DCT

2:25-cv-00691

Headwater Research LLC v. T-Mobile USA Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00691, E.D. Tex., 07/07/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because T-Mobile conducts business in the district, has a regular and established place of business, and has committed alleged acts of infringement within the district, including by advertising, selling, and operating its wireless network services and devices.
  • Core Dispute: Plaintiff alleges that Defendant’s cellular networks, services, and associated eSIM-enabled devices infringe four patents related to automated device provisioning, user notifications, service plan management, and enterprise network access control.
  • Technical Context: The technology addresses the management of services, policies, and billing for mobile devices, which has become increasingly complex amid exponential growth in mobile data consumption.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of U.S. Patent Nos. 8,635,678 and 8,745,220 due to a patent marking notice included in "ItsOn software," a technology Plaintiff states was licensed and implemented to improve device and data management capabilities for carriers.

Case Timeline

Date Event
2009-01-28 Earliest Priority Date for ’678, ’220, and ’983 Patents
2009-02-04 Earliest Priority Date for ’627 Patent
2014-01-21 U.S. Patent No. 8,635,678 Issues
2014-06-03 U.S. Patent No. 8,745,220 Issues
2019-10-29 U.S. Patent No. 10,462,627 Issues
2020-01-14 U.S. Patent No. 10,536,983 Issues
2020-04-01 T-Mobile and Sprint merger closes
2025-07-07 Complaint Filed

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

U.S. Patent No. 8,635,678 - “Automated device provisioning and activation”

The Invention Explained

  • Problem Addressed: The patent describes the increasing complexity of managing mobile device services as networks and devices become more varied. Traditional provisioning is described as often being cumbersome and expensive for service providers and end-users. (’678 Patent, col. 85:20-39).
  • The Patented Solution: The invention provides a system for automating the provisioning and activation of wireless devices. It describes using temporary or partial credentials to allow a device to connect to a network to complete its own activation, potentially without significant user intervention. This allows for a more flexible and efficient activation process managed by a network system that can handle a plurality of devices within a defined "device group." (’678 Patent, col. 132:25-52).
  • Technical Importance: This approach suggests a shift from manual, carrier-centric device activation to a more automated, network-managed system, designed to reduce operational costs for service providers and simplify the user experience. (’678 Patent, col. 85:20-39).

Key Claims at a Glance

  • The complaint asserts infringement of Claim 1. (Compl. ¶40).
  • Independent Claim 1 of the ’678 Patent includes the following essential elements:
    • A method performed by a network system.
    • Storing a plurality of device credentials associated with a device group of wireless devices, where the group is managed by a "device-group management entity" different from the network system operator.
    • Providing a secure interface for the management entity to create or modify a service policy for the device group.
    • The service policy assists the network in controlling, monitoring, or accounting for communications associated with the device group.
    • Provisioning one or more elements based on the service policy.
    • Identifying at least a portion of the service policy based on the identified communications.

U.S. Patent No. 8,745,220 - “System and method for providing user notifications”

The Invention Explained

  • Problem Addressed: As mobile data usage has grown, users and providers face challenges in tracking service consumption against plan limits, which can lead to unexpected charges or service disruptions. The patent background notes that providing timely and relevant notifications about service usage is critical. (’220 Patent, col. 13:1-13).
  • The Patented Solution: The invention claims a method for managing a shared data allocation among a group of devices. A first, or primary, device is authorized to set a data usage policy for a second device. The system then monitors the second device's usage and enforces the policy, which may include providing notifications to the user(s) based on network-detected trigger events. (’220 Patent, Abstract). This allows for granular control and awareness of data usage within a shared plan, such as a family or small business account.
  • Technical Importance: This technology provides a framework for managing shared data plans by delegating policy-setting authority to a primary user and automating enforcement and notification through the network, a key feature for modern cellular service offerings. (’220 Patent, col. 8:1-14).

