DCT

4:24-cv-00625

Morris Routing Tech LLC v. T-Mobile USA Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:24-cv-00625, E.D. Tex., 07/08/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant T-Mobile maintains numerous regular and established places of business, including retail stores and corporate offices, within the district, and has committed acts of infringement there. The complaint also notes that in several other recent patent cases, T-Mobile has not contested that venue is proper in this district.
  • Core Dispute: Plaintiff alleges that Defendant’s 4G and 5G wireless networks, which utilize Segment Routing technology, infringe nine patents related to methods for routing data packets efficiently across networks.
  • Technical Context: The technology at issue is segment-based routing (SR), a network traffic engineering method that simplifies network operations and improves scalability by encoding routing paths within packet headers, which is a key enabling technology for 5G networks.
  • Key Procedural History: The complaint details T-Mobile's membership in and the activities of several standard-setting organizations (SSOs) relevant to 5G and segment routing, including ETSI and the O-RAN ALLIANCE. It also notes contributions by T-Mobile's parent company, Deutsche Telekom AG, to the development of SR-related technical standards (RFCs), suggesting a potential undercurrent of standards-essentiality, though no such claims are explicitly made.

Case Timeline

Date Event
2012-12-27 Earliest Priority Date for all Patents-in-Suit
2019-02-19 U.S. Patent No. 10,212,076 Issues
2019-08-06 U.S. Patent No. 10,374,938 Issues
2019-08-27 U.S. Patent No. 10,397,100 Issues
2019-09-03 U.S. Patent No. 10,404,583 Issues
2020-03-10 U.S. Patent No. 10,587,505 Issues
2020-07-07 U.S. Patent No. 10,708,168 Issues
2020-09-22 U.S. Patent No. 10,785,143 Issues
2021-01-01 U.S. Patent No. 10,904,144 Issues
2021-05-18 U.S. Patent No. 11,012,344 Issues
2024-07-08 Complaint Filing Date

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

U.S. Patent No. 10,212,076 - "Routing Methods, Systems, and Computer Program Products for Mapping a Node-Scope Specific Identifier"

  • Patent Identification: U.S. Patent No. 10,212,076, "Routing Methods, Systems, and Computer Program Products for Mapping a Node-Scope Specific Identifier," issued February 19, 2019.

The Invention Explained

  • Problem Addressed: The patent’s background section describes challenges in traditional Internet Protocol addressing, which distinguishes between names, addresses, and routes, leading to complexity and latency. It notes that the Internet Protocol "deals primarily with addresses," leaving the mapping between different contexts to other protocol layers, which can be inefficient (’076 Patent, col. 2:2-6). The complaint adds that traditional MPLS networks suffer from scalability problems because state information for a packet's path must be maintained at every router along that path (Compl. ¶22).
  • The Patented Solution: The invention proposes a routing method where a network node receives data based on a "node-scope specific identifier" that is only meaningful within the context of a previous node. The current node then determines an equivalent identifier that is meaningful within its own local context (its "node-specific identifier space") and maps the first identifier to the second. This mapping allows the data to be transmitted to the next node in the path without requiring each node to maintain state information for the entire network. ('076 Patent, Abstract; col. 3:3-22; Fig. 2).
  • Technical Importance: This source-routing approach simplifies network architecture and dramatically reduces the per-flow state that must be maintained in network nodes, which enhances scalability and flexibility (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶67).
  • The essential elements of claim 1 are:
    • Receiving network path information in a packet header based on a "node-scope specific identifier" from a "first node's" identifier space, where that identifier points to a particular node in the network path.
    • Determining a corresponding "node-scope specific identifier" in a "second node's" identifier space that also identifies the same particular node.
    • Mapping the identifier from the first node's space to the identifier in the second node's space.
    • Transmitting the data based on the newly mapped identifier from the second node's space.
  • The complaint reserves the right to assert additional claims (Compl. ¶68).

U.S. Patent No. 10,374,938 - "Routing Methods, Systems, and Computer Program Products"

  • Patent Identification: U.S. Patent No. 10,374,938, "Routing Methods, Systems, and Computer Program Products," issued August 6, 2019.

