WebSock Global Strategies LLC v. Coburn Supply Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: Coburn Supply Company, Inc. (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00566, E.D. Tex., 05/22/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district and having committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified products and services infringe a patent related to methods for establishing symmetrical, bi-directional communication over traditionally asymmetric network protocols.
• Technical Context: The technology addresses limitations in client-server protocols like HTTP, enabling network nodes to dynamically reverse roles to allow for peer-to-peer communication, particularly through firewalls or Network Address Translation (NAT) devices.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer and is a continuation of an earlier U.S. application, which may be relevant to the patent’s term and claim scope. The complaint itself notes no prior litigation or other proceedings.

Case Timeline

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

U.S. Patent No. 7,756,983 - "Symmetrical bi-directional communication" (Issued Jul. 13, 2010)

The Invention Explained

• Problem Addressed: Standard network protocols like HTTP are inherently asymmetric; a "client" node must initiate a request to a "server" node, which can only respond (’983 Patent, col. 2:10-21). This structure prevents a server from initiating communication, a significant hurdle for peer-to-peer applications, especially when a node is behind a firewall or NAT that blocks unsolicited inbound connections (’983 Patent, col. 2:41-51).
• The Patented Solution: The invention describes a method where two nodes establish a conventional, client-initiated connection. The nodes then negotiate a "transactional role reversal." The initial higher-level protocol session (e.g., HTTP) is terminated, but the underlying network connection (e.g., TCP/IP socket) is preserved. A new HTTP session is then created over the preserved connection, but with the roles flipped, allowing the original server to now act as a client and initiate requests. (’983 Patent, Abstract; col. 4:18-32; Fig. 9).
• Technical Importance: This method enables true peer-to-peer communication using the ubiquitous HTTP protocol, bypassing the typical restrictions of NATs and firewalls without resorting to inefficient continuous polling by the client (’983 Patent, col. 3:4-16).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specifying them (Compl. ¶11). Independent claim 1 is representative of the core method.
• Independent Claim 1 recites a method with the following essential elements:
  • First and second network nodes engage in an asymmetric HTTP transactional session over an underlying network connection, with one node acting as client and the other as server.
  • The asymmetric HTTP session is terminated while the underlying network connection is maintained.
  • The nodes negotiate a transactional role reversal.
  • The nodes communicate further under a reversed asymmetric transactional protocol, where each node enacts the initial role of the other.
  • The session uses a network connection that traverses hardware enforcing asymmetric communication.
• The complaint's reference to "one or more claims" suggests it may reserve the right to assert additional independent or dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products or services by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in an exhibit not attached to the publicly filed complaint (Compl. ¶13).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It makes only the conclusory allegation that the unidentified products "practice the technology claimed by the '983 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits that allegedly compare the patent claims to the "Exemplary Defendant Products" (Compl. ¶13). In the absence of these charts or more specific factual allegations, the infringement theory must be inferred from the complaint's general statements.

The complaint alleges that Defendant directly infringes the ’983 Patent by making, using, selling, or importing the accused products, and by having its employees internally test and use them (Compl. ¶¶ 11-12). The narrative infringement theory appears to be that the unidentified "Exemplary Defendant Products" implement a communication method that satisfies all elements of the asserted claims, including the establishment of an initial session, a subsequent role reversal, and further communication under the reversed roles (Compl. ¶13). The complaint does not, however, provide any specific facts describing how the accused products perform these steps.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the meaning of "negotiating transactional role reversal." The question for the court will be whether this term requires a specific, explicit protocol exchange as detailed in the patent's embodiments (e.g., an "HTTP FLIP request") or if it can be read more broadly to cover any mechanism that results in a reversal of client-server roles over a persistent connection.
  • Technical Questions: A key evidentiary challenge for the plaintiff will be to demonstrate that the accused products perform the specific technical sequence of "terminating said asymmetric HTTP transactional session while maintaining said underlying network connection." The complaint offers no facts on how this two-part step is accomplished by the accused products, raising the question of what evidence exists to prove this element.

V. Key Claim Terms for Construction

• The Term: "negotiating transactional role reversal" (from Claim 1)

  • Context and Importance: This phrase defines the core inventive act. The defendant's liability may turn on whether its accused functionality falls within the court's construction of this term. Practitioners may focus on this term because it is not a standard industry term and its meaning will be derived almost exclusively from the patent's intrinsic evidence.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify a particular method of negotiation, which may support a construction covering any form of agreement or protocol exchange between nodes that results in role reversal (’983 Patent, col. 16:21-23).
    • Evidence for a Narrower Interpretation: The detailed description and figures disclose a specific embodiment where the client sends an "HTTP FLIP request" to the server, which then explicitly accepts or refuses the request. A party could argue that "negotiating" requires such a two-way, explicit request-and-response protocol. (’983 Patent, Fig. 9, steps 504-506; col. 10:61-66).

• The Term: "terminating said asymmetric HTTP transactional session while maintaining said underlying network connection" (from Claim 1)

  • Context and Importance: This limitation distinguishes the invention from simply opening two separate, independent connections. Proving infringement requires showing the specific destruction of the HTTP layer while preserving the TCP/IP layer.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim does not dictate the precise technical steps for termination and maintenance, potentially allowing for various software implementations to meet the limitation.
    • Evidence for a Narrower Interpretation: The specification describes a process of extracting and saving "raw TCP circuit information," terminating the "existing HTTP layer session," and then creating a "new HTTP layer session" using the saved circuit information. This detailed sequence could be argued as definitional for the claim element. (’983 Patent, Fig. 9, steps 508-514; col. 11:40-55).

VI. Other Allegations

• Willful Infringement: The complaint does not explicitly allege willful infringement. However, in its prayer for relief, it requests that the case be "declared exceptional" and seeks an award of attorneys' fees under 35 U.S.C. § 285 (Compl., Prayer for Relief, ¶E.i). The complaint provides no factual predicate for this request, such as allegations of pre-suit notice or egregious conduct.

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

This case, as currently pleaded, presents two fundamental questions that will likely define its trajectory:

1. A core issue will be one of evidentiary sufficiency: The complaint lacks specific factual allegations identifying the accused products or describing how they operate. A threshold question for the court will be whether the plaintiff can produce sufficient evidence to show that any of Defendant’s specific products actually perform the complex, multi-step method of terminating a high-level protocol session while preserving the underlying network connection for a role-reversed session.

2. The central legal dispute will likely be one of definitional scope: Can the phrase "negotiating transactional role reversal," which is central to the asserted claims, be construed broadly to cover various methods of reversing communication roles, or will the court limit its meaning to the specific "HTTP FLIP request" protocol described in the patent’s preferred embodiments? The answer to this claim construction question may be dispositive for the infringement analysis.