DCT

4:25-cv-00852

Morris Routing Tech LLC v. Ribbon Communications Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-852, E.D. Tex., 08/07/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is headquartered and maintains a regular and established place of business in Plano, Texas, which is within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s networking products and solutions that are capable of Segment Routing (SR) infringe seven patents related to methods for routing data packets using path information encoded in the packet itself.
  • Technical Context: Segment-based routing is a modern networking technique that simplifies traffic engineering by pre-determining a packet's path at the source, reducing the state management burden on intermediate routers and enabling advanced network capabilities like service chaining and network slicing, which are significant for 5G telecommunications.
  • Key Procedural History: The complaint alleges Defendant's involvement with the Internet Engineering Task Force (IETF) and the European Telecommunications Standards Institute (ETSI), standard-setting bodies that have published specifications for the accused Segment Routing technology. This history may be relevant to questions of industry practice and potential knowledge of the technologies at issue.

Case Timeline

Date Event
2012-10-05 Earliest Priority Date for all Patents-in-Suit
2017-10-27 Defendant registered to do business in Texas
2019-08-20 U.S. Patent No. 10,389,624 Issues
2019-09-03 U.S. Patent No. 10,404,583 Issues
2020-02-25 U.S. Patent No. 10,574,562 Issues
2020-03-17 U.S. Patent No. 10,594,594 Issues
2020-05-12 U.S. Patent No. 10,652,133 Issues
2020-05-12 U.S. Patent No. 10,652,134 Issues
2020-08-25 U.S. Patent No. 10,757,010 Issues
2023-10-01 ETSI NFV ISG publishes Group Report analyzing SRv6 and SR-MPLS
2024-05-01 3GPP and ETSI publish technical specification including SRv6
2025-08-07 Complaint Filing Date

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

U.S. Patent No. 10,652,133 - "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS"

  • Patent Identification: U.S. Patent No. 10,652,133, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS,” issued May 12, 2020.
  • The Invention Explained:
    • Problem Addressed: The patent addresses scalability problems in traditional IP/MPLS networks, which required intermediate routers to maintain extensive "per-flow state" information to direct traffic, leading to complexity and inefficiency (Compl. ¶15). The patent background further notes the limitations of traditional distinctions between names, addresses, and routes in network protocols (’133 Patent, col. 2:35-42).
    • The Patented Solution: The invention proposes a method where a packet’s entire path is chosen by the source and encoded within the packet header as a sequence of "segment identifiers" (Compl. ¶17). As the packet traverses the network, each node processes the next segment identifier to determine the next hop, eliminating the need for intermediate nodes to maintain state information for each path (’133 Patent, col. 41:49-57).
    • Technical Importance: This source-routing approach, known as Segment Routing, simplifies network architecture and enables more precise traffic control and efficient use of network resources (Compl. ¶¶21-23).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 12 (Compl. ¶56).
    • Claim 12 requires a method comprising:
      • Detecting, by a current node, data in a data unit that includes a first path-based protocol address comprising a plurality of path segment identifiers for a network path from a source node to a destination node.
      • Detecting, based on the current location, a current-next path segment identifier in the plurality for transmitting the data to a next node.
      • Determining, based on the current-next path segment identifier, a current-next network interface that is included in the current-next path segment.
      • Sending, via the current-next network interface, the data to the next node.

U.S. Patent No. 10,574,562 - "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS"

  • Patent Identification: U.S. Patent No. 10,574,562, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS,” issued February 25, 2020.
  • The Invention Explained:
    • Problem Addressed: Like its family members, this patent addresses the complexity and scalability issues of prior art routing protocols that rely on maintaining state information at each hop along a path (’562 Patent, col. 2:7-59).
    • The Patented Solution: The patent describes a system where nodes receive and calculate segment identifiers based on globally unique index values and base values specific to the network domain (’562 Patent, Abstract). This allows for the creation of path-based addresses that direct packets through the network without requiring intermediate nodes to maintain path-specific state information, as the path is encoded in the packet itself.
    • Technical Importance: This technique provides a structured way to generate and manage the identifiers used in segment routing, contributing to the simplification and scalability of traffic engineering in large networks (Compl. ¶¶17, 22).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 (Compl. ¶64).
    • Claim 1 requires a system comprising a first node configured to:
      • Receive an index value that is globally unique within a network domain.
      • Receive a base value comprising one of a plurality of segment routing values.
      • Calculate a segment identifier (ID) based on the index value and the base value.
      • Calculate a next hop segment ID based on the index value and a second base value.

