DCT
2:25-cv-00898
Golden Eye Tech LLC v. Cisco Systems Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Golden Eye Technologies LLC (Texas)
- Defendant: Cisco Systems, Inc. (Delaware)
- Plaintiff’s Counsel: Bragalone Olejko Saad PC
- Case Identification: 2:25-cv-00898, E.D. Tex., 08/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Cisco has committed acts of infringement in the district and maintains a regular and established place of business in Richardson, Texas, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s wireless networking products, including access points and wireless controllers, infringe five patents related to optimizing wireless network coverage, capacity, and client scanning procedures.
- Technical Context: The technology concerns the management of wireless local area networks (WLANs), specifically methods for mitigating signal interference between access points and efficiently directing client devices during network discovery.
- Key Procedural History: The complaint alleges that Defendant was notified of its infringement of the asserted patent portfolio through correspondence beginning on March 2, 2022, with detailed claim charts for the various patents provided between March 2022 and June 2023.
Case Timeline
| Date | Event |
|---|---|
| 2009-05-18 | Cisco 5500 Series Wireless Controllers Release Date |
| 2011-06-03 | ’243 Patent Priority Date |
| 2011-11-30 | ’978 and ’236 Patents Priority Date |
| 2012-06-28 | ’037 and ’556 Patents Priority Date |
| 2012-08-28 | Cisco 8500 Series Wireless Controllers Release Date |
| 2012-08-30 | Cisco Virtual Wireless Controller Release Date |
| 2016-02-23 | ’243 Patent Issue Date |
| 2016-05-17 | ’978 Patent Issue Date |
| 2017-03-28 | Cisco 3504 Wireless Controller Release Date |
| 2017-07-25 | ’037 Patent Issue Date |
| 2018-03-13 | ’236 Patent Issue Date |
| 2018-08-14 | ’556 Patent Issue Date |
| 2018-11-13 | Cisco Catalyst 9800 Series Wireless Controllers Release Date |
| 2019-03-19 | Cisco 9100 Family of Access Points Release Date |
| 2022-03-02 | Plaintiff alleges first notice of infringement of portfolio to Defendant |
| 2022-03-21 | Plaintiff alleges providing claim charts for ’243 and ’236 patents to Defendant |
| 2023-06-23 | Plaintiff alleges providing claim charts for ’037 and ’556 patents to Defendant |
| 2025-08-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,271,243 - Wireless access point and method and device for controlling wireless access point
The Invention Explained
- Problem Addressed: In wireless networks with multiple access points (APs), using separate APs to cover signal "shadow areas" can cause interference if two APs use the same channel, degrading network performance (’243 Patent, col. 1:32-42).
- The Patented Solution: The invention describes a central control device that manages co-channel APs to minimize interference. The device groups APs using the same channel, computes a "virtual map" of the received signal strength indicator (RSSI) between them, and if interference is detected, it identifies the AP with the highest RSSI. It then calculates a "corrected output strength value" for the other APs to adjust their power, thereby reducing interference (’243 Patent, Abstract; Fig. 3).
- Technical Importance: This approach provides a centralized, automated method for dynamic power control in dense Wi-Fi deployments, aiming to optimize performance without manual cell planning (’243 Patent, col. 4:1-4).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (’243 Patent, col. 9:41-62; Compl. ¶51).
- Claim 1 of the ’243 Patent is a device claim with the following key elements:
- a grouping unit configured to group wireless access points using a same channel based on channel use information;
- a map generator configured to compute a received signal strength indicator (RSSI) between the grouped wireless access points and an output strength value for each;
- an extractor configured to extract a wireless access point having a highest RSSI value among the grouped wireless access points, if interference occurs; and
- an optimal output strength value calculator configured to compute a corrected output strength value based on the highest RSSI value, a predetermined threshold, and a currently used output strength value.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,344,978 - Access Point Having Multichannel and Multi Transmission Power, Cell Formation Method
The Invention Explained
- Problem Addressed: A single AP serves users at varying distances, resulting in different data rates. Low-speed users at the cell edge can occupy the wireless channel for longer periods, reducing overall network efficiency for high-speed users located closer to the AP (’978 Patent, col. 5:48-67).
