Fractal Networks LLC v. Amantya Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fractal Networks LLC (NM)
  • Defendant: Amantya Technologies, Inc. (India)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00097, E.D. Tex., 01/31/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s cellular network products and systems infringe patents related to 5G edge computing, steerable antennas, and low-latency data processing.
• Technical Context: The technology concerns advanced 5G network infrastructure designed to manage high-density communications by performing computationally intensive tasks at the network edge, close to the end-user, to reduce latency.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other significant procedural events.

Case Timeline

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

U.S. Patent No. 10,637,142 - "Computing system"

The Invention Explained

• Problem Addressed: The patent describes the challenge of deploying 5G networks, which require a "huge number of 5G towers" in dense areas to provide ultra-fast speeds and low delays. These small cells often require a direct line of sight with the receiving device, creating logistical and coverage challenges. (’142 Patent, col. 1:35-48).
• The Patented Solution: The invention proposes a system that places significant computational power directly at the network's edge, physically close to or integrated with the antennas. This "edge processing module" is designed to provide "low-latency computation" for tasks like managing steerable antennas to direct communication beams efficiently. (’142 Patent, Abstract; col. 2:51-60). By processing data locally rather than sending it to a distant data center, the system aims to reduce delays critical for 5G applications.
• Technical Importance: This edge computing architecture is intended to enable the low-latency performance required for advanced 5G use cases, such as autonomous vehicles or virtual reality, which cannot tolerate the delays of traditional, centralized network processing. (’142 Patent, col. 2:1-17).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1.
• The essential elements of Claim 1 are:
  • A transceiver to communicate with a predetermined target.
  • One or more antennas coupled to the transceiver, each electrically or mechanically steerable.
  • An edge processing module coupled to the transceiver and antennas to provide low-latency computation for the target.
  • A quantum computer coupled to the edge processing module.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,694,399 - "Cellular system"

The Invention Explained

• Problem Addressed: Similar to the ’142 Patent, this patent addresses the need for an efficient and responsive architecture to manage the high data traffic and low-latency requirements of dense 5G cellular networks. (’399 Patent, col. 1:31-48).
• The Patented Solution: The invention describes a system featuring a 5G transceiver, steerable antennas, and an edge processing module. This patent places particular emphasis on a distributed computing architecture where the edge module "shares workload with a core processing module located at a head-end and a cloud module located at a cloud data center." (’399 Patent, col. 90:50-55). This tiered approach allows tasks to be allocated based on their latency requirements, with the most time-sensitive computations occurring at the edge.
• Technical Importance: This distributed workload model aims to optimize network resources by balancing computational loads between the edge, a regional head-end, and a centralized cloud, providing a flexible framework for delivering various 5G services efficiently. (’399 Patent, col. 2:20-31).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1.
• The essential elements of Claim 1 are:
  • A 5G cellular transceiver to communicate with a predetermined target.
  • One or more antennas coupled to the transceiver, each electrically or mechanically steerable.
  • A processor to control the directionality of the antennas.
  • An edge processing module for low-latency computation that shares workload with a core processing module (at a head-end) and a cloud module (at a data center), with each module having specified components (e.g., GPU, neural network).
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products or services by name. It refers to "Exemplary Defendant Products" detailed in Exhibits 3 and 4, which were not filed with the complaint (Compl. ¶12, ¶17, ¶21, ¶26).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. Based on the technology of the patents-in-suit, the accused instrumentalities are likely related to Defendant's 5G network infrastructure products, software, or services that involve distributed or edge computing capabilities for managing cellular networks.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement details are provided in claim charts in Exhibits 3 and 4, which are incorporated by reference but were not attached to the publicly filed document (Compl. ¶18, ¶27). The complaint’s narrative theory asserts that the "Exemplary Defendant Products" practice the technology claimed by the ’142 and ’399 Patents, satisfying all elements of the asserted claims (Compl. ¶17, ¶26). Without the exhibits, a detailed element-by-element analysis based on the complaint is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • ’142 Patent: The infringement analysis for Claim 1 will turn on the "quantum computer" limitation. A central question will be whether Defendant's accused systems, which likely utilize classical computing components such as GPUs and FPGAs, can be shown to meet the "quantum computer" limitation, either literally or under the doctrine of equivalents. The high specificity of this term suggests it will be a primary point of dispute.
  • ’399 Patent: The dispute regarding Claim 1 may focus on the specific, three-tiered distributed architecture. The analysis will likely question whether the accused system's architecture embodies the claimed workload sharing model between a distinct "edge processing module," a "core processing module located at a head-end," and a "cloud module located at a cloud data center," and whether each of these modules possesses the specifically recited components.

