Webcon Vectors LLC v. Livestorm SAS

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Webcon Vectors LLC (Delaware)
  • Defendant: Livestorm SAS (France)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00747, E.D. Tex., 07/28/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, has committed acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s teleconferencing products and services infringe a patent related to methods for simplifying and managing conference calls.
• Technical Context: The technology concerns systems for initiating and managing multi-party communications, a field central to modern remote work and collaboration platforms.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 11,290,428 - "Telecommunication method and system for simplifying communication such as conference calls"

• Patent Identification: U.S. Patent No. 11,290,428, "Telecommunication method and system for simplifying communication such as conference calls", issued March 29, 2022 (the "’428 Patent").

The Invention Explained

• Problem Addressed: The patent’s background section describes conventional teleconferencing as burdensome, citing the need for participants to coordinate schedules, sift through old emails to find dial-in numbers and access codes, and contend with the technical challenges of joining a call, which can waste valuable meeting time (’428 Patent, col. 1:13-58).
• The Patented Solution: The invention proposes a system that automates and simplifies conference calls by having the system, rather than the users, initiate the connections. A host selects participants, and at the scheduled time, a "stateful application" automatically effects a "bridge set up" and "initiates a call to all users in a simultaneous manner" using their unique electronic identifiers (e.g., phone number, SIP client, Skype handle) (’428 Patent, col. 7:29-34). This approach aims to eliminate the need for users to manually dial-in or enter authorization codes, with the system managing the process (’428 Patent, Abstract; Fig. 1).
• Technical Importance: The described approach seeks to shift the burden of connection from the end-user to a centralized, automated system, thereby improving efficiency and reducing the logistical friction common in multi-party calls (’428 Patent, col. 7:25-44).

Key Claims at a Glance

• The complaint asserts one or more claims of the ’428 Patent, including what it terms the "Exemplary ’428 Patent Claims" (Compl. ¶11). While not specified, Claim 1 is the primary independent claim.
• The essential elements of independent Claim 1 include:
  • selecting a plurality of users for simultaneous contact at a predetermined time from a provided or determined electronic identifier of each selected user;
  • collating a respective identifier of all selected users;
  • forming a conferencing bridge where the identifier of each selected user is on said bridge at the predetermined time;
  • simultaneously contacting bridged identifiers of all selected users at said predetermined time absent any action by any selected user;
  • enabling communication between all selected users simultaneously contacted as a group; and
  • precluding contacted nonresponsive selected users from communication with said group unless subsequently authorized.
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the specific features or functionality of the accused products. It alleges that the accused products are teleconferencing systems that practice the technology claimed in the ’428 Patent (Compl. ¶16). The allegations are detailed in "claim charts of Exhibit 2," which was not provided with the complaint (Compl. ¶17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" directly infringe the ’428 Patent by satisfying all elements of the asserted claims (Compl. ¶16). It incorporates by reference claim charts from an external "Exhibit 2," which is not part of the filed complaint document (Compl. ¶17). Without this exhibit, a detailed element-by-element analysis based on the complaint's allegations is not possible. The narrative infringement theory is that Defendant's products, by their nature as teleconferencing systems, practice the patented method (Compl. ¶11, ¶16).

Identified Points of Contention

Based on the patent’s claims and the general nature of the dispute, several technical and legal questions may arise.

• Technical Question: A central factual question will likely be whether the accused products perform a "simultaneous contacting" of all users that is "absent any action by any selected user," as required by Claim 1. The analysis may turn on whether the system actively initiates an outbound connection to each user (as the patent appears to describe) or whether users must take an action, such as clicking a "join" link, to initiate their own connection to the conference bridge.
• Scope Question: A dispute may emerge over the meaning of "precluding contacted nonresponsive selected users." The court may need to determine what specific technical actions (or inactions) by the accused system constitute "preclusion" and whether the system’s handling of users who fail to join a meeting meets this limitation.

V. Key Claim Terms for Construction

The Term: "electronic identifier"

• Context and Importance: This term defines the universe of contact methods covered by the patent. The patent provides a broad, non-exhaustive list, including website addresses, email, phone numbers, and social media handles (’428 Patent, col. 12:57-65). The construction of this term will be critical to determining the scope of infringement, as it dictates which communication platforms fall within the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification explicitly lists a wide variety of identifier types, including "Twitter address, a Facebook address, a Skype address, LinkedIn address, website address, email address, land based phone number, cellular phone number, text message," and others, suggesting the term is meant to be capacious and technology-agnostic (’428 Patent, col. 12:57-65).
  • Evidence for a Narrower Interpretation: A party might argue that the term should be limited by the functional context of the claim, which requires the system to be able to "contact" the identifier. This could suggest the term covers only identifiers that can receive an active, system-initiated connection (like a phone number or SIP client) rather than passive ones (like a web address that a user must click).

The Term: "simultaneously contacting bridged identifiers of all selected users... absent any action by any selected user"

• Context and Importance: This limitation is the core functional step of the invention and a likely focal point of dispute. Practitioners may focus on this term because it distinguishes the claimed "push" method (system calls users) from the conventional "pull" method (users call system).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue "absent any action" merely means absent the action of dialing in and entering a code, and that a single click to join could still fall within the scope.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the system itself initiating the call, stating it "initiates a call to all users in a simultaneous manner" (’428 Patent, col. 7:32-34). This language may support a narrower construction requiring the system to perform an active, outbound connection to each user without any user input at the time of the meeting.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that since the filing of the lawsuit, Defendant has knowingly induced its customers to infringe by distributing "product literature and website materials" that instruct them on how to use the accused products in an infringing manner (Compl. ¶14-15).

Willful Infringement

The complaint alleges willfulness based on post-suit conduct. It asserts that the service of the complaint provided Defendant with "actual knowledge" of the ’428 Patent and its infringement, and that Defendant’s continued infringing activities thereafter are willful (Compl. ¶13-14).

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

1. A core issue will be one of functional operation: Does the accused teleconferencing platform "simultaneously contact" users "absent any action" on their part, as the patent claims? The case may turn on the factual distinction between a system that actively calls out to participants and one that requires participants to actively click a link to join.
2. A second key issue will be one of definitional scope: How broadly will the court construe "precluding contacted nonresponsive selected users"? The viability of the infringement claim will depend on whether the accused system's method for handling users who do not join a call performs the specific function required by this claim limitation.
3. A significant evidentiary question is presented by the complaint's reliance on an un-filed external exhibit for its specific infringement contentions. A primary challenge for the plaintiff will be to substantiate its generalized allegations with specific evidence mapping the accused product's functionality to each asserted claim element.