Reframe Tech LLC v. JPMorgan Chase Bank NA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Reframe Technologies LLC (New Mexico)
  • Defendant: JPMorgan Chase Bank, N.A. (New York)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00589, E.D. Tex., 05/28/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business in the Eastern District of Texas and having committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a system for trading network resources, such as Wi-Fi access.
• Technical Context: The technology concerns systems that allow owners of network access points (e.g., Wi-Fi routers) to earn tradeable credits by providing access to roaming users, who can then spend those credits to access other participating networks.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,552,870 - "Trading network resources"

• Patent Identification: U.S. Patent No. 7,552,870, "Trading network resources", issued June 30, 2009.

The Invention Explained

• Problem Addressed: The patent identifies a problem where millions of wireless access gateways (e.g., Wi-Fi hotspots) exist, but roaming users cannot easily access them. Existing paid-access services have sparse geographic coverage and high costs, which discourages user adoption and limits revenue for hotspot operators (’870 Patent, col. 2:1-17).
• The Patented Solution: The invention proposes a "Network Resource Trading System" that allows an "Access Gateway Operator" to earn credits for providing network access to others. These earned credits can then be used to "trade" for access when that operator is roaming and needs to use a different participating access gateway. This creates a barter-like system, enabling a broader network of accessible hotspots without requiring direct cash payments for each session (’870 Patent, Abstract; col. 2:18-28; Fig. 1).
• Technical Importance: The system aims to create a viable method for monetizing the vast number of underutilized, privately-owned internet access points, thereby expanding roaming options beyond the limited footprint of commercial billing providers (’870 Patent, col. 2:18-28).

Key Claims at a Glance

• The complaint asserts infringement of one or more claims of the ’870 Patent, but does not specify which claims in the body of the complaint, instead referencing an external exhibit (Compl. ¶11, ¶16). The patent contains one independent method claim (Claim 1) and one independent system claim (Claim 7).
• Independent Claim 1 (Method):
  • Storing data in first type accounts for a network resource user.
  • Storing data in second type accounts for a network resource access gateway operator.
  • Wherein credit on a second type account acts as credit on a first type account.
  • Receiving a request from a requestor to authorize provision of network resources, with the request identifying a specific first and second type account.
  • Sending a reply authorizing or denying provision of resources based at least partially on the balance of the identified first type account.
  • Adjusting the balances of the first and second type accounts based on the network resources used.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products, methods, or services. It refers to them generally as "Exemplary Defendant Products" that are identified in "charts incorporated into this Count" (Compl. ¶11). These charts are referenced as Exhibit 2, which was not filed with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within an "Exhibit 2," which was not attached to the publicly filed document (Compl. ¶16, ¶17). The complaint states that the charts in Exhibit 2 compare the "Exemplary '870 Patent Claims to the Exemplary Defendant Products" and that these products "practice the technology claimed by the '870 Patent" (Compl. ¶16). Without access to Exhibit 2, a detailed analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "credit on at least one of said second type accounts acts as credit on at least one of said first type accounts" (’870 Patent, col. 22:3-5).
• Context and Importance: This clause appears to be the central mechanism of the "trading" system. Its construction will be critical to determining whether an accused system that uses a single, unified account structure, or one that involves direct financial settlement between parties, falls within the scope of the claims. Practitioners may focus on whether "acts as credit" requires a direct, non-monetary barter system or if it can encompass systems where credits are convertible to or settled with currency.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes embodiments where "a single account might be used, with earned credits and cash credits being made to the same account" (’870 Patent, col. 5:44-48). This could suggest that the "first type" and "second type" accounts need not be structurally separate, but could be logical distinctions within a single data structure.
  • Evidence for a Narrower Interpretation: The patent repeatedly distinguishes between "Earned Balance" and "Cash Balance" accounts, each with its own UniqueID, suggesting they are distinct entities (’870 Patent, col. 5:38-44; col. 8:26-34). The summary describes the invention as enabling access "without having to make any traditional form of payment," which could support an interpretation requiring a purely non-monetary credit transfer (’870 Patent, col. 2:25-28).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes the '870 Patent" (Compl. ¶14). The factual support for this allegation is purportedly contained in the unattached Exhibit 2 (Compl. ¶14).
• Willful Infringement: The complaint alleges willful infringement based on post-suit knowledge. It asserts that the filing of the complaint and its attached claim charts provides Defendant with "actual knowledge of infringement" and that any continued infringement thereafter is willful (Compl. ¶13, ¶14).

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

1. Evidentiary Sufficiency: The primary immediate question is whether the complaint, which omits identification of the accused products and all specific infringement allegations from its body in favor of an unfiled exhibit, meets federal pleading standards.
2. Definitional Scope: A core substantive issue will be one of claim construction, focusing on whether the claimed "trading" system—where credit from a gateway operator’s account "acts as credit" for a user’s account—can be read to cover the specific architecture and transaction models of the yet-to-be-identified accused products.
3. Direct vs. Indirect Liability: The case may turn on questions of liability, specifically whether Defendant's role is that of a direct infringer (operating the claimed system) or an indirect infringer (providing tools or instructions for others to build or use an infringing system), a distinction that cannot be analyzed without details on the accused products.