Calibrate Networks LLC v. Medal BV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Calibrate Networks LLC (New Mexico)
  • Defendant: Medal B.V. (Netherlands)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01076, E.D. Tex., 10/28/2025
• Venue Allegations: Plaintiff alleges venue is proper because the defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for managing network communications, specifically concerning how addresses are changed and data packets are processed within a layered network architecture.
• Technical Context: The technology at issue addresses fundamental inefficiencies in traditional network architectures, aiming to reduce processing overhead and improve flexibility in routing and addressing.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

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, "Method and system for managing network communications", issued February 28, 2017.

The Invention Explained

• Problem Addressed: The patent’s background section describes conventional network architectures as inefficient, noting that processing data packets (PDUs) through multiple protocol layers entails "data copies and task switching" that is "very inefficient" and leads to "expensive and complex custom silicon" ('633 Patent, col. 1:20-28). The patent also identifies the difficulty of changing a device's network address "without losing some packets or... destroying connections" as a critical problem for mobility and routing efficiency ('633 Patent, col. 1:55-61).
• The Patented Solution: The invention proposes a more efficient network architecture. One aspect involves treating each data packet as a "serial tape" processed by a single state machine, which avoids the overhead of passing the packet between distinct software layers ('633 Patent, col. 3:3-9). Another core aspect, central to the patent’s claims, is a method for changing the address of a network process without disruption. This is achieved by assigning a "new address" to an "Inter-Process Communication (IPC) process" while its "old address" remains temporarily valid, allowing for a seamless transition where the process begins using the new address as its source address in outgoing data flows ('633 Patent, col. 6:13-30; Abstract).
• Technical Importance: This approach seeks to "flatten" protocol processing, which the patent suggests can lead to a "smaller implementation and improved CPU cache performance," and to enable dynamic renumbering of networks, a task described as a "complex, expensive and disruptive affair" in traditional systems ('633 Patent, col. 1:61-63, col. 3:6-9).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '633 Patent Claims" detailed in an unprovided exhibit (Compl. ¶11, ¶16). Independent claim 1 is representative of the address-changing technology.
• The essential elements of independent claim 1 include:
  • Determining an address change is desired for an Inter-Process Communication (IPC) process that has an "old address" known only within a specific "layer" and a globally known "application name."
  • Assigning a "new address" to the IPC process, where the new address is also only known within the layer.
  • The IPC process then utilizes the new address as a source address in any new Data Transfer Process (DTP) flows it originates.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any accused products, methods, or services by name (Compl. ¶¶11-12, 16).

Functionality and Market Context

• The complaint refers generally to "Exemplary Defendant Products" and alleges that their functionality is detailed in claim charts contained in an unprovided document, Exhibit 2 (Compl. ¶16). The complaint itself provides no description of the technical functionality or market context of any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint provides only a conclusory allegation of infringement, stating that the accused products "practice the technology claimed by the '633 Patent" and "satisfy all elements of the Exemplary '633 Patent Claims" (Compl. ¶16). It incorporates by reference an unprovided claim chart exhibit (Exhibit 2) for all substantive details of its infringement theory (Compl. ¶17). Without this exhibit, a detailed analysis of the infringement allegations is not possible. No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on an analysis of independent claim 1 of the ’633 Patent, the following terms may be central to the dispute.

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

• Context and Importance: This term defines the entity to which the old and new addresses are assigned. The scope of this term is critical for determining whether the accused technology contains a corresponding element. Practitioners may focus on whether this term is limited to the specific "Recursive Inter Network Architecture (RINA)" context described in the patent or can be read more broadly.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent defines IPC Processes as "Application Processes that are members of a DIF [Distributed IPC Facility]" ('633 Patent, col. 6:53-54), which could be argued to encompass a general class of communicating software processes.
  • Evidence for a Narrower Interpretation: The specification introduces the address-change procedure in the context of RINA ('633 Patent, col. 6:42-43). A defendant may argue that an "IPC process" must operate within such a recursive architecture to fall within the claim's scope.

The Term: "only known in a layer"

• Context and Importance: This limitation, which applies to both the "old address" and the "new address," distinguishes them from the "globally" known application name. Infringement will depend on whether the addresses in the accused system have this specific, limited scope of visibility.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue the term simply requires that the address is a local or network-specific identifier used for routing within a particular protocol context, as opposed to a universal, application-level name.
  • Evidence for a Narrower Interpretation: The patent states that "a-old and a-new are only known within the layer" ('633 Patent, col. 6:18-19). A defendant could contend that "layer" is not a generic term but refers to the specific, recursively-defined protocol layers of the architecture disclosed in the specification.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, asserting that Defendant sells its products to customers and provides "product literature and website materials" that instruct end users to operate the products in an infringing manner (Compl. ¶14, ¶15). The complaint references an unprovided exhibit for specific details supporting this allegation (Compl. ¶14).

Willful Infringement

• The complaint alleges Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and its attached claim charts (Compl. ¶13). It further alleges that Defendant's infringement has continued post-filing, which may form the basis for a claim of post-suit willful infringement (Compl. ¶14). No allegations of pre-suit knowledge are made.

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

Based on the provided documents, the resolution of this case may depend on the following open questions:

• A core issue will be one of architectural scope: Are the claims of the ’633 Patent, which are described in the context of a specific "Recursive Inter Network Architecture," limited to that environment, or can claim terms like "IPC process" and "layer" be construed broadly enough to read on more conventional networking technologies?
• A key evidentiary question will be one of technical proof: As the complaint lacks specific factual allegations, a central challenge for the plaintiff will be to produce evidence demonstrating that the accused products perform the precise, multi-step method of address transition claimed, including assigning new, layer-specific addresses and utilizing them as source addresses in new data flows.
• A threshold procedural question may arise from the complaint's structure: Does a complaint that contains no factual detail regarding the accused product or the mechanism of infringement, and instead relies entirely on incorporation of an unprovided external exhibit, meet the federal pleading standard of plausibility?