DCT

2:25-cv-00439

CommWorks Solutions LLC v. Texas Instruments Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00439, E.D. Tex., 04/25/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains established and regular places of business in the district, including a manufacturing facility in Richardson, Texas, has committed acts of infringement in the district, and has not contested venue in the district in prior patent litigation.
  • Core Dispute: Plaintiff alleges that Defendant’s Wi-Fi capable Systems-on-Chips (SoCs) and related devices infringe seven patents concerning methods for simplifying wireless device setup, managing network traffic, and enabling mesh network communications.
  • Technical Context: The technologies at issue relate to fundamental aspects of modern Wi-Fi networking, including user-friendly device provisioning and quality-of-service traffic prioritization, which are critical for the functionality of IoT, consumer, and mobile electronic devices.
  • Key Procedural History: Plaintiff alleges it sent notice letters to Defendant on February 11, 2021, and March 5, 2021, identifying several of the asserted patents and accusing Defendant of infringement; this event forms the primary basis for the allegations of willful infringement.

Case Timeline

Date Event
2002-06-11 ’465 Patent and ’904 Patent Priority Date
2003-01-13 ’807 Patent, ’285 Patent, ’596 Patent, and ’979 Patent Priority Date
2004-10-08 ’285 Patent Application Filed
2005-05-10 ’807 Patent Issue Date
2006-04-11 ’465 Patent Issue Date
2007-02-09 ’596 Patent Application Filed
2007-02-13 ’285 Patent Issue Date
2008-11-25 ’979 Patent Application Filed
2008-12-09 ’596 Patent Issue Date
2010-11-19 ’304 Patent Priority Date
2011-03-22 ’979 Patent Issue Date
2013-11-26 ’304 Patent Application Filed
2014-05-20 ’904 Patent Reissue Date
2017-01-24 ’304 Patent Issue Date
2021-02-11 First Notice Letter Sent to Defendant
2021-03-05 Second Notice Letter Sent to Defendant
2025-04-25 Complaint Filing Date

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

U.S. Patent No. 7,177,285 - Time Based Wireless Access Provisioning

Issued February 13, 2007

The Invention Explained

  • Problem Addressed: The patent describes conventional wireless network provisioning as "impractical" for devices lacking a user interface (e.g., a wireless picture frame) and "cumbersome" for devices that have one, requiring users to be "technically proficient" to manually enter device identification information like a MAC address (Compl. ¶27; ’285 Patent, col. 3:13-36).
  • The Patented Solution: The invention proposes a time-based system to simplify this process. A network access point tracks an "operating parameter" of a wireless device, such as its power-on time or the start of its signal transmission. A user activates a provisioning mode on the access point, which opens a "time interval." If the device's tracked parameter occurred within that interval, the access point automatically initiates provisioning, thereby connecting the device to the network without manual data entry (Compl. ¶¶28, 32; ’285 Patent, Abstract; col. 4:53-65).
  • Technical Importance: This approach simplified the process of securely adding new devices to a network, a key step in making home Wi-Fi and the broader ecosystem of connected devices more accessible to non-technical consumers (Compl. ¶28).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶30).
  • Essential elements of claim 1 include:
    • A process for provisioning between a wireless device and a network.
    • Tracking an operating parameter of the wireless device, wherein the parameter comprises an onset of a signal transmission.
    • Initiating provisioning of the device if the tracked operating parameter occurs within a time interval.

U.S. Patent No. 7,463,596 - Time Based Wireless Access Provisioning

Issued December 9, 2008

The Invention Explained

  • Problem Addressed: Like its related patents, the ’596 Patent addresses the difficulty and technical skill required for conventional wireless device provisioning, particularly for devices with limited or no user interface for entering network credentials (Compl. ¶47; ’596 Patent, col. 3:13-36).
  • The Patented Solution: The patent claims a process for associating devices based on temporally proximate events. The system tracks an operating parameter of a first device, which can be either the device powering on or the start of its signal transmission. If this event occurs within a defined "time interval," the system "automatically associat[es] the first device with at least one other device," such as a network access point (Compl. ¶¶48, 52; ’596 Patent, Abstract; claim 1).
  • Technical Importance: This method provided a streamlined, event-driven mechanism for network association, reducing user burden and facilitating the expansion of multi-device home wireless networks (Compl. ¶48).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶50).
  • Essential elements of claim 1 include:
    • A process for associating devices.
    • Tracking an operating parameter of a first device, wherein the parameter comprises either a power on or an onset of a signal transmission.
    • Automatically associating the first device with at least one other device if the tracked parameter occurs within a time interval.

