WebSock Global Strategies LLC v. Naver Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: NAVER Corporation (South Korea)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00760, E.D. Tex., 08/04/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for enabling symmetrical, bi-directional communication between network nodes over inherently asymmetrical protocols like HTTP.
• Technical Context: The technology addresses limitations in standard web protocols, particularly for peer-to-peer applications where one or more communicating devices may be behind a network firewall or Network Address Translator (NAT).
• Key Procedural History: The patent-in-suit is a continuation of an application filed in 2003, establishing an early priority date for the technology. The complaint itself is a "notice pleading" that refers to but does not include an exhibit containing the specific infringement allegations and claim charts.

Case Timeline

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

U.S. Patent No. 7,756,983 - "Symmetrical bi-directional communication", issued July 13, 2010

The Invention Explained

• Problem Addressed: The patent describes a "fundamental problem" in network communications where protocols like HTTP are inherently asymmetrical: a "client" must initiate a request to a "server," which can only respond ('983 Patent, col. 2:5-12). This model prevents a server from initiating communication, which is a significant barrier for peer-to-peer applications, especially when one node is behind a Network Address Translator (NAT) and has a private, non-routable address ('983 Patent, col. 2:44-50). The patent notes that prior solutions like "polling" are inefficient and waste network bandwidth ('983 Patent, col. 3:4-8).
• The Patented Solution: The invention enables two network nodes to establish a symmetrical communication channel. This is achieved by first creating a standard, client-initiated connection. The nodes then negotiate a "transactional role reversal." Critically, the initial high-level HTTP session is terminated, but the underlying, persistent TCP/IP network connection is maintained ('983 Patent, col. 9:13-21; Fig. 9, element 512). A new, "reversed" HTTP session is then established over this same preserved TCP/IP connection, which allows the original server to act as a client and initiate requests to the original client, which now acts as a server ('983 Patent, col. 9:22-40; Fig. 9, element 514).
• Technical Importance: This approach provided a method for applications to achieve true peer-to-peer functionality using the ubiquitous HTTP protocol, bypassing the structural limitations of both the protocol itself and common network configurations like NAT firewalls ('983 Patent, col. 3:18-24).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, referring only to "Exemplary '983 Patent Claims" (Compl. ¶11). Independent claim 1 is representative of the core invention.
• Independent Claim 1 requires:
  • First and second network nodes engaging in an asymmetric HTTP transactional session over an underlying network connection, with each node having distinct initial roles (client or server).
  • Terminating the asymmetric HTTP session while maintaining the underlying network connection.
  • The first and second nodes negotiating a transactional role reversal.
  • The nodes communicating further under a reversed asymmetric transactional protocol where each node enacts the initial role of the other.
  • The session using a network connection that traverses "hardware enforcing asymmetric communication."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not specifically name any accused products or services. It refers to "Exemplary Defendant Products" that are purportedly identified in charts "incorporated into this Count below" and in "Exhibit 2" (Compl. ¶¶ 11, 13). However, no charts are incorporated into the body of the complaint, and Exhibit 2 was not provided with the pleading.

Functionality and Market Context

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

IV. Analysis of Infringement Allegations

The complaint’s infringement theory is contained in claim charts within an external document, Exhibit 2, which is incorporated by reference but was not attached to the provided complaint (Compl. ¶¶ 13-14). Therefore, a detailed claim chart summary cannot be constructed. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Questions: A central evidentiary question will be whether Plaintiff can demonstrate that the accused products perform the specific sequence of steps recited in the claims. For example, what evidence shows that an accused product specifically "terminat[es] said asymmetric HTTP transactional session while maintaining said underlying network connection" before establishing a new, reversed session? ('983 Patent, col. 15:21-23).
  • Scope Questions: The dispute may turn on the scope of key claim phrases. For instance, what level of interaction constitutes "negotiating transactional role reversal"? Does it require a formal, multi-step handshake as depicted in the patent's flowcharts (e.g., '983 Patent, Fig. 9), or could it be interpreted more broadly to cover any protocol that results in switched roles?

V. Key Claim Terms for Construction

The Term: "negotiating transactional role reversal"

• Context and Importance: This term is the central mechanism of the invention. Its definition will determine what kind of role-switching process infringes. Practitioners may focus on this term because the patent's specific examples show a formal "FLIP REQUEST" and response, which may be narrower than how role-switching is implemented in modern protocols (Compl. ¶13; '983 Patent, col. 9:57-66).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Narrower Interpretation: The detailed flowcharts for the client and server agents show a distinct, multi-step negotiation process, including sending a "FLIP REQUEST" and receiving an "OK" or "REFUSE" response ('983 Patent, Fig. 9, element 504; Fig. 10, element 534). This may support a construction requiring an explicit, programmatic negotiation.
  • Evidence for a Broader Interpretation: The summary of the invention and the claims use the more general term "negotiate" without detailing a specific message exchange, which could support a construction that covers any process by which two nodes agree to reverse roles, regardless of the specific implementation ('983 Patent, col. 3:28-31; col. 15:24-25).

The Term: "terminating said asymmetric HTTP transactional session while maintaining said underlying network connection"

• Context and Importance: This limitation distinguishes the invention from simply opening two separate, independent connections. Proving both the termination of the HTTP layer and the simultaneous preservation of the underlying TCP/IP layer is critical to infringement. The technical evidence required to prove this two-part step will be a key focus.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Narrower Interpretation: The specification explicitly describes a process where the "existing HTTP layer session" is terminated, and a "new HTTP layer session" is created using the "preserved TCP circuit information" ('983 Patent, Fig. 9, elements 512-514). This could require proof of distinct, sequential software operations.
  • Evidence for a Broader Interpretation: The patent also describes the concept more generally as destroying and re-creating "interaction at the HTTP layer" while the underlying "socket created by the first request call ... was never broken" ('983 Patent, col. 12:4-8). This language might allow for a more functional interpretation of what it means to terminate one layer while preserving another.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege facts to support either induced or contributory infringement.
• Willful Infringement: The complaint does not use the word "willful." However, the prayer for relief requests a judgment that the case be declared "exceptional" under 35 U.S.C. § 285 and seeks an award of attorney's fees (Compl. p. 4). It also requests damages under 35 U.S.C. § 284, which allows for enhancement of up to three times the actual damages, typically in cases of egregious infringement (Compl. p. 4). The complaint alleges no facts regarding pre- or post-suit knowledge of the patent by the Defendant.

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

• A core issue will be one of evidentiary proof: Given the complaint's lack of specific factual allegations, a primary question is whether Plaintiff can produce technical evidence (e.g., source code, network packet captures) demonstrating that the accused products perform the precise, multi-step process claimed, particularly the termination of the HTTP layer while preserving the underlying network connection.
• The case will also turn on a question of definitional scope: The construction of the term "negotiating transactional role reversal" will be critical. The court will need to determine whether this requires an explicit, formal "request-and-response" sequence as detailed in the patent’s embodiments, or if it can be construed more broadly to cover any protocol that achieves a functional reversal of client-server roles over a persistent connection.