DCT

2:25-cv-01257

CommWorks Solutions LLC v. Renesas Electronics Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01257, E.D. Tex., 12/30/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a resident of the United States and may be sued in any judicial district. The complaint further notes that Defendant has not contested venue in prior patent infringement actions in the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s Systems-on-Chips (SoCs) and related devices that support various Wi-Fi functionalities infringe seven U.S. patents concerning time-based wireless device provisioning, network traffic management, and scalable media access control for mesh networks.
  • Technical Context: The technologies at issue relate to simplifying the setup process for new wireless devices on a network and methods for prioritizing and managing data traffic to ensure network efficiency and quality of service.
  • Key Procedural History: The complaint notes three prior patent infringement cases filed against Renesas in the Eastern District of Texas where Renesas did not contest venue, potentially to preemptively counter a motion to dismiss on venue grounds. The asserted patents appear to fall into three families related to time-based provisioning, contention-free traffic detection, and scalable media access control.

Case Timeline

Date Event
1999-12-17 U.S. Patent No. RE44,904 Priority Date
2002-06-11 U.S. Patent No. 7,027,465 Priority Date
2003-01-13 U.S. Patent No. 6,891,807 Priority Date
2004-10-08 U.S. Patent No. 7,177,285 Priority Date
2005-05-10 U.S. Patent No. 6,891,807 Issue Date
2006-04-11 U.S. Patent No. 7,027,465 Issue Date
2007-02-09 U.S. Patent No. 7,463,596 Priority Date
2007-02-13 U.S. Patent No. 7,177,285 Issue Date
2008-11-25 U.S. Patent No. 7,911,979 Priority Date
2008-12-09 U.S. Patent No. 7,463,596 Issue Date
2011-03-22 U.S. Patent No. 7,911,979 Issue Date
2011-07-19 U.S. Patent No. 7,911,979 Certificate of Correction Issued
2013-11-26 U.S. Patent No. 9,554,304 Priority Date
2014-05-20 U.S. Patent No. RE44,904 Reissue Date
2017-01-24 U.S. Patent No. 9,554,304 Issue Date
2025-12-30 Complaint Filing Date

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

U.S. Patent No. 7,177,285 - *“Time Based Wireless Access Provisioning,”* Issued February 13, 2007

The Invention Explained

  • Problem Addressed: The patent describes that, at the time of the invention, provisioning wireless devices to a network was often impractical (Compl. ¶24). This was particularly true for devices lacking a user interface, which would require a user to manually transcribe identification information like a MAC address to an access point, a process requiring technical proficiency (’285 Patent, col. 3:13-26).
  • The Patented Solution: The invention provides a time-based method for simplifying this process. A network access point tracks an "operating parameter" of a wireless device, such as the onset of its signal transmission (’285 Patent, Abstract). A user then activates a provisioning mode on the access point. If the device's tracked parameter occurred within a predefined "time interval" relative to the activation, the system initiates provisioning automatically, thereby securely adding the device to the network (’285 Patent, col. 4:8-12; Compl. ¶25).
  • Technical Importance: This method obviated the need for a dedicated user interface on a wireless device for network setup and lowered the technical barrier for users to add new devices to a home or local network (Compl. ¶25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶27).
  • The essential elements of claim 1 are:
    • Tracking an operating parameter of the wireless device within a service area, wherein the operating parameter comprises an onset of a signal transmission of the wireless device.
    • Initiating provisioning of the wireless device if the tracked operating parameter occurs within a time interval.
  • The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶26).

U.S. Patent No. 7,463,596 - *“Time Based Wireless Access Provisioning,”* Issued December 9, 2008

The Invention Explained

  • Problem Addressed: Similar to the '285 patent, this patent addresses the cumbersome and impractical nature of provisioning wireless devices, especially those lacking user interfaces suitable for communicating provisioning information (’596 Patent, col. 3:13-36; Compl. ¶38).
  • The Patented Solution: The invention claims a process for associating devices based on a temporal correlation. The system tracks an operating parameter of a first device—either its power-on event or the onset of its signal transmission. If this event occurs within a specified time interval, the system automatically associates the first device with at least one other device on the network (’596 Patent, Abstract; col. 4:32-37).
  • Technical Importance: The invention offers an improved method for network provisioning that requires minimal device hardware and user proficiency, enabling devices to be readily associated while preventing unauthorized devices from gaining access (Compl. ¶39).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶41).
  • The essential elements of claim 1 are:
    • Tracking an operating parameter of a first device, wherein the operating parameter comprises any of a power on of the first device, and an onset of a signal transmission of the first device.
    • Automatically associating the first device with at least one other device if the tracked operating parameter occurs within a time interval.
  • The complaint alleges infringement of "one or more claims" of the ’596 patent, reserving the right to assert others (Compl. ¶40).