U.S. Patent No. 7,911,979 - Time Based Access Provisioning System And Process

Issued March 22, 2011

  • Technology Synopsis: The patent addresses the impracticality of conventional wireless provisioning for devices with limited user interfaces. The invention is a provisioning process performed by a system with logic that tracks a device's operating parameter (power on or signal onset) and sends a signal to initiate provisioning if the event occurs within a designated time interval (Compl. ¶¶67, 68, 72).
  • Asserted Claims: At least claim 1 (Compl. ¶70).
  • Accused Features: TI devices and SoCs that support Wi-Fi Protected Setup (WPS) functionality (Compl. ¶61).

U.S. Patent No. RE44,904 - Method For Contention Free Traffic Detection

Reissued May 20, 2014

  • Technology Synopsis: The patent addresses the problem that low-cost network access points lacked the processing power to analyze high-level data packet headers to prioritize traffic. The invention provides a method for identifying priority traffic at a lower network layer (MAC layer) by extracting a specific bit pattern from a predetermined frame position and matching it against a search pattern, allowing for efficient traffic routing without complex processing (Compl. ¶¶87-88).
  • Asserted Claims: At least claim 1 (Compl. ¶90).
  • Accused Features: TI devices and SoCs supporting Wi-Fi Multimedia (WMM) and 802.11-2007+ functionality (Compl. ¶81).

U.S. Patent No. 7,027,465 - Method For Contention Free Traffic Detection

Issued April 11, 2006

  • Technology Synopsis: This patent, the original version of the '904 reissue, targets the same problem of inefficient traffic prioritization in conventional wireless systems. The solution is a method to detect priority data frames by extracting a bit pattern from a predetermined position, defined by an offset, and comparing it to a search pattern (Compl. ¶¶107, 112).
  • Asserted Claims: At least claim 1 (Compl. ¶110).
  • Accused Features: TI devices and SoCs supporting Wi-Fi Multimedia (WMM) and 802.11-2007+ functionality (Compl. ¶101).

U.S. Patent No. 6,891,807 - Time Based Wireless Access Provisioning

Issued May 10, 2005

  • Technology Synopsis: This patent addresses the problem of cumbersome and technically demanding wireless network setup. The invention is a time-based provisioning system wherein a network access point tracks the operation of a wireless device and provisions it for network access if that operation occurs within an "activatable time interval" (Compl. ¶¶127, 131).
  • Asserted Claims: At least claim 17 (Compl. ¶129).
  • Accused Features: TI devices and consumer electronics chips supporting Wi-Fi Protected Setup (WPS) functionality (Compl. ¶¶121, 130).

U.S. Patent No. 9,554,304 - Scalable Media Access Control for Multi-Hop High Bandwidth Communications

Issued January 24, 2017

  • Technology Synopsis: The patent addresses the impracticality and communication errors in scalable multi-hop wireless networks caused by a failure to account for end-to-end resource allocation. The invention provides a wireless mesh network that integrates layer-2 routing with resource allocation to prevent conflicts and performance degradation as the network scales (Compl. ¶¶146-147). The asserted infringement theory involves receiving beacon signals and establishing links based on signal quality (Compl. ¶150).
  • Asserted Claims: At least claim 1 (Compl. ¶148).
  • Accused Features: TI chips and SoCs supporting Wi-Fi Mesh functionality (Compl. ¶140).

III. The Accused Instrumentality

Product Identification

The complaint identifies certain Texas Instruments Systems-on-Chips (SoCs) and devices as the "Accused Products" (Compl. ¶17).

Functionality and Market Context

The complaint categorizes the accused products based on their support for specific industry standards for wireless communication. These categories are:

  • TI Wi-Fi Multimedia Products: SoCs that support Wi-Fi Multimedia (WMM) and the IEEE 802.11-2007+ standard, which are protocols designed to prioritize data traffic for applications like video and voice streaming (Compl. ¶17).
  • TI WPS Products: SoCs and devices that support Wi-Fi Protected Setup (WPS), a network security standard created to simplify the process of connecting devices to a secure wireless network (Compl. ¶17).
  • Wi-Fi Mesh Products: SoCs that support Wi-Fi Mesh functionality, which allows wireless nodes to connect directly and non-hierarchically to one another to route data through the network (Compl. ¶17).

These SoCs are foundational components for a wide range of electronic products requiring Wi-Fi connectivity.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint references claim-chart exhibits that are not provided; the narrative infringement theory is summarized below.

