DCT

2:25-cv-01206

Bison Patent Licensing LLC v. LG Electronics Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01206, E.D. Tex., 12/10/2025
  • Venue Allegations: Plaintiff alleges venue is proper for LG Electronics Inc. as a foreign corporation and for LG Electronics U.S.A., Inc. based on its commission of alleged infringing acts and maintenance of a regular and established place of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, private 5G network solutions, and smart televisions infringe eight U.S. patents related to wireless network authentication, mobile device location, data communication architecture, and digital rights management.
  • Technical Context: The patents-in-suit address a range of technologies fundamental to modern consumer electronics, including secure ad hoc networking, location-based services, efficient data handling in wireless networks, and content protection.
  • Key Procedural History: The complaint does not reference any prior litigation involving the patents-in-suit, any administrative proceedings such as inter partes review, or any prior licensing history.

Case Timeline

Date Event
2004-12-28 Priority Date for U.S. Patent No. 7,571,313
2007-10-12 Priority Date for U.S. Patent No. 8,576,781
2007-10-12 Priority Date for U.S. Patent No. 8,855,058
2008-10-06 Priority Date for U.S. Patent No. 8,331,956
2009-08-04 U.S. Patent No. 7,571,313 Issued
2010-12-09 Priority Date for U.S. Patent No. 8,489,122
2012-03-14 Priority Date for U.S. Patent No. 9,106,979
2012-12-11 U.S. Patent No. 8,331,956 Issued
2013-07-16 U.S. Patent No. 8,489,122 Issued
2013-09-09 Priority Date for U.S. Patent No. 9,693,030
2013-11-05 U.S. Patent No. 8,576,781 Issued
2014-10-07 U.S. Patent No. 8,855,058 Issued
2015-03-30 Priority Date for U.S. Patent No. 10,162,944
2015-08-11 U.S. Patent No. 9,106,979 Issued
2017-06-27 U.S. Patent No. 9,693,030 Issued
2018-12-25 U.S. Patent No. 10,162,944 Issued
2025-12-10 Complaint Filed

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

U.S. Patent No. 7,571,313 - "Authentication for Ad Hoc Network Setup," Issued August 4, 2009

The Invention Explained

  • Problem Addressed: The patent describes a need for a method to authenticate devices to establish a secure ad hoc network, particularly in scenarios like emergency response where devices from different services (e.g., fire, police) must quickly form a single, secure network while preventing attackers from joining or monitoring it (’313 Patent, col. 1:26-48).
  • The Patented Solution: The invention proposes a two-factor authentication method. A device first receives a "pre-emergency security configuration" (e.g., a digital certificate issued by a regional authority). Upon arriving at an emergency site, the device must then receive a second, location-based "emergency security configuration" from a trusted master device in close proximity. A network is formed only between devices that possess both the pre-approved and the on-site, location-verified configurations (’313 Patent, col. 2:15-26, 3:46-4:2).
  • Technical Importance: This approach enabled the rapid deployment of temporary, secure wireless networks by combining a persistent credential with a transient, location-specific credential, intended to enhance security in dynamic environments (’313 Patent, col. 1:39-41).

Key Claims at a Glance

  • Asserted Independent Claim: Claim 1.
  • Elements of Claim 1:
    • receiving a first security configuration into the first node;
    • receiving a second security configuration based on location into the first node after the first security configuration is verified;
    • authenticating at least a second node already having both the first and the second security configurations;
    • wherein both the first and the second security configurations are used in the authenticating step in order to form a network with the at least a second node.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,331,956 - "System and Method of UMTS UE Location Using Uplink Dedicated Physical Control Channel and Downlink Synchronization Channel," Issued December 11, 2012

The Invention Explained

  • Problem Addressed: The patent addresses the need to provide location-based services for mobile phone users, which requires accurately and efficiently determining the location of a mobile device (User Equipment or "UE") within a wireless network (’956 Patent, col. 2:52-56; Compl. ¶13).
  • The Patented Solution: The invention describes a two-stage search method to estimate a device's location. First, a location measurement unit (LMU) performs a broad search for the device's signal within a large search window to get a first, approximate Time of Arrival (TOA). This first TOA is then used to define a much narrower second search window. The LMU then performs a more refined, high-gain search within this smaller window to determine a more accurate second TOA, which is used to calculate the device's location (’956 Patent, col. 5:20-35; Abstract).
  • Technical Importance: This method improves the efficiency of locating a device by reducing a large timing uncertainty (e.g., 38,400 chips) to a much smaller one (e.g., 128 chips), allowing for a more computationally intensive and accurate measurement to be performed only within a limited, relevant window (’956 Patent, col. 7:20-29).