- The Patented Solution: The invention describes an access point that forms two distinct service zones within a single cell. A "first access point processor" uses lower transmission power to create a service zone for high-speed users at the cell's center, while a "second access point processor" uses higher power for low-speed users at the cell's edge. The AP selectively responds to client "probe requests" based on the request's signal strength, guiding devices to the appropriate service zone (’978 Patent, Abstract; col. 2:45-67).
- Technical Importance: This method of cell-splitting within a single AP allows for more efficient management of clients with different performance characteristics, aiming to prevent slow clients from degrading the experience for fast clients (’978 Patent, col. 6:1-8).
Key Claims at a Glance
- The complaint asserts at least independent claim 7 (’978 Patent, col. 16:14-38; Compl. ¶66).
- Claim 7 of the ’978 Patent is an access point claim with the following key elements:
- a first access point processor configured to provide connection to a first user equipment located approximate to a center area of an associated cell;
- a second access point processor configured to provide connection to a second user equipment located approximate to an edge area of the associated cell;
- a first probe response control unit configured to control the first access point processor to transmit a first probe response signal... only when an associated first probe request signal... has signal strength higher than a probe response threshold; and
- a second probe response control unit configured to control the second access point processor to transmit a second probe response signal... only when an associated second probe request signal... has signal strength lower than the probe response threshold.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,918,236 - Access Point Having Multichannel and Multi Transmission Power, Cell Formation Method
- Technology Synopsis: Similar to the ’978 Patent, this patent describes an access point that forms multiple service zones within a cell. It uses different transmission powers for management frames directed to users in a center "micro" zone versus an edge "macro" zone and selectively responds to probe requests based on signal strength to steer clients appropriately (Compl. ¶16).
- Asserted Claims: At least independent claim 1 (Compl. ¶81).
- Accused Features: The complaint alleges that Cisco's "Flexible Radio Architecture" (FRA) system, which creates distinct "Macro" and "Micro" cells with different power levels, infringes this patent (Compl. ¶¶ 32, 81).
U.S. Patent No. 9,717,037 - Method for Scanning For Access Point in Wireless LAN System
- Technology Synopsis: This patent describes a method for active scanning where an access point receives a probe request frame from a station that includes signal strength information. The AP acquires information about the "uplink quality" based on this signal strength and transmits a probe response only if the quality satisfies a predetermined standard, allowing the station to gain access based on the response and a maximum probe response time (Compl. ¶17).
- Asserted Claims: At least independent claim 13 (Compl. ¶96).
- Accused Features: The complaint accuses Cisco's access points that implement "enhanced FILS active scanning" procedures as part of the 802.11ax protocol (Compl. ¶¶ 37-38, 96).
U.S. Patent No. 10,051,556 - Method for Scanning For Access Point in Wireless LAN System
- Technology Synopsis: This patent is directed to a similar active scanning method as the ’037 patent. An access point receives a probe request from a station containing signal strength information and transmits a probe response based on that information. A station's access to the AP is then based on receiving this probe response within a maximum probe response time (Compl. ¶18).
- Asserted Claims: At least independent claim 9 (Compl. ¶111).
- Accused Features: The complaint again accuses Cisco's access points that use "enhanced FILS active scanning" procedures (Compl. ¶¶ 37-38, 111).
III. The Accused Instrumentality
Product Identification
- The complaint identifies two categories of accused products: "Accused Wireless Controllers" (e.g., Cisco 3504, 5520, 8540, 9800, and Virtual Wireless Controllers) and "Accused Access Points" (e.g., Cisco Catalyst 9100 series, Meraki-branded, Aironet series, and Cisco Business 150AX) (Compl. ¶¶ 20-22).
