DCT

2:25-cv-00822

Patent Armory Inc v. Royal Caribbean Cruises Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-822, E.D. Tex., 08/20/2025
  • Venue Allegations: Plaintiff alleges that venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unidentified products and services infringe patents related to intelligent call routing and auction-based systems for matching entities.
  • Technical Context: The patents address technologies for optimizing resource allocation in communications systems, such as call centers, by using skill-based or economic criteria to match incoming requests with available agents.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2002-03-07 ’979 Patent - Earliest Priority Date
2003-03-07 ’086 Patent - Earliest Priority Date
2006-04-04 ’979 Patent - Issue Date
2016-09-27 ’086 Patent - Issue Date
2025-08-20 Complaint Filing Date

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

U.S. Patent No. 7,023,979 - "Telephony control system with intelligent call routing"

(Issued Apr. 4, 2006)

The Invention Explained

  • Problem Addressed: The patent’s background section describes inefficiencies in traditional call centers that use simple, static rules for routing calls, such as first-come-first-served. These systems can lead to mismatches where calls are routed to under-skilled or over-skilled agents, or where static agent groupings fail to adapt to changing call volumes and types, reducing overall efficiency (’979 Patent, col. 4:25-67).
  • The Patented Solution: The invention proposes a communications management system where the intelligent routing logic is integrated at a low level within the telephony switching architecture itself, rather than being externalized to a separate high-level system. A processor within the system computes an "optimum agent selection" and directly controls the routing of the call, allowing for more dynamic and efficient matching of callers to agents based on various criteria (’979 Patent, Abstract; col. 59:8-22). Figure 1 illustrates a process flow for this intelligent routing, including branches for skill-based routing and long-term optimization (’979 Patent, Fig. 1).
  • Technical Importance: This approach sought to reduce latency and improve resource allocation in call centers by moving complex, data-driven routing decisions closer to the core switching hardware, enabling real-time optimization (’979 Patent, col. 60:29-39).

Key Claims at a Glance

  • The complaint does not identify the specific claims asserted, instead referring to "Exemplary '979 Patent Claims" detailed in an exhibit not attached to the publicly filed document (Compl. ¶¶12, 14). Therefore, an analysis of key claims is not possible based on the provided documents.

U.S. Patent No. 9,456,086 - "Method and system for matching entities in an auction"

(Issued Sep. 27, 2016)

The Invention Explained

  • Problem Addressed: The patent addresses the general problem of efficiently matching entities, contextualized by the same call center inefficiencies described in the ’979 Patent, such as mismatches between caller needs and agent skills (’086 Patent, col. 3:32-4:67). It also frames the matching problem in the context of auctions, noting the inefficiencies of traditional proxy bidding in online auctions (’086 Patent, col. 38:5-22).
  • The Patented Solution: The invention describes a method for matching a "first entity" (e.g., a caller) with a "second entity" (e.g., an agent) from a plurality of available options. The system defines both entities using "multivalued scalar data" (representing skills or needs) and performs an automated optimization based on the "economic surplus" of a potential match and the "opportunity cost" of making that second entity unavailable for other potential matches (’086 Patent, Abstract). This generalizes skill-based routing into a more formal economic and auction-based framework for resource allocation (’086 Patent, col. 61:53-62:55).
  • Technical Importance: This technology provides a formal, economically-driven model for optimizing resource allocation, extending the concepts of skill-based routing to a broader auction framework applicable to various matching problems (’086 Patent, col. 73:52-74:3).

Key Claims at a Glance

  • The complaint does not identify the specific claims asserted, instead referring to "Exemplary '086 Patent Claims" detailed in an exhibit not attached to the publicly filed document (Compl. ¶¶18, 23). Therefore, an analysis of key claims is not possible based on the provided documents.

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify the accused instrumentality by name. It refers generally to "Exemplary Defendant Products" that are detailed in exhibits incorporated by reference but not attached to the publicly filed complaint (Compl. ¶¶12, 14, 18, 23).

Functionality and Market Context

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

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of the ’979 Patent and direct and induced infringement of the ’086 Patent (Compl. ¶¶12, 18, 22). It states that detailed infringement comparisons are provided in claim charts attached as Exhibits 3 and 4 (Compl. ¶¶14, 23). As these exhibits were not included with the publicly filed complaint, a detailed claim chart summary cannot be constructed.

The narrative infringement theory for both patents is that Defendant has infringed by "making, using, offering to sell, selling and/or importing" the accused products and by having its employees "internally test and use" them (Compl. ¶¶12, 13, 18, 19). For the ’086 patent, the complaint further alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶21).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: The complaint does not provide sufficient detail for analysis of specific points of contention regarding infringement.

V. Key Claim Terms for Construction

As the complaint does not identify any specific asserted claims, no key terms for construction can be identified for analysis.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of the ’086 Patent. This allegation is based on Defendant's distribution of "product literature and website materials" that allegedly direct end users to use the accused products in a manner that infringes the patent (Compl. ¶21). The complaint also alleges inducement occurring since Defendant was served with the complaint and its corresponding claim charts (Compl. ¶22).
  • Willful Infringement: While not pleaded as a separate count, the complaint alleges facts that may support a claim for post-suit willful infringement of the ’086 Patent. It asserts that service of the complaint and its exhibits provided Defendant with "actual knowledge of infringement" and that Defendant has continued its allegedly infringing activities despite this knowledge (Compl. ¶¶20-21). The prayer for relief also requests a finding that the case is "exceptional," a standard often associated with findings of willful infringement (Compl. Prayer ¶H.i).

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

Given the limited information provided in the public complaint, the case will initially turn on procedural and foundational questions before substantive technical disputes can be addressed.

  • Evidentiary Specificity: A primary issue for early stages of litigation will be establishing the specific factual basis for the infringement claims. The case cannot proceed substantively until Plaintiff identifies which of Defendant's specific products are accused and how their functionalities map to the elements of specific, asserted patent claims—details currently confined to exhibits not publicly available.
  • Definitional Scope: A central substantive question will likely be one of definitional scope: can the patents' terminology, rooted in the context of call centers and auctions, be construed to cover the functionalities of Defendant's modern customer service and logistics systems? For example, does the ’086 Patent’s claim to an "auction" for matching entities read on a system that automatically assigns customer inquiries or allocates resources without a formal bidding process?