Key Claims at a Glance

  • The complaint asserts infringement of Claim 1. (Compl. ¶52).
  • Independent Claim 1 of the ’220 Patent includes the following essential elements:
    • A method obtaining a credential associated with a first end-user device in a device group that has a shared data allocation.
    • The first end-user device is authorized to set a data usage policy for a second end-user device in the group.
    • Obtaining from the first device one or more user preferences regarding the policy for the second device.
    • Provisioning one or more network elements to enforce or apply the data usage policy for the second device based on the authorization and preferences from the first device.

Multi-Patent Capsule: U.S. Patent No. 10,462,627

  • Patent Identification: U.S. Patent No. 10462627, titled “Service plan design, user interfaces, application programming interfaces, and device management,” issued October 29, 2019.
  • Technology Synopsis: The patent addresses the need for more flexible and customizable mobile service plans. The disclosed invention provides systems and methods that allow carriers, third parties, and even end-users to design, select, and manage service plans and bundles through graphical user interfaces on the device and corresponding application programming interfaces (APIs) in the network. (’627 Patent, Abstract; col. 2:27-40). This enables features like creating device groups with shared plans and offering sponsored data services. (’627 Patent, col. 2:41-53).
  • Asserted Claims: The complaint references infringement of at least Claim 1. (Compl. ¶63).
  • Accused Features: T-Mobile’s systems for creating, offering, and managing its various cellular service plans to consumers and businesses. (Compl. ¶¶24, 62).

Multi-Patent Capsule: U.S. Patent No. 10,536,983

  • Patent Identification: U.S. Patent No. 10536983, titled “Enterprise access control and accounting allocation for access networks,” issued January 14, 2020.
  • Technology Synopsis: The patent addresses the technical challenge of allocating billing for a single device's wireless usage between a corporate or enterprise account and a personal or consumer account. The invention provides for monitoring a device's service usage activity and determining an enterprise/consumer billing allocation, which allows an enterprise to pay for business-related activities while the employee pays for personal use on the same device. (’983 Patent, Abstract).
  • Asserted Claims: The complaint references infringement of at least Claim 1. (Compl. ¶73).
  • Accused Features: T-Mobile’s networks and services that support enterprise customers and enable the allocation of service usage and billing between corporate and individual accounts. (Compl. ¶¶24, 72).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities include T-Mobile's cellular networks, servers, and services, along with eSIM-enabled devices that operate on that network. (Compl. ¶24). The complaint specifically lists network components related to eSIM provisioning and management, such as SM-DP+, SM-DP, and RSP, as well as core network entities like AAA, HLR/HSS, and PCRF/PCF. (Compl. ¶24).
  • Functionality and Market Context: The complaint alleges these instrumentalities work together to provide cellular connectivity and services to a wide range of devices, including mobile phones, tablets, wearables, and IoT devices. (Compl. ¶24). The complaint provides a coverage map to illustrate the geographic scope of T-Mobile's accused 5G and 4G LTE network services within the Eastern District of Texas. (Compl. p.10). The commercial scale of the accused services is highlighted by the allegation that T-Mobile had approximately 110 million subscribers as of late 2021. (Compl. ¶31).

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement, induced infringement, and contributory infringement of all four Asserted Patents. (Compl. ¶¶39, 41, 51, 53, 62, 64, 72, 74). For each patent, the complaint states that an exhibit provides a claim chart showing how the Accused Instrumentalities infringe at least Claim 1. (Compl. ¶¶40, 52, 63, 73). However, these exhibits were not filed with the complaint. The pleading itself does not contain a detailed narrative mapping specific product features to claim elements.

  • '678 Patent Infringement Allegations
    • The complaint’s infringement theory for the ’678 Patent is not detailed in prose, instead referring to an unfiled "Exhibit 5." (Compl. ¶40). The core allegation is that T-Mobile's systems for provisioning and activating devices, particularly eSIM-enabled devices, on its network practice the method of Claim 1. (Compl. ¶¶24, 39).
  • '220 Patent Infringement Allegations
    • Similarly, the infringement theory for the ’220 Patent refers to an unfiled "Exhibit 6." (Compl. ¶52). The allegation suggests that T-Mobile's services that allow users to manage shared data plans (e.g., family plans) and receive usage notifications practice the method of Claim 1. (Compl. ¶¶24, 51).
  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the term "device-group management entity" from the ’678 Patent, which is defined as being "different from a network system operator," can be read on systems where T-Mobile (the network operator) provides account management tools to its customers (e.g., enterprise administrators or heads of family plans). The interpretation of the relationship between the "entity" and the "operator" will be critical.
    • Technical Questions: The complaint lists numerous modern, standards-based network components (e.g., SM-DP+, PCRF/PCF) as part of the accused instrumentality. (Compl. ¶24). A key technical question will be what evidence demonstrates that these specific components, individually or collectively, perform the steps recited in the claims of the 2009-priority patents in the manner described by the patents.

