DCT

2:25-cv-00388

Integral Wireless Tech LLC v. D Link Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00388, E.D. Tex., 04/11/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant D-Link is a foreign corporation that does not reside in any U.S. judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s extensive portfolio of networking and home security products, including server systems, 5G devices, Wi-Fi routers, and Bluetooth devices, infringes eight patents related to a wide range of technologies including wireless network handovers, power management, user behavioral data analysis, data coding, and data processing.
  • Technical Context: The patents-in-suit cover diverse technologies central to modern wireless communications, data transmission efficiency, and personalized online content delivery.
  • Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or specific licensing history concerning the asserted patents.

Case Timeline

Date Event
2004-12-20 Earliest Priority Date ('716 Patent)
2005-06-08 Earliest Priority Date ('805 Patent)
2005-06-09 Earliest Priority Date ('411 Patent)
2006-03-16 Earliest Priority Date ('866 Patent)
2006-08-17 Earliest Priority Date ('654 Patent)
2007-02-21 Earliest Priority Date ('213 & '214 Patents)
2008-07-07 Earliest Priority Date ('360 Patent)
2009-12-01 Issue Date (U.S. Patent No. 7,627,805)
2010-04-27 Issue Date (U.S. Patent No. 7,707,213)
2010-04-27 Issue Date (U.S. Patent No. 7,707,214)
2011-05-31 Issue Date (U.S. Patent No. 7,953,411)
2011-10-04 Issue Date (U.S. Patent No. 8,031,654)
2011-12-06 Issue Date (U.S. Patent No. 8,073,866)
2012-04-10 Issue Date (U.S. Patent No. 8,156,360)
2018-07-24 Issue Date (U.S. Patent No. 10,033,716)
2025-04-11 Complaint Filing Date

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

U.S. Patent No. 7,953,411 - “Virtual Soft Hand Over in OFDM and OFDMA Wireless Communication Network”

  • Issued: May 31, 2011

The Invention Explained

  • Problem Addressed: The patent addresses the complexity and resource intensity of conventional soft handover (SHO) processes in wireless networks, where a mobile device must synchronize and communicate with multiple base stations simultaneously during a handover (Compl. ¶19; ’411 Patent, col. 1:43-65).
  • The Patented Solution: The invention proposes a "virtual soft handover" (VSHO) mechanism where a mobile subscriber station (MSS) communicates with only one base station at a time in any given frame, while still monitoring adjacent base stations. This allows the MSS to switch quickly to the base station with the best channel condition without the overhead of simultaneous multi-station communication (Compl. ¶19; ’411 Patent, col. 2:4-11, Fig. 3).
  • Technical Importance: This approach aimed to improve link quality and handover efficiency in OFDM and OFDMA networks by using a fast-switching selection diversity method instead of more complex multi-station synchronization (Compl. ¶19).

Key Claims at a Glance

  • The complaint asserts at least independent claim 10 (Compl. ¶22).
  • Claim 10 describes a method for implementing a handover for a mobile subscriber station (MSS), with the essential elements including:
    • Maintaining an active set of transmitting base stations.
    • The MSS communicating with only one current transmitting base station in a single frame.
    • Monitoring all transmitting base stations in the active set while transmitting/receiving data with the current one.
    • The current base station being the only one operated to transmit data to the MSS in the allocated bursts within the single frame.
    • Determining a preferred base station based on the monitoring.
    • Informing the current base station of the preferred base station via a fast feedback channel.
    • Stopping communication with the current base station.
    • Operating the MSS to exchange data with the preferred base station in a subsequent frame.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,156,360 - “Systems and Methods for Waking Wireless LAN Devices”

  • Issued: April 10, 2012

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of waking network-connected computing devices from a low-power or sleep state for administrative tasks (e.g., software updates, virus scans) without requiring physical intervention, particularly in a wireless environment (’360 Patent, col. 1:21-47).
  • The Patented Solution: The invention describes a system where a wireless network card can operate in a low-power "wireless signal monitoring state" independent of the main device. In this state, it scans wireless channels for a specific "wake up data sequence" or "MAGIC PACKET" addressed to it. Upon receiving and verifying the correct sequence, the card signals the main computing device to restore full power (’360 Patent, col. 2:1-13, Fig. 7).
  • Technical Importance: This technology, often known as Wake-on-Wireless-LAN (WoWLAN), enables remote management of networked devices, improving administrative efficiency and energy conservation without sacrificing accessibility (Compl. ¶46).

