identification

• Defendant’s "baseband (base station) supporting 4G and 5G technology" (Compl. ¶12).

Functionality and Market Context

• The complaint alleges that Defendant's base station equipment performs the method steps recited in claim 2 of the '409 patent (Compl. ¶13). The complaint does not provide specific technical details about the operation of the accused base stations, instead referencing a "preliminary claim chart attached hereto as Exhibit B" for further detail (Compl. ¶12). Exhibit B was not provided with the complaint. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s 4G and 5G base station equipment directly infringes by performing all steps of claim 2 (Compl. ¶¶12-13).

'409 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern whether the patent's terminology, rooted in early 2000s "ad hoc wireless networks" with "cluster heads," can be read to cover modern, standardized 4G/5G cellular networks and their "base stations." The patent’s focus on self-organizing nodes that can "promote" themselves to cluster heads ('409 Patent, col. 5:35-37) raises the question of whether this model is technically analogous to the architecture of a 4G/5G cellular network.
  • Technical Questions: As the complaint lacks specific technical allegations, a key factual question will be what evidence demonstrates that Samsung’s 4G/5G systems perform the specific method steps of claim 2. For example, what evidence shows that the accused systems use a process of "assigning" a station to "plural clusters" that is equivalent to the affiliation and handshaking protocols described in the patent, as opposed to a technically distinct, standardized protocol for multi-connectivity or handovers.

V. Key Claim Terms for Construction

• The Term: "cluster head station"

• Context and Importance: The definition of this term is critical to determining if the patent's claims apply to the accused 4G/5G base stations. Practitioners may focus on this term because the Plaintiff's infringement theory depends on equating a modern cellular "base station" with the "cluster head station" of the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification suggests the term can be read broadly, at times using it interchangeably with "network access point" or "gateway" ('409 Patent, col. 8:5-6) and stating the invention is applicable to "cellular telephone systems" ('409 Patent, col. 6:65-68).
  • Evidence for a Narrower Interpretation: The specification primarily describes "cluster heads" in the context of an ad hoc network where any mobile station can "promote itself to be a cluster head" if one is unavailable ('409 Patent, col. 2:10-13; col. 5:35-37). This could support a narrower definition tied to a dynamic, peer-to-peer network structure, which may be argued as distinct from the fixed infrastructure of a cellular network.

• The Term: "assigning said station to each of the plural clusters"

• Context and Importance: This term's construction will likely focus on the specific actions required to establish the claimed multi-cluster affiliation. The dispute will be whether the accused products' method of managing connections meets the definition of "assigning" as taught in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the affiliation process as "asynchronous" and independent for each cluster head ('409 Patent, col. 9:48-50), which could support construing "assigning" to cover any technical process that results in a station being simultaneously connected to multiple access points.
  • Evidence for a Narrower Interpretation: The specification details a specific "handshaking" protocol to achieve affiliation, involving "affiliation 'request'," "response," and "join" messages ('409 Patent, col. 7:25-48, Fig. 7). This could support a narrower construction requiring a similar multi-step protocol, which may differ from the standardized procedures used in 4G/5G networks.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induced infringement by conditioning the user's use of the accused functionality on performance of the claimed steps and by controlling the manner and timing of that functionality (Compl. ¶13).
• Willful Infringement: The complaint does not contain allegations to support a claim for willful infringement.

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

• A core issue will be one of definitional scope: Can the term "cluster head station," as used in the context of a 2004 patent on ad hoc networks, be construed to encompass a modern 4G/5G "base station" operating within a standardized cellular architecture? The outcome may depend on whether the court views the patent's teachings as a high-level architecture applicable to various systems or as a specific solution tied to the unique characteristics of ad hoc networks.

• A key evidentiary question will be one of technical mechanism: Assuming the definitional scope is met, does discovery reveal that Samsung's systems perform the specific method of "determining a communication state" and "assigning" a station to multiple access points as claimed? The case will likely require a detailed technical comparison between the affiliation process described in the patent and the actual operation of standardized 4G/5G multi-connectivity and handover protocols.