DCT

2:24-cv-01074

Quicker Connections LLC v. Cisco Systems Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-01074, E.D. Tex., 03/31/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business in Richardson and Allen, Texas, and makes, uses, or sells the accused products within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s high-speed networking platforms and related products infringe five patents related to network multiplexing, failover protection, and management in ring-based network topologies.
  • Technical Context: The patents address methods for improving the efficiency, management, and reliability of high-speed data networks, a technology domain critical to telecommunications and internet infrastructure.
  • Key Procedural History: This filing is a First Amended Complaint. The complaint alleges that a prior assignee, Orckit-Corrigent, maintained a patent marking program for products sold in other countries and provides a visual of a patent label that lists several of the patents-in-suit. Willful infringement is alleged for one patent based on knowledge acquired after the filing of the original complaint.

Case Timeline

Date Event
2000-08-11 U.S. Patent No. 6,834,038 Priority Date
2000-11-08 U.S. Patent No. 6,822,943 Priority Date
2001-07-24 U.S. Patent No. 7,054,264 Priority Date
2001-08-30 U.S. Patent No. 7,061,859 Priority Date
2002-06-05 U.S. Patent No. 7,483,399 Priority Date
2004-11-23 U.S. Patent No. 6,822,943 Issues
2004-12-21 U.S. Patent No. 6,834,038 Issues
2006-05-30 U.S. Patent No. 7,054,264 Issues
2006-06-13 U.S. Patent No. 7,061,859 Issues
2009-01-27 U.S. Patent No. 7,483,399 Issues
2025-03-31 First Amended Complaint Filing Date

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

U.S. Patent No. 6,822,943 - "Network access multiplexer with protocol address translation"

Issued November 23, 2004

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of remotely managing large, "multi-shelf" Digital Subscriber Line Access Multiplexer (DSLAM) systems at a time when public Internet Protocol (IP) addresses were becoming increasingly scarce (’943 Patent, col. 1:59-62). Assigning a unique public IP address to each shelf for management was inefficient and costly ('943 Patent, col. 2:10-12).
  • The Patented Solution: The invention proposes a master-slave architecture where a remote management station can communicate with numerous "slave shelves" through a single "master shelf" that has one common, external IP address ('943 Patent, Abstract). To distinguish between slave shelves, the management station sends messages to different transport-layer ports (e.g., UDP ports) at the master shelf's IP address. The master shelf then translates the specific port number into a unique internal IP address corresponding to the intended slave shelf, effectively conserving public IP addresses by using port numbers as a form of sub-addressing ('943 Patent, col. 2:26-48).
  • Technical Importance: This address translation method allowed network operators to manage large, physically distributed access systems as a single network entity, significantly reducing the consumption of valuable public IPv4 addresses ('943 Patent, col. 1:59-62).

Key Claims at a Glance

  • The complaint alleges infringement of an "exemplary claim" without specifying which one (Compl. ¶37). Independent claim 1 is representative.
  • Independent Claim 1 requires:
    • A "master shelf" with a "master switching unit" linked to a high-speed network.
    • A plurality of "slave shelves" in a given topology, each with ports for subscribers and a "slave switching unit" that receives management messages addressed to a unique "internal network-layer address" based on the topology.
    • A "management station" that conveys messages to the master shelf over a network where slave shelves share a "common external network-layer address" by mapping the internal address of each shelf to a "respective transport-layer address."
  • The complaint reserves the right to assert additional claims (Compl. ¶37).

U.S. Patent No. 6,834,038 - "Protection against master unit failure in remote network access multiplexing"