Key Claims at a Glance

  • The complaint asserts at least independent claim 8 (Compl. ¶49).
  • Claim 8 describes an apparatus with the essential elements including:
    • A controller configured to monitor a plurality of wireless channels for a wake-up packet.
    • The wake-up packet is addressed to a wireless device during a "monitor timeframe."
    • The packet is configured to cause the device to transition from a first power mode to a second power mode.
    • The controller is configured to initiate this transition if the packet is received before the monitor timeframe has elapsed.
    • The controller is configured to cease monitoring the channels if the packet is not received after the monitor timeframe has elapsed.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,033,716 - “Method and Device for Publishing Cross-Network User Behavioral Data”

  • Issued: July 24, 2018
  • Technology Synopsis: The patent describes a method for improving client computing by summarizing a user's cross-network behavioral data (e.g., websites visited) on the client computer itself. This summarized data is then published to data structures (like cookies) that become accessible to a server, allowing for targeted content delivery (Compl. ¶73; ’716 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶76).
  • Accused Features: The D-Link System is accused of performing the claimed method, wherein a server receives summarized user behavior data from a client and uses it to customize and send messages or advertisements (Compl. ¶77).

U.S. Patent No. 8,073,866 - “Method for Providing Content to an Internet User Based On the User's Demonstrated Content Preferences”

  • Issued: December 6, 2011
  • Technology Synopsis: The patent claims a method for delivering content from a server based on a user's internet navigation history. This involves installing a profile decoder on the server, receiving an encrypted summary of the user's history, matching that summary to available content, and delivering content based on the identified preferences (Compl. ¶100; ’866 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶103).
  • Accused Features: The D-Link System is accused of performing the claimed method by storing content, using a profile library to map user navigation history to content categories, and sending selected content to the user (Compl. ¶104).

U.S. Patent No. 7,627,805 - “Data Coding with an Efficient LDPC Encoder”

  • Issued: December 1, 2009
  • Technology Synopsis: The invention relates to improving data transmission in communication systems through a method of coding data. The method uses a specific mathematical structure involving a "mother code parity check matrix" and a "macro matrix" to generate a codeword for transmission (’805 Patent, Abstract; Compl. ¶127).
  • Asserted Claims: At least independent claim 1 (Compl. ¶130).
  • Accused Features: The D-Link 5G Devices and D-Link 802.11n Devices are accused of performing the claimed method of coding data using the specified matrix structures (Compl. ¶131).

U.S. Patent No. 8,031,654 - “Wireless Communication System, Apparatus for Supporting Data Flow and Methods Therefor”

  • Issued: October 4, 2011
  • Technology Synopsis: The patent describes a system for more efficient handling of acknowledgment signaling in TCP-based data transfers. It discloses a wireless subscriber unit that receives an allocation of downlink (DL) resources plus sufficient uplink (UL) resources to transfer a stand-alone acknowledgement (ACK) segment, improving efficiency (’654 Patent, Abstract; Compl. ¶154, ¶158).
  • Asserted Claims: At least independent claim 5 (Compl. ¶157).
  • Accused Features: D-Link 5G Devices are accused of providing a wireless subscriber communication unit that performs the claimed method of receiving resource allocations for both TCP data and the corresponding stand-alone ACK segment (Compl. ¶158).

U.S. Patent No. 7,707,213 - “Hierarchical Update Scheme for Extremum Location”

  • Issued: April 27, 2010
  • Technology Synopsis: The patent claims a method for improving data processing by organizing data into a hierarchical structure of partitions. Each level in the hierarchy stores extrema (e.g., maximum or minimum values) for a group of elements from the level below, enabling efficient and scalable data updates without reprocessing the entire dataset (’213 Patent, Abstract; Compl. ¶181).
  • Asserted Claims: At least independent claim 16 (Compl. ¶184).
  • Accused Features: D-Link HEVC Devices are accused of performing the claimed method by partitioning a data set, generating a coarse representation of extrema, and updating that representation when data values are altered (Compl. ¶185).

