DCT

2:25-cv-00945

Integral Wireless Tech LLC v. Teltonika IoT Group

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00945, E.D. Tex., 09/10/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that does not reside in any U.S. judicial district, making venue appropriate in any district.
  • Core Dispute: Plaintiff alleges that Defendant’s diverse portfolio of networking devices, IoT products, and website functionalities infringes eight patents related to wireless communications, search result generation, video coding, power management, and user behavior analysis.
  • Technical Context: The asserted patents cover a wide range of technologies fundamental to modern digital communications and internet services, including Wi-Fi, 5G, Bluetooth, video compression, and web-based search and advertising.
  • Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
2002-10-04 U.S. Patent No. 7,269,127 Priority Date
2003-06-17 U.S. Patent No. 7,483,878 Priority Date
2005-07-21 U.S. Patent No. 7,676,007 Priority Date
2007-02-21 U.S. Patent No. 7,707,214 Priority Date
2007-09-11 U.S. Patent No. 7,269,127 Issues
2008-07-07 U.S. Patent No. 8,156,360 Priority Date
2008-12-09 U.S. Patent No. 8,976,714 Priority Date
2009-01-27 U.S. Patent No. 7,483,878 Issues
2010-03-09 U.S. Patent No. 7,676,007 Issues
2010-04-27 U.S. Patent No. 7,707,214 Issues
2012-04-10 U.S. Patent No. 8,156,360 Issues
2014-07-30 U.S. Patent No. 9,207,748 Priority Date
2015-03-10 U.S. Patent No. 8,976,714 Issues
2015-12-08 U.S. Patent No. 9,207,748 Issues
2016-09-28 U.S. Patent No. 10,033,716 Priority Date
2018-07-24 U.S. Patent No. 10,033,716 Issues
2025-09-10 Complaint Filing Date

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

U.S. Patent No. 7,269,127 - "Preamble Structures for Single-Input, Single-Output (SISO) and Multi-Input, Multi-Output (MIMO) Communication Systems"

The Invention Explained

  • Problem Addressed: The patent describes that prior art preamble structures for wireless communication, such as those in the IEEE 802.11a standard, had considerable redundancy which reduced system throughput and efficiency, and were not directly applicable to more complex MIMO systems without significant modification (’127 Patent, col. 3:9-15).
  • The Patented Solution: The invention proposes a more efficient preamble structure for data frames transmitted in wireless systems (’127 Patent, Abstract). It uses at least one "training symbol" and an "enhanced training symbol," where the training blocks have a time length that is an integer fraction of the data block's length, and the cyclic prefix is a fraction of the training block's length (’127 Patent, col. 4:26-37). This structure is designed to provide robust time and frequency synchronization and channel estimation while minimizing overhead (’127 Patent, col. 3:16-25).
  • Technical Importance: This approach sought to improve the efficiency of wireless data transmission by reducing the overhead associated with preamble signals, which is critical for increasing data rates in standards-based communication systems like Wi-Fi (’127 Patent, col. 3:9-15).

Key Claims at a Glance

  • The complaint asserts independent claim 20 (Compl. ¶22).
  • Claim 20 is a method claim for forming a frame structure, comprising the essential elements of:
    • providing data blocks and training blocks;
    • combining them in a parallel format;
    • taking an inverse discrete fourier transform (IDFT) of the combination;
    • inserting cyclic prefixes to form parallel symbols;
    • converting the parallel symbols to a serial format to form a preamble structure and a data structure;
    • wherein the preamble structure comprises at least one training symbol and an enhanced training symbol;
    • wherein the data symbols and the enhanced training symbol each comprise a cyclic prefix and a data/training block with specific, mathematically related sample lengths (G, N, N₁).
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,483,878 - "Generation and Presentation of Search Results Using Addressing Information"

