ReadyComm LLC v. Mitel Networks Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ReadyComm LLC (New Mexico)
  • Defendant: Mitel Networks Corporation (Canada)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00303, E.D. Tex., 03/14/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Eastern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s telephone communication products and systems infringe a patent related to managing multiple telephone devices by designating one as "active" for calls while others remain in "stand-by."
• Technical Context: The technology addresses the management of multiple communication devices (e.g., office phone, mobile phone) by enabling a system where only one device is active at a time, simplifying call routing and user accessibility.
• Key Procedural History: The patent-in-suit, U.S. Patent No. 9,179,011, is a continuation-in-part of an earlier application that issued as U.S. Patent No. 9,049,275. The patent-in-suit was filed subject to a terminal disclaimer, which may limit its enforceable term to that of the parent patent.

Case Timeline

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

U.S. Patent No. 9,179,011 - “Telephone Communication System and Method of Using,” issued Nov. 3, 2015

The Invention Explained

• Problem Addressed: The patent identifies the problem of individuals having numerous telephone devices (home, office, mobile), each with a separate number, which complicates contact management and creates a proliferation of 10-digit numbers. ('011 Patent, col. 1:22-32; col. 2:3-14). Existing solutions like call forwarding are described as having limitations, such as requiring each device to have its own number and forwarding capabilities. ('011 Patent, col. 1:45-54).
• The Patented Solution: The invention proposes a system of interdependent telephone devices where, at any given time, only one device is in "active mode" and capable of making or receiving calls. ('011 Patent, col. 2:59-62). All other devices in the group are in "stand-by mode," rendering them incapable of making or receiving calls until a user operates a "switch" to change which device is active. ('011 Patent, col. 4:26-31, 4:46-59). This allows an incoming call to any number associated with the group to be directed to the single active device, and allows a user to "on-the-fly" redirect a call by switching the active device. ('011 Patent, col. 5:1-7).
• Technical Importance: The described system aims to provide the user with the flexibility of multiple devices while presenting a simplified, single point of contact, potentially under a single calling number, and enhancing privacy by controlling which device is live. ('011 Patent, col. 2:38-44).

Key Claims at a Glance

• The complaint does not specify claims but refers to "Exemplary '011 Patent Claims" detailed in an external exhibit. (Compl. ¶11). Independent claim 1 is representative of the core system.
• Independent Claim 1:
  • A telephone communication system comprising a group of N telephones (where N is at least two).
  • Each telephone is configured to be placed in an activated mode or a stand-by mode.
  • In stand-by mode, a telephone is "incapable of placing or receiving a call unless switched to active mode."
  • Each telephone is associated with a "switch."
  • The switch is configured to activate one telephone, which places all remaining (N-1) telephones on standby "prior to making an outgoing call or taking an incoming call."
  • At least one of the standby telephones is configured to be switched to active mode "during a telephone call."

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" which are detailed in charts within Exhibit 2. (Compl. ¶11, ¶16). Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '011 Patent." (Compl. ¶16). It states that Defendant makes, uses, sells, and imports these products, and that they are used internally by Defendant's employees and sold to its customers. (Compl. ¶11-12). The complaint does not provide further technical detail on the operation of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, "charts comparing the Exemplary '011 Patent Claims to the Exemplary Defendant Products" in Exhibit 2. (Compl. ¶16). The narrative infringement theory asserts that the accused products "satisfy all elements of the Exemplary '011 Patent Claims" either literally or under the doctrine of equivalents. (Compl. ¶16). The allegations cover direct infringement through Defendant's own making, use, and testing, as well as sales to customers. (Compl. ¶11-12).

• Identified Points of Contention:
  • Technical Question: The central dispute may involve the functionality of "stand-by mode." The claim requires a standby telephone to be "incapable of placing or receiving a call." Modern unified communications systems, such as those offered by Mitel, often feature "simultaneous ring" or "find me/follow me" capabilities where multiple devices can ring at once. The court will have to determine whether such a configuration, where a secondary device can still signal an incoming call, meets the "incapable" limitation.
  • Scope Question: A key question will be how the term "switch" is construed. The patent describes this element as potentially being a toggle, a PIN entry, or a menu selection. ('011 Patent, col. 4:50-59). The analysis will question whether a software setting in a web portal or mobile application, which is a likely implementation in the accused products, performs the function of the claimed "switch" in the manner described by the patent.

V. Key Claim Terms for Construction

• The Term: "in stand-by mode a telephone is incapable of placing or receiving a call" (from Claim 1)

  • Context and Importance: This limitation is the functional core of the claimed invention, defining the essential difference between an "active" and "stand-by" device. The viability of the infringement claim depends on whether the accused products have a mode that meets this restrictive "incapable" definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Narrower Interpretation: The claim language itself is restrictive. The specification reinforces this, stating "A phone in standby mode cannot make or receive calls." ('011 Patent, col. 2:61-62). This suggests a strict interpretation where the device must be completely inert with respect to call handling.
    • Evidence for a Broader Interpretation: A party might argue that "incapable of...receiving a call" means the device cannot be used to answer or complete the connection, even if it can alert the user to the call's existence. The patent states that stand-by devices can alert users with a "second ringtone, different from the first ringtone" of the active device, which suggests the standby device is not entirely unaware of the incoming call. ('011 Patent, col. 3:4-7).

• The Term: "switch" (from Claim 1)

  • Context and Importance: This term defines the mechanism for changing a device's status. Practitioners may focus on this term because its construction will determine whether a modern software-based user interface for call routing in the accused products can be mapped onto the patent's claimed element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly provides for multiple forms, including "a toggle switch, a Personal Identification Number (PIN), and/or a menu-type switch listing all phones associated with the one and only one identical calling number." ('011 Patent, col. 4:52-56). This language supports a broad construction that covers various user-initiated actions, including software interactions.
    • Evidence for a Narrower Interpretation: While the specification is broad, an opposing party might focus on the context of the 2008 priority date, arguing the "switch" was envisioned as a more direct, device-level command rather than a network-level routing preference set in a cloud-based portal, which may characterize the accused systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '011 Patent." (Compl. ¶14).
• Willful Infringement: Willfulness is alleged based on knowledge obtained "at least since being served by this Complaint." (Compl. ¶15). The complaint alleges that despite this actual knowledge, Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" the accused products. (Compl. ¶14).

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

The resolution of this dispute will likely depend on the answers to two central questions:

1. A core issue will be one of definitional scope: Can the claim limitation that a "stand-by" telephone is "incapable of... receiving a call" be construed to read on a modern communication device that may still alert a user to an incoming call (e.g., via simultaneous ringing), even if it is not the primary device for answering?

2. A key evidentiary question will be one of technical mapping: Does the software-based configuration of call handling rules within the accused products constitute the "switch" that activates one device while rendering others "incapable," as required by the claims, or is there a fundamental mismatch in their technical operation compared to the system described in the '011 patent?