XR Communications LLC v. Nokia Of America Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: XR Communications, LLC, dba Vivato Technologies (Delaware)
  • Defendant: Nokia of America Corporation (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 2:26-cv-00001, E.D. Tex., 01/05/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is registered to do business in Texas, has transacted business in the District, has committed alleged acts of infringement in the District, and maintains regular and established places of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s Wi-Fi 7 networking products infringe a patent related to coordinating signal transmissions and receptions among multiple co-located access points to prevent interference.
• Technical Context: The technology addresses signal collision and interference in dense wireless environments, a foundational challenge for modern high-throughput standards like Wi-Fi 7 that utilize multiple communication links simultaneously.
• Key Procedural History: The complaint alleges that Defendant has had knowledge of the asserted patent through at least a prior case, Case No. 2:23-cv-202, a fact which may be relevant to the allegations of indirect and willful infringement.

Case Timeline

Date	Event
2002-11-04	’939 Patent Priority Date
2012-10-16	’939 Patent Issue Date
2026-01-05	Complaint Filing Date

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

U.S. Patent No. 8,289,939 - "Signal Communication Coordination"

• Patent Identification: U.S. Patent No. 8,289,939, "Signal Communication Coordination", issued October 16, 2012.

The Invention Explained

• Problem Addressed: The patent addresses the problem of signal "thrashing" and interference in wireless networks, which occurs when multiple access points with overlapping coverage areas attempt to transmit and receive signals simultaneously, causing packet collisions and degrading network performance (Compl. ¶7; ’939 Patent, col. 1:63 - col. 2:5).
• The Patented Solution: The invention is an access station containing "signal transmission/reception coordination logic." This logic monitors multiple co-located access points. When it ascertains that one access point is receiving a signal (e.g., an uplink packet from a user device), it can "restrain" other access points from transmitting signals (e.g., downlink packets) that would otherwise cause interference, thereby coordinating activity to protect the integrity of ongoing communications (’939 Patent, Abstract; col. 5:58 - col. 6:8; Fig. 4).
• Technical Importance: This coordination mechanism allows for more efficient and reliable operation in crowded radio frequency environments, a critical capability for deploying high-density wireless networks (’939 Patent, col. 2:6-10).

Key Claims at a Glance

• The complaint asserts independent claim 30 (Compl. ¶25).
• The essential elements of Claim 30 are:
  • A wireless input/output (I/O) unit that establishes a plurality of access points.
  • Signal transmission/reception coordination logic that ascertains a first access point is receiving a first signal on a first channel.
  • The logic is adapted to restrain at least a second access point from transmitting a second signal on a second channel different from the first channel in response to the reception on the first channel.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies "Wi-Fi 7 access points, gateways, beacons, extenders, and routers" as the Accused Products (Compl. ¶25). Specific examples include the Nokia Wi-Fi Beacon G19.1, Nokia FastMile 5G Gateway series, and Nokia ONT XS-2437X-B (Compl. ¶25).

Functionality and Market Context

• The complaint alleges these products utilize "Wi-Fi 7 multi-link operation functionalities" (Compl. ¶26). This refers to a key feature of the Wi-Fi 7 standard (IEEE 802.11be) that allows a single device to transmit and receive data simultaneously across multiple frequency bands or channels to increase throughput and reduce latency. The complaint alleges these products are used in "wireless communications systems" (Compl. ¶26).

IV. Analysis of Infringement Allegations

The complaint references an "Exhibit 1" containing exemplary claim charts, but this exhibit was not filed with the complaint (Compl. ¶28). The narrative infringement theory alleges that Nokia’s Wi-Fi 7 products, by implementing multi-link operation, necessarily perform the coordination claimed in the ’939 Patent. To manage simultaneous transmissions and receptions across different channels without interference, the products must contain logic that monitors activity on one link (channel) and controls or restrains transmissions on another, thereby allegedly meeting the limitations of claim 30 (Compl. ¶¶25-26). The complaint, however, does not provide specific technical details on how the accused products perform this coordination.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The dispute may turn on whether the routine coordination functions inherent in the Wi-Fi 7 standard's multi-link operation (MLO) fall within the scope of the patent's term "signal transmission/reception coordination logic."
  • Technical Questions: A central factual question will be whether the accused Nokia products actually "restrain" transmission on a different channel in response to reception on a first channel, as specifically required by claim 30. Evidence will be needed to show that the accused MLO functionality performs this specific type of inter-channel coordination, rather than merely performing standard collision avoidance on each individual channel independently.

