E Beacon LLC v. Ionidea Interactive Pvt Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (DE)
  • Defendant: IonIdea Interactive Pvt. Ltd. (India)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00730, E.D. Tex., 07/21/2025
• Venue Allegations: Venue is alleged to be proper based on the defendant being a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified products infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology concerns methods for automatically determining and transmitting the physical location of a VoIP phone user to an emergency call center, a critical function for mobile or non-traditional phone systems.
• Key Procedural History: The patent-in-suit is a continuation-in-part of an earlier application and is subject to a terminal disclaimer. The complaint does not reference any prior litigation or licensing history involving the patent.

Case Timeline

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

U.S. Patent No. 8,515,386 - “Emergency services for voice over IP telephony (E-VoIP),” issued August 20, 2013

The Invention Explained

• Problem Addressed: The patent addresses the unreliability of emergency services for VoIP telephone systems. Unlike traditional landlines with fixed addresses, a VoIP phone can be used anywhere with an internet connection, making it difficult for a 911 operator to automatically determine the caller's physical location during an emergency (’386 Patent, col. 1:23-28).
• The Patented Solution: The invention proposes a system that automatically determines a VoIP phone's location using multiple available technologies, such as GPS or cellular network triangulation. When a user dials an emergency number, the system attempts to find the current location and transmit it to the emergency call center (PSAP), potentially falling back on previously stored coordinates if a live location cannot be found ('386 Patent, col. 2:45-62; Fig. 1). The system is designed to use a plurality of location detection methods to increase the likelihood of success ('386 Patent, col. 13:52-65).
• Technical Importance: This technology aims to provide VoIP users with a level of emergency location service reliability comparable to that of traditional and cellular phones, a key requirement for market adoption and regulatory compliance (E911).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "exemplary claims" but focuses on a method claim framework (Compl. ¶11). Claim 1 is the principal independent method claim.
• Independent Claim 1:
  • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT");
  • if an attempt is successful, storing the physical location determined using the corresponding LDT;
  • placing a call to the emergency services call center with the VoIP phone; and
  • automatically transmitting the physical location of the VoIP phone to the emergency services call center.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). However, no specific products are named in the body of the complaint, and the referenced charts in "Exhibit 2" were not provided with the filing (Compl. ¶¶ 16-17).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It alleges in general terms that the products "practice the technology claimed by the '386 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges direct and indirect infringement but relies entirely on "the claim charts of Exhibit 2," which are incorporated by reference but not included in the public filing (Compl. ¶¶ 16-17). Therefore, a detailed element-by-element analysis based on the complaint is not possible.

The narrative theory of infringement is that the unspecified "Exemplary Defendant Products" perform a method that satisfies all elements of the asserted claims (Compl. ¶16). The complaint alleges that Defendant infringes by making, using, offering to sell, and/or importing these products, and also by having its employees internally test and use them (Compl. ¶¶ 11-12).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"a separate location detection technology ('LDT')"

• Context and Importance: This term is central to the core inventive concept of using multiple, distinct location methods. The infringement analysis will depend on whether the different location-finding techniques used by an accused product qualify as "separate" LDTs as envisioned by the patent. Practitioners may focus on this term to dispute whether, for example, using two different Wi-Fi triangulation algorithms constitutes using two "separate" technologies, or merely two modes of a single technology.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of technologies, including "geolocation, location based service (LBS), GSM localization, triangulation... GPS, CDMA and GSM technologies... Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies that can provide geolocation information" ('386 Patent, col. 13:56-65). This broad list suggests "LDT" should be construed to cover a wide range of distinct methods.
  • Evidence for a Narrower Interpretation: An argument could be made that the primary examples given, such as GPS versus cellular triangulation, represent fundamentally different physical-layer methods (satellite timing vs. cell tower signal strength). A defendant might argue that two software-based techniques running on the same hardware (e.g., two different IP-address-to-location database lookups) are not "separate" in the way the patent's main embodiments are described.

"plurality of attempts ... each using a separate location detection technology"

• Context and Importance: This phrase requires not just the presence of multiple LDTs but an active process of "making... attempts" with them. The dispute will likely focus on whether an accused system is merely capable of using different LDTs or whether it actually performs the claimed sequence of making distinct attempts with each.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The language does not require the attempts to be sequential. Claim 2, a dependent claim, specifies that the attempts are made "simultaneously," while Claim 3 specifies they are made "successively." Under the doctrine of claim differentiation, this could imply the independent claim is broader and covers any mode of making multiple attempts, whether simultaneous, successive, or otherwise.
  • Evidence for a Narrower Interpretation: Flowcharts in the patent, such as Figure 4, depict a process where the system tries one LDT (e.g., GPS, step 2a), checks for success (step 3a), and if not, may try another (e.g., CDMA, step 2b). This could support a narrower reading that requires a structured, iterative process of attempting, rather than a single, monolithic process that happens to draw on data from multiple sources.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the products in a manner that infringes the ’386 Patent (Compl. ¶14). The specific content of these materials is purportedly detailed in the unprovided Exhibit 2 (Compl. ¶14).

Willful Infringement

The willfulness allegation is based entirely on post-suit knowledge. The complaint asserts that "service of this Complaint, in conjunction with the attached claim charts and references cited, constitutes actual knowledge of infringement" and that any subsequent infringement is therefore willful (Compl. ¶¶ 13-14).

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

1. A threshold evidentiary issue will be product identification: what specific products are accused of infringement? The complaint's reliance on an unprovided exhibit leaves the identity and technical operation of the "Exemplary Defendant Products" entirely undefined.
2. A central claim construction question will be one of technological scope: what constitutes a "separate location detection technology"? The outcome will determine whether the methods used in the accused products, once identified, meet the core claim requirement of using a "plurality" of distinct technologies or merely different modes of a single technology.
3. The key infringement question will be one of operative process: assuming the accused products are identified, does their software architecture perform the claimed method of "making a plurality of attempts" using different LDTs to find a location, or does it employ a different, non-infringing logic to determine location for emergency calls?