V. Key Claim Terms for Construction

For the '678 Patent:

  • The Term: "device-group management entity" (Claim 1)
  • Context and Importance: This term is central to the claim, as it defines the actor responsible for creating or modifying the service policy for a group of devices. The claim requires this entity to be "different from a network system operator." The viability of the infringement claim may depend on whether a T-Mobile enterprise customer using T-Mobile-provided tools qualifies as this separate "entity."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the entity could be a variety of actors, including a "master account service subscriber (e.g., a person)," an "employer," a "parent," or a "third party." (’678 Patent, col. 23:3-14). This language may support an argument that any party using the network's tools to manage a group of devices, even if they are a customer of the network operator, meets the definition.
    • Evidence for a Narrower Interpretation: The repeated distinction between the "network system operator" and the "device-group management entity" could support an argument that the claimed entity must have a degree of operational independence from the network operator beyond that of a mere customer using standard account management features. The patent also discusses Mobile Virtual Network Operators (MVNOs) as distinct entities, which could be used to argue for a narrower definition requiring a separate corporate or service-providing structure. (’678 Patent, col. 20:2-10).

For the '220 Patent:

  • The Term: "provisioning...one or more elements of the network system" (Claim 1)
  • Context and Importance: This term describes the action taken by the network in response to the policy set by the primary user. The dispute will likely focus on what level of network modification or configuration is required to meet this "provisioning" step.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes provisioning in broad terms, including setting policies related to "access control, service plan selection, service activation, service usage monitoring," and notifications. (’220 Patent, col. 25:60-65). This could support a reading where simply updating a user's profile in a database to reflect a new data limit for a secondary device constitutes "provisioning" a network element.
    • Evidence for a Narrower Interpretation: The patent frequently discusses network elements like gateways, home agents, and service controllers as the locus of policy enforcement. (’220 Patent, FIG. 1, FIG. 2A). This may support a narrower interpretation requiring a direct configuration change to a network hardware or software element that actively controls data traffic, rather than just updating an account database.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that T-Mobile induces infringement by "actively encouraging and instructing their customers to use and integrate the Accused Instrumentalities in ways that directly infringe" the patents. (Compl. ¶¶42, 54, 65, 75). It is alleged that these acts include providing instructions on the use of the accused products and services. (Compl. ¶¶44, 56, 66, 76).
  • Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the Asserted Patents. For the ’678 and ’220 patents, knowledge is alleged to stem from at least a patent marking notice on "ItsOn software." (Compl. ¶¶41, 53). For all four patents, knowledge is alleged to have been established "through at least the filing and service of this Complaint." (Compl. ¶¶41, 53, 64, 74). The complaint alleges that despite this knowledge, Defendants continue to infringe. (Compl. ¶¶42, 54, 65, 75).

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

  • A core issue will be one of entity and scope: Can the "device-group management entity" of the ’678 Patent, which must be "different from a network system operator," be construed to cover a T-Mobile customer (such as an enterprise or family plan administrator) that uses T-Mobile’s own tools to manage its group of devices? The answer may determine whether the fundamental architecture of the accused system aligns with that of the claims.
  • A second key question will be one of evidentiary sufficiency: The complaint makes broad allegations of infringement across four patents, referencing network components from core infrastructure to eSIM management systems, but provides minimal narrative detail, relying instead on unfiled exhibits. This raises the question of whether the factual allegations meet the plausibility standard required to proceed to discovery, or if they will be challenged as insufficient at the pleading stage.