DCT

2:25-cv-00644

Integral Wireless Tech LLC v. MW Intl Ventures LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00644, E.D. Tex., 06/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business in the Eastern District of Texas, including through the presence of employees and board members, and has committed acts of patent infringement in the District.
  • Core Dispute: Plaintiff alleges that Defendant’s portfolio of enterprise mobility devices, which are compatible with 802.11ac/n, 5G, and Bluetooth standards, infringes nine patents related to foundational wireless communication technologies, including MIMO-OFDM systems, signal processing methods, and power-saving techniques.
  • Technical Context: The patents address core challenges in modern wireless communications, focusing on enhancing data throughput, signal reliability, and power efficiency in complex multi-antenna (MIMO) environments.
  • Key Procedural History: The complaint does not allege any significant procedural history, such as prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the asserted patents, or a prior licensing relationship.

Case Timeline

Date Event
2001-10-04 U.S. Patent No. 7,269,127 Priority Date
2004-07-02 U.S. Patent No. 7,738,595 Priority Date
2004-07-02 U.S. Patent No. 7,822,141 Priority Date
2004-07-21 U.S. Patent No. 7,676,007 Priority Date
2004-07-30 U.S. Patent No. 8,139,544 Priority Date
2004-11-24 U.S. Patent No. 8,812,888 Priority Date
2004-11-24 U.S. Patent No. 9,207,748 Priority Date
2005-04-26 U.S. Patent No. 7,949,068 Priority Date
2007-09-11 U.S. Patent No. 7,269,127 Issues
2008-12-09 U.S. Patent No. 8,976,714 Priority Date
2010-03-09 U.S. Patent No. 7,676,007 Issues
2010-06-15 U.S. Patent No. 7,738,595 Issues
2010-10-26 U.S. Patent No. 7,822,141 Issues
2011-05-24 U.S. Patent No. 7,949,068 Issues
2012-03-20 U.S. Patent No. 8,139,544 Issues
2014-08-19 U.S. Patent No. 8,812,888 Issues
2015-03-10 U.S. Patent No. 8,976,714 Issues
2015-12-08 U.S. Patent No. 9,207,748 Issues
2025-06-18 Complaint Filed

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

U.S. Patent No. 7,676,007 - *"System and Method for Interpolation Based Transmit Beamforming for MIMO-OFDM with Partial Feedback"*

The Invention Explained

  • Problem Addressed: The patent addresses the problem of excessive feedback overhead in multiple-input multiple-output (MIMO) systems that use orthogonal frequency division multiplexing (OFDM) (Compl. ¶34). For optimal "beamforming" (directing a wireless signal), the transmitter needs channel state information for all of the system's subcarriers. In systems where the uplink and downlink channels are not reciprocal, this information must be sent from the receiver back to the transmitter, and the amount of feedback increases in proportion to the number of subcarriers, consuming valuable bandwidth (’007 Patent, col. 2:37-43).
  • The Patented Solution: The invention proposes a method to reduce this feedback. Instead of sending back beamforming information for all subcarriers, the receiver sends back information for only a subset of them. The transmitter then uses this partial information to calculate the beamforming vectors for the remaining subcarriers through interpolation, leveraging the correlation between adjacent subcarriers to estimate the missing data (’007 Patent, Abstract; col. 2:44-54).
  • Technical Importance: This approach aims to make high-performance beamforming more efficient and practical by reducing the amount of control information required to be sent over the feedback channel.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶37).
  • Claim 1 requires a communication apparatus with a transmitter configured to:
    • Receive "limited feedback information" from a receiver, where that information includes "beamforming vectors for a subset of the subcarriers" and "interpolation information."
    • "derive beamforming vectors for at least one subcarrier... not included in the subset based at least on an interpolation" of the received vectors.
    • The interpolation must be based on the "interpolation information," which includes "phase values."
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,738,595 - *"Multiple Input, Multiple Output Communications Systems"*

