Atlas Global Tech LLC v. Hewlett Packard Enterprises Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Atlas Global Technologies LLC (Texas)
  • Defendant: Hewlett Packard Enterprise Company (Delaware)
  • Plaintiff’s Counsel: Nelson Bumgardner Conroy PC
• Case Identification: 2:25-cv-00534, E.D. Tex., 05/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district, specifically a brick-and-mortar office in Frisco, Texas, and derives substantial revenue from sales of the accused products within the district.
• Core Dispute: Plaintiff alleges that Defendant’s networking products that implement the Wi-Fi 6 standard infringe four patents related to wireless communication technologies.
• Technical Context: The technology concerns methods for improving the efficiency, bandwidth, and reliability of wireless local area networks (WLANs), particularly in high-density environments, as standardized in IEEE 802.11ax (Wi-Fi 6).
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patents-in-suit via letters dated June 8, 2021, which identified the patents as Standard Essential Patents (SEPs) for Wi-Fi 6 and presented an opportunity to license them.

Case Timeline

Date	Event
2015-03-25	’310 Patent Priority Date
2015-08-07	’471 Patent Priority Date
2015-08-07	’425 Patent Priority Date
2015-10-12	’919 Patent Priority Date
2017-04-18	’310 Patent Issue Date
2018-07-10	’919 Patent Issue Date
2019-07-09	’471 Patent Issue Date
2021-03-30	’425 Patent Issue Date
2021-06-08	Plaintiff allegedly sent notice letters to Defendant
2025-05-16	Complaint Filing Date

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

U.S. Patent No. 9,638,310 - "Drive Assembly With A Rotating Housing Attached To An Output Interface"

The Invention Explained

• Problem Addressed: The patent addresses the high manufacturing cost and complexity of known drive assemblies for vehicles, which often require expensive materials and manufacturing techniques for integrating a planetary gear set's ring gear into a housing. (’310 Patent, col. 1:33-47, col. 4:1-14).
• The Patented Solution: The invention is a drive assembly where the housing cylinder itself includes an integrally formed ring gear on its inner circumference. (’310 Patent, col. 2:1-4). This housing then connects directly to an output interface (e.g., an output hub), simplifying the design, reducing the number of components, and lowering manufacturing costs. (’310 Patent, Abstract).
• Technical Importance: This design approach seeks to reduce the cost of manufacturing drive assemblies by eliminating a separate ring gear component and enabling the use of less complex production methods. (’310 Patent, col. 4:5-14).

Key Claims at a Glance

• The complaint asserts independent claims 1, 15, and 19 (Compl. ¶36).
• Essential elements of independent claim 1 include:
  • A housing cylinder mounted for rotation, having a cap end and an attachment end.
  • The attachment end having an annular first attachment surface and gear teeth on an inner circumference forming at least one ring gear.
  • A planetary gear set surrounded by the housing cylinder.
  • An output interface with an annular attachment lip having a second attachment surface that overlaps and is in contact with the first attachment surface.
  • A welded connection between the attachment end of the housing cylinder and the attachment lip of the output interface.

U.S. Patent No. 10,020,919 - "Protection Methods for Wireless Transmissions"

The Invention Explained

• Problem Addressed: In multi-user (MU) wireless networks, stations must coordinate transmissions to avoid interference. (’919 Patent, col. 1:18-21). Protection mechanisms like Request-to-Send/Clear-to-Send (RTS/CTS) frames are used, but when multiple stations respond simultaneously (e.g., with a combined CTS frame), their transmissions must use the same scrambling sequence to be successfully combined, which presents a coordination challenge. (’919 Patent, col. 1:33-38).
• The Patented Solution: The patent describes a method where a wireless device receives a Multi-User RTS (MU-RTS) frame containing data scrambled with a first scrambling sequence. (’919 Patent, Abstract). The device then generates its CTS response frame by scrambling data with a second scrambling sequence that is a specific, mathematically defined cyclic shift of the first sequence. (’919 Patent, col. 2:47-53). This allows multiple responding devices to independently generate the same, correct scrambling sequence for their combined response without explicit instruction.
• Technical Importance: The invention provides an efficient, implicit method for coordinating scrambling sequences in multi-user RTS/CTS exchanges, a technique valuable for improving the reliability and throughput of high-efficiency WLANs operating under standards like IEEE 802.11ax. (’919 Patent, col. 1:21-25).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 11 (Compl. ¶47).
• Essential elements of independent claim 1 include:
  • Receiving, by a wireless device, a Multi-User Request-To-Send (MU-RTS) frame including first scrambled data.
  • Descrambling the first scrambled data using a first scrambling sequence.
  • Generating second scrambled data by scrambling data for a Clear-To-Send (CTS) frame using a second scrambling sequence.
  • Transmitting the CTS frame including the second scrambled data.
  • Wherein the second scrambling sequence is an N-bit left cyclic shift of the first scrambling sequence.

