Calibrate Networks LLC v. Lee Hecht Harrison LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Calibrate Networks LLC (New Mexico)
  • Defendant: Lee Hecht Harrison LLC (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-1075, E.D. Tex., 01/12/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Texas and committing the alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to methods for managing network communications, specifically concerning the dynamic changing of network addresses.
• Technical Context: The technology at issue relates to foundational network architecture, aiming to improve efficiency and flexibility over traditional layered protocols for routing data and managing device addresses.
• Key Procedural History: The complaint alleges that Defendant gained actual knowledge of the asserted patent and its alleged infringement upon service of an original complaint in this matter on October 28, 2025.

Case Timeline

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

U.S. Patent No. 9,584,633 - "Method and system for managing network communications"

• Patent Identification: U.S. Patent No. 9,584,633, issued February 28, 2017 (the "’633 Patent").

The Invention Explained

• Problem Addressed: The patent’s background section describes inefficiencies in traditional layered network architectures, which can require extensive data copying and task switching to process data packets (’633 Patent, col. 1:20-28). It also notes that in most network architectures, changing a device's address is difficult "without losing some packets or in some architectures... destroying connections," which hinders mobility and makes renumbering a network a "complex, expensive and disruptive affair" (’633 Patent, col. 1:55-63).
• The Patented Solution: The invention proposes a method to change the address of a network process without losing data or connections by assigning a new address to the process while an old one remains temporarily active. The process begins using the new address as its source identifier for outgoing data flows, while other network entities are updated to recognize the new address (’633 Patent, col. 5:41-col. 6:46). This is enabled by a recursive architecture where an "application name" is known globally, but the "addresses" used for routing are known only within a specific network "layer," allowing for more flexible address management (’633 Patent, Claim 1).
• Technical Importance: This approach suggests a method for enabling seamless device mobility and network administration by decoupling a stable, global identifier from the transient, layer-specific addresses used for routing.

Key Claims at a Glance

• The complaint asserts infringement of one or more claims, including "Exemplary '633 Patent Claims" identified in an incorporated exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative of the patent's core method.
• Independent Claim 1:
  • Determining that an address change is desired for an "Inter-Process Communication (IPC) process."
  • The IPC process has an "old address" that is "only known in a layer" and an "application name that is known globally."
  • Assigning a "new address" to the IPC process, where the new address is also "only known in the layer."
  • The IPC process then utilizes the new address as a source address in its outgoing "Data Transfer Process (DTP) flows."
• The complaint does not explicitly reserve the right to assert dependent claims, but its reference to "one or more claims" suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products or services (Compl. ¶11). It refers generally to "Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused instrumentalities. It alleges that the infringement theory and product identification are detailed in claim charts attached as Exhibit 2, but this exhibit was not provided with the complaint (Compl. ¶14, ¶16, ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges that "the Exemplary Defendant Products practice the technology claimed by the '633 Patent" and that they "satisfy all elements of the Exemplary '633 Patent Claims" (Compl. ¶16). However, the complaint incorporates its specific infringement allegations by reference to claim charts in an external document, Exhibit 2, which was not filed with the public complaint (Compl. ¶17). The complaint provides no narrative summary of its infringement theory or how the accused products are alleged to meet the limitations of the asserted claims.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of a detailed infringement theory in the complaint, litigation may center on foundational questions of applicability.
  • Architectural Mismatch: A primary question will be whether the architecture of the accused products can be mapped to the specific "layered" architecture required by the claims. For example, does the Defendant's system distinguish between a "globally" known "application name" and an address "only known in a layer" in the manner described by the patent?
  • Functional Mismatch: It will be a point of contention whether the accused products perform the specific, ordered steps of claim 1: determining a need for an address change, assigning a new address, and utilizing that new address as a source address for outgoing data flows, all while maintaining an existing connection.

V. Key Claim Terms for Construction

• The Term: "Inter-Process Communication (IPC) process"

• Context and Importance: This term defines the entity whose address is being changed. Its construction is critical to determining if the claims read on the components of the accused systems. Practitioners may focus on this term because its scope will determine whether the claim is limited to the specific "Recursive Inter Network Architecture (RINA)" discussed in the patent or can apply more broadly to processes in other network architectures.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim itself does not limit the term to a specific architecture, suggesting it could be given its plain and ordinary meaning as understood in the field of computer networking.
  • Evidence for a Narrower Interpretation: The specification states, "IPC Processes are Application Processes that are members of a DIF [Distributed IPC Facility]" (’633 Patent, col. 5:54-56). This definition, tied to the specific RINA framework, could be used to argue for a narrower construction.

• The Term: "only known in a layer"

• Context and Importance: This limitation, which applies to both the "old address" and "new address," is a key differentiator from conventional network models where an IP address, for example, has broader significance. The case may turn on whether the addresses in the accused system have the limited, layer-specific scope required by the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not provide a specific definition of "layer," which may support an argument that the term should be interpreted broadly to encompass logical or functional divisions in various network stacks, not just the formal layers of a specific model like RINA.
  • Evidence for a Narrower Interpretation: The specification contrasts the layer-specific address with the "A-Appl-name," which "is known globally" (’633 Patent, col. 6:17-18). This explicit distinction suggests that "layer" has a specific meaning within the patent's disclosed architecture and is not a generic term.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '633 Patent" (Compl. ¶14-15). The specific evidentiary basis for this allegation is referenced as being in the unprovided Exhibit 2 (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful," but it lays the foundation for such a claim. It alleges that Defendant had "Actual Knowledge of Infringement" as of October 28, 2025, the filing date of the original complaint, and that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" the accused products (Compl. ¶13-14). This alleges post-suit knowledge and ongoing infringement.

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

• A central issue will be one of applicability: Can the specific architectural elements of the ’633 Patent’s claims—such as an "IPC process," a "globally known" application name, and an address "only known in a layer"—be mapped onto the components and operations of the Defendant's products, which may be based on a different networking paradigm?
• A key evidentiary question will be one of technical function: Assuming the architectural elements can be mapped, does the complaint's forthcoming evidence (presumably in Exhibit 2) demonstrate that the accused products perform the precise, multi-step method of dynamically assigning and utilizing a new source address for an existing process as required by the claims? The lack of this detail in the complaint itself makes this a primary open question.
• The dispute may also involve a significant claim construction battle over the scope of foundational terms. Whether terms like "layer" and "IPC process" are construed narrowly to the specific RINA architecture described in the patent, or more broadly to cover analogous concepts in other systems, will likely be dispositive for infringement.