NetMomentum LLC v. Sahara Presentation System Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: NetMomentum LLC (Delaware)
  • Defendant: Sahara Presentation System LTD (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01085, E.D. Tex., 10/28/2025
• Venue Allegations: Venue is asserted based on the defendant being a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to semi-transparent Radio Frequency Identification (RFID) tags designed to function when stacked or in close proximity.
• Technical Context: The technology addresses interference issues in RFID systems, which are widely used for tracking inventory, assets, and documents, by enabling the reading of multiple tagged items that are densely packed together.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,714,726 - Semi-transparent RFID tags

The Invention Explained

• Problem Addressed: Conventional RFID tags, when stacked or placed in close proximity, can interfere with each other. The patent describes how the antenna of an outer tag can act as a "Faraday shield," blocking the RF signal and preventing tags on the inside of a stack from being read. (’726 Patent, col. 1:26-41). This problem is particularly acute for thin, flat objects like poker chips, documents, or currency. (’726 Patent, col. 1:30-32).
• The Patented Solution: The invention is a "semi-transparent" antenna for an RF device. This antenna is designed to gather only some of the RF energy from a reader's signal, allowing most of the energy to pass through to other tags nearby. (’726 Patent, Abstract). This is achieved by constructing the antenna from materials with high sheet resistivity, which "minimally affects the electromagnetic RF fields surrounding the antenna." (’726 Patent, col. 2:66 – col. 3:4). This design allows an entire stack of tagged objects, as depicted in Figure 4, to be read successfully.
• Technical Importance: This approach enables reliable RFID tracking for assemblies of closely packed objects, a scenario where conventional RFID technology was previously considered ineffective. (’726 Patent, col. 1:39-41, col. 1:56-59).

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring generally to "exemplary method claims" and "Exemplary '726 Patent Claims" identified in an external chart. (Compl. ¶11, ¶13). Independent Claim 1 is the broadest apparatus claim.

• Independent Claim 1:
  • A Radio Frequency (RF) device, comprising:
  • a circuit; and
  • an antenna coupled to the circuit, wherein the antenna minimally affects electromagnetic RF fields surrounding the antenna even in the vicinity of the antenna.

III. The Accused Instrumentality

Product Identification

The complaint does not identify the specific accused products by name. (Compl. ¶11, ¶13). It refers to "Exemplary Defendant Products" that are purportedly detailed in an "Exhibit 2," which was not filed with the complaint. (Compl. ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that the unspecified "Exemplary Defendant Products" infringe the ’726 Patent by practicing the claimed technology. (Compl. ¶13). However, it relies entirely on claim charts in an unprovided "Exhibit 2" to substantiate these allegations. (Compl. ¶13-14). Without this exhibit, a detailed analysis of the infringement theory is not possible based on the complaint's text alone. The narrative theory suggests that Defendant's products are RF devices that incorporate the patented semi-transparent antenna technology. (Compl. ¶11). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the antennas in the accused products can be characterized as "minimally affect[ing] electromagnetic RF fields," as required by Claim 1. The definition of this relative term will be critical to the infringement analysis.
  • Technical Questions: Assuming the accused products are identified, a key factual dispute may arise over the physical properties of their antennas, such as sheet resistivity, and the measurable degree to which they permit RF energy to pass through to other devices.

V. Key Claim Terms for Construction

• The Term: "minimally affects" electromagnetic RF fields
• Context and Importance: This limitation appears in the preamble of independent claim 1 and captures the core of the purported invention: an antenna that does not significantly block or interfere with RF signals intended for other nearby tags. The construction of this term of degree will likely determine the scope of the patent and be dispositive of infringement. Practitioners may focus on this term because it is not explicitly defined with a precise numerical value, creating ambiguity.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a quantitative floor, stating that "at least about 50%" of RF energy striking the antenna is "useable by another RF device in the vicinity of the tag." (’726 Patent, col. 5:19-22). This could support an interpretation where any antenna allowing more than half the energy to pass through "minimally affects" the field.
  • Evidence for a Narrower Interpretation: The same passage states that "preferably greater than about 90%" of the RF energy passes through. (’726 Patent, col. 5:20). A defendant may argue this preferred embodiment should guide the interpretation toward a much higher transparency threshold. The specification also links the "minimally affects" property to specific physical characteristics, such as an antenna constructed of a planar conductor with a sheet resistivity "greater than about 1 Ω/sq, preferably greater than about 10 Ω/sq." (’726 Patent, col. 5:26-28).

VI. Other Allegations

• Indirect Infringement: The complaint alleges only direct infringement. (Compl. ¶11). It does not contain factual allegations to support claims for induced or contributory infringement.
• Willful Infringement: The complaint does not explicitly allege willful infringement. However, the prayer for relief requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285," which could entitle the plaintiff to an award of attorney's fees. (Compl. p. 4, ¶ E.i).

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

1. A core issue will be one of definitional scope: How will the court construe the term of degree ""minimally affects" electromagnetic RF fields"? The outcome of this claim construction battle may determine whether the patent reads on a commercially viable range of RFID antenna designs or is limited to the specific high-resistivity embodiments described.
2. A fundamental evidentiary question will be one of factual proof: As the complaint does not identify accused products or provide infringement contentions, a primary hurdle for the plaintiff will be to produce evidence demonstrating that specific, accused products manufactured or sold by the defendant actually incorporate the patented semi-transparent antenna technology and meet the "minimally affects" limitation.