E Beacon LLC v. Coolpad Group Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Coolpad Group Limited (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00401, E.D. Tex., 04/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business within the Eastern District of Texas and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products, which are not specified beyond reference to an unattached exhibit, infringe a patent related to determining and transmitting the physical location of a Voice over IP (VoIP) phone during an emergency call.
• Technical Context: The technology addresses the public safety challenge of locating mobile VoIP users during 9-1-1 calls, a problem distinct from traditional landlines with fixed addresses.
• Key Procedural History: The patent-in-suit is a continuation-in-part of an earlier application, now issued as a patent, and is subject to a terminal disclaimer. This prosecution history may be relevant to claim construction and the scope of the patent's claims. The complaint does not mention any prior litigation or inter partes review 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)

The Invention Explained

• Problem Addressed: The patent’s background section describes the unreliability of emergency services for VoIP users. Because a VoIP phone can be used anywhere with an internet connection, a static, pre-registered address is often incorrect, preventing 911 operators from dispatching help to the user's actual location (Compl. ¶9; ’386 Patent, col. 1:23-44).
• The Patented Solution: The invention proposes a system that determines the current physical location of a VoIP device using one or more location detection technologies, such as GPS or cellular network triangulation. When an emergency call is placed, the system is designed to automatically transmit these physical coordinates to the emergency call center (Public Safety Answering Point, or "PSAP"), thereby enabling first responders to locate the caller (’386 Patent, Abstract; col. 2:32-44). The process flow illustrated in Figure 1 shows a logic for detecting location, placing a call, and sending coordinates to an operator (’386 Patent, Fig. 1).
• Technical Importance: This technology sought to provide location-finding capabilities for VoIP communications that were comparable to the automatic location identification available in traditional E911 systems for landlines (’386 Patent, col. 1:15-22).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and "exemplary claims" identified in an exhibit, but does not specify any claim numbers in the body of the complaint itself (Compl. ¶11). Claim 1, as the first independent claim, is representative of the patented method.
• Independent Claim 1 elements:
  • making a plurality of attempts to determine the physical location of a 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 reserves the right to assert other direct and indirect infringement claims (Compl. ¶11, ¶15).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers generally to "Defendant products identified in the charts incorporated into this Count" and "Exemplary Defendant Products" (Compl. ¶11). These charts, contained in Exhibit 2, were not filed with the complaint, leaving the specific accused instrumentalities unidentified.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '386 Patent" and "satisfy all elements of the Exemplary '386 Patent Claims" (Compl. ¶16). This suggests the products are alleged to be communication devices capable of determining their own location and providing that information during emergency calls. The complaint does not provide any specific details about how the accused products operate or their position in the market.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits to support its infringement allegations but does not include them (Compl. ¶16, ¶17). Therefore, a detailed element-by-element analysis is not possible from the provided documents. The narrative theory alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" products that practice the claimed methods (Compl. ¶11). The complaint also alleges internal testing by Defendant’s employees constitutes direct infringement (Compl. ¶12). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A potential dispute may arise over the claim term "a plurality of attempts... each using a separate location detection technology" (’386 Patent, col. 15:26-29). The question is whether a modern smartphone's integrated location service, which may fuse data from GPS, Wi-Fi, and cellular networks into a single output, performs "separate" attempts as depicted in the patent’s flowcharts, or if it constitutes a single, unified location determination process.
• Technical Questions: A central factual question will be what evidence Plaintiff can provide to demonstrate that the accused products "automatically transmit[] the physical location" to an emergency call center (’386 Patent, col. 15:35-37). The analysis may focus on whether the accused device itself performs this transmission step, or if it merely provides location data to a carrier network, which then manages communication with the PSAP.

V. Key Claim Terms for Construction

The Term: "separate location detection technology ('LDT')"

Context and Importance

This term is foundational to Claim 1, which requires making attempts using a "plurality" of "separate" LDTs. The definition will determine what type of device architecture meets this limitation. Practitioners may focus on this term because modern devices often use a single, fused location service, raising questions about whether the underlying technologies are "separate" in the manner claimed.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of LDTs, including "GPS, CDMA and GSM technologies," as well as "A-GPS", "Wi-Fi, WiMAX, and other such technologies" (’386 Patent, col. 8:56-65). This broad enumeration could support an interpretation where any distinct source of location information (e.g., a satellite signal versus a Wi-Fi network lookup) qualifies as a "separate" LDT.
• Evidence for a Narrower Interpretation: Figure 4 of the patent depicts distinct, parallel process flows for different LDTs (GPS, CDMA, GSM), each with its own success/failure check (’386 Patent, Fig. 4, items 2a-2d). This could support a narrower construction requiring that the attempts be discrete and independently executed, rather than components of a single, integrated process.

The Term: "automatically transmitting the physical location of the VoIP phone"

Context and Importance

The definition of this active step is critical to determining infringement. The dispute will likely concern the division of responsibility between the end-user device and the network carrier in the E911 system.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent states that the "E-VoIP system transmits the physical coordinates," which could be interpreted to encompass the entire chain of events initiated by the device, even if network components are involved in the final delivery to the PSAP (’386 Patent, col. 2:39-42).
• Evidence for a Narrower Interpretation: Language describing the system transmitting a "data packet which is routed over the Internet" could suggest the device itself is responsible for creating and sending the location information directly, a function that may not align with how modern carrier-managed E911 services operate (’386 Patent, col. 5:63-65).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end users to use the accused products in an infringing manner (Compl. ¶14-15).
• Willful Infringement: The complaint alleges Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and attached (but not provided) claim charts (Compl. ¶13). It further alleges that Defendant's infringement continues despite this knowledge, which establishes a basis for a claim of post-filing willful infringement and potential enhanced damages (Compl. ¶14).

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

• A core issue will be one of technological evolution versus claim scope: Can the method of "making a plurality of attempts... each using a separate location detection technology," as described in a patent with a 2005 priority date, be interpreted to read on a modern smartphone's highly integrated and fused location-services engine? The court will need to determine if these are equivalent processes or if a fundamental operational difference exists.
• The case may also turn on a question of pleading sufficiency and evidence: Given that the complaint omits the specific accused products and the claim charts detailing the infringement theory, a primary challenge for the Plaintiff will be to produce specific, technical evidence demonstrating how Defendant's devices actually perform each step of the asserted claims, particularly the "automatically transmitting" step within the complex, multi-party E911 ecosystem.