E Beacon LLC v. ASUSTeK Computer Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (DE)
  • Defendant: Asustek Computer Inc. (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00398, E.D. Tex., 04/16/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that certain unidentified products made by Defendant infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology addresses the challenge of locating mobile or nomadic VoIP phone users for 9-1-1 emergency services, a problem not present in traditional, fixed-location telephone systems.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer. The complaint does not specify any other prior litigation, licensing history, or administrative proceedings.

Case Timeline

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

U.S. Patent No. 8,515,386 - "Emergency services for voice over IP telephony (E-VoIP)"

• Patent Identification: U.S. Patent No. 8,515,386, “Emergency services for voice over IP telephony (E-VoIP),” issued August 20, 2013.

The Invention Explained

• Problem Addressed: Unlike traditional landlines where a phone is tied to a fixed address, a Voice over IP (VoIP) phone can be used in any location with internet access. This mobility creates a critical problem for emergency services, as dialing 9-1-1 does not automatically transmit the user’s current physical location to the operator. (’386 Patent, col. 1:24-44).
• The Patented Solution: The invention describes a system that automatically determines the physical location of a VoIP device using technologies like GPS or cellular network triangulation. When an emergency number is dialed, the system transmits these location coordinates to the emergency call center (Public Safety Answering Point or "PSAP"), allowing operators to dispatch help to the correct location even if the caller cannot verbally provide it. (’386 Patent, col. 2:32-44; Abstract). The system is designed to periodically update and store location coordinates to ensure the most current information is available. (’386 Patent, col. 2:56-62).
• Technical Importance: The technology aimed to close a significant public safety gap by providing reliable E911 capabilities for the growing population of VoIP users. (’386 Patent, col. 1:11-14).

Key Claims at a Glance

• The complaint does not identify any specific asserted claims, instead referring to "Exemplary '386 Patent Claims" identified in an external chart (Compl. ¶11). For illustrative purposes, independent claim 1 is analyzed below.
• Independent Claim 1 (Method):
  • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT");
  • if an attempt is successful, storing the physical location determined using the corresponding LDT;
  • placing a call to the emergency services call center with the VoIP phone; and
  • automatically transmitting the physical location of the VoIP phone to the emergency services call center.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are identified in an external claim chart (Exhibit 2), which was not filed with the complaint. (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, other than to allege that they are devices that "infringe the claims of the '386 Patent." (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint's infringement allegations are contained entirely within "claim charts of Exhibit 2," which is incorporated by reference but was not provided with the complaint document. (Compl. ¶16-17). The complaint alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims. (Compl. ¶16). Without access to the charts, a detailed analysis of the infringement theory is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "location detection technology ('LDT')" (from claim 1)
• Context and Importance: The definition of "LDT" is fundamental to the scope of infringement. The dispute will likely center on what specific location-finding methods qualify as a "LDT." Practitioners may focus on this term because its breadth will determine whether the claim reads on a wide range of modern and future positioning systems or is confined to the specific examples disclosed in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a list of examples including "GPS, CDMA and GSM technologies," but follows with the phrase "and other such technologies that can provide geolocation information," suggesting the term is not limited to the enumerated examples. (’386 Patent, col. 8:61-66). This open-ended language may support a construction that includes a variety of methods for determining a device's physical location.
  • Evidence for a Narrower Interpretation: A party could argue that the term should be limited by the context of the invention, which focuses on established telecommunications technologies like "GPS or cellular technology" for triangulation. (’386 Patent, col. 2:49-54). An argument could be made that "other such technologies" must be similar in nature to the specific examples provided and not encompass fundamentally different approaches.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant sells the accused products and distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '386 Patent." (Compl. ¶14-15).
• Willful Infringement: The willfulness claim is based on alleged post-suit knowledge. The complaint asserts that service of the complaint itself provides "actual knowledge of infringement" and that Defendant’s continued infringing activities thereafter are willful. (Compl. ¶13-14).

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

1. Evidentiary Sufficiency: A primary issue stems from the complaint's lack of specificity. A threshold question for the court will be whether the complaint, which relies entirely on an unprovided external exhibit to identify the accused products and the basis for infringement, meets federal pleading standards.
2. Definitional Scope: The case will likely turn on a question of claim construction: how broadly will the court define the term "location detection technology"? Whether this term is construed to cover a wide array of modern positioning systems or is limited to the specific cellular and GPS-based examples in the patent will be critical to the infringement analysis.
3. Indirect Infringement: A key factual question will be one of intent: what evidence exists in Defendant's "product literature and website materials" to demonstrate that Defendant specifically intended for its customers to use the accused products in a way that directly infringes the method claims of the '386 Patent?