The Invention Explained

  • Problem Addressed: The patent background discusses the general goal of increasing channel capacity in wireless systems using MIMO techniques (Compl. ¶61). A key challenge in such systems is that different spatial streams can experience different signal-to-noise ratios, leading to unequal performance and potential degradation of overall throughput (’595 Patent, col. 12:4-9).
  • The Patented Solution: The invention describes a MIMO transmitter that calculates signal weighting vectors using a specific mathematical technique called "unit magnitude decomposition." This process involves decomposing the transmission channel matrix into a "unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane" (’595 Patent, Abstract; col. 12:1-6). The purpose of this decomposition is to create multiple transmission channels with equal, or near-equal, signal quality.
  • Technical Importance: This method aims to improve the reliability and performance of MIMO communications by ensuring that all parallel data streams have equivalent signal-to-noise ratios, thereby minimizing packet error rate degradation.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶64).
  • Claim 1 requires a MIMO signal transmitter with at least two vector multipliers and at least two antennas, wherein:
    • Each vector used for weighting is computed using a "unit magnitude decomposition of a transmission channel matrix."
    • This decomposition includes decomposing at least a portion of the channel matrix "into a unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane."
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,822,141 - *"Multiple Input, Multiple Output Communications Systems"*

  • Technology Synopsis: This patent describes an iterative method for optimizing MIMO communications. It involves generating weighted signals using initial transmitter weights, receiving reverse signals from a receiver, and then iteratively updating the transmitter weights based on the determined receiver weights to achieve a target level of gain (’141 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶90).
  • Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform the claimed iterative method of generating, transmitting, receiving, and updating transmitter and receiver weights (Compl. ¶91).

U.S. Patent No. 7,949,068 - *"Systems and Methods for Transmitter Diversity"*

  • Technology Synopsis: This patent discloses a method for transmitter diversity expansion, where a set of "base data streams" are used to generate a set of "extension data streams." The extension data streams are created through a matrix multiplication of the base streams with a unitary matrix, and then all base and extension streams are transmitted from separate antennas (’068 Patent, Abstract).
  • Asserted Claims: At least independent claim 17 (Compl. ¶100).
  • Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform the claimed method of generating extension data streams from base data streams via matrix multiplication and transmitting them from corresponding antennas (Compl. ¶101).

U.S. Patent No. 8,139,544 - *"Pilot Tone Processing Systems and Methods"*

  • Technology Synopsis: The patent describes a system for processing pilot tones in a multi-antenna wireless system. A receiver is configured to receive separate signals, each with data and pilot subcarriers, from different antennas and uses a signal separating function based on channel estimates to separate the data and pilot subcarriers from each other (’544 Patent, Abstract).
  • Asserted Claims: At least independent claim 15 (Compl. ¶126).
  • Accused Features: The complaint alleges that Defendant's 802.11n compatible devices provide a receiver that receives first and second signals with data and pilot subcarriers, separates them based on channel estimates, and match-filter combines the pilot subcarriers (Compl. ¶127).

U.S. Patent No. 8,812,888 - *"Systems and Methods for Scanning for A Wake Up Packet Addressed to A Wireless Device"*

  • Technology Synopsis: This patent relates to power-saving methods for wireless devices. It discloses a method where a device scans for a "wake-up packet" for a predetermined period and ceases scanning if the packet is not received, allowing the device to conserve power (’888 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶152).
  • Accused Features: The complaint alleges that Defendant's Bluetooth compatible devices perform the method of scanning for a wake-up packet for a predetermined time and ceasing to scan if it is not received within that time (Compl. ¶153).

U.S. Patent No. 8,976,714 - *"Providing and Acquiring A System Information Message In A Wireless Network"*

  • Technology Synopsis: The patent discloses a user equipment (UE) in a wireless network that receives system information (SI). The UE is configured to receive "si-Windowlength" information in a specific message type and use it to calculate the downlink subframe and radio frame where an SI message starts, enabling reception of the message during the specified window (’714 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶163).
  • Accused Features: The complaint alleges that Defendant's 5G compatible devices provide a UE that receives "si-Windowlength" information in an SI type 1 message and uses it to calculate the subframe and radio frame to receive the SI message (Compl. ¶164).

