DCT

4:24-cv-00798

Mobility Workx LLC v. Samsung Electronics Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:24-cv-00798, E.D. Tex., 09/02/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business there.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile device handover technologies infringe two patents related to proactively allocating network resources during handoffs, and that Defendant's separate network emulation products infringe a third patent on emulating mobile network conditions.
  • Technical Context: The patents address technologies for improving performance and reliability in mobile wireless networks, particularly during the "handoff" process when a device moves between different network access points.
  • Key Procedural History: The complaint notes that U.S. Patent No. 8,213,417 was subject to an Inter Partes Review (IPR). The asserted claims from that patent, claims 3 and 6, were confirmed to be valid and enforceable during that proceeding, while other claims were cancelled. This prior validation may inform the parties' strategies regarding these specific claims.

Case Timeline

Date Event
2003-07-31 Priority Date ('508, '417, '330 Patents)
2007-06-12 U.S. Patent No. 7,231,330 Issued
2010-04-13 U.S. Patent No. 7,697,508 Issued
2012-07-03 U.S. Patent No. 8,213,417 Issued
2018-06-01 Inter Partes Review IPR2018-01150 Filed for '417 Patent
2023-02-15 Inter Partes Review Certificate Issued for '417 Patent
2024-09-02 Complaint Filed

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

U.S. Patent No. 7,697,508 - System, Apparatus, and Methods for Proactive Allocation of Wireless Communication Resources, issued April 13, 2010

The Invention Explained

  • Problem Addressed: In mobile IP networks, when a mobile device moves from one network cell to another, the handoff process can cause significant registration delays and data packet loss ('508 Patent, col. 1:20-35). Conventional systems typically react to the mobile node's arrival in a new region, a process that takes time and can disrupt communication ('508 Patent, col. 2:20-35).
  • The Patented Solution: The patent proposes a "preemptive and predictive" system using "ghost" entities to prepare for handoffs before they occur ('508 Patent, Abstract). A "ghost-mobile node" predicts the mobile device's future location and initiates registration with the next network access point (a "foreign agent") in advance ('508 Patent, col. 2:56-62). A corresponding "ghost-foreign agent" advertises the presence of the upcoming access point to the mobile device before it is physically in range, effectively smoothing the transition ('508 Patent, col. 3:1-8).
  • Technical Importance: This approach aims to make handoffs seamless by allocating network resources proactively rather than reactively, thereby improving the performance and reliability of communications for users of mobile devices, especially those moving at moderate or high speeds ('508 Patent, col. 2:49-54).

Key Claims at a Glance

  • The complaint asserts independent claims 7 and 14.
  • Claim 7 (System): A wireless node pair comprising:
    • A mobile node for communicating with a wireless network, having a current geographical state and predicted future states.
    • A "ghost mobile node" associated with the mobile node, which can announce its presence to a foreign agent to signal it based on a predicted future state.
    • The ghost mobile node is configured to predict the future state based on Global Positioning System (GPS) data from a linked GPS unit and is remote from the mobile node.
  • Claim 14 (Method): A computer-implemented method for handling mobile devices, comprising the steps of:
    • Identifying a mobile node.
    • Determining a geographical current state of the mobile node.
    • Predicting one or more geographical future states based on GPS data.
    • Identifying at least one foreign agent for each future state.
    • Creating at least one "ghost foreign agent" for each foreign agent.
    • Registering the ghost mobile node or mobile node with the associated foreign agent while the mobile node remains in the current state.
  • The complaint reserves the right to assert additional claims (Compl. ¶12).