Issued December 21, 2004

The Invention Explained

  • Problem Addressed: In a multi-shelf network access system, a failure of the central master unit could sever connectivity for all subscribers served by remote slave units (’038 Patent, col. 2:3-6). Existing redundancy methods for preventing such outages were often complex and required significant hardware duplication ('038 Patent, col. 2:21-26).
  • The Patented Solution: The patent describes a "master sub-system" containing a first (active) master unit and a second (standby) master unit ('038 Patent, Abstract). Both are connected to the remote slave unit. Downstream traffic is sent only by the active unit. Upstream traffic from the slave is received by the first master unit and "bi-cast" (duplicated) to both the active and standby units; the standby unit discards the packets during normal operation ('038 Patent, col. 6:8-17). If the first unit fails, the second unit can seamlessly take over communication because it is already receiving the upstream traffic, providing failover protection without requiring complex signaling with the remote slave unit ('038 Patent, col. 4:32-41).
  • Technical Importance: This architecture provided a simplified and automated mechanism to ensure high availability for remote network subscribers, enhancing reliability against central-site equipment failures ('038 Patent, col. 3:31-39).

Key Claims at a Glance

  • The complaint alleges infringement of an "exemplary claim" without specifying which one (Compl. ¶41). Independent claim 1 is representative.
  • Independent Claim 1 requires:
    • A "slave unit" with subscriber ports and a multiplexer.
    • A "master sub-system" including:
      • A "first master unit" that communicates with the slave unit via an assigned link.
      • A "second master unit" that is "coupled through the first master unit" to communicate with the slave unit over the same link, providing access in the event of a failure of the first master unit.
  • The complaint reserves the right to assert additional claims (Compl. ¶41).

U.S. Patent No. 7,054,264 - "Interconnect and gateway protection in bidirectional ring networks"

Issued May 30, 2006

  • Technology Synopsis: The patent addresses failures of gateway nodes that interconnect bidirectional ring networks. The solution uses a pair of interconnect modules that normally share the traffic load. If one module fails, the other is reconfigured to handle the entire traffic load, providing rapid fault recovery and maintaining network connectivity (’264 Patent, Abstract).
  • Asserted Claims: The complaint does not specify which claims are asserted (Compl. ¶45).
  • Accused Features: The complaint accuses Cisco's products generally of infringement without identifying specific features (Compl. ¶43).

U.S. Patent No. 7,061,859 - "Fast protection in ring topologies"

Issued June 13, 2006

  • Technology Synopsis: The patent discloses a method for fast fault protection in a bidirectional ring network. In response to a fault, each network node creates a "general mask" of unreachable segments and a "specific mask" of a data flow's intended path. By logically superimposing these masks, the node can instantly determine whether to continue, reroute, or discard the data flow (’859 Patent, Abstract).
  • Asserted Claims: The complaint does not specify which claims are asserted (Compl. ¶49).
  • Accused Features: The complaint accuses Cisco's products generally of infringement without identifying specific features (Compl. ¶47).

U.S. Patent No. 7,483,399 - "Signaling MPLS over RPR rings"

Issued January 27, 2009

  • Technology Synopsis: The patent addresses the explicit routing of traffic over Resilient Packet Ring (RPR) networks using Multi-Protocol Label Switching (MPLS) signaling. The invention modifies standard MPLS signaling objects to include a direction indicator, allowing a network operator to specify the direction of traffic flow (e.g., east or west) on the ring, a capability not present in conventional signaling methods for such networks (’399 Patent, Abstract).
  • Asserted Claims: The complaint does not specify which claims are asserted (Compl. ¶54).
  • Accused Features: The complaint accuses Cisco's products generally of infringement without identifying specific features (Compl. ¶51).

III. The Accused Instrumentality

Product Identification

The accused products include multiple series of Cisco's networking platforms: "Catalyst Passive Optical Network Series Switches," "Network Convergence System 2000 Series," "Network Convergence System 2002 Series," "Network Convergence System 2006 Series," "ONS 15454 Multiservice Transport Platform," and "ONS 15600 Multiservice Transport Platform" (Compl. ¶32).