V. Key Claim Terms for Construction

"quantum computer" (’142 Patent, Claim 1)

• Context and Importance: This term is highly specific and likely dispositive for Claim 1. Infringement will depend entirely on whether the accused product contains a component that falls within the court's construction of this term. Practitioners may focus on this term because its presence in a commercial 5G networking product would be highly unusual, making it a critical potential point of non-infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification includes "quantum processors" in a list of examples of components that can be included in "edge processing," alongside more conventional "cryogenic processors, ... learning machines, GPUs, and FPGA" (’142 Patent, col. 2:61-65). A party might argue this context suggests the term could encompass any form of advanced, non-classical computation.
  • Evidence for a Narrower Interpretation: The specification provides a detailed description and a dedicated figure (FIG. 8) for a "hybrid classical/quantum computer supporting edge computing" (’142 Patent, col. 15:9-12; col. 73:1-74:54). This specific embodiment provides strong support for a narrower construction limited to a device with the actual properties of a quantum computer, as opposed to a conventional high-performance processor.

"edge processing module" (’399 Patent, Claim 1)

• Context and Importance: The definition of this term is central to defining the physical and functional location of the invention. The infringement analysis will depend on whether the processing components in the accused system are situated and function in a way that meets the definition of an "edge" module as distinct from a "head-end" or "cloud" module.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the module can be physically embodied in diverse locations, including a "pole, a building, or a light," and that it can be "embedded in the antenna housing" (’399 Patent, col. 2:7-10). This could support a broad interpretation of its physical form factor.
  • Evidence for a Narrower Interpretation: Claim 1 requires the module to "provide low-latency computation" and to "share workload" with core and cloud modules (’399 Patent, col. 90:47-55). This functional language, tying the module directly to latency reduction and a specific role in a distributed architecture, may support a narrower construction that limits the term to components physically and logically positioned to perform these specific functions relative to the antennas and the rest of the network.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant's distribution of "product literature and website materials" that allegedly instruct end users on how to use the accused products in an infringing manner (Compl. ¶15, ¶24).
• Willful Infringement: The complaint does not use the word "willful" but alleges that service of the complaint provides Defendant with "Actual Knowledge of Infringement" for its ongoing conduct (Compl. ¶14, ¶23). The prayer for relief also requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is often associated with findings of willful infringement or other litigation misconduct (Compl. p. 7).

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

1. Definitional Scope and Factual Existence: A primary issue for the ’142 Patent will be whether the accused instrumentality contains a "quantum computer" as required by Claim 1. The case may hinge on how this highly technical and specific term is construed and whether any component in the accused system can factually meet that definition.
2. Architectural Congruence: For the ’399 Patent, a key question will be one of architectural mapping. Does the accused system practice the specific three-tiered processing architecture recited in Claim 1—sharing workloads between distinct "edge," "head-end," and "cloud" modules—or does it utilize a different model of distributed computing that falls outside the claim scope?
3. Evidentiary Foundation: Given the complaint’s reliance on un-provided exhibits to identify the accused products and their functionality, a foundational issue for the entire case will be evidentiary. The initial phases of litigation will likely focus on establishing exactly which products are accused and what public or internal documentation exists to demonstrate that they practice the highly specific computational features of the asserted claims.