Multi-Patent Capsules

  • U.S. Patent No. 10,652,134

    • Patent Identification: U.S. Patent No. 10,652,134, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGAM PRODUCTS,” issued May 12, 2020.
    • Technology Synopsis: This patent, part of the same family, discloses methods for routing data using path-based protocol addresses. The invention focuses on generating a set of segment identifiers that encode a network path, allowing data packets to be self-directed through the network.
    • Asserted Claims: Claim 1 (Compl. ¶72).
    • Accused Features: Ribbon’s SR-capable solutions are accused of infringing by implementing Segment Routing functionalities (Compl. ¶¶50-51).

  • U.S. Patent No. 10,757,010

    • Patent Identification: U.S. Patent No. 10,757,010, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS,” issued August 25, 2020.
    • Technology Synopsis: This patent describes methods for routing where a packet header includes a stack of segment identifiers. The invention involves assembling this stack to define a network path and forwarding the packet according to the identifier at the top of the stack.
    • Asserted Claims: Claim 2 (Compl. ¶80).
    • Accused Features: Ribbon’s SR-capable solutions are accused of infringing by implementing Segment Routing functionalities (Compl. ¶¶50-51).

  • U.S. Patent No. 10,389,624

    • Patent Identification: U.S. Patent No. 10,389,624, titled “SCOPED IDENTIFIER SPACE ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS,” issued August 20, 2019.
    • Technology Synopsis: This patent focuses on routing using "scoped" identifier spaces, where identifiers are unique within a specific network span or domain. The invention describes a network controller that determines network paths and uses these scoped identifiers to manage routing, creating globally unique identifiers within that span.
    • Asserted Claims: Claim 1 (Compl. ¶88).
    • Accused Features: Ribbon’s SR-capable solutions are accused of infringing by implementing Segment Routing functionalities (Compl. ¶¶50-51).

  • U.S. Patent No. 10,404,583

    • Patent Identification: U.S. Patent No. 10,404,583, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS USING MULTIPLE OUTSIDE-SCOPE IDENTIFIERS,” issued September 3, 2019.
    • Technology Synopsis: This patent discloses a routing technique using "outside-scope" identifiers, which allow a node in one network region to identify a path or destination in another region without needing a globally unique address. This is achieved by using a first identifier to reach the border of a new region, and a second identifier to direct the packet within that new region.
    • Asserted Claims: Claim 1 (Compl. ¶96).
    • Accused Features: Ribbon’s SR-capable solutions are accused of infringing by implementing Segment Routing functionalities (Compl. ¶¶50-51).

  • U.S. Patent No. 10,594,594

    • Patent Identification: U.S. Patent No. 10,594,594, titled “ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS,” issued March 17, 2020.
    • Technology Synopsis: This patent describes a system for selecting and storing a sequence of segment identifiers that define a network path based on a specified policy. The sequence is then placed in a packet header to direct the packet through the network.
    • Asserted Claims: Claim 1 (Compl. ¶104).
    • Accused Features: Ribbon’s SR-capable solutions are accused of infringing by implementing Segment Routing functionalities (Compl. ¶¶50-51).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Defendant Ribbon's "SR-capable solutions" (Compl. ¶50). This includes, but is not limited to, Ribbon's Neptune product family, 5G native solutions, HFR offerings, and Muse orchestration solutions (Compl. ¶50).
  • Functionality and Market Context: The complaint alleges that these products are networking hardware and software solutions that support Segment Routing (SR) functionalities for both MPLS (SR-MPLS) and IPv6 (SRv6) data planes (Compl. ¶¶35-36, 51). The complaint includes a table from a Ribbon product datasheet that lists SR capabilities such as "SR-MPLS," "Segment Routing Traffic Engineering (SR-TE, SR Policies)," and "Path Protection" (Compl. p. 14). Plaintiff alleges that SR technology is a "key enabler for traffic engineering" and network slicing, particularly for 5G networks, giving the accused products significant commercial value (Compl. ¶26).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided with the complaint document (Compl. ¶¶57, 65). The infringement theory is therefore summarized in prose.