Functionality and Market Context
- The Accused Wireless Controllers are alleged to be enterprise-grade platforms that provide Radio Resource Management (RRM) and Transmit Power Control (TPC) features to "automatically adjust to real-time changes in the... RF environment" (Compl. ¶¶ 15, 24). A key accused feature is the "TPCv1 Channel Aware" mode, which allegedly groups co-channel APs into "RF Neighborhoods" and adjusts their power to minimize interference (Compl. ¶¶ 26-27). A visual provided in the complaint shows an example of neighbor lists and power settings used in the TPC algorithm (Compl. ¶29, Fig. 25).
- The Accused Access Points are alleged to implement a "Flexible Radio Architecture" (FRA) system, which uses a special "XOR radio" that can be configured to create two distinct 5-GHz cells from a single AP: a lower-power "Micro" cell for nearby clients and a higher-power "Macro" cell for distant clients (Compl. ¶¶ 32, 34, 36). A diagram from Cisco documentation illustrates this creation of Micro and Macro cells (Compl. ¶34, Fig. 29). The system allegedly uses "probe suppression" to selectively respond to client devices based on their RSSI relative to a threshold, steering them to the appropriate cell (Compl. ¶35). The complaint also alleges the APs use an "enhanced FILS active scanning" procedure as part of the 802.11ax standard (Compl. ¶37).
IV. Analysis of Infringement Allegations
’243 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a grouping unit configured to group wireless access points using a same channel based on channel use information received from the wireless access points | The "channel aware" feature groups APs into "RF Neighborhoods" based on information collected by the "RF Group Leader" determining which APs can "hear one another" on the same channel. | ¶¶26-27 | col. 7:5-10 |
| a map generator configured to compute a received signal strength indicator (RSSI) between the grouped wireless access points and an output strength value for each of the grouped wireless access points | The TPC feature uses the Neighbor Discovery Protocol (NDP) to generate "RSSI organized lists" which "form a picture of how every AP is heard by every other AP within the RF Neighborhood and RF Group." | ¶¶28-29 | col. 7:11-15 |
| an extractor configured to extract a wireless access point having a highest RSSI value among the grouped wireless access points, if interference occurs between the grouped wireless access points | The "channel aware" feature "keeps track of [the] loudest radio on the same channel" in order to "reduce interference." | ¶30 | col. 7:27-31 |
| an optimal output strength value calculator configured to compute a corrected output strength value based on the highest RSSI value of the extracted wireless access point, a predetermined threshold value of the RSSI between the grouped wireless access points, and a currently used output strength value | The TPCv1 algorithm "calculates Tx_ideal power" for a target AP based on the highest RSSI value from a neighboring AP, a "TPCv1_Threshold," and the current transmit power. | ¶31 | col. 7:49-54 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Cisco's distributed RRM architecture, where an "RF Group Leader" controller performs calculations based on data from member APs, constitutes the singular "device for controlling a wireless access point" recited in the claim. The analysis may explore whether the claim requires all functional units to reside on a single, integrated device.
- Technical Questions: The analysis may focus on whether the "RSSI organized lists" generated by the accused TPC feature meet the "map generator" limitation, which the patent describes as generating a "virtual map" (’243 Patent, col. 7:13-15).
’978 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first access point processor configured to provide connection to a first user equipment located approximate to a center area of an associated cell | The Flexible Radio Architecture (FRA) system creates a "Micro" cell using a lower power setting, which serves as the first service zone for clients in the center area with high RSSI. | ¶¶34, 36 | col. 2:1-5 |
| a second access point processor configured to provide connection to a second user equipment located approximate to an edge area of the associated cell | The FRA system creates a "Macro" cell using a higher power setting, which serves as the second service zone for clients in the edge area with low RSSI. | ¶¶34, 36 | col. 2:5-8 |
| a first probe response control unit configured to control the first access point processor to transmit a first probe response signal... only when an associated first probe request signal... has signal strength higher than a probe response threshold | The FRA system's "probe suppression" feature selectively responds from the "Micro" cell radio to probing clients that have an RSSI at the AP above a threshold (e.g., -55dBm). A diagram illustrates this selective response (Compl. ¶35). | ¶¶35-36 | col. 2:60-64 |
| a second probe response control unit configured to control the second access point processor to transmit a second probe response signal... only when an associated second probe request signal... has signal strength lower than the probe response threshold | The FRA system's "probe suppression" feature controls the "Macro" cell radio to respond to probing clients that have an RSSI below the threshold. | ¶35 | col. 2:64-67 |
- Identified Points of Contention:
- Scope Questions: A primary question will be whether a single AP with a flexible "XOR radio" that creates two logical cells ("Micro" and "Macro") contains "a first access point processor" and "a second access point processor" as required by the claim. The dispute may turn on whether "processor" requires distinct hardware/software structures or can read on different operational modes of a single component.