V. Key Claim Terms for Construction

• The Term: "signal transmission/reception coordination logic"

• Context and Importance: This term defines the core inventive component. Its construction will determine what type of hardware or software architecture meets the claim limitation. A broad definition could cover a wide range of control systems, while a narrow one might limit it to the specific embodiments disclosed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the logic "may be implemented as hardware, software, firmware, some combination thereof, and so forth," suggesting it is not limited to a specific physical structure (’939 Patent, col. 5:34-37).
  • Evidence for a Narrower Interpretation: A defendant may argue the term should be limited by the more detailed embodiment described, which includes a "MAC coordinator logic" that processes specific "receive indicators" from baseband units, suggesting a more complex and specific system (’939 Patent, col. 6:55-58; Fig. 6).

• The Term: "restrain"

• Context and Importance: The meaning of "restrain" is critical to establishing infringement. The parties will likely dispute the degree of control or prevention required to meet this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent explicitly defines restraining broadly to include "limiting, preventing, delaying, etc.," which could encompass a wide variety of traffic management or scheduling actions, not just complete prohibition of transmission (’939 Patent, col. 6:6-8).
  • Evidence for a Narrower Interpretation: A defendant may argue that in the context of the invention's goal to prevent signal "thrashing," the term implies a more direct and preventative action, rather than mere modulation or delay of a signal for general traffic-shaping purposes (’939 Patent, col. 1:28-33).

• The Term: "a second channel different from the first channel"

• Context and Importance: This limitation in claim 30 is highly specific and raises the technical bar for infringement. It requires proof of cross-channel coordination. Practitioners may focus on this term because standard collision avoidance typically operates on a single channel.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent contemplates this exact scenario, noting that "If the different channels are adjacent and/or not sufficiently-well defined, it may be beneficial to restrain transmission on a first channel...even when receiving a wireless communication on a second different channel," supporting the technical feasibility and necessity of this feature (’939 Patent, col. 6:43-49).
  • Evidence for a Narrower Interpretation: The primary problem described in the patent relates to collisions that occur when uplink and downlink transmissions happen on the same channel. A defendant might argue that the cross-channel restraint is a secondary consideration and that the claim term should be construed in light of a primary purpose of same-channel coordination, potentially requiring a high degree of inter-channel interference before restraint is warranted.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant’s alleged knowledge of the ’939 Patent from prior litigation (Case No. 2:23-cv-202) and its subsequent actions of providing user manuals, technical specifications, and other materials that allegedly instruct customers on how to use the accused "Wi-Fi 7 multi-link operation functionalities" (Compl. ¶26).
• Willful Infringement: The willfulness allegation is predicated on alleged pre-suit knowledge of the ’939 Patent from the same prior litigation, asserting that Defendant "has known or has been willfully blind to the fact that" its actions would constitute infringement (Compl. ¶¶26, 33).

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

• A core issue will be one of definitional scope: How will the court construe "signal transmission/reception coordination logic"? Will the term be interpreted broadly to read on the standardized multi-link operation (MLO) controllers in Nokia's Wi-Fi 7 products, or will it be narrowed to the specific "MAC coordinator logic" architecture detailed in the patent's embodiments?
• A key evidentiary question will be one of technical proof: Can the Plaintiff provide evidence that the accused products perform the specific function required by Claim 30—restraining a transmission on a second, different channel in direct response to a signal reception on a first channel? The case may depend on whether discovery reveals this specific cross-channel control mechanism in the operation of Nokia's products.