U.S. Patent No. 7,707,214 - “Hierarchical Update Scheme for Extremum Location with Indirect Addressing”

  • Issued: April 27, 2010
  • Technology Synopsis: This patent, related to the ’213 Patent, describes an improved data processing system using a hierarchical data structure. It enables efficient identification and updating of extrema based on indirect addressing of data values, by storing indices that point to the locations of the extrema (’214 Patent, Abstract; Compl. ¶208, ¶212).
  • Asserted Claims: At least independent claim 15 (Compl. ¶211).
  • Accused Features: D-Link HEVC Devices are accused of performing a method of partitioning data, generating a coarse representation of extrema, and storing and updating indices indicative of the locations of those extrema (Compl. ¶212).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies five broad categories of accused products: the "D-Link System" (a server system); "D-Link 5G Devices"; "D-Link 802.11n Devices"; "D-Link HEVC Devices"; and "D-Link Bluetooth Devices" (Compl. ¶12). Dozens of specific product models, including routers, gateways, cameras, access points, and adapters, are listed within these categories (Compl. ¶12).

Functionality and Market Context

  • The accused products collectively provide wireless networking, internet access, and home security functionalities. The complaint alleges these products are sold, distributed, and imported into the United States through various channels, including online and retail stores (Compl. ¶14). For example, the complaint alleges D-Link provides installation guides for products like the 2K QHD Indoor Wi-Fi Camera (DCS-8350LH) and sells them through major retailers (Compl. ¶13-14).

IV. Analysis of Infringement Allegations

’411 Patent Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a method for implementing a hand over of a mobile subscriber station (MSS) in a wireless communication network, comprising: maintaining an active set comprising a list of transmitting base stations... D-Link 5G Devices perform a method for implementing a handover. ¶23 col. 6:49-51
...the MSS communicating with only one current transmitting base station in a single frame; The MSS communicates with only one current transmitting base station in a single frame. ¶23 col. 2:21-24
monitoring all transmitting base stations in the active set while transmitting data to and receiving data from the current transmitting base station in one or more bursts that are allocated for the MSS in the single frame... The accused devices monitor all transmitting base stations in the active set while transmitting to and receiving data from the current base station. ¶23 col. 2:28-31
...wherein the current transmitting base station is the only base station of the list of transmitting base stations operated to transmit data to the MSS using the one or more bursts that are allocated for the MSS in the single frame... The current base station is the only base station operated to transmit data to the MSS using its allocated bursts. ¶23 col. 2:21-24
determining a preferred transmitting base station included in the transmitting base stations based upon the monitoring; The accused devices determine a preferred transmitting base station based on monitoring. ¶23 col. 2:32-35
informing the preferred transmitting base station to the current transmitting base station by a fast feedback channel; The accused devices inform the current base station of the preferred one via a fast feedback channel. ¶23 col. 2:32-35
stopping the MSS from transmitting data to and receiving data from the current transmitting base station; and operating the MSS to exchange transmission of data at a subsequent frame with the preferred base station. The accused devices stop communication with the current base station and operate the MSS to exchange data transmission with the preferred base station at a subsequent frame. ¶23 col. 2:35-39

’360 Patent Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus comprising: a controller configured to monitor a plurality of wireless channels for a wake-up packet addressed to a wireless device during a monitor timeframe... D-Link Bluetooth Devices provide an apparatus with a controller that monitors multiple wireless channels for a wake-up packet during a monitor timeframe. ¶50 col. 7:1-6
...wherein the wake-up packet is configured to cause the wireless device to initiate a transition from operating in a first power mode to operating in a second power mode... The wake-up packet causes the wireless device to transition from a first power mode to a second power mode. ¶50 col. 7:6-9
...wherein the controller is configured to initiate the transition from operating the wireless device in the first power mode to operating the wireless device in the second power mode when a wake-up packet addressed to the wireless device has been received before the monitor timeframe has elapsed... The controller initiates the power mode transition when a wake-up packet is received before the monitor timeframe elapses. ¶50 col. 7:10-15
...and wherein the controller is configured to cease to monitor the plurality of wireless channels when a wake-up packet addressed to the wireless device has not been received after the monitor timeframe has elapsed. The controller ceases to monitor the channels when a wake-up packet has not been received after the monitor timeframe elapses. ¶50 col. 7:15-19