Key Claims at a Glance

  • Asserted Independent Claim: Claim 1.
  • Elements of Claim 1:
    • collecting a plurality of signal samples from a first wireless device and a second wireless device by one or more LMUs in a first search window;
    • determining a first time of arrival ("TOA") from the plural signal samples;
    • determining a second search window as a function of the first TOA;
    • determining a second TOA from the plural signal samples in the second search window; and
    • determining an estimated location of the first wireless device as a function of the first TOA or the second TOA.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,489,122 - "System and Method for Total Flight Time Ratio Pattern Matching," Issued July 16, 2013

  • Technology Synopsis: The patent addresses the need for technologies to determine a mobile device's location while combating multipath effects, where signals are distorted by reflections (Compl. ¶16; '122 Patent, col. 1:39-41). The proposed solution involves determining the range of a mobile device to a reference station and comparing that measured relationship against a database of pre-calculated "grid points," each with its own expected range metric, to find the best match and thereby determine the device's location ('122 Patent, Abstract).
  • Asserted Claims: Claim 15 (Compl. ¶45).
  • Accused Features: LG smartphones supporting 802.11mc (Compl. ¶45).

U.S. Patent No. 8,576,781 - "Femtocell Architecture in Support of Voice and Data Communications," Issued November 5, 2013

  • Technology Synopsis: The patent describes a need for improved data handling efficiency in wireless traffic (Compl. ¶19). It proposes a femtocell architecture where data traffic is carried in a native IP packet to a gateway, enhancing efficiency, while voice traffic is tunneled to a Mobile Switching Center ('781 Patent, Abstract; col. 2:62-67). This separation is designed to improve data performance without requiring extra burdens on the base station.
  • Asserted Claims: Claim 1 (Compl. ¶51).
  • Accused Features: LG Private 5G Network (Compl. ¶51).

U.S. Patent No. 8,855,058 - "Wireless Architecture in Support of Voice and Data Communications," Issued October 7, 2014

  • Technology Synopsis: The patent addresses enhancing data handling efficiency by reducing protocol and processing overhead on base stations ('058 Patent, col. 2:62-67; Compl. ¶22). The invention discloses a wireless architecture where a base station, for data traffic, terminates Iu-b signals from user equipment, strips the IP payload, and sends it directly inside an IPsec tunnel to a gateway, bypassing the need to encapsulate it in GTP as defined over Iu-ps ('058 Patent, Claim 6).
  • Asserted Claims: Claim 12 (Compl. ¶55).
  • Accused Features: LG Private 5G Network (Compl. ¶55).

U.S. Patent No. 9,106,979 - "Sentiment Mapping in a Media Content Item," Issued August 11, 2015

  • Technology Synopsis: The patent addresses the technical problem of how to effectively associate and recommend media content based on more granular data than genre or actors (Compl. ¶25). The invention proposes creating a "sentiment map" that delimits segments of a content item (e.g., a movie scene) and associates them with sentiment-state keywords (e.g., "happy," "exciting"). These maps can then be compared to provide more meaningful and contextually appropriate recommendations ('979 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶60).
  • Accused Features: LG Channels (Compl. ¶60).

U.S. Patent No. 9,693,030 - "Generating Alerts Based Upon Detector Outputs," Issued June 27, 2017

  • Technology Synopsis: The patent describes a system for providing an improved video processing and enhanced viewing experience ('030 Patent, Abstract; Compl. ¶28). The system allows a user to select a region of a video display to monitor for a "triggering item" (e.g., a specific word or name). When the system detects the item in textual data corresponding to that region, it can generate an alert ('030 Patent, Abstract).
  • Asserted Claims: Claims 1, 2, 5, 9, and 11 (Compl. ¶66).
  • Accused Features: LG smartphones with "tracking focus," including the LG G8 ThinQ (Compl. ¶66).

U.S. Patent No. 10,162,944 - "Library Style Media DRM APIs in a Hosted Architecture," Issued December 25, 2018

  • Technology Synopsis: The patent addresses improvements in digital rights management (DRM) technology ('944 Patent, col. 1:12-15; Compl. ¶31). It discloses a system where a server-side application can proactively issue multiple DRM licenses to a client application in a single transaction, including licenses that were not explicitly requested but may be relevant based on "license cues," to support prefetching ('944 Patent, col. 1:56-62).
  • Asserted Claims: Claim 1 (Compl. ¶72).
  • Accused Features: LG smart televisions (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies several categories of accused instrumentalities:
    • LG smartphones, including at least the LG G8 ThinQ and LG G8X ThinQ (Compl. ¶33, ¶39, ¶45, ¶66).
    • LG Private 5G Network solutions (Compl. ¶51, ¶55).
    • LG Channels, identified as a service or feature (Compl. ¶60).
    • LG smart televisions (Compl. ¶72).

