E Beacon LLC v. Sharp Electronics Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Sharp Electronics Corporation (Japan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00404, E.D. Tex., 04/17/2025
• 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 Defendant’s unspecified products infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology addresses the challenge of accurately locating mobile or nomadic VoIP users during 9-1-1 emergency calls, a problem not present in traditional landline systems with fixed addresses.
• Key Procedural History: The patent-in-suit is a continuation-in-part of a prior application that issued as U.S. Patent No. 7,933,580, indicating a developed prosecution history within this technology area. The complaint alleges only post-suit knowledge for its inducement and willfulness claims.

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)," Issued Aug. 20, 2013

The Invention Explained

• Problem Addressed: The patent's background section describes the unreliability of emergency services for VoIP phone users. Unlike traditional telephones with fixed addresses, a VoIP phone can be used in any location with internet access, meaning a pre-registered address may be incorrect during an emergency call, preventing first responders from locating the user (’386 Patent, col. 1:23-44).
• The Patented Solution: The invention is a system that overcomes this limitation by actively determining the VoIP phone's current physical location using "multiple location detection technologies" such as GPS or cellular network triangulation (e.g., CDMA, GSM) (’386 Patent, col. 2:49-53). When an emergency number is dialed, the system automatically transmits these current physical coordinates to the emergency call center (PSAP), ensuring the operator can locate the caller regardless of their physical location (’386 Patent, col. 2:37-44).
• Technical Importance: The described technology provides a method for VoIP systems to comply with Enhanced 9-1-1 (E911) mandates, which require the automatic provision of a caller's location to dispatchers.

Key Claims at a Glance

The complaint does not identify specific claims asserted, referring only to "Exemplary '386 Patent Claims" detailed in an unattached exhibit (Compl. ¶11). Independent claim 1 is representative of the patent's core method and includes the following essential elements:

• 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.
• Automatically transmitting the physical location of the VoIP phone to the emergency services call center.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as 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. It alleges only that the unspecified products "practice the technology claimed by the '386 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint provides no factual allegations of infringement in its main body, instead incorporating by reference claim charts from Exhibit 2, which is not publicly available (Compl. ¶¶16-17). The complaint alleges direct infringement through making, using, selling, and testing the accused products (Compl. ¶¶11-12). Without the referenced exhibit, 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: "a separate location detection technology ("LDT")" (from claim 1)
• Context and Importance: The validity and scope of the claims may depend on the definition of "LDT" and what makes two such technologies "separate." The infringement analysis will hinge on whether the accused products use a "plurality" of distinct LDTs as required by the claim, or a single technology with multiple modes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of LDTs, including "geolocation, location based service (LBS), GSM localization, triangulation... GPS, CDMA and GSM technologies... Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies that can provide geolocation information," which may support a broad reading of the term (’386 Patent, col. 7:57-66).
  • Evidence for a Narrower Interpretation: A party could argue that "separate" requires fundamentally different physical or logical principles (e.g., satellite-based vs. cell tower-based). The repeated emphasis on distinct systems like GPS and cellular networks as primary examples throughout the detailed description could be used to argue that different modes of a single system (e.g., different Wi-Fi location techniques) do not constitute "separate" LDTs (’386 Patent, col. 2:49-53).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant distributing "product literature and website materials" that allegedly instruct end users on how to use the products in a manner that infringes the ’386 Patent (Compl. ¶14). The knowledge element for inducement is pleaded as arising "at least since being served by this Complaint" (Compl. ¶15).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge of infringement" from the date of service of the complaint and its attached claim charts (Compl. ¶13). The allegations of continued infringement after this date form the basis of the claim for willfulness (Compl. ¶14). No pre-suit knowledge is alleged.

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

1. An Evidentiary Question of Specificity: The complaint's complete reliance on an unattached exhibit to identify accused products and articulate its infringement theories creates a significant factual vacuum. A threshold issue will be whether the specifics in that exhibit, once revealed, can sustain the bare allegations against a motion to dismiss for failure to state a claim under Twombly/Iqbal pleading standards.
2. A Definitional Question of Scope: The case will likely involve a significant dispute over the meaning of "a separate location detection technology". The central question for claim construction will be how distinct two location-finding methods must be to qualify as "separate" under the patent's teachings—a determination that will define the boundaries of infringement.
3. A Temporal Question of Intent: Plaintiff's claims for induced and willful infringement are based exclusively on post-suit knowledge. The viability of these claims will depend on Defendant's conduct after receiving the complaint, raising the question of whether continued sales, without more, are sufficient to establish the specific intent required for inducement or the "egregious" conduct often associated with enhanced damages.