U.S. Patent No. 10,348,471 - "Control Information for Multi-User Transmissions in WLAN Systems"

• Technology Synopsis: The patent addresses methods for efficiently signaling control information in high-efficiency WLANs that use multi-user transmissions. It describes structuring a High Efficiency Signal B (HE-SIG-B) field to communicate resource allocation information, such as which resource units (RUs) on a channel are assigned to which user stations. (’471 Patent, Abstract).
• Asserted Claims: Independent claims 1, 14, and 16 are asserted (Compl. ¶58).
• Accused Features: The accused features are the functionalities within HPE’s Wi-Fi 6 products that manage and signal resource allocation for multi-user transmissions in accordance with the 802.11ax standard (Compl. ¶58).

U.S. Patent No. 10,965,425 - "Control Information for Multi-User Transmissions in WLAN Systems"

• Technology Synopsis: As a continuation of the '471 patent family, this patent further details methods for signaling control information. It specifies how the HE-SIG-B field can contain an indication of whether a special type of resource unit, such as a center 26-tone RU, is allocated to a station, thereby managing allocation of specific, shared frequency resources. (’425 Patent, Abstract).
• Asserted Claims: Independent claims 1, 8, and 15 are asserted (Compl. ¶69).
• Accused Features: The accused features are the functionalities within HPE’s Wi-Fi 6 products that use the HE-SIG-B field to signal resource allocation, including the allocation of special RUs, to multiple users (Compl. ¶69).

III. The Accused Instrumentality

Product Identification

The Accused Instrumentalities are broadly defined as "any and all of HPE's networking products and services that comply with, implement, support, or utilize the Wi-Fi 6 Standard" (Compl. ¶30). The complaint provides a non-limiting list that includes numerous product lines such as the HPE Aruba Networking 500, 600, and Instant On Series Access Points (Compl. ¶31).

Functionality and Market Context

The accused products are hardware and software, including Wi-Fi access points, switches, and gateways, that operate according to the IEEE 802.11ax (Wi-Fi 6) standard (Compl. ¶3, ¶4). Their relevant functionality includes implementing key Wi-Fi 6 features such as Orthogonal Frequency Division Multiple Access (OFDMA) and Multi-User Multiple Input, Multiple Output (MU-MIMO) to increase network capacity and efficiency in environments with many connected devices (Compl. ¶19). Plaintiff alleges Defendant markets these products through its "Intelligent Edge" business segment and sells them across the United States, including within the Eastern District of Texas, where it maintains a physical presence (Compl. ¶4, ¶5). The complaint includes a screenshot from HPE’s corporate website listing a brick-and-mortar office in Frisco, TX (Compl. p. 7).

IV. Analysis of Infringement Allegations

'310 Patent Infringement Allegations

The complaint alleges infringement of the ’310 patent and incorporates by reference an exemplary claim chart (Ex. 7) that was not provided with the complaint (Compl. ¶37). The narrative allegations in the complaint focus on the functionality of the Accused Instrumentalities as Wi-Fi 6 devices. The provided U.S. Patent No. 9,638,310, however, is directed to a mechanical "drive assembly with a rotating housing." The complaint does not provide sufficient detail to map the accused Wi-Fi functionality to the claims of the provided patent document.