Functionality and Market Context

  • The complaint alleges infringement based on specific technical standards and features supported by the accused products.
    • The accused smartphones are alleged to support WiFi TDLS (Tunneled Direct Link Setup), the 802.11mc wireless standard (which includes location-finding capabilities), and a "tracking focus" feature for video (Compl. ¶33, ¶39, ¶45, ¶66).
    • The complaint does not provide sufficient detail for analysis of the functionality of the LG Private 5G Network, LG Channels, or LG smart televisions. For each, it makes a conclusory allegation of infringement and refers to an external, unprovided exhibit (Compl. ¶51, ¶55, ¶60, ¶72).
    • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement for all eight patents-in-suit. For each asserted claim, the complaint states that a detailed infringement analysis is provided in a corresponding preliminary claim chart (Exhibits I-P), none of which were filed with the complaint itself (Compl. ¶33, ¶39, ¶45, ¶51, ¶55, ¶60, ¶66, ¶72). The body of the complaint does not contain a narrative mapping of accused functionalities to specific claim elements.

'313 Patent Infringement Allegations

  • The complaint alleges that LG smartphones supporting WiFi TDLS infringe at least claim 1 (Compl. ¶33).
  • Identified Points of Contention: The central dispute may concern whether the process of establishing a WiFi TDLS connection meets the limitations of claim 1. A primary technical question is whether the TDLS setup protocol involves receiving a "second security configuration based on location" after verifying a "first security configuration," as required by the claim. The analysis may explore whether any location-aware information is used during authentication or if the security is based on other factors.

'956 Patent Infringement Allegations

  • The complaint alleges that LG smartphones supporting the 802.11mc standard infringe at least claim 1 (Compl. ¶39).
  • Identified Points of Contention: The analysis will likely focus on the specific steps of the location-finding methods within the 802.11mc standard. A key question will be whether these methods perform the claimed two-step process: determining a first TOA in a broad search window and then using that result to define a second, narrower search window for determining a second TOA. The dispute may turn on evidence of how the accused devices' software and hardware actually implement the 802.11mc protocol.

V. Key Claim Terms for Construction

For the ’313 Patent

  • The Term: "security configuration based on location" (from Claim 1).
  • Context and Importance: This term is central to the inventive concept of adding a location-based factor to network authentication. The infringement analysis for WiFi TDLS will depend on whether any part of its authentication handshake can be characterized as a security configuration that is "based on location."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional and does not specify a particular method for being "based on location." The specification notes the configuration is received based upon the location of the node "e.g., with respect to a master device" (’313 Patent, col. 2:23-24), which suggests the master device is an example, not a requirement.
    • Evidence for a Narrower Interpretation: The patent’s background and detailed description are heavily focused on the context of an "emergency site" where a "master device" provides the second configuration to nodes "within a predetermined proximity" (’313 Patent, col. 2:19-21, 3:35-41). A party could argue the term's meaning is tethered to this specific embodiment of physical proximity to a temporary, on-site authority.

For the ’956 Patent

  • The Term: "determining a second search window as a function of the first TOA" (from Claim 1).
  • Context and Importance: This term defines the sequential, two-step search process. Infringement will require evidence that the accused 802.11mc implementation uses the result of an initial, broad search to constrain a subsequent, finer search, rather than simply performing a single search or an unrelated series of searches.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim requires only that the second window be "a function of" the first TOA, a broad mathematical relationship. The specification supports this by describing the goal as reducing "timing uncertainty from 3000 km to a few km," a functional outcome not tied to a specific algorithm (’956 Patent, col. 5:29-31).
    • Evidence for a Narrower Interpretation: The patent consistently describes the invention in the context of UMTS cellular networks and the specific technical parameters associated with them (e.g., DPCCH fields, 38400 chips per frame) (’956 Patent, col. 7:1-15, Abstract). An argument may be made that the claim terms should be construed in light of this specific technological environment, potentially limiting their applicability to different standards like 802.11mc.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement only for the ’944 Patent. The allegation is based on Defendant's sale of accused smart TVs to customers and the distribution of "product literature or videos inducing end users and others to use the accused products in a manner that infringes" (Compl. ¶74).

Willful Infringement

  • The complaint does not contain a formal count for willful infringement. However, for the ’944 Patent, it alleges that Defendant has had knowledge of its infringement "at least since receiving notice of its infringement by service of Plaintiff's complaint" and has "actively, knowingly, and intentionally continued to induce infringement" (Compl. ¶74). This allegation of post-suit knowledge could form the basis for a later claim of willfulness or a request for enhanced damages. No pre-suit knowledge is alleged for any of the patents-in-suit.

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

  • A primary issue will be one of evidentiary sufficiency: The complaint’s infringement allegations rely entirely on unprovided external claim charts. A threshold question for the case will be whether the Plaintiff can produce technical evidence sufficient to map the specific, real-world operations of the accused products—such as the WiFi TDLS protocol or the 802.11mc location-finding implementation—to the discrete elements recited in the asserted claims.
  • A central legal question will be one of contextual scope and claim construction: The case may turn on whether claim terms rooted in the technological context in which the patents were drafted (e.g., "location-based security" for emergency ad-hoc networks in the ’313 Patent; TOA search windows in UMTS cellular systems for the ’956 Patent) can be construed to read on the different functionalities implemented in modern, multi-purpose consumer electronics standards.