DCT

4:24-cv-00624

Morris Routing Tech LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:24-cv-00624, E.D. Tex., 10/09/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendants maintaining regular and established places of business in the district, including Samsung Electronics America’s "Flagship North Texas Campus" in Plano, and having committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s 5G networking solutions, including its Software-Defined Networking (SDN), Radio Access Network (RAN), and Core solutions, infringe eight patents related to segment-based routing technology.
  • Technical Context: The dispute centers on segment routing (SR), a network traffic engineering technology that simplifies network operations by embedding routing paths into packet headers, which is a key enabling technology for 5G infrastructure.
  • Key Procedural History: The case was initiated as a First Amended Complaint, filed to add U.S. Patent No. 12,058,042, which was issued on August 6, 2024, after the filing of the initial complaint.

Case Timeline

Date Event
2012-12-27 Earliest Priority Date for Patents-in-Suit
2019-09-17 U.S. Patent No. 10,419,335 Issues
2019-11-12 U.S. Patent No. 10,476,788 Issues
2020-03-12 U.S. Patent No. 10,652,150 Issues
2020-03-17 U.S. Patent No. 10,594,594 Issues
2020-07-21 U.S. Patent No. 10,721,164 Issues
2020-08-04 U.S. Patent No. 10,735,306 Issues
2021-12-07 U.S. Patent No. 11,196,660 Issues
2024-08-06 U.S. Patent No. 12,058,042 Issues
2024-10-09 First Amended Complaint Filed

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

U.S. Patent No. 10,419,335 - Region Scope-Specific Outside-Scope Indentifier-Equipped Routing Methods, Systems, and Computer Program Products

The Invention Explained

  • Problem Addressed: The patent's background section describes problems arising from the internet's growth, such as network latency and the limitations of traditional IP addressing, which rigidly distinguishes between names (what is sought), addresses (where it is), and routes (how to get there) (Compl. ¶19; ’335 Patent, col. 1:6-47). Traditional routing required intermediate nodes to maintain extensive state information, leading to scalability issues (Compl. ¶18).
  • The Patented Solution: The invention provides a routing method where a packet header contains network path information that includes a "region scope-specific outside-scope identifier." This identifier, when processed by a node within a specific network region (a "scope"), identifies a second, external region of the network, allowing data to be transmitted to a path node outside the current region without the current node needing specific details about the destination's network interface (Compl. ¶¶ 20-21; ’335 Patent, Abstract, col. 3:1-20). This approach embeds routing logic into the packet itself, reducing the state-keeping burden on network nodes.
  • Technical Importance: This source-routing approach simplifies the network control plane and reduces the amount of state information that network nodes must maintain, which is a key principle of segment routing technology adopted in 5G networks (Compl. ¶¶ 24, 29).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶69).
  • The essential elements of claim 1, a non-transitory computer-readable medium with instructions for a node in a first network region, include:
    • receiving an indication of a receipt of a first packet specified according to an IP network protocol;
    • identifying, from the packet's header, network path information that includes a "region scope-specific outside-scope identifier";
    • This identifier is in a space specific to the current node, does not include a network interface identifier portion specified by the IP protocol, and identifies a second region of the network;
    • causing transmission of data from the current node to a path node (not in the first region) via a path segment that couples the current node and the second region.
  • The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶70).

U.S. Patent No. 10,476,788 - Outside-Scope Identifier-Equipped Routing Methods, Systems, and Computer Program Products

The Invention Explained

  • Problem Addressed: Like the ’335 Patent, the ’788 Patent addresses the scalability and latency problems of traditional IP routing, where routing decisions are made hop-by-hop based on routing tables, requiring each node to maintain significant state information (Compl. ¶17; ’788 Patent, col. 1:6-45).
  • The Patented Solution: This patent describes a method where a packet header includes a destination IP address and a first "outside-scope identifier." This identifier is specific to a first network region and identifies a second region containing a path node. The invention uses both the destination IP address and this outside-scope identifier to transmit data along a path segment toward the destination ('788 Patent, Abstract, col. 3:1-23). This allows a packet's path to be defined by a sequence of identifiers encoded by the source, simplifying intermediate router functions.
  • Technical Importance: The technology facilitates source routing where the packet itself dictates its path, a core concept of segment routing that reduces network complexity and improves traffic engineering capabilities, particularly for modern 5G networks (Compl. ¶¶ 20, 26, 29).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶77).

  • The essential elements of claim 1, a method performed at a node in a first network region, include:

    • receiving an indication of a receipt of a first packet specified according to an IP protocol;
    • identifying, from the packet's header, network path information including a destination IP address and a first "outside-scope identifier";
    • The identifier is in a space specific to the first region and identifies, for that region, a second region that includes a path node;
    • using the destination IP address and the outside-scope identifier to cause transmission of data via a first path segment that includes the current node and the receiving node.

  • The complaint reserves the right to assert additional claims (Compl. ¶78).

