Quantion LLC v. Cisco Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Quantion LLC (New Mexico)
  • Defendant: Cisco Systems, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-1015, E.D. Tex., 10/07/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district, has committed acts of patent infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to methods for providing free, ad-supported internet access at wireless "Hot Spots."
• Technical Context: The technology concerns captive portal systems used in public Wi-Fi networks, where users must view content, such as advertisements, before being granted full network access.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

Date	Event
2005-12-02	’283 Patent Priority Date
2010-06-08	’283 Patent Issue Date
2025-10-07	Complaint Filing Date

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

U.S. Patent No. 7,734,283 - Internet accessing method from a mobile station using a wireless network

• Patent Identification: U.S. Patent No. 7,734,283, Internet accessing method from a mobile station using a wireless network, issued June 8, 2010.

The Invention Explained

• Problem Addressed: The patent describes conventional wireless "Hot Spot" access methods as requiring payment from the end-user, for example, by purchasing an access card or paying via a telephone bill (Compl. Ex. 1, ’283 Patent, col. 1:24-36). This creates a barrier for users who desire free and immediate internet access.
• The Patented Solution: The invention proposes a method where a user receives free internet access in exchange for viewing advertising content. When a user connects to a wireless access point, a management platform sends content associated with that specific access point to the user's device. The content is displayed for a preset time, and only after this period expires are the user's credentials (identifier, password, login) automatically generated to open the internet session, thereby ensuring the content is viewed before access is granted (’283 Patent, col. 2:3-20; Fig. 2).
• Technical Importance: This method provides a business model for establishments to offer free Wi-Fi to customers, subsidized by advertising revenue, rather than charging users directly for access (’283 Patent, col. 3:30-37).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including what it terms the "Exemplary '283 Patent Claims," without specifying claim numbers (Compl. ¶11). Claim 1 is the sole independent claim.
• Independent Claim 1:
  • A method for opening a wireless communication session using a management platform, a wireless access point, and a user station.
  • Establishing a connection from the wireless access point to the management platform.
  • Generating a request from the access point to the platform, the request comprising an identifier of the access point.
  • Extracting advertising content associated with the identifier from the platform.
  • Sending and displaying the advertising content at the user station.
  • Upon expiration of a preset time higher than the display duration, "thereby forcing said user to view said content," automatically generating an identifier, password, and login for the user.
  • Opening a wireless connection session using the automatically generated credentials.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products or services by name (Compl. ¶11, ¶16). It refers generally to "Exemplary Defendant Products" that are purportedly detailed in an unattached exhibit (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '283 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided with the filing (Compl. ¶16-17). The complaint alleges that these charts compare the "Exemplary '283 Patent Claims" to the "Exemplary Defendant Products" and demonstrate that the products "satisfy all elements" of the claims (Compl. ¶16). Without access to these charts or identification of the accused products, a detailed element-by-element analysis is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Pleading Sufficiency Question: The complaint's failure to name any specific accused products or provide the referenced exhibits raises the question of whether it meets the pleading standards required to give the Defendant adequate notice of the infringement claims.
  • Technical Questions: Once products are identified, a central technical question will be whether they perform the specific two-step process required by Claim 1: first, displaying content for a mandatory preset time, and second, subsequently and automatically generating a unique set of credentials for that session. Does the accused system's authentication process map onto the claimed "generating" step, or does it use a different mechanism, such as pre-existing or user-provided credentials?

V. Key Claim Terms for Construction

• The Term: "automatically generating at least an identifier, password and login of said user"

• Context and Importance: This term appears to be the central novel step of the claimed method. Its definition will be critical to determining infringement. The dispute will likely focus on what actions constitute "generating" credentials in this context.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language does not specify how or where the generation must occur, which may support an interpretation that covers any automated process that produces or assigns credentials to a user for session authentication after content is viewed.
  • Evidence for a Narrower Interpretation: The specification states that "the end users' identifier, password and login, are automatically generated at the authentication server" (’283 Patent, col. 3:18-21). This could be used to argue that the "generating" step must be performed by a specific component (the authentication server) and must create new credentials for the session, rather than simply retrieving or validating existing ones.

• The Term: "forcing said user to view said content for at least said preset time"

• Context and Importance: This term is crucial for establishing that the user cannot bypass the advertising content before the allotted time expires. The scope of "forcing" will determine what technical implementations infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not describe a specific technical mechanism for the "forcing." This may support a broad construction that reads on any system that delays access until a timer expires, regardless of whether the user can navigate away from the content window itself.
  • Evidence for a Narrower Interpretation: The claim's structure—linking the "forcing" to the subsequent automatic generation of credentials—could support an argument that the system must technically prevent the session-opening step from occurring until the preset time has fully elapsed, implying a more robust "forcing" mechanism than a simple countdown timer that a user could ignore.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant distributes "product literature and website materials" that instruct end-users to operate the accused products in a manner that infringes the ’283 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. The complaint asserts that its service provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14).

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

• A primary procedural issue will be one of pleading sufficiency: does the complaint’s failure to identify any specific accused products or provide its referenced claim-chart exhibits provide Defendant with fair notice of the claims against it, or will it be subject to dismissal?
• The central technical issue will be one of claim scope and operational correspondence: assuming specific products are identified, do they in fact "automatically generate" a new "identifier, password and login" for a user after "forcing" them to view content for a preset time, as strictly required by the claim, or do they employ a different authentication architecture that falls outside this claimed sequence?