U.S. Patent No. 7,911,979 - *“Time Based Access Provisioning System And Process,”* Issued March 22, 2011

  • Technology Synopsis: This patent, part of the same family as the ’285 and ’596 patents, describes a system and process for time-based wireless access provisioning. The invention aims to improve upon existing systems by enabling provisioning without requiring a complex user interface and by integrating with easily monitored device parameters, such as power-on or signal transmission, to establish secure communication (Compl. ¶¶ 52, 53).
  • Asserted Claims: At least independent claim 1 (Compl. ¶55).
  • Accused Features: Renesas chips, SoCs, and devices supporting Wi-Fi Protected Setup (WPS) functionality (the "Renesas WPS Products") are accused of infringement (Compl. ¶¶ 46, 56).

U.S. Patent No. RE44,904 - *“Method For Contention Free Traffic Detection,”* Reissued May 20, 2014

  • Technology Synopsis: This patent addresses inefficiencies in network traffic routing. At the time of the invention, differentiating traffic based on priority was complex and processor-intensive for low-cost access points, as it required analyzing all headers in all data frames (Compl. ¶66). The invention provides a method to easily distinguish priority traffic by extracting a bit pattern from a predetermined position in a frame and comparing it with a search pattern, thereby allowing low-cost access points to route priority traffic more efficiently (Compl. ¶67).
  • Asserted Claims: At least independent claim 1 (Compl. ¶69).
  • Accused Features: Renesas chips, devices, and software supporting Wi-Fi Multimedia (WMM) and 802.11-2007+ functionality (the "Renesas Wi-Fi Multimedia Products") are accused of infringement (Compl. ¶¶ 60, 70).

U.S. Patent No. 7,027,465 - *“Method For Contention Free Traffic Detection,”* Issued April 11, 2006

  • Technology Synopsis: This patent relates to the same technical problem as the ’904 patent: the difficulty for low-cost access points to identify and prioritize network traffic, which required complex processing of all frame headers (Compl. ¶80). The invention provides a method to detect priority frames by extracting a bit pattern from a predetermined position (defined by an offset) in a data frame and comparing it to a search pattern, improving the efficiency of priority traffic handling (Compl. ¶81).
  • Asserted Claims: At least independent claim 1 (Compl. ¶83).
  • Accused Features: Renesas chips, devices, and software supporting WMM and 802.11-2007+ functionality are accused of infringement (Compl. ¶¶ 74, 84).

U.S. Patent No. 6,891,807 - *“Time Based Wireless Access Provisioning,”* Issued May 10, 2005

  • Technology Synopsis: As a parent to the ’285 and ’596 patents, this patent discloses a system for time-based network access provisioning. It addresses the impracticality of provisioning devices that lack a user interface (Compl. ¶94). The claimed system includes a network access point with logic for tracking the operation of a wireless device and provisioning it if that operation occurs within an activatable time interval, simplifying the setup process (Compl. ¶¶ 95, 98).
  • Asserted Claims: At least independent claim 17 (Compl. ¶96).
  • Accused Features: Renesas chips, SoCs, and devices supporting WPS functionality are accused of infringement (Compl. ¶¶ 88, 97).

U.S. Patent No. 9,554,304 - *“Scalable Media Access Control for Multi-Hop High Bandwidth Communications,”* Issued January 24, 2017

  • Technology Synopsis: This patent addresses challenges in multi-hop wireless networks (mesh networks), where end-to-end resource allocation was impractical, leading to communication errors when routing protocols selected paths without sufficient resources (Compl. ¶107). The invention provides a scalable media access control (MAC) for wireless mesh networks that avoids resource reservation conflicts to prevent performance degradation as the network grows, integrating resource allocation with layer-2 routing (Compl. ¶108).
  • Asserted Claims: At least independent claim 1 (Compl. ¶109).
  • Accused Features: Renesas chips, SoCs, and devices supporting Wi-Fi Mesh functionality (the "Wi-Fi Mesh Products") are accused of infringement (Compl. ¶¶ 101, 110).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies three categories of accused products: "Renesas Wi-Fi Multimedia Products," "Renesas WPS Products," and "Wi-Fi Mesh Products" (Compl. ¶¶ 5, 6). These categories encompass a broad range of Renesas Systems-on-Chips (SoCs), devices, and reference designs, including the CL8000 product family, DA16200, and FC9000, among many others (Compl. ¶¶ 5, 6).