The Invention Explained

  • Problem Addressed: The patent addresses the problem that advertisements and messages delivered to internet users are often irrelevant because they are provided by servers with "no intelligence as to the interests of the end-user," leading to inefficiency and user frustration (’878 Patent, col. 1:29-38).
  • The Patented Solution: The invention describes a method where a client program monitors a user's web browsing activity by receiving "addressing information" (e.g., a URL) identifying a location the user navigates to (’878 Patent, col. 2:40-43; Fig. 1). This addressing information is then processed to generate a keyword, which is used to perform a search. The results are then presented to the user, for example, in a pop-under window, thereby providing more relevant content based on the user's immediate browsing context (’878 Patent, Abstract; col. 3:32-41).
  • Technical Importance: This method provided a way to deliver more targeted content or advertisements by linking them directly to a user's specific, real-time browsing location, rather than relying on broader, less timely user profiles (’878 Patent, col. 2:44-48).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶32).
  • Claim 1 is a method claim for providing search results, comprising the essential elements of:
    • receiving addressing information identifying a location in a computer network;
    • processing the addressing information to generate a keyword;
    • performing a search on the keyword to generate a search result; and
    • presenting an end-user the search result responsive to the keyword that is based on the addressing information in response to the end-user navigating to the location using a client computer.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,676,007 - "System and Method for Interpolation Based Transmit Beamforming for MIMO-OFDM with Partial Feedback"

  • Technology Synopsis: This patent addresses the problem of excessive feedback required for optimal beamforming in MIMO-OFDM systems. The solution involves a receiver sending back beamforming vectors for only a subset of subcarriers, and the transmitter then interpolates to derive the vectors for the remaining subcarriers, reducing feedback overhead while maintaining performance (’007 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (independent apparatus claim) (Compl. ¶59).
  • Accused Features: Teltonika 802.11ac Wi-Fi compatible devices (Compl. ¶53).

U.S. Patent No. 7,707,214 - "Hierarchical Update Scheme for Extremum Location with Indirect Addressing"

  • Technology Synopsis: The patent addresses the inefficiency of repeatedly searching large datasets to find an extremum (maximum or minimum) value when data values change. The solution is a hierarchical data structure where data is partitioned, and indices of extrema in lower-level partitions are stored in higher levels, allowing for efficient updates by limiting recalculations to affected partitions (’214 Patent, Abstract). This is alleged to be relevant to video encoding.
  • Asserted Claims: At least Claim 15 (independent method claim) (Compl. ¶86).
  • Accused Features: Teltonika HEVC (High Efficiency Video Coding) compatible devices, such as the Teltonika DashCam and DualCam (Compl. ¶80).

U.S. Patent No. 8,156,360 - "Systems and Methods for Waking Wireless LAN Devices"

  • Technology Synopsis: The patent addresses the challenge of waking a wireless device from a low-power "sleep mode" over a network. The solution involves a network card that, while the main device sleeps, monitors wireless channels for a specific "wake-up packet" containing the device's hardware address. Upon receiving and matching the packet, it signals the main computing device to restore full power (’360 Patent, Abstract).
  • Asserted Claims: At least Claim 8 (independent apparatus claim) (Compl. ¶112).
  • Accused Features: Teltonika Bluetooth Low Energy (BLE) 5.0+ and Bluetooth Basic Rate/Enhanced Data Rate (BT BR-EDR) version 4.1+ compatible devices (Compl. ¶106).

U.S. Patent No. 8,976,714 - "Providing and Acquiring A System Information Message In A Wireless Network"

  • Technology Synopsis: This patent describes a method for a user equipment (UE) in a wireless network (such as LTE) to efficiently receive system information (SI) messages. The invention specifies how a UE calculates the specific downlink subframe and radio frame where an SI message will start, based on information (like "si-Windowlength") received in a prior message, allowing the device to listen for the SI message at the correct time (’714 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (independent apparatus claim) (Compl. ¶138).
  • Accused Features: Teltonika 5G compatible devices (Compl. ¶132).

U.S. Patent No. 9,207,748 - "Systems and methods for a wireless device wake-up process including power-save and non-power-save modes"

  • Technology Synopsis: This patent, related to the ’360 patent, describes a wake-up process for a wireless device. A controller triggers a wake-up detection mode for a set time period; if a valid wake-up packet is received within that time, it transitions the device from a power-save mode to a non-power-save mode. If the packet is not received, the device exits the detection mode to conserve power (’748 Patent, col. 10:46-65).
  • Asserted Claims: At least Claim 8 (independent computer claim) (Compl. ¶164).
  • Accused Features: Teltonika Bluetooth Low Energy (BLE) 5.0+ and BT BR-EDR 4.1+ compatible devices (Compl. ¶158).

U.S. Patent No. 10,033,716 - "Method and Device for Publishing Cross-Network User Behavioral Data"

  • Technology Synopsis: The patent describes a method for targeted advertising where user behavior is summarized on the client computer across different websites. This summarized behavioral data is published to a memory structure (e.g., a cookie) that becomes accessible to a server of an authorized domain, which can then decode it and deliver customized content or advertising responsive to the user's cross-network behavior (’716 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (independent method claim) (Compl. ¶173).
  • Accused Features: Teltonika's website functionality related to cookies, personalization, and customization (Compl. ¶167).