The Invention Explained

  • Problem Addressed: The patent addresses the same general problems of network complexity and latency as its family members, arising from the traditional separation of names, addresses, and routes (’938 Patent, col. 1:54-2:39). The complaint frames the problem as the inefficiency of traditional IP/MPLS networks that required state information to be maintained at every hop (Compl. ¶22).
  • The Patented Solution: The invention describes a method for routing a data packet to a "path node" that is located outside the domain of the current node's native protocol, specifically a Multiprotocol Label Switching (MPLS) network. A packet arrives at a current node containing a "segment identifier" that identifies this external path node. The current node detects this identifier and determines, from a plurality of possible path portions, which one to use to send the data toward the external path node. (’938 Patent, Abstract; col. 2:40-56).
  • Technical Importance: This method allows for segment routing to extend across different network domains (e.g., between an MPLS domain and a pure IPv6 domain), which is critical for creating flexible and scalable modern networks that often use equipment from multiple vendors (Compl. ¶¶ 20, 26, 33).

Key Claims at a Glance

  • The complaint asserts independent claim 15 (Compl. ¶75).
  • The essential elements of claim 15 are:
    • Receiving a packet at a "current node" which is destined for a "destination node."
    • Identifying in the packet's header a "segment identifier" that points to a "path node" that is reachable via multiple path portions.
    • The destination node is "outside a domain" of the MPLS network protocol that the path node operates in, but the segment identifier identifies the path node "in the domain" of that MPLS protocol.
    • Detecting the segment identifier.
    • Determining, based on the identifier, that the data is to be sent to the path node.
    • Sending the data toward the path node via at least one of the available path portions.
  • The complaint reserves the right to assert additional claims (Compl. ¶76).

U.S. Patent No. 10,397,100 - "Routing Methods, Systems, and Computer Program Products Using a Region Scoped Outside-Scope Identifier"

  • Patent Identification: U.S. Patent No. 10,397,100, "Routing Methods, Systems, and Computer Program Products Using a Region Scoped Outside-Scope Identifier," issued August 27, 2019 (Compl. ¶80).
  • Technology Synopsis: This patent relates to routing a packet using an identifier that is scoped to a specific network region but identifies a destination outside of that scope. This allows a node within a region to route traffic to an external destination without needing a globally unique address, improving addressing efficiency.
  • Asserted Claims: At least claim 1 (Compl. ¶83).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶83).

U.S. Patent No. 10,404,583 - "Routing Methods, Systems, and Computer Program Products Using Multiple Outside-Scope Identifiers"

  • Patent Identification: U.S. Patent No. 10,404,583, "Routing Methods, Systems, and Computer Program Products Using Multiple Outside-Scope Identifiers," issued September 3, 2019 (Compl. ¶88).
  • Technology Synopsis: This invention extends the concept of outside-scope identifiers by using multiple such identifiers in a packet header. This allows for the specification of more complex routing paths that cross multiple network regions or domains.
  • Asserted Claims: At least claim 1 (Compl. ¶91).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶91).

U.S. Patent No. 10,587,505 - "Routing Methods, Systems, and Computer Program Products"

  • Patent Identification: U.S. Patent No. 10,587,505, "Routing Methods, Systems, and Computer Program Products," issued March 10, 2020 (Compl. ¶96).
  • Technology Synopsis: This patent appears to cover fundamental methods and systems for implementing segment-based routing, likely related to the creation, processing, and forwarding of packets containing path-based protocol addresses.
  • Asserted Claims: At least claim 1 (Compl. ¶99).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶99).

U.S. Patent No. 10,785,143 - "Routing Methods, Systems, and Computer Program Products"

  • Patent Identification: U.S. Patent No. 10,785,143, "Routing Methods, Systems, and Computer Program Products," issued September 22, 2020 (Compl. ¶104).
  • Technology Synopsis: This patent, like others in the family, concerns methods for routing packets. Its specific focus is likely on a particular aspect of processing segment identifiers or handling paths, possibly related to path selection or modification by intermediate nodes.
  • Asserted Claims: At least claim 6 (Compl. ¶107).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶107).

U.S. Patent No. 10,708,168 - "Routing Methods, Systems, and Computer Program Products"

  • Patent Identification: U.S. Patent No. 10,708,168, "Routing Methods, Systems, and Computer Program Products," issued July 7, 2020 (Compl. ¶112).
  • Technology Synopsis: This patent discloses methods and systems for network routing, likely focused on the logic within a network node for interpreting a sequence of segment identifiers and making a forwarding decision based on that sequence.
  • Asserted Claims: At least claim 1 (Compl. ¶115).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶115).

