RightQuestion LLC v. T-Mobile USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: RightQuestion, LLC (California)
  • Defendant: T-Mobile USA, Inc. and T-Mobile US, Inc. (Delaware)
  • Plaintiff’s Counsel: Kramer Alberti Lim & Tonkovich LLP; Miller Fair Henry PLLC
• Case Identification: 2:25-cv-00978, E.D. Tex., 09/24/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because T-Mobile has committed acts of infringement in the district, operates numerous retail stores and other facilities that constitute a regular and established place of business, provides extensive network coverage to residents, and advertises its services within the district. The complaint also cites prior litigation in which T-Mobile allegedly admitted to or did not contest venue in the district.
• Core Dispute: Plaintiff alleges that Defendant’s telecommunications network and associated call-protection services infringe three patents related to call-authentication and verification technologies designed to combat spoofing and fraud.
• Technical Context: The technology addresses the problem of malicious actors falsifying caller ID information ("spoofing") to perpetrate fraud or deliver unwanted spam calls, a significant issue in modern telecommunications.
• Key Procedural History: The complaint notes that the Federal Communications Commission (FCC) mandated that telecommunications carriers implement call-authentication technology, known as STIR/SHAKEN, by June 30, 2021, providing market context for Defendant's adoption of the accused technologies.

Case Timeline

Date	Event
2013-11-07	’009, ’989, and ’132 Patents Priority Date
2020-03-31	FCC adopts Report and Order mandating STIR/SHAKEN implementation
2020-06-02	U.S. Patent No. 10,674,009 Issued
2021-05-11	U.S. Patent No. 11,005,989 Issued
2021-06-30	FCC deadline for STIR/SHAKEN implementation
2023-12-26	U.S. Patent No. 11,856,132 Issued
2025-09-24	Complaint Filed

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

U.S. Patent No. 10,674,009 - "Validating Automatic Number Identification Data"

The Invention Explained

• Problem Addressed: The patent addresses the challenge of determining the trustworthiness of caller identification information, such as Automated Number Identification (ANI), which can be easily falsified or "spoofed" by malicious entities, creating high fraud risks ('009 Patent, col. 1:20-29).
• The Patented Solution: The invention describes a system where a party receiving a call (a "callee") can request verification of the incoming call's ANI data from a third-party verification service. This service then communicates with the calling device over a separate, second channel (a "backchannel") to confirm the call is legitimate. Based on the device's response, the service provides a security determination back to the callee, enabling a decision on how to handle the call ('009 Patent, Abstract; Fig. 1).
• Technical Importance: This out-of-band verification method was designed to provide a reliable way to detect and defeat caller ID spoofing, a major source of robocalls and fraud that traditional telephone infrastructure struggled to prevent (Compl. ¶¶ 3-4).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶44).
• The essential elements of independent claim 1 include:
  • Enrolling a first device with a verification service provider by associating the device with a "device fingerprint" generated from its configuration information.
  • Storing that device fingerprint at the verification service provider.
  • Obtaining information transmitted by a second device.
  • Performing a security determination by determining if the information from the second device matches the stored device fingerprint of the first enrolled device.

U.S. Patent No. 11,005,989 - "Validating Automatic Number Identification Data"

The Invention Explained

• Problem Addressed: The patent targets the same problem of spoofed ANI information that makes it difficult for call recipients to trust caller ID ('989 Patent, col. 1:24-32).
• The Patented Solution: This invention discloses a system that receives information about an incoming call, which includes both a generated "value" (e.g., a cryptographic key or unique identifier) and a "score" that indicates the validity of the phone number. A security determination is then performed based on both the score and a verification of the value, allowing a callee to receive an assurance of the call's legitimacy ('989 Patent, Abstract).
• Technical Importance: The introduction of a scoring mechanism allows for a more nuanced, risk-based assessment of a call's legitimacy, moving beyond a simple binary verified/unverified outcome toward a system that can weigh multiple factors (Compl. ¶7; ’989 Patent, col. 9:8-12).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶53).
• The essential elements of independent claim 1 include:
  • Receiving information pertaining to a call initiated by a calling device, where the information includes both a "value" generated from data associated with the device and a "score" indicating the validity of the phone number.
  • Performing a security determination based at least in part on the score and on verifying the value.
  • Conveying an assurance or a failure to confirm to the callee based on the security determination.

U.S. Patent No. 11,856,132 - "Validating Automatic Number Identification Data"

Technology Synopsis

This patent also addresses the technical problem of spoofed caller ID ('132 Patent, col. 1:29-37). Its solution involves a system that receives information about an initiated call, including data about the caller device and a "cryptographic element," and performs a security determination based on that element to validate the call's origin before transmitting a notification to the callee device ('132 Patent, Abstract; col. 3:35-46).

Asserted Claims

Independent claim 1 (Compl. ¶62).

Accused Features

The complaint accuses T-Mobile's call-protection services, specifically the Call Validation Treatment (CVT) and Secure Telephone Identity Verification Service (STI-VS) network elements that support its STIR/SHAKEN framework, of infringing the ’132 patent (Compl. ¶¶ 2, 7-8, 60-61).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is T-Mobile's IP Multimedia Subsystem (IMS) network and its supporting software and network elements, including Call Validation Treatment (CVT), STI-VS (Secure Telephone Identity Verification Service), and the T-Mobile T-Life or Scam Shield mobile applications (collectively, the "accused system") (Compl. ¶2).