  • Multi-Patent Capsule: U.S. Patent No. 10,594,594

    • Patent Identification: U.S. Patent No. 10,594,594, Routing Methods, Systems, and Computer Program Products, issued March 17, 2020.
    • Technology Synopsis: The patent addresses scalability problems in traditional IP/MPLS networks where state information must be maintained at all hops (Compl. ¶18). The solution allows a source to choose a path and encode it in the packet header as a sequence of segment identifiers, reducing the need for network nodes to maintain per-flow state and simplifying the network architecture (Compl. ¶¶ 20-21).
    • Asserted Claims: At least independent claim 1 (Compl. ¶85).
    • Accused Features: Samsung's networking solutions that support segment routing, including SR-MPLS and SRv6 (Compl. ¶¶ 60-64).

  • Multi-Patent Capsule: U.S. Patent No. 10,652,150

    • Patent Identification: U.S. Patent No. 10,652,150, Routing Methods, Systems, and Computer Program Products, issued March 12, 2020.
    • Technology Synopsis: This patent describes routing methods based on a "path-based protocol address" to overcome prior art limitations where Internet protocol dealt primarily with addresses and left mapping to other layers (Compl. ¶19). The invention allows a source to encode a path in a packet header as a sequence of identifiers, simplifying the control plane and reducing state management in routers (Compl. ¶¶ 20, 24).
    • Asserted Claims: At least independent claim 1 (Compl. ¶93).
    • Accused Features: Samsung's networking solutions that support segment routing and path-based protocol addresses (Compl. ¶¶ 60-64).

  • Multi-Patent Capsule: U.S. Patent No. 10,721,164

    • Patent Identification: U.S. Patent No. 10,721,164, Routing Methods, Systems, and Computer Program Products with Multiple Sequences of Identifiers, issued July 21, 2020.
    • Technology Synopsis: The patent discloses routing methods that improve upon traditional IP/MPLS networks by using source routing where the packet’s path is identified in the packet itself (Compl. ¶¶ 17, 20). This approach reduces reliance on control protocols and the per-flow state that needs to be maintained in network nodes, thereby enhancing scalability and flexibility (Compl. ¶¶ 20-21).
    • Asserted Claims: At least independent claim 1 (Compl. ¶101).
    • Accused Features: Samsung's networking solutions that utilize source routing and segment-based path identification, such as SR-MPLS and SRv6 (Compl. ¶¶ 60-64).

  • Multi-Patent Capsule: U.S. Patent No. 10,735,306

    • Patent Identification: U.S. Patent No. 10,735,306, Routing Methods, Systems, and Computer Program Products, issued August 4, 2020.
    • Technology Synopsis: The patent describes routing based on path information contained within a packet header, which allows for precise traffic control and dynamic routing that can respond to network disruptions (Compl. ¶¶ 27-28). This contrasts with prior art methods that relied on complex control protocols and hop-by-hop routing decisions, which were less scalable and flexible (Compl. ¶¶ 17-18).
    • Asserted Claims: At least independent claim 27 (Compl. ¶109).
    • Accused Features: Samsung's networking solutions that implement segment routing for traffic engineering and control in 5G networks (Compl. ¶¶ 29, 60-64).

  • Multi-Patent Capsule: U.S. Patent No. 11,196,660

    • Patent Identification: U.S. Patent No. 11,196,660, Routing Methods, Systems, and Computer Program Products, issued December 7, 2021.
    • Technology Synopsis: This patent addresses the complexity and scalability problems of traditional traffic engineering by using segment-based routing (Compl. ¶30). The invention allows a packet's path to be identified in the packet itself, which simplifies the control plane, reduces state information in network nodes, and enables capabilities like service chaining and network slicing (Compl. ¶¶ 20, 24, 29).
    • Asserted Claims: At least independent claim 11 (Compl. ¶117).
    • Accused Features: Samsung's networking solutions that support segment routing technologies like SRv6 and SR-MPLS, particularly in the context of 5G network slicing (Compl. ¶¶ 29, 49, 60-64).

  • Multi-Patent Capsule: U.S. Patent No. 12,058,042

    • Patent Identification: U.S. Patent No. 12,058,042, Routing Methods, Systems, and Computer Program Products, issued August 6, 2024.
    • Technology Synopsis: The patent relates to segment-based routing where the path is encoded in the packet header, reducing reliance on control protocols like LDP or RSVP-TE (Compl. ¶20). The technology simplifies network architecture and improves scalability by removing the need for intermediate nodes to maintain per-application and per-flow state, instead having them obey the forwarding information provided in the packet (Compl. ¶20).
    • Asserted Claims: At least independent claim 1 (Compl. ¶125).
    • Accused Features: Samsung's networking solutions that support segment routing over MPLS and IPv6 data planes (SR-MPLS and SRv6) (Compl. ¶¶ 16, 60-64).

III. The Accused Instrumentality

Product Identification

The Accused Instrumentalities are identified as "Samsung's networking solutions," including but not limited to its Software-Defined Networking (SDN), Radio Access Network (RAN), and Core solutions (Compl. ¶64).