III. The Accused Instrumentality

Product Identification

The complaint identifies six categories of accused products and services: (1) Teltonika 802.11n Wi-Fi compatible devices; (2) Teltonika website search functionality; (3) Teltonika 802.11ac Wi-Fi compatible devices; (4) Teltonika HEVC compatible devices; (5) Teltonika Bluetooth compatible devices; (6) Teltonika 5G compatible devices; and (7) Teltonika website cookie and personalization functionality (Compl. ¶¶12, 16, 26, 53, 80, 106, 132, 158, 167). The complaint provides non-limiting lists of specific product model numbers for each hardware category (Compl. ¶12).

Functionality and Market Context

The complaint alleges that the accused instrumentalities are devices and services that implement standardized technologies (e.g., 802.11n, 802.11ac, 5G, HEVC, Bluetooth) or perform common web functions (search, use of cookies) (Compl. ¶¶12, 23, 33, 60, 87, 113, 139, 174). The complaint alleges Defendant sells these products in the United States and Texas through various channels, including online retailers and distribution partners (Compl. ¶¶8, 14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,269,127 Infringement Allegations

Claim Element (from Independent Claim 20) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of forming a frame structure that is transmitted in a communication system, the method comprising the steps of: providing data blocks; providing training blocks; The accused 802.11n devices perform a method of forming and transmitting frame structures. ¶23 col. 10:20-25
combining the data blocks and training blocks in a parallel format to provide a parallel combination; The accused devices combine data and training information to form a transmittable frame. ¶23 col. 11:36-39
taking an inverse discrete fourier transform (IDFT) of the parallel combination to form IDFT blocks; The accused devices, compliant with OFDM-based standards like 802.11n, use an IDFT as part of signal modulation. ¶23 col. 4:50-52
inserting the cyclic prefixes between the IDFT blocks to form parallel symbols; The accused devices insert cyclic prefixes into the frame structure. ¶23 col. 4:52-54
converting the parallel symbols to serial format to form a preamble structure and a data structure... The accused devices convert the processed symbols into a serial format for transmission. ¶23 col. 13:20-22
...the preamble structure comprising at least one training symbol and an enhanced training symbol; the data structure comprising a plurality of data symbols; The transmitted frame structure in the accused devices includes a preamble and a data portion. ¶23 col. 6:40-45
forming data symbols such that each data symbol comprises a cyclic prefix and a data block, the cyclic prefix having a number of samples G, the data block having a number of samples N; and The data symbols in the accused devices' transmissions are formed with a cyclic prefix and a data block of specific lengths. ¶23 col. 11:25-30
forming a preamble structure having an enhanced training symbol, the enhanced training symbol comprising a cyclic prefix and a training block, the cyclic prefix having a number of samples G, the training block having a number of samples N₁ such that N₁=N/I, where I is an integer and G=N₁/4. The preamble in the accused devices' transmissions includes an enhanced training symbol with a cyclic prefix and training block whose sample lengths are in the claimed mathematical relationship. ¶23 col. 11:25-35

U.S. Patent No. 7,483,878 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of providing search results to an end-user over a computer network, the method comprising: receiving addressing information identifying a location in a computer network; The accused search functionality on Defendant's website receives addressing information (e.g., a URL) when a user navigates to a location on the site. ¶33 col. 2:40-43
processing the addressing information to generate a keyword; The accused search functionality processes this addressing information to generate a keyword for a search. ¶33 col. 3:7-9
performing a search on the keyword to generate a search result; and The accused search functionality performs a search using the generated keyword. ¶33 col. 3:34-36
presenting an end-user the search result responsive to the keyword that is based on the addressing information in response to the end-user navigating to the location using a client compute. The accused website functionality presents the search results to the end-user who navigated to the location. ¶33 col. 3:36-41

Identified Points of Contention

  • Scope Questions: The complaint broadly accuses products compliant with industry standards (e.g., 802.11n, 5G, HEVC, Bluetooth). A key question will be whether the specific implementation of these standards by the accused products meets every limitation of the asserted claims. For the ’878 patent, a point of contention may be the scope of "addressing information" and whether the routine operation of a website search bar constitutes "receiving" and "processing" it in the manner claimed.
  • Technical Questions: For the ’127 patent, the case may turn on whether the accused 802.11n devices form a preamble with an "enhanced training symbol" having the precise mathematical relationship of sample lengths (G=N₁/4 and N₁=N/I) recited in claim 20. For the ’878 patent, a technical question is how the accused system "generates a keyword" from the "addressing information," as the complaint does not detail this mechanism.