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: The infringement allegations for the ’411 Patent, which has a 2005 priority date, are directed at "D-Link 5G Devices" (Compl. ¶23). A central dispute may be whether the claim term "single frame," as described in the context of older OFDM/OFDMA standards, can be construed to read on the complex frame structures and communication protocols of modern 5G NR standards.
  • Technical Questions: For the ’360 Patent, the complaint alleges that D-Link's Bluetooth devices infringe (Compl. ¶50). A key technical question will be how the claimed "first power mode" and "second power mode" map onto the specific, standardized power states of Bluetooth technology (e.g., sniff, park, active modes). The analysis may turn on whether the accused devices' actual operation meets the specific transition and monitoring logic required by the claim's "monitor timeframe" element.

V. Key Claim Terms for Construction

For the ’411 Patent

  • The Term: "communicating with only one current transmitting base station in a single frame"
  • Context and Importance: This term is the core of the VSHO concept, distinguishing it from traditional soft handovers involving simultaneous communication. Its construction will be critical to determining if modern 5G protocols, which may involve complex and rapid signaling with multiple cells, fall within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the concept generally as allowing "fast switching of data transmission from one BS to another BS dynamically" and states that "only one BS is transmitting at any given time," which may support an interpretation focused on the transmission of payload data rather than all control signaling (’411 Patent, col. 2:16-19).
    • Evidence for a Narrower Interpretation: The detailed description specifies that the MSS controls switching by processing messages from multiple base stations to "decide which base station is to be used for a frame," suggesting a frame-by-frame exclusive relationship that may be narrower than the operation of some modern systems (’411 Patent, col. 2:32-35).

For the ’360 Patent

  • The Term: "monitor timeframe"
  • Context and Importance: The definition of this term is central to the claimed logic. Infringement will depend on whether the accused devices' power-saving and listening cycles constitute a "monitor timeframe" that "elapses," after which monitoring "ceases" as required by the claim. Practitioners may focus on whether this term requires a fixed, predetermined duration or can cover the variable, event-driven listening windows common in modern low-energy wireless protocols.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 8 itself does not specify a fixed duration, only that the timeframe can "elapse." This may support a construction that covers any period during which the device is configured to listen, after which it returns to a deeper sleep state.
    • Evidence for a Narrower Interpretation: The specification discusses setting a timer to a specific time 'T' for scanning a channel, and flowcharts show a distinct "TIMER EXPIRED ?" decision point, which could suggest that the "monitor timeframe" is a specific, pre-set duration, potentially excluding more dynamic or intermittent listening protocols (’360 Patent, col. 4:18-20; Fig. 7).

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that D-Link provides instructions, advertising, and technical support that guide users to use the Accused Products in an infringing manner (e.g., Compl. ¶27-29, ¶54-56). Contributory infringement is based on allegations that the Accused Products have "special features" that are a material part of the invention and are not staple articles of commerce suitable for substantial non-infringing use (e.g., Compl. ¶33-36, ¶59-62).

Willful Infringement

  • Willfulness is alleged for all asserted patents. The basis is twofold: first, an alleged "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (e.g., Compl. ¶24, ¶51); and second, alleged actual knowledge of the patents "since at least the time of receiving the original complaint in this action" (e.g., Compl. ¶25, ¶52).

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

  • Technology Translation: A central issue will be whether claim limitations drafted for technologies of the mid-to-late 2000s (e.g., early OFDM, Wi-Fi, and remote wake-up protocols) can be construed to cover the operational realities of significantly more advanced, and differently architected, modern standards like 5G, Wi-Fi 6, and Bluetooth 5.1 that are practiced by the accused products.
  • Evidentiary Burden on System-Level Claims: Many of the asserted claims are directed at complex system-level methods involving interactions between clients and servers (e.g., '716, '866 patents) or between mobile devices and a network of base stations (e.g., '411 patent). A key question will be how Plaintiff will obtain and present evidence to prove that the accused D-Link systems, in their entirety, perform each step of these claimed methods, particularly for server-side and network infrastructure operations.
  • Portfolio Scope and Cohesion: The complaint asserts eight patents spanning at least five distinct technological fields against a vast and varied product line. This raises the question of whether the case will proceed as a series of separate, technology-specific infringement analyses or if it will be treated as a broader portfolio-level dispute where the core issue is the alleged unlicensed use of a wide swath of foundational technologies.