Functionality and Market Context

The complaint alleges that these solutions support segment routing (SR) technologies, including SR over IPv6 (SRv6) and SR over MPLS (SR-MPLS) (Compl. ¶¶ 60-62). Plaintiff asserts that these products are developed, manufactured, and sold to support various SR-related technical standards published by the Internet Engineering Task Force (IETF), referred to as "SR RFCs" (Compl. ¶63). The complaint positions these technologies as commercially significant and key enablers for 5G networks, providing capabilities such as network slicing and service chaining (Compl. ¶29). Samsung is alleged to contribute to and provide solutions compliant with standards from organizations like 3GPP, ETSI, and O-RAN that incorporate segment routing (Compl. ¶¶ 45-46, 51, 54, 58). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentalities directly infringe the patents-in-suit by implementing segment routing technologies (Compl. ¶¶ 69, 77, 85, 93, 101, 109, 117, 125). The complaint references but does not include preliminary infringement charts (Exhibits I-P), which would map claim elements to accused product functionality (Compl. ¶¶ 70, 78, 86, 94, 102, 110, 118, 126).

In the absence of these exhibits, the infringement theory presented in the complaint narrative is based on the assertion that Samsung's development, testing, and sale of products that are compliant with SR-related standards (e.g., SRv6, SR-MPLS) and IETF RFCs inherently practice the patented methods (Compl. ¶¶ 45, 58, 63). The core of the infringement allegation appears to be that the standardized functions for source routing, packet header modification, and path segment identification practiced by Samsung's products meet the limitations of the asserted claims.

  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the specific terminology used in the patent claims, such as "region scope-specific outside-scope identifier," can be construed to read on the standardized components and identifiers used in technologies like SRv6 (e.g., Segment IDs or SIDs). The dispute may focus on whether Samsung’s implementation of a public standard necessarily practices the specific, and potentially narrower, methods defined by the patent claims.
    • Technical Questions: The complaint's reliance on standards compliance raises the question of whether it provides sufficient evidence that the Accused Instrumentalities perform every step of the asserted claims as construed. The analysis may require a technical deep-dive to determine if Samsung's specific implementation of SR protocols matches the claimed sequence of identifying, transmitting, and processing path segment identifiers.

V. Key Claim Terms for Construction

  • The Term: "region scope-specific outside-scope identifier" (’335 Patent, Claim 1).
  • Context and Importance: This term is the central inventive concept described in the ’335 Patent. Its construction will be critical to the infringement analysis, as Plaintiff's case may depend on mapping this term onto standardized identifiers used in SR-MPLS or SRv6. Practitioners may focus on this term because the infringement case appears to hinge on whether Samsung's use of standardized Segment IDs (SIDs) falls within the scope of this patent-specific language.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the subject matter challenges the traditional distinctions between names, addresses, and routes, suggesting an intent to cover new forms of addressing generally ('335 Patent, col. 2:42-47). The description of the identifier's function—identifying a second region of the network for a node in a first region—could be argued to describe the general function of certain segment identifiers in SR.
    • Evidence for a Narrower Interpretation: The claim requires the identifier to be in "an identifier space specific to at least the current node" and to lack a "network interface identifier portion specified by the IP network protocol" ('335 Patent, col. 55:10-15). These specific characteristics may be argued to limit the term to a narrower set of implementations than all possible SIDs under the SR standards. The Abstract and detailed embodiments may provide further limitations on what constitutes a "region" or "scope."

VI. Other Allegations

  • Indirect Infringement: The complaint's counts explicitly allege "direct infringement" (Compl. ¶¶ 69, 77, 85, 93, 101, 109, 117, 125). The complaint does not appear to plead the specific factual elements of knowledge and intent required for indirect infringement claims such as inducement or contributory infringement.
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement or use the word "willful." The prayer for relief requests a declaration that the case is "exceptional under 35 U.S.C. § 285," which is a related but distinct request (Compl., p. 27). The complaint does not allege that Defendants had pre-suit knowledge of any of the patents-in-suit.

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

  • A core issue will be one of definitional scope: can the patent-specific term "region scope-specific outside-scope identifier," and similar terms in the asserted patents, be construed to cover the standardized Segment Identifiers (SIDs) used in SR-MPLS and SRv6 as implemented by Samsung? The outcome may depend on whether the patents claim the general concept of segment routing or a more specific, novel implementation thereof.
  • A key evidentiary question will be one of standards implementation vs. claim infringement: does Plaintiff's allegation of Samsung’s compliance with IETF standards provide sufficient technical proof to demonstrate that Samsung's products practice the specific sequence of steps and utilize the particular identifier structures required by the asserted claims, or is there a technical mismatch between the standards and the patented methods?
  • A foundational question will be one of claim validity in light of industry standards: the complaint's emphasis on the patented technology's alignment with IETF standards for segment routing raises the question of how the patents distinguish themselves from the collaborative, public development process that created those standards, which may become a focal point for invalidity challenges.