Functionality and Market Context

The complaint describes the accused products as "high-speed networking platforms" that provide "agility, programmability, and massive scale across ultra-long-haul, metro, and enterprise optical networks" (Compl. ¶30). The ONS platforms are alleged to simplify metro networks and integrate core and edge network functions for service provisioning and management (Compl. ¶31). As part of its marking allegations, the complaint includes an image of a patent label from a former assignee, listing several patents-in-suit, that was allegedly affixed to products sold outside the U.S. (Compl. ¶25, p. 7).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim chart exhibits appended as Exhibits F-J (Compl. ¶29). As these exhibits were not provided, this report summarizes the infringement allegations based on the complaint's text. The complaint's body, however, does not contain specific, element-by-element infringement allegations for any asserted claim. It states only that Defendant's Accused Products directly infringe one or more claims of the patents-in-suit (Compl. ¶¶35, 39, 43, 47, 51). Accordingly, a claim chart summary cannot be constructed from the provided complaint.

Identified Points of Contention

  • Scope Questions: The infringement analysis may raise the question of whether terminology from the patents, which are often grounded in the context of DSLAM systems (e.g., "master shelf," "slave shelves"), can be construed to read on the architecture and components of modern optical and passive optical networking platforms.
  • Technical Questions: A key technical question may be whether the Accused Products implement the specific address translation scheme of the ’943 Patent—mapping an external transport-layer port to an internal network-layer address—or if they use different, more modern network management and addressing techniques. A similar question arises for the ’038 Patent concerning whether the Accused Products' high-availability or redundancy features operate using the specific "bi-cast" architecture where a standby unit is "coupled through" an active unit.

V. Key Claim Terms for Construction

Term: "master shelf" / "slave shelves" ('943 Patent)

  • Context and Importance: The master/slave relationship is foundational to the architecture claimed in the ’943 Patent. The outcome of the case may depend on whether the distributed components in Cisco's allegedly peer-to-peer optical networks can be characterized as functioning within such a hierarchical framework.
  • Intrinsic Evidence for a Broader Interpretation: The patent describes slave shelves arranged in various topologies, including "a hybrid star/chain configuration," which may suggest the terms are not limited to a single physical layout ('943 Patent, col. 3:14-15).
  • Intrinsic Evidence for a Narrower Interpretation: The patent's background and detailed description consistently frame the invention in the context of DSLAM systems, where the master/slave terminology refers to a specific architecture for concentrating subscriber lines ('943 Patent, col. 1:15-30, col. 3:11-12).

Term: "a second master unit, coupled through the first master unit" ('038 Patent)

  • Context and Importance: This phrase appears to define a specific physical or logical data path for the failover mechanism. Practitioners may focus on this term because infringement could depend on whether the accused systems' redundancy architecture mirrors this specific "daisy-chain" like coupling.
  • Intrinsic Evidence for a Broader Interpretation: The term "coupled through" could be argued to encompass any logical arrangement where control signals or data packets destined for the standby unit are processed or routed by logic associated with the active unit.
  • Intrinsic Evidence for a Narrower Interpretation: The specification and Figure 3 describe a "daisy chain configuration" where upstream packets are duplicated by a "bi-cast block" associated with the first master unit and sent to both units, suggesting a specific structural arrangement ('038 Patent, col. 6:8-17, Fig. 3).

VI. Other Allegations

Indirect Infringement

The complaint does not contain allegations of indirect infringement; it alleges direct infringement under 35 U.S.C. § 271(a) for all counts (Compl. ¶¶35, 39, 43, 47, 51).

Willful Infringement

Willfulness is alleged for the ’399 Patent only. The complaint asserts that infringement of this patent has been willful "since the date of the Original Complaint," suggesting a theory of post-filing willfulness based on notice provided by the lawsuit itself (Compl. ¶53).

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

  • Evidentiary Sufficiency: A threshold issue may be whether the complaint, which outsources all factual detail of infringement to un-provided exhibits, satisfies modern pleading standards that require sufficient factual matter to state a claim for relief that is plausible on its face.
  • Technological Congruence: A central dispute will likely involve whether the specific network architectures patented in the early 2000s for DSLAM and early packet-ring systems are actually practiced by Cisco's modern optical transport and switching platforms, which may employ fundamentally different technologies for management, addressing, and high availability.
  • Definitional Scope: The case may turn on claim construction and whether terms rooted in the technological context of the early 2000s (e.g., "master shelf," "slave unit") can be interpreted broadly enough to encompass the potentially more distributed and non-hierarchical components of the accused systems.