Calibrate Networks LLC v. Tata Consultancy Services Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Calibrate Networks LLC (New Mexico)
  • Defendant: Tata Consultancy Services Limited (India)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01077, E.D. Tex., 10/28/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified network communication products and services infringe a patent related to dynamically managing network addresses without disrupting connections.
• Technical Context: The technology addresses methods for changing an entity's address within a computer network, a critical function for supporting device mobility and network re-organization without losing active data sessions.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

Date	Event
2013-03-15	U.S. Patent No. 9,584,633 Priority Date
2014-03-14	Application for U.S. Patent No. 9,584,633 Filed
2017-02-28	U.S. Patent No. 9,584,633 Issued
2025-10-28	Complaint Filed

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 the difficulty in traditional network architectures of changing the address for a device or application without disrupting active connections, noting this is "critical for the support of mobility and the efficiency of routing" and that renumbering an entire network is a "complex, expensive and disruptive affair" (’633 Patent, col. 1:56-64).
• The Patented Solution: The invention proposes a method for changing an address for an "Inter-Process Communication (IPC) process" while it is active. An entity (NMS, or Network Management System) assigns a "new address" to the process in addition to its "old address." The IPC process immediately begins using the new address as its source address for outgoing data flows (’633 Patent, col. 6:15-22). When other processes communicating with it receive a packet from the new address, they update their own records to use that new address as the destination for future communications, allowing for a seamless transition without losing data or connections (’633 Patent, col. 6:31-39).
• Technical Importance: This approach allows for dynamic address changes within a network layer, which can support device mobility or network reorganization without the need to tear down and re-establish communication sessions, a significant operational challenge in large-scale networks (’633 Patent, col. 1:56-64).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '633 Patent Claims" (Compl. ¶11). The patent’s independent claims are 1 and 8.
• Independent Claim 1 (Method):
  • Determining an address change is desired for an Inter-Process Communication (IPC) process that has an "old address" known only in a specific "layer" and a globally known "application name."
  • Assigning a "new address" to the IPC process, also known only in that layer.
  • Wherein the IPC process utilizes the new address as a source address in any Data Transfer Process (DTP) flows originating from it.
• Independent Claim 8 (System):
  • A processing system and memory with instructions to perform the steps of:
  • Determining an address change is desired for an IPC process with a globally known application name and an old address.
  • Assigning a new address to the IPC process.
  • Wherein the IPC process utilizes the new address as a source address in any DTP flows originating from it.
• The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services. It refers generally to "Exemplary Defendant Products" that are identified in an "Exhibit 2" which is incorporated by reference but was not filed with the complaint (Compl. ¶¶11, 16).

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 that Defendant makes, uses, sells, and imports these products, and that its employees internally test and use them (Compl. ¶¶11-12).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference "charts comparing the Exemplary '633 Patent Claims to the Exemplary Defendant Products" in an unprovided Exhibit 2 (Compl. ¶16). The body of the complaint itself does not contain a narrative infringement theory or a claim chart. It makes only a conclusory allegation that the accused products "practice the technology claimed" and "satisfy all elements" of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

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 and is the central subject of the claim. The scope of "IPC process" will be critical to determining whether the accused products, which are likely components of a larger service architecture, contain an equivalent entity that undergoes the claimed address change. Practitioners may focus on whether this term is limited to processes within a specific architecture like RINA (Recursive Inter Network Architecture), which is discussed in the specification, or if it can be read more broadly to cover any software process communicating over a network (’633 Patent, col. 5:40-42).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims themselves do not limit the term to any particular operating system or network architecture. The definition provided in the specification states that "IPC Processes are Application Processes that are members of a DIF [Distributed IPC Facility]," which could be argued to be a broad, functional definition (’633 Patent, col. 6:53-55).
  • Evidence for a Narrower Interpretation: The specification heavily references concepts from the RINA framework (’633 Patent, col. 5:40-42). A defendant may argue that the term should be construed in light of these specific embodiments, limiting its scope to processes operating within such a recursive architecture.

• The Term: "wherein the old address is only known in a layer"

• Context and Importance: This limitation requires that the address being changed has a scope limited to a specific network "layer." This is a key element distinguishing the claimed invention from, for example, changing a global IP address. The dispute will likely center on whether the accused system employs a layered architecture where addresses have a scope that can be mapped to the claim language.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent background describes traditional network architectures as having "layers of protocol of different scope" and notes that "scope increases with higher layers," suggesting the term should be understood in its conventional networking sense (’633 Patent, col. 1:19-21).
  • Evidence for a Narrower Interpretation: The detailed description discusses a specific "recursive architecture" where "the protocols are the same" across layers, separating mechanism from policy (’633 Patent, col. 4:22-26). A defendant may argue that the term "layer" should be construed as a layer in this specific recursive sense, not in the sense of the OSI or TCP/IP models.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on the theory that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The knowledge element for inducement is alleged to be met at least as of the service of the complaint (Compl. ¶15).
• Willful Infringement: Willfulness is alleged based on continued infringement after receiving actual knowledge of the patent and the infringement allegations via the filing and service of the complaint (Compl. ¶¶13-14).

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

1. A central issue will be one of definitional scope: can the term "Inter-Process Communication (IPC) process," which is described in the patent in the context of a Recursive Inter Network Architecture (RINA), be construed broadly enough to read on the components of Defendant’s (currently unidentified) service offerings?
2. A threshold procedural question will be one of pleading sufficiency: does the complaint, which identifies neither the accused products nor the asserted claims and provides no infringement theory beyond incorporating an unfiled exhibit, meet the plausibility standard required by Federal Rule of Civil Procedure 8, or will it be subject to a successful motion to dismiss?
3. A key technical question will be one of architectural mapping: does the accused system operate using a "layer" in which addresses are "only known," as required by the claims, or does its architecture differ in a way that avoids this specific limitation?