DCT

2:25-cv-01161

CommPlex Systems LLC v. Altai Tech Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01161, E.D. Tex., 11/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that has committed acts of patent infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified communication products infringe a patent related to systems for sending and receiving digital data using multiple orthogonal frequencies.
  • Technical Context: The technology at issue involves methods for increasing the rate and efficiency of digital data transmission over wireless channels, a foundational element of modern telecommunications and Wi-Fi systems.
  • Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

Date Event
2006-10-30 '900 Patent Priority Date
2011-01-04 '900 Patent Issue Date
2025-11-26 Complaint Filing Date

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

U.S. Patent No. 7,864,900 - "Communication system for sending and receiving digital data"

  • Patent Identification: U.S. Patent No. 7,864,900, "Communication system for sending and receiving digital data," issued January 4, 2011 (’900 Patent).

The Invention Explained

  • Problem Addressed: The patent's background section describes challenges with conventional Frequency Shift Keying (FSK) data transmission, where inaccuracies in determining a signal's center frequency can lead to a "distorted mark/space ratio in the demodulated data," causing errors in data sampling and interpretation (’900 Patent, col. 2:56-65).
  • The Patented Solution: The invention proposes a system using multiple orthogonal frequencies that are locked to each other to represent data (’900 Patent, Abstract). A transmitter uses an encoder and a look-up table to convert groups of data bits into a specific combination of frequencies (e.g., two frequencies out of a possible 32) to be transmitted simultaneously (’900 Patent, col. 5:51-65; Fig. 7). A corresponding receiver detects these frequencies, uses its own look-up table to decode the frequency combination back into the original data bits, and employs techniques like Fast Fourier Transform (FFT) to process the signals efficiently (’900 Patent, col. 7:1-12; Fig. 8).
  • Technical Importance: This approach, described as a "Multiple Orthogonal locked frequencies Narrow Band Frequency Shift Keying (Mary-NBFSK) system," aims to achieve a higher code density and data rate per hertz of bandwidth compared to traditional binary FSK systems, while also reducing hardware complexity and power consumption (’900 Patent, col. 4:9-23).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’900 Patent without specifying them (Compl. ¶11). Independent claim 1 is representative.
  • Independent Claim 1:
    • A communication system for sending and receiving data, comprising a transmitter and a receiver.
    • A general binary coded Orthogonal Frequency-Division Multiplexing carrier scheme is provided between the transmitter and receiver.
    • The scheme is used to increase code density and data rate per Hz of bandwidth.
    • The system includes a plurality of narrow band carrier frequencies that are orthogonal and are transmitted in a binary code to represent data.
    • The narrow band carrier frequencies include narrow band separation between orthogonal carriers of the order of 0.1 MHz, providing a bandwidth of the order of 3.2 MHz for 32 carriers, allowing the bandwidth to transmit at least 6 Mbps in a 2 of 32 Orthogonal Frequency-Division Multiplexing scheme.
  • 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 by name. It refers to "Exemplary Defendant Products" that are purportedly identified in charts attached as Exhibit 2 (Compl. ¶11, ¶16). However, Exhibit 2 was not provided with the complaint.

Functionality and Market Context

  • The complaint alleges that the accused products "practice the technology claimed by the '900 Patent" (Compl. ¶16). It states that Defendant makes, uses, sells, and imports these products in the United States and provides "product literature and website materials" that induce end users to use them in an infringing manner (Compl. ¶11, ¶14). The complaint does not provide sufficient detail for analysis of the products' specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided, stating that these charts compare the "Exemplary '900 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16). The complaint itself contains no specific factual allegations mapping any feature of an accused product to any element of a patent claim. It asserts in a conclusory manner that the accused products "satisfy all elements of the Exemplary '900 Patent Claims" (Compl. ¶16). Without the referenced charts, a detailed analysis of the infringement allegations is not possible based on the complaint's text.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Questions: The central threshold issue will be whether Plaintiff can produce evidence demonstrating that the accused products, once identified, practice each element of the asserted claims. The complaint's reliance on an unprovided exhibit for all substantive infringement allegations raises the question of what specific facts support the claims.
    • Scope Questions: Assuming evidence is presented, a dispute may arise over the scope of the claim term "Orthogonal Frequency-Division Multiplexing carrier scheme." The court will need to determine if the accused products' modulation and transmission methods fall within the construction of this term as defined by the patent.
    • Technical Questions: A key technical question will be whether the accused products utilize "a plurality of narrow band carrier frequencies" that are "orthogonal" and "transmitted in a binary code to represent data" as required by claim 1. The specific technical implementation of the accused products' signal transmission will be compared against the patent's claims and specification.

V. Key Claim Terms for Construction

  • The Term: "Orthogonal Frequency-Division Multiplexing carrier scheme" (from Claim 1)
  • Context and Importance: This term defines the core technical standard of the claimed system. The infringement analysis will depend heavily on whether the Defendant's products are found to implement such a scheme. Practitioners may focus on this term because the patent also uses the more specific, and potentially distinct, term "Mary-NBFSK" in the specification, creating a potential ambiguity regarding the claim's intended scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 itself introduces the term broadly as a "general binary coded" scheme provided between a transmitter and receiver for increasing code density (’900 Patent, col. 8:61-65). This language may support an interpretation that covers various systems achieving this functional result using OFDM principles.
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the invention in the context of a "Multiple Orthogonal locked frequencies Narrow Band Frequency Shift Keying (Mary-NBFSK) system" (’900 Patent, col. 4:9-11, 4:32-36). This specific embodiment could be used to argue that the broader claim term should be limited to the specific Mary-NBFSK systems detailed in the patent.

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 '900 Patent" (Compl. ¶14). The specific content of these materials is purportedly referenced in Exhibit 2 (Compl. ¶14).
  • Willful Infringement: The complaint alleges willful infringement based on knowledge obtained from the service of the complaint itself. It asserts that "service of this Complaint...constitutes actual knowledge" and that Defendant's continued infringing activities thereafter are willful (Compl. ¶13, ¶14).

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

  • A primary issue will be one of evidentiary sufficiency: Can the Plaintiff, whose complaint relies entirely on an unprovided exhibit for its infringement contentions, produce the specific technical evidence required to demonstrate that an accused product practices each limitation of the asserted claims?
  • The case may also turn on a question of definitional scope: Will the term "Orthogonal Frequency-Division Multiplexing carrier scheme" be construed broadly to encompass a general class of OFDM-based systems, or will it be limited to the specific "Mary-NBFSK" embodiments described in detail within the ’900 Patent's specification?
  • A third key question will be one of technical implementation: Does the functionality of the accused products align with the patent's requirement of using a "plurality of narrow band carrier frequencies...transmitted in a binary code," or is there a fundamental mismatch in how the accused systems encode and transmit data?