'919 Patent Infringement Allegations

The complaint alleges infringement of the ’919 patent and incorporates by reference an exemplary claim chart (Ex. 8) that was not provided with the complaint (Compl. ¶48). The narrative allegations are conclusory and state that HPE infringes by "testing and/or using the Accused Instrumentalities within the United States" (Compl. ¶47). The complaint does not provide a detailed narrative infringement theory sufficient for summary.

Identified Points of Contention

• Scope Questions: A threshold issue for the ’310 patent will be the apparent mismatch between the subject matter of the provided patent document (a mechanical drive assembly) and the technological basis of the infringement allegations in the complaint (wireless networking). For the remaining patents, a key question may be whether the term "wireless device," as used in the claims, is properly construed to cover both access points and client stations as implemented in Defendant's product ecosystem.
• Technical Questions: For the ’919 patent, a central technical question will be what evidence the Plaintiff can provide that the accused products' RTS/CTS protection mechanism performs the specific function of generating a second scrambling sequence that is an "N-bit left cyclic shift of the first scrambling sequence" as required by claim 1. For the '471 and '425 patents, a key question will be whether the specific data structures within the HE-SIG-B field of the accused products contain the "indication" of resource allocation as claimed.

V. Key Claim Terms for Construction

Given the subject matter mismatch concerning the provided '310 patent document and the complaint's allegations, an analysis of key claim terms for that patent's role in the asserted dispute is not feasible based on the provided documents.

• The Term: "a second scrambling sequence is an N-bit left cyclic shift of the first scrambling sequence" (from '919 patent, claim 1)
• Context and Importance: This term appears to define the core technical mechanism of claim 1 of the ’919 patent. Practitioners may focus on this term because the infringement analysis will likely depend on whether the accused Wi-Fi 6 products generate scrambling sequences for CTS frames using this precise mathematical relationship or employ an alternative, technically distinct method.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not limit the values of "N" or the length of the scrambling sequence, suggesting the method could apply to various implementations beyond the specific examples shown. The specification describes the invention in the general context of MU communications in a WLAN. (’919 Patent, col. 1:21-25).
  • Evidence for a Narrower Interpretation: The abstract explicitly provides an example where "N may be 7, and lengths of the first and second scrambling sequences may be 127 bits." (’919 Patent, Abstract). Furthermore, the detailed description provides specific scrambling sequences in FIG. 16 and a detailed process flow in FIG. 18A, which a defendant may argue limit the scope of the claimed "cyclic shift" to the embodiments disclosed. (’919 Patent, FIG. 16, FIG. 18A).

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant induces infringement by providing customers with advertisements, user manuals, and technical support documents that instruct them on how to use the accused Wi-Fi 6 products in an infringing manner (Compl. ¶39-40, ¶50-51, ¶61-62, ¶72-73). It is also alleged that the products incorporate executable code that causes performance of the claimed inventions (Compl. ¶19, ¶22).

Willful Infringement

The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the patents-in-suit. This knowledge is alleged to have been established by notice letters sent by Plaintiff to Defendant on June 8, 2021 (Compl. ¶28, ¶42, ¶53, ¶64, ¶75). The complaint alleges that Defendant continued its infringing conduct despite this notice, disregarding an objectively high likelihood of infringement (Compl. ¶42).

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

1. A fundamental threshold issue will be one of subject matter applicability: can the infringement allegations, which are grounded in wireless networking technology, proceed against the provided U.S. Patent No. 9,638,310, which claims a mechanical drive assembly? The resolution of this apparent discrepancy will be foundational to the case's progression.

2. A core technical question will be one of functional specificity: for the patents related to wireless communications, does the evidence show that HPE's Wi-Fi 6 products operate in a manner that meets the precise technical limitations of the claims, such as generating a response scrambling sequence via a specific "N-bit left cyclic shift" ('919 patent) or using the HE-SIG-B field to signal resource allocations in the exact manner described ('471 and '425 patents)?

3. A central legal and damages question will turn on the implications of pre-suit notice and standard-essentiality: how will the Plaintiff's alleged pre-suit licensing offers and characterization of the patents as Standard Essential Patents (SEPs) influence the analyses of willful infringement and the determination of a reasonable royalty?