U.S. Patent No. 11,012,344 - "Routing Methods, Systems, and Computer Program Products"

  • Patent Identification: U.S. Patent No. 11,012,344, "Routing Methods, Systems, and Computer Program Products," issued May 18, 2021 (Compl. ¶120).
  • Technology Synopsis: This patent covers foundational methods for implementing segment routing. Given its later issue date in the family, it may claim inventions with refinements or alternative embodiments related to the core path-based addressing technology.
  • Asserted Claims: At least claim 1 (Compl. ¶123).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶123).

U.S. Patent No. 10,904,144 - "Methods, Systems, and Computer Program Products for Associating a Name with a Network Path"

  • Patent Identification: U.S. Patent No. 10,904,144, "Methods, Systems, and Computer Program Products for Associating a Name with a Network Path," issued January 1, 2021 (Compl. ¶128).
  • Technology Synopsis: This invention describes a system for associating a symbolic name (like a hostname) with a specific, engineered network path. This goes beyond traditional DNS (which maps a name to an address) by linking a name to a route, allowing for more granular traffic control.
  • Asserted Claims: At least claim 1 (Compl. ¶131).
  • Accused Features: T-Mobile Networks and its Segment Routing Standard-Compliant Appliances (Compl. ¶131).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are T-Mobile's networks, including its wireless, fixed wireless, and fiber networks, which are alleged to incorporate "Segment Routing Standard-Compliant Appliances" (Compl. ¶¶ 61, 67). This encompasses T-Mobile's 4G and 5G wireless services.

Functionality and Market Context

  • The complaint alleges that T-Mobile's networks support the functionality specified in a suite of Internet Engineering Task Force (IETF) standards documents known as SR RFCs (Request for Comments) (Compl. ¶62). This includes support for both SR-MPLS (Segment Routing over Multiprotocol Label Switching) and SRv6 (Segment Routing over IPv6) (Compl. ¶20, pp. 20-21 n.58). The complaint asserts that these technologies are key enablers for advanced 5G features like network slicing, which T-Mobile advertises and supports (Compl. ¶¶ 33, 11 n.10). The complaint includes a screenshot of T-Mobile's website showing its 4G & 5G network coverage map to illustrate the nationwide scope of the accused services (Compl. p. 5, ¶12). It also provides a visual from its store locator feature, showing its physical retail presence used to market and sell the accused services within the judicial district (Compl. p. 4, ¶11).

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement charts as exhibits but does not include them in the provided document. The infringement theories are therefore summarized from the complaint's narrative allegations (Compl. ¶¶ 68, 76).

U.S. Patent No. 10,212,076 Infringement Allegations

  • The complaint alleges that T-Mobile's networks, by using equipment compliant with segment routing standards, practice the method of claim 1 (Compl. ¶67). The core of the infringement theory suggests that when a router in T-Mobile's network processes a packet with a segment-routed path, it performs the claimed method. Specifically, it receives the packet based on a segment identifier (a "node-scope specific identifier" from a previous router's perspective), determines the corresponding identifier for the next hop in its own forwarding context (a "node-scope specific identifier" for itself), and "maps" the first to the second to transmit the packet.

U.S. Patent No. 10,374,938 Infringement Allegations

  • The complaint alleges that T-Mobile's networks, which are composed of different network technologies, infringe claim 15 by routing packets across these technology domains (Compl. ¶75). The infringement theory centers on situations where a packet must traverse from one type of network segment (e.g., MPLS) to another (e.g., pure IP or SRv6). In this scenario, a router at the boundary allegedly receives a packet with a "segment identifier" that identifies a "path node" existing "outside" its native MPLS "domain." The router then uses this identifier to determine which of several available paths to use to forward the packet toward that external node, thereby practicing the claimed invention.