Functionality and Market Context

  • The accused products are alleged to be semiconductor components that provide functionality compliant with established industry standards, namely Wi-Fi Multimedia (WMM), Wi-Fi Protected Setup (WPS), and Wi-Fi Mesh (Compl. ¶¶ 5, 6). The complaint alleges that Renesas develops, manufactures, and sells these infringing products in the United States through an established distribution channel, where they are incorporated into downstream consumer and commercial electronic devices (Compl. ¶¶ 5, 10).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’285 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A process for provisioning between a wireless device and a network, comprising the steps of: tracking an operating parameter of the wireless device within a service area, wherein the operating parameter of the wireless device comprises an onset of a signal transmission of the wireless device; The Accused Products allegedly perform a process for provisioning between a wireless device and a network that includes tracking an operating parameter, such as the onset of signal transmission from the wireless device. ¶29 col. 3:50-53
and initiating provisioning of the wireless device if the tracked operating parameter occurs within a time interval. The Accused Products allegedly initiate provisioning if the tracked operating parameter is detected within a specific time interval, consistent with WPS functionality. ¶29 col. 4:8-12

’596 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A process for associating devices, comprising the steps of: tracking an operating parameter of a first device, wherein the operating parameter of the first device comprises any of a power on of the first device, and an onset of a signal transmission of the first device; The Renesas WPS Products are alleged to perform a process for associating devices that involves tracking an operating parameter, including power-on or the onset of signal transmission from a first device. ¶43 col. 3:50-58
and automatically associating the first device with at least one other device if the tracked operating parameter occurs within a time interval. The Accused Products allegedly perform the step of automatically associating the first device with another device if the tracked parameter occurs within a defined time interval. ¶43 col. 4:32-37

Identified Points of Contention

  • Scope Questions: The infringement allegations for the '285 and '596 patents map the functionality of the industry-standard Wi-Fi Protected Setup (WPS) protocol onto the claim language. A potential point of contention may be whether the specific sequence and timing defined by the WPS standard (e.g., a user pushing a button on an access point to open a two-minute window) falls within the scope of the patents' broader terms like "tracking an operating parameter" and occurring "within a time interval."
  • Technical Questions: The complaint alleges that the accused products "track" an operating parameter. A technical question may arise as to what evidence demonstrates that the accused access points or systems actively monitor for a "power on" or "onset of signal transmission" of a new device, as opposed to simply being receptive to a connection request initiated by the device during an open provisioning window. The sequence of events (e.g., whether the device powers on before or after the access point's provisioning mode is activated) may become a focus of dispute.

V. Key Claim Terms for Construction

The Term: "operating parameter" ('285 Claim 1; '596 Claim 1)

  • Context and Importance: This term's construction is critical because it defines the triggering event on the wireless device that the provisioning system tracks. Whether this term is construed broadly to cover any signal transmission or narrowly to cover only the initial power-on or signal from a new device could be dispositive for infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language in both patents states the parameter "comprises" an onset of signal transmission, which may suggest the list is not exhaustive and could include subsequent transmissions.
    • Evidence for a Narrower Interpretation: The background and detailed description of both patents consistently frame the invention in the context of provisioning a new device to a network for the first time, which may support an interpretation limiting the "operating parameter" to an initial event like a first power-on (’285 Patent, col. 3:8-18).

The Term: "time interval" ('285 Claim 1; '596 Claim 1)

  • Context and Importance: The definition of this term will be central to determining whether the fixed, standardized time windows used in protocols like WPS meet the claim limitation. Practitioners may focus on whether the "time interval" requires a specific relationship to the device's action, or if any predefined period of receptivity suffices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim term itself is generic and does not specify the duration, start, or end point of the interval, which may support a broad construction covering any defined period, such as the two-minute window common in WPS.
    • Evidence for a Narrower Interpretation: The specification and figures describe an "acceptance time interval" that is initiated by a user action and has a defined start and end time relative to that action (’285 Patent, Fig. 5, element 74; col. 4:4-7). This could be argued to require a specific sequence of events not present in all accused functionalities.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges that Defendant has indirectly infringed by contributing to and inducing infringement by third parties (Compl. ¶9). It further alleges that Defendant "provides information and assistance to its customers to enable them to use the Accused Products in an infringing manner" (Compl. ¶16). This suggests a theory of induced infringement based on customer-facing documentation or support materials.

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

  • A core issue will be one of mapping and scope: Can the functional steps of standardized protocols like Wi-Fi Protected Setup (WPS) and Wi-Fi Multimedia (WMM) be mapped directly onto the broader, more conceptual language of the asserted claims? The dispute may center on whether the specific, standardized operations of the accused products are coextensive with the patents' descriptions of "tracking an operating parameter" or "extracting a bit pattern."
  • A second key question will be one of temporal relationship and sequence: For the time-based provisioning patents, the case may turn on the precise sequence of events required by the claims versus the sequence performed by the accused WPS products. It raises the evidentiary question of whether the accused systems track a device event that occurs within a subsequent time interval, or merely open a time interval during which a device can independently initiate a connection.