Functionality and Market Context

The accused system provides call-protection services to T-Mobile customers by implementing the STIR/SHAKEN framework, an industry standard mandated by the FCC to combat unwanted and fraudulent calls (Compl. ¶¶ 5-6). The CVT component is alleged to use "reputation scores and other information to determine how a call should be handled," including notifying recipients whether a call has been verified or presents a risk (Compl. ¶7). The T-Life and Scam Shield apps allegedly allow users to interact with these network services (Compl. ¶46). The complaint includes a coverage map showing the nationwide availability of the accused network services, which supports allegations of T-Mobile's extensive market presence (Compl. p. 7).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits 4, 5, and 6, but these exhibits were not filed with the complaint. The narrative infringement theories are summarized below.

’009 Patent Infringement Allegations

The complaint alleges that T-Mobile’s accused system, including its CVT and STI-VS components, infringes claim 1 of the ’009 patent (Compl. ¶¶ 42-44). The theory suggests that T-Mobile’s network performs call validation that meets the elements of the claim. However, the complaint does not provide specific factual allegations detailing how the accused system creates or uses a "device fingerprint" or communicates over a separate backchannel as recited in the claim.

’989 Patent Infringement Allegations

The complaint alleges that T-Mobile's accused system infringes claim 1 of the ’989 patent (Compl. ¶¶ 51-53). The infringement theory centers on the CVT component, which allegedly "uses reputation scores and other information to determine how a call should be handled" (Compl. ¶7). This functionality is alleged to satisfy the claim’s requirement of receiving a "score... indicating a validity of a phone number" and performing a security determination based upon that score.

Identified Points of Contention

• Scope Questions: A central question for the ’989 Patent may be whether T-Mobile's "reputation score," as described in the complaint, falls within the scope of the claimed "score indicating a validity of a phone number." The analysis may turn on whether a general risk or reputation assessment is equivalent to a specific determination of a phone number's validity.
• Technical Questions: For the ’009 Patent, the complaint does not specify what technical data used by T-Mobile's system allegedly constitutes the claimed "device fingerprint." A key question will be what evidence supports the allegation that T-Mobile's system generates and stores a fingerprint based on device-specific configuration information as required by the claim.

V. Key Claim Terms for Construction

Term: "device fingerprint" (from ’009 Patent, claim 1)

• Context and Importance: This term is foundational to the infringement theory for the ’009 Patent. The definition will determine whether the type of data T-Mobile's system uses for call validation meets the claim limitations. Practitioners may focus on this term because its construction will define the breadth of the asserted claim and its applicability to standardized systems like STIR/SHAKEN.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad, exemplary definition, stating a fingerprint can be created from a "combination of device settings, installed applications, system or application software versions, or contact list stored on the phone" (’009 Patent, col. 9:35-39).
  • Evidence for a Narrower Interpretation: While the definition is broad, a defendant may argue that the term implies a level of uniqueness sufficient to reliably distinguish one device from another, potentially narrowing its scope from any arbitrary combination of settings.

Term: "score... indicating a validity of a phone number" (from ’989 Patent, claim 1)

• Context and Importance: The allegation that T-Mobile's "reputation scores" (Compl. ¶7) meet this limitation is a core component of the infringement case for the ’989 Patent. The construction of this term will be critical to determining whether a general risk score is legally equivalent to a score specifically directed to the "validity" of the number itself (e.g., confirming it is not spoofed).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes using the score in a "risk-based decision system" and applying "custom verification processing and policies," which may support a construction that includes general reputation or risk assessments (’989 Patent, col. 9:8-12).
  • Evidence for a Narrower Interpretation: The patent’s focus on combating spoofing (’989 Patent, col. 1:24-32) could support an argument that "validity" has a specific technical meaning tied to authenticating the call's origin, which may be narrower than a general reputation metric.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement by providing customers with the T-Mobile T-Life or Scam Shield app and related instructions, which allegedly cause customers to use the accused system in an infringing manner (Compl. ¶¶ 46, 55, 64). It also pleads contributory infringement, alleging the app is a material component of the invention that is not a staple article of commerce and has no substantial non-infringing uses (Compl. ¶¶ 48, 57, 66).

Willful Infringement

The complaint alleges willful infringement based on T-Mobile’s knowledge of the patents "at least as of the filing date of this Complaint" (Compl. ¶¶ 45, 54, 63). The allegations also state T-Mobile "was or is now aware of the ['patent] or has willfully blinded itself as to the existence of the ['patent]," which may support a theory of willfulness based on post-suit conduct (Compl. ¶¶ 47, 56, 65).

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

• A core issue will be one of definitional scope: does T-Mobile's alleged use of "reputation scores" in its CVT service meet the specific requirement of the ’989 Patent for a "score indicating a validity of a phone number," or is there a material distinction between a general risk assessment and the specific validity determination described in the patent?
• A key technical and evidentiary question for the ’009 Patent will be whether the data utilized by T-Mobile's STIR/SHAKEN-based system can be proven to constitute a "device fingerprint" as that term is broadly defined in the patent's specification, which includes elements such as installed applications and contact lists.