U.S. Patent No. 9,207,748 - *"Systems and methods for a wireless device wake-up process including power-save and non-power-save modes"*

  • Technology Synopsis: This patent describes a computer with a controller configured to manage a wireless device's wake-up process. The controller triggers a "wake-up detection mode" for a set time, receives a wake-up packet that initiates a switch from power-save to non-power-save mode, and exits the detection mode after the process is performed or the time expires (’748 Patent, Abstract).
  • Asserted Claims: At least independent claim 8 (Compl. ¶189).
  • Accused Features: The complaint alleges that Defendant's Bluetooth compatible devices provide a computer with a controller that performs the claimed wake-up process management (Compl. ¶190).

U.S. Patent No. 7,269,127 - *"Preamble Structures for Single-Input, Single-Output (SISO) and Multi-Input, Multi-Output (MIMO) Communication Systems"*

  • Technology Synopsis: This patent describes an efficient preamble structure for wireless frames. The preamble includes training symbols with a specific structure: the training block has a time length that is an integer fraction (N/I) of a data block's length, and the cyclic prefix is an integer fraction of the training block's length (e.g., N/4) (’127 Patent, Abstract). This structure is designed for synchronization and channel estimation.
  • Asserted Claims: At least independent claim 20 (Compl. ¶199).
  • Accused Features: The complaint alleges that Defendant's 802.11n compatible devices perform a method of forming a frame structure with a preamble containing an enhanced training symbol that has a specific cyclic prefix and training block length relationship as claimed (Compl. ¶200).

III. The Accused Instrumentality

Product Identification

  • The accused products include a range of enterprise mobility devices sold under the RHINO brand (e.g., RHINO C10, RHINO C6, RHINO D2 5G) as well as the Social Mobile One and RHINO Helium Pro devices (Compl. ¶27).

Functionality and Market Context

  • The complaint identifies the accused products as devices compatible with various wireless standards, including 802.11ac, 802.11n, 5G, and Bluetooth (Compl. ¶27). Their accused functionality stems directly from their implementation of these standards, which allegedly practice the methods claimed in the patents-in-suit.
  • Plaintiff alleges Defendant markets these products as "enterprise mobility solutions" and for use in industries such as "healthcare, transportation, retail, and defense" (Compl. ¶4). This positions the products in markets where reliable and efficient wireless communication is a critical feature.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing the infringement allegations for each patent (Compl. ¶37, ¶64, ¶90, etc.). The analysis below is based on the narrative infringement summaries provided in the body of the complaint.

U.S. Patent No. 7,676,007 Infringement Allegations

The complaint alleges that Defendant's 802.11ac compatible devices directly infringe at least claim 1 of the ’007 Patent (Compl. ¶37-38). The narrative theory asserts that these devices provide a communication apparatus with a transmitter that receives "limited feedback information" from a receiver. This feedback allegedly includes "beamforming vectors for a subset of the subcarriers" and "interpolation information" containing "phase values." The transmitter is then alleged to use this limited information to derive, via interpolation, the beamforming vectors for the remaining subcarriers not included in the feedback subset (Compl. ¶38). This theory closely tracks the language of claim 1.

U.S. Patent No. 7,738,595 Infringement Allegations

The complaint alleges that Defendant's 802.11n compatible devices directly infringe at least claim 1 of the ’595 Patent (Compl. ¶64-65). The infringement theory claims these devices provide a MIMO signal transmitter that computes weighting vectors for its antennas using a "unit magnitude decomposition of a transmission channel matrix." This decomposition is alleged to include the step of decomposing the channel matrix into a "unitary matrix with eigenvalues that lie substantially on a unit circle of a complex plane," directly mapping to the key limitations of claim 1 (Compl. ¶65).