V. Key Claim Terms for Construction

The Term: "enhanced training symbol" (’127 Patent, Claim 20)

  • Context and Importance: This term is central to defining the novel preamble structure. The infringement analysis will depend on whether the preambles used in the accused 802.11n devices contain a structure that meets the definition and functional requirements of the "enhanced training symbol" as defined by the patent, particularly its specific composition of cyclic prefixes and training blocks with related sample lengths.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines the term structurally as comprising "a cyclic prefix and a training block" with specific mathematical relationships between their sample lengths (G, N₁) and the data block length (N) (’127 Patent, col. 18:13-20). This could be argued to cover any preamble structure meeting these mathematical constraints, regardless of other implementation details.
    • Evidence for a Narrower Interpretation: The specification describes the enhanced training symbol as being located "at the beginning of the preamble structure" and being used for functions like "synchronization and ... channel parameter estimation" (’127 Patent, col. 11:7-11). Embodiments show the symbol being subdivided into sections for specific functions, which could support a narrower construction requiring these functional attributes (’127 Patent, col. 13:8-20).

The Term: "processing the addressing information to generate a keyword" (’878 Patent, Claim 1)

  • Context and Importance: This step forms the link between the user's location and the search that is performed. The outcome of the case may depend on whether the accused website functionality performs an affirmative "processing" step to "generate" a keyword, or if it simply uses terms already present in a URL or search query entered by the user, which might not constitute "generating" a keyword from "addressing information."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the keyword can be determined by consulting a database that maps URLs to keywords, stating a "server program may then consult a database to determine at least one keyword assigned to the URL" (’878 Patent, col. 3:28-31). This could support a broad interpretation where "processing" includes a simple database lookup.
    • Evidence for a Narrower Interpretation: The specification describes a human operator categorizing websites and assigning keywords, which are then stored in a database (’878 Patent, col. 3:12-21). This context could support a narrower interpretation requiring a system that relies on such a pre-categorized database to derive a keyword, as opposed to simply extracting a term from a URL string itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for the ’878, ’007, ’214, ’360, ’714, and ’716 patents. Inducement is alleged based on Defendant providing instructions, advertising, and technical support that guide users to use the Accused Products in an infringing manner (e.g., Compl. ¶¶37-39). Contributory infringement is alleged on the basis that the Accused Products have "special features" that are not staple articles of commerce and have no substantial non-infringing uses (e.g., Compl. ¶¶45-46).
  • Willful Infringement: Willfulness is alleged for the same six patents (’878, ’007, ’214, ’360, ’714, and ’716 patents). The allegations are based on alleged knowledge of the patents since at least the filing of the complaint (e.g., Compl. ¶35) and on an alleged "policy or practice of not reviewing the patents of others," constituting willful blindness (e.g., Compl. ¶34).

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

  • Definitional Scope vs. Standard Implementation: A central issue will be whether the specific claim limitations, such as the "enhanced training symbol" of the ’127 patent or the "si-Windowlength" processing of the ’714 patent, can be read onto products that implement broad industry standards like 802.11n and 5G. The case may turn on whether the defendant’s standards-compliant products perform the precise, patented methods or merely achieve a similar result through a different, non-infringing technical implementation.
  • Evidentiary Sufficiency of Infringement Allegations: The complaint makes high-level allegations that largely track the language of the asserted claims without providing detailed technical evidence of how the accused products operate. A key question will be one of evidentiary proof: can the plaintiff produce sufficient technical evidence during discovery to demonstrate that the accused devices and web services perform each and every step of the asserted method claims, particularly for the software-based inventions where the underlying processes are not readily apparent?
  • Functional Interpretation of User Interaction: For patents covering website functionality (e.g., the ’878 and ’716 patents), a key question will be one of functional interpretation: does the ordinary operation of a website's search bar or cookie-based personalization system constitute the specific, multi-step methods claimed? For example, does extracting a search term from a URL constitute "processing the addressing information to generate a keyword," or is this a fundamentally different technical operation?