U.S. Patent No. 8,213,417 - System, Apparatus, and Methods for Proactive Allocation of Wireless Communication Resources, issued July 3, 2012

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the '508 Patent, this patent addresses the same problem of registration delays and data loss during mobile network handoffs (’417 Patent, col. 2:20-35).
  • The Patented Solution: The '417 Patent likewise discloses the use of "ghost-foreign agent" and "ghost-mobile node" entities to predict a mobile node's movement and proactively establish network connections and allocate resources before a handoff is required (’417 Patent, Abstract; col. 4:8-18).
  • Technical Importance: The technology provides a framework for reducing or eliminating service disruption during handoffs, a critical function for maintaining quality of service in cellular and other wireless networks (’417 Patent, col. 2:49-54).

Key Claims at a Glance

  • The complaint asserts dependent claims 3 and 6, which survived an Inter Partes Review (Compl. ¶20-21). These claims depend on independent claim 1, which was cancelled in the IPR. However, the reissued claims 3 and 6 now stand on their own. For analysis, the limitations of the original claim 1 are foundational.
  • Original Independent Claim 1 (System): A system comprising:
    • A mobile node, a home agent, and a foreign agent.
    • A "ghost-foreign agent" that advertises messages to the mobile node on behalf of a foreign agent when the mobile node is in an area where the foreign agent is not physically present.
    • A "ghost-mobile node" that creates replica IP messages and triggers signals based on a predicted physical location of the mobile node to initiate mobility on its behalf.
  • Asserted Dependent Claim 3 adds the limitation: The signaling comprises a "tunnel" to allocate resources, and this signaling is triggered at a "threshold distance" to a foreign agent, which is determined based on the mobile node's projected "trajectory and speed."
  • Asserted Dependent Claim 6 adds the limitation: The ghost-foreign agent "populates mobile IP Advertisement messages" with the "care-of-address of neighboring foreign agents" to extend the range of those agents.
  • The complaint reserves the right to assert additional claims (Compl. ¶21).

U.S. Patent No. 7,231,330 - Rapid Mobility Network Emulator Method and System, issued June 12, 2007

Technology Synopsis

The patent describes a method and system for emulating mobile network communications for testing purposes ('330 Patent, Abstract). Instead of physically moving a device, the system simulates mobility by using fixed wireless nodes and dynamically adjusting their signal characteristics, such as signal strength and sensitivity, via components like variable attenuators. This allows for the realistic and repeatable testing of mobile network protocols and performance under various motion scenarios ('330 Patent, col. 2:18-33).

Asserted Claims

The complaint asserts claims 1-19, which includes independent system claim 1, independent method claim 11, and independent computer-readable medium claim 20 (Compl. ¶29). The complaint accuses "certain products and services ('Accused Emulation Products/Services')" made or used by Defendant (Compl. ¶29).

III. The Accused Instrumentality

Product Identification

The complaint identifies two distinct categories of accused instrumentalities:

  1. "Accused Handover Products/Services": These are alleged to infringe the '508 and '417 patents (Compl. ¶12, ¶21).
  2. "Accused Emulation Products/Services": These are alleged to infringe the '330 patent (Compl. ¶29).

Functionality and Market Context

The complaint does not provide specific product names or technical descriptions of how the accused instrumentalities operate. It makes broad allegations that Defendant "makes, uses, offers for sale, sells, or imports" these products and services in the United States (Compl. ¶12, ¶21, ¶29). The infringement theories are detailed in preliminary claim charts attached as exhibits to the complaint; however, these exhibits were not publicly available for this analysis.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, preliminary infringement claim charts (Exhibits 2, 4, and 6) detailing its infringement theories. Therefore, a detailed element-by-element analysis based on the complaint's specific allegations cannot be performed. The complaint alleges that the "Accused Handover Products/Services" infringe the '508 and '417 patents, and that "Accused Emulation Products/Services" infringe the '330 patent.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Architectural Equivalence ('508 and '417 Patents): A central issue will concern whether the architecture of modern cellular handover standards (e.g., in 4G/LTE or 5G networks), as implemented by Samsung, contains equivalents of the claimed "ghost-mobile node" and "ghost-foreign agent." The dispute may focus on whether standard handover preparation functions—such as advance signaling, resource reservation, and neighbor cell measurements—perform the specific roles of the claimed predictive, virtual "ghost" entities that register and advertise on behalf of the mobile node before it enters a new coverage area.
  • Functional Mapping ('330 Patent): For the '330 patent, a key question will be whether Samsung's internal network testing tools or commercial emulation products perform the specific claimed method. The dispute may turn on what evidence shows that Samsung simulates mobility by dynamically adjusting signal attenuation and sensitivity between fixed wireless access points, as opposed to using purely software-based simulation or other hardware-in-the-loop testing methods.