- Technical Questions: The analysis may examine whether Cisco's "probe suppression" functionality, designed for intra-cell roaming, performs the specific control functions recited for both the first and second probe response control units as claimed.
V. Key Claim Terms for Construction
Term: "a device for controlling a wireless access point" (from ’243 Patent, Claim 1)
- Context and Importance: This term appears in the preamble and is critical because the infringement theory maps this singular "device" to Cisco's distributed RRM architecture, where one controller acts as an "RF Group Leader" for many APs. The definition will determine whether a distributed system can meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the "AP Control Device (200)" as a separate entity that communicates with multiple APs (100), which may support an interpretation that it can be a logically centralized but physically separate controller (’243 Patent, Fig. 1).
- Evidence for a Narrower Interpretation: The block diagram for the device itself depicts all the claimed functional units (grouping, map generating, etc.) within a single box labeled "200," which may suggest the claim requires a single, self-contained apparatus (’243 Patent, Fig. 3).
Term: "a first access point processor... and a second access point processor" (from ’978 Patent, Claim 7)
- Context and Importance: The infringement allegation is that a single AP with a flexible radio that creates two logical cells embodies these two "processors." The construction of "processor" will be central to determining if one physical component operating in two modes can satisfy a claim reciting two distinct processors.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent refers to these as a "first access point module" and a "second access point module," which could be interpreted as logical or software modules that can run on a single physical processor (’978 Patent, col. 2:1-8).
- Evidence for a Narrower Interpretation: The patent's block diagram shows two physically separate blocks, "AP_H (330)" and "AP_L (350)," each with its own transmitter, receiver, and power control unit. This may support an argument that the claim requires two functionally distinct processing paths or hardware components (’978 Patent, Fig. 3).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all five patents. The allegations are based on Defendant providing customers with product documentation, configuration guides, technical support, and marketing materials that allegedly instruct users on how to configure and use the accused features (e.g., TPC, FRA, FILS scanning) in an infringing manner (Compl. ¶¶ 55, 70, 85, 100, 115).
- Willful Infringement: The complaint alleges willful infringement for all five patents, asserting that Defendant had pre-suit knowledge based on a series of communications. Plaintiff alleges it first notified Defendant of the patent portfolio on March 2, 2022, and subsequently provided detailed infringement claim charts for the asserted patents between March 2022 and June 2023 (Compl. ¶¶ 53, 57, 68, 83, 98, 113).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of architectural mapping: can Plaintiff demonstrate that Cisco's distributed Radio Resource Management system, coordinated by an "RF Group Leader," meets the limitations of the singular "device for controlling a wireless access point" as claimed in the ’243 patent, or is there a fundamental mismatch between the claimed centralized device and the accused distributed system?
- A second core issue will be one of structural scope: does a single access point utilizing a "Flexible Radio Architecture" to create two logical service zones ("Micro" and "Macro" cells) contain the "first access point processor" and "second access point processor" required by the claims of the ’978 and ’236 patents, or do the claims require physically or functionally distinct hardware components?
- A key evidentiary question for the ’037 and ’556 patents will be one of functional operation: what evidence will show that Cisco's "enhanced FILS active scanning" procedure performs the specific claimed steps of using signal strength information from a client's probe request to assess "uplink quality" and subsequently decide whether to transmit a probe response?