Identified Points of Contention

  • Technical Questions: A primary question for both the ’007 and ’595 patents will be evidentiary and technical. Does the standard operation of 802.11ac and 802.11n devices, as implemented by Defendant, necessarily perform the specific "interpolation of... beamforming vectors" (’007 Patent) and "unit magnitude decomposition" (’595 Patent) as required by the claims? The dispute may focus on whether the accused functionality is an inherent part of the standard or a specific implementation choice by Defendant.
  • Scope Questions: The infringement analysis for the ’595 patent may raise a definitional question regarding the term of degree "substantially on a unit circle." The parties may dispute how close to unity the magnitude of the eigenvalues must be to satisfy this limitation. For the ’007 patent, the scope of "limited feedback information" could be a point of contention, specifically whether it requires the particular subset-and-interpolation structure described in the patent's specification.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

For U.S. Patent No. 7,676,007:

  • The Term: "limited feedback information" (Claim 1)
  • Context and Importance: This term is central to the invention's contribution of reducing feedback overhead. Its construction will determine whether the claim reads on any system with less-than-complete feedback or is restricted to systems using the specific partial-feedback-plus-interpolation scheme disclosed in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning of "limited" suggests any amount of feedback that is not complete or total.
    • Evidence for a Narrower Interpretation: The specification consistently describes the invention in the context of a specific type of limited feedback: providing "beamforming vectors for a subset of the subcarriers" (’007 Patent, col. 16:16-17) and then interpolating the rest. A defendant may argue that the term should be construed in light of this detailed description, limiting its scope to that specific technical approach.

For U.S. Patent No. 7,738,595:

  • The Term: "eigenvalues that lie substantially on a unit circle" (Claim 1)
  • Context and Importance: This term defines the core technical requirement of the claimed "unit magnitude decomposition." The case may turn on whether the accused devices' signal processing results in eigenvalues that are close enough to the unit circle to be considered "substantially" on it. Practitioners may focus on this term because it is a term of degree that is not explicitly defined in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "substantially" may suggest that some deviation from a perfect unit circle is permissible, potentially covering systems that achieve approximate but not perfect signal gain equality across channels.
    • Evidence for a Narrower Interpretation: The patent explains that the purpose of this feature is to ensure "the signal-to-noise ratios for each of the signals... will be equal, thereby minimizing packet error rate degradation" (’595 Patent, col. 12:4-9). A party could argue that "substantially" must be interpreted to mean close enough to achieve this stated objective of equal SNR, thereby narrowing the term's scope to exclude systems with more significant eigenvalue variance.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on allegations that Defendant instructs end-users on how to use the Accused Products in an infringing manner through user manuals, advertising, and technical support (Compl. ¶28, ¶44, ¶71, ¶107). Contributory infringement is based on allegations that the Accused Products have "special features" that are material to the invention and are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶50-51, ¶76-77).

Willful Infringement

  • The complaint alleges willful infringement based on two theories. First, it alleges pre-suit willful blindness, claiming Defendant has a "policy or practice of not reviewing the patents of others" (Compl. ¶39, ¶66). Second, it alleges post-suit willfulness based on Defendant having "actual knowledge of said patent since at least the time of receiving the original complaint in this action" (Compl. ¶40, ¶67).

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

This case appears to present several central questions for the court, spanning a large portfolio of patents asserted against products implementing common wireless standards.

  • A primary issue will be one of technical implementation: Do the accused 802.11ac/n, 5G, and Bluetooth devices, by virtue of complying with their respective standards, necessarily practice the specific methods of signal processing, feedback handling, and power management recited in the asserted claims? Or will Plaintiff be required to prove that Defendant’s products contain specific, non-standard design choices that map onto the patent claims?
  • A second key question will be one of claim scope and construction, particularly for terms of degree. The dispute may turn on the court's interpretation of phrases such as "limited feedback information" (’007 Patent) and "eigenvalues that lie substantially on a unit circle" (’595 Patent), which will determine whether the claims are broad enough to read on the accused functionality or are confined to the specific embodiments detailed in the patent specifications.
  • Finally, a significant question regarding damages and willfulness will be the state of mind of the Defendant. The allegation of a "policy or practice of not reviewing the patents of others" as a basis for willful blindness will likely be a point of factual contention, requiring discovery into Defendant's internal patent-related policies.