V. Key Claim Terms for Construction

For the '508 and '417 Patents:

  • The Term: "ghost-mobile node"

  • Context and Importance: This term is a cornerstone of the inventions in the '508 and '417 patents. The outcome of the infringement analysis will heavily depend on whether any software or hardware component within Samsung's accused systems can be properly characterized as this entity. Practitioners may focus on this term because its definition distinguishes the invention from conventional reactive handoff mechanisms.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests the term is not limited to a specific physical form, describing it as potentially a "set of software instructions running on a device that is remote from the mobile node" (’508 Patent, col. 6:20-25). This could support an argument that the "ghost" is a distributed function rather than a discrete component.
    • Evidence for a Narrower Interpretation: The claims require the "ghost-mobile node" to perform specific functions, such as creating "replica IP messages on behalf of a mobile node" and "triggering signals based on a predicted physical location" (’417 Patent, col. 12:60-67). The patent figures also depict it as a distinct block (e.g., '508 Patent, Fig. 2A, item 220), which could support a narrower construction requiring a more defined virtual proxy structure.

  • The Term: "ghost-foreign agent"

  • Context and Importance: This is the complementary novel element to the "ghost-mobile node". Its existence and specific function—advertising a future foreign agent's presence in advance—are critical limitations for infringement.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes a ghost-foreign agent as an "extension of a foreign agent" (’508 Patent, col. 10:50-53). This language might be used to argue that it covers any functionality that provides advanced notice of a future network access point.
    • Evidence for a Narrower Interpretation: The claims state the "ghost-foreign agent" advertises "when the mobile node is located in a geographical area where the foreign agent is not physically present" (’417 Patent, col. 12:56-59). This requirement that the advertisement occurs while the device is physically outside the target agent's normal range may be a significant point of dispute.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant knowingly induces infringement by "actively encourage[ing] users of its products and services" to use them in an infringing manner (Compl. ¶13, ¶22, ¶30). It also alleges contributory infringement, stating that the accused products "have no substantial non-infringing uses" (Compl. ¶15, ¶23, ¶31).
  • Willful Infringement: For all three patents, the complaint alleges willfulness based on Defendant’s knowledge of the patents, asserting this knowledge existed "[p]rior to, or at least through, the filing and service of this complaint" (Compl. ¶13, ¶16, ¶22, ¶24, ¶30, ¶32). This language preserves a claim for both pre-suit and post-suit willful infringement.

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

  • A core issue will be one of architectural definition: Can the claimed "ghost-mobile node" and "ghost-foreign agent" entities, described as predictive virtual proxies that register on a mobile node's behalf, be construed to read on the standardized handover preparation and signaling functions implemented in modern 4G/LTE and 5G cellular networks?
  • A key evidentiary question will be one of internal practice: What evidence will demonstrate that Samsung's "Accused Emulation Products/Services" actually employ the '330 patent's claimed method of simulating mobility by dynamically varying signal attenuation between fixed wireless nodes, as distinct from other known network simulation techniques?
  • A critical legal and factual question for the '417 patent will be the impact of the Inter Partes Review: How does the survival of only dependent claims 3 and 6, which add specific limitations regarding "tunnels" and "mobile IP Advertisement messages," narrow the scope of the infringement inquiry and focus the dispute on technical details that go beyond the basic "ghost" entity concept?