Identified Points of Contention

  • Scope Questions: For the ’076 Patent, a central dispute may be whether the standard processing of a Segment Identifier (SID) in an SR network constitutes "mapping" between different "node-specific identifier spaces" as required by the claim. A court may need to determine if a simple forwarding table lookup based on a SID meets this "mapping" limitation, or if the claim requires a more complex translation between distinct contexts that is not present in standard SR operation.
  • Technical Questions: For the ’938 Patent, a key factual question will be whether T-Mobile's networks are actually configured to perform the specific cross-domain routing of claim 15. The allegation relies on the network using both MPLS and non-MPLS (e.g., SRv6) technologies; infringement will depend on evidence that routers at the boundaries of these domains perform the claimed steps of identifying a path node as being "outside" their MPLS domain and selecting a path accordingly.

V. Key Claim Terms for Construction

  • Term from ’076 Patent, Claim 1: "map the node-scope specific identifier ... to the node-scope specific identifier"

    • Context and Importance: The definition of "map" is critical. The infringement case for the ’076 patent hinges on whether a network router's standard processing of a segment routing label or address constitutes "mapping." Practitioners may focus on this term because if it is construed narrowly to require more than a standard forwarding lookup, the infringement case could be significantly weakened.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract describes a sequence of "determine," "map," and "transmit," suggesting "map" is a distinct step that links the determined identifiers (’076 Patent, Abstract). This could support a construction where any function that correlates an incoming identifier with an outgoing one for forwarding purposes is a "map."
      • Evidence for a Narrower Interpretation: The specification discusses mapping in the context of mathematical metric spaces and coordinate transformations, which is a more complex operation than a simple table lookup (’076 Patent, col. 13:5-25). A defendant may argue that the term should be limited to these more complex embodiments, distinguishing it from standard router operations.

  • Term from ’938 Patent, Claim 15: "outside a domain of a multiple protocol-labeling switch (MPLS) network protocol"

    • Context and Importance: This term establishes the specific technical scenario of cross-domain routing. Infringement depends on T-Mobile's network having identifiable MPLS "domains" and routing packets to nodes explicitly outside of them. The construction of "domain" will determine whether the claim applies to any MPLS-to-IP handoff or only to handoffs between formally separate and administered networks.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s background discusses improving routing across different types of networks generally, including MPLS-based and IPv6-based data planes (Compl. ¶20, citing ’938 patent, col. 20:42-67). This may support a broad reading where any transition from an MPLS-forwarding environment to a non-MPLS one falls within the scope of a different "domain."
      • Evidence for a Narrower Interpretation: The term "domain" in networking often implies a distinct administrative or protocol boundary. A defendant could argue that its entire backhaul network, even if using multiple technologies, constitutes a single administrative "domain," meaning no node is ever routed to a destination "outside" it. The patent's explicit contrast between "SR-MPLS" and "SRv6" suggests a technical distinction between domains is intended (Compl. ¶20).

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement in the body of the complaint.

  • Indirect Infringement: The complaint contains counts for direct infringement only (Compl. ¶¶ 67, 75, 83, 91, 99, 107, 115, 123, 131). No specific facts are alleged to support the knowledge and intent elements required for claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not allege pre- or post-suit knowledge of the patents-in-suit as a basis for willfulness. However, the Prayer for Relief requests "A declaration that this case is exceptional under 35 U.S.C. § 285" (Compl. p. 30, ¶C), a remedy often associated with findings of willful infringement or litigation misconduct.

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

  • A core issue will be one of claim scope: can the term "map," which is central to the '076 patent and rooted in the specification's discussion of transforming identifiers between different spaces, be construed broadly enough to read on the standardized lookup-and-forward operations of Segment Routing equipment? The outcome of this construction may be pivotal to the infringement analysis for a significant portion of the asserted patent portfolio.
  • A key evidentiary question will be one of technical implementation: beyond mere capability, what evidence will emerge from discovery regarding how T-Mobile's 4G and 5G networks are actually configured and operated? The infringement allegations, particularly for claims involving cross-domain routing like in the '938 patent, depend not on the theoretical capabilities of standards-compliant hardware, but on proof that these specific, claimed functionalities are actively used in T-Mobile's live network.
  • A central strategic question will concern the intersection of the patents and industry standards: given the complaint's extensive focus on T-Mobile's participation in SSOs and its use of standards-compliant technology, to what extent does the infringement case rely on T-Mobile's adherence to the SR-MPLS and SRv6 standards? This raises the possibility that defenses related to standards-essential patents (SEPs), such as FRAND licensing obligations or patent exhaustion, could become central to the dispute, even though they are not raised in the initial complaint.