  • ’285 Patent Infringement Allegations: The complaint alleges that the TI WPS Products infringe at least claim 1 by performing a process for provisioning a wireless device onto a network. This process allegedly involves the WPS-compatible device "tracking an operating parameter" of another wireless device, specifically the "onset of a signal transmission," and subsequently "initiating provisioning" if that transmission occurs within a "time interval" defined by the WPS protocol (Compl. ¶32).
  • ’596 Patent Infringement Allegations: The complaint alleges that the TI WPS Products infringe at least claim 1 by performing a process for associating devices. The accused process is alleged to involve "tracking an operating parameter of a first device," specified as either a "power on" or an "onset of a signal transmission." If this event occurs within a "time interval," the products allegedly perform the claimed step of "automatically associating the first device with at least one other device" (Compl. ¶52).
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the operations of the standardized Wi-Fi Protected Setup (WPS) protocol, as implemented in the accused products, fall within the scope of the patent claims. The dispute could focus on whether the user-initiated WPS sequence (e.g., a button push) qualifies as the claimed "tracking [of] an operating parameter" that occurs within a "time interval" to trigger provisioning.
    • Technical Questions: The complaint asserts that the accused products perform "tracking," but it does not specify the technical mechanism by which this is accomplished. A key question will be what evidence demonstrates that the accused chips actively monitor for a power-on or signal onset event, as opposed to passively responding to a standardized set of WPS protocol messages initiated by a user.

V. Key Claim Terms for Construction

  • The Term: "tracking an operating parameter" (from the ’285 and ’596 Patents)

  • Context and Importance: This term describes the core action of the invention. Its construction will be critical, as the infringement case depends on mapping this claimed action to the functionality of the accused WPS-enabled products. Practitioners may focus on this term because Defendant could argue its products do not actively "track" events but rather react to user-initiated commands and standard protocol messages, which may not meet the construed definition of the term.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes a network access point that "monitors operation of wireless devices" and "keeps track of all wireless devices" in its vicinity, suggesting an ongoing observational function (’285 Patent, Abstract; col. 7:30-32).
    • Evidence for a Narrower Interpretation: The patent figures and their descriptions detail a specific sequence of events: a device is powered on, a user presses a button on an access point, and the access point logic determines if there was a "recent power on" (’285 Patent, Fig. 3; col. 5:30-45). This might support a narrower construction limited to a discrete, event-driven check rather than continuous monitoring.

  • The Term: "time interval" (from the ’285 and ’596 Patents)

  • Context and Importance: The infringement allegation hinges on the existence of a temporal window within which the accused WPS products operate. The definition of this interval—how it is initiated, its duration, and its purpose—will be central to determining whether the accused functionality meets this limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification explicitly mentions an "acceptance time interval, e.g. such as a 5 minute interval," which begins and ends at specific times relative to a user's activation of the provisioning logic, suggesting a defined temporal window (’285 Patent, col. 6:2-7).
    • Evidence for a Narrower Interpretation: The claims require that provisioning is initiated if the event occurs within the interval. A defendant might argue that while the WPS protocol has timeout periods, their purpose is for session security, not for the claimed causal function of qualifying a device for provisioning based on the timing of its power-on or signal transmission.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement for all asserted patents. The inducement allegations are based on Defendant allegedly providing user manuals, advertising, and other instructions that guide customers to use the Accused Products in an infringing manner (e.g., Compl. ¶¶33, 53). The contributory infringement allegations state that the Accused Products contain special features designed for infringing use with no substantial non-infringing uses (e.g., Compl. ¶¶34, 54).
  • Willful Infringement: Willfulness is alleged for all asserted patents, based primarily on Defendant's alleged knowledge of the patents since receiving notice letters in February and March of 2021 (e.g., Compl. ¶¶35, 55). The complaint further alleges that Defendant maintains a "policy or practice of not reviewing the patents of others," which it characterizes as willful blindness and objectively reckless conduct (e.g., Compl. ¶¶36-37, 56-57).

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

  • A core issue will be one of protocol mapping: can the standardized operations of Wi-Fi Protected Setup (WPS) and Wi-Fi Multimedia (WMM) be construed as practicing the specific, novel steps of the asserted claims, or are the patented methods distinct from the implementation of these industry standards? The case may turn on whether compliance with a standard is sufficient to constitute infringement of these particular patents.
  • A second central question will be one of technical evidence: what proof will be offered to show that the accused TI SoCs perform the claimed method steps, such as "tracking an operating parameter" or "extracting a bit pattern from a predetermined position," beyond conclusory allegations that their standards-compliant operation inherently does so?
  • A key legal and factual question will be one of willfulness and intent: given that the accused functionalities are based on widely adopted industry standards, the dispute will likely focus on what specific knowledge and intent Defendant possessed after receiving notice in 2021, and whether continuing to sell standards-compliant products can be deemed objectively reckless conduct sufficient to support enhanced damages.