The complaint’s central infringement theory is that by developing and providing solutions that are "SR-capable" and support the functionality specified in the IETF's SR RFCs (Request for Comments), Ribbon's products inherently practice the methods claimed in the Patents-in-Suit (Compl. ¶¶50-51). For the '133 Patent, the allegation is that the accused products directly infringe at least claim 12 by performing the claimed method of detecting and forwarding packets based on path segment identifiers (Compl. ¶56). Similarly, for the '562 Patent, the allegation is that the accused products directly infringe at least claim 1 by implementing a system that calculates segment identifiers as required by the claim (Compl. ¶64). The infringement allegations for the other five patents follow the same logic, accusing Ribbon's SR-capable solutions of practicing the specific routing methods claimed in each patent (Compl. ¶¶72, 80, 88, 96, 104).

  • Identified Points of Contention:
    • Scope Questions: A primary question may be whether the scope of the asserted patent claims is co-extensive with the public SR standards (e.g., RFC 8402, RFC 8660) that the accused products allegedly implement. The dispute may focus on whether compliance with these standards necessarily results in infringement of every claim limitation.
    • Technical Questions: The complaint alleges infringement based on the products being "SR-capable" without detailing the specific operations of the accused instrumentalities. A key technical question will be what evidence demonstrates that Ribbon's products actually perform the specific steps recited in the asserted claims (e.g., for the ’562 Patent, the step of "calculating a segment identifier based on the index value and the base value"), as opposed to implementing the SR standards in a technically distinct, non-infringing manner.

V. Key Claim Terms for Construction

  • The Term: "path-based protocol address"

  • Context and Importance: This term appears in the asserted claim of the ’133 Patent and is fundamental to the asserted patent family. Its construction is critical because it will determine whether modern data structures like an SR-MPLS label stack or an SRv6 segment list in a packet header fall within the scope of the claims. Practitioners may focus on this term because the patentee appears to have defined it to encompass the core concept of segment routing.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests the invention challenges the traditional distinctions "between and among names, addresses, and routes" and that the "internet protocol deals primarily with addresses" (’624 Patent, col. 2:35-42). This may support a broad construction that covers any address format containing routing information.
    • Evidence for a Narrower Interpretation: The detailed description and figures illustrate specific binary formats for these addresses, including "address separator fields" (e.g., ’133 Patent, Fig. 6A, 604a). A defendant may argue these specific embodiments limit the term to the particular structures disclosed, rather than covering all forms of segment routing headers.

  • The Term: "segment identifier"

  • Context and Importance: This term is also central to the asserted claims. Its definition will determine whether common industry implementations, such as an MPLS label or an IPv6 address segment, are covered. The complaint explicitly alleges that a segment identifier can be embodied as an MPLS label or as a sequence of IPv6 addresses (Compl. ¶¶18-19).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The complaint cites passages suggesting the invention covers both MPLS and IPv6 implementations, which implies a broad definition for "segment identifier" that is not tied to a single protocol (Compl. ¶13, citing ’133 Patent, col. 20:11-45).
    • Evidence for a Narrower Interpretation: A defendant may argue that the term should be limited by the specific calculation methods or data structures disclosed in the patent's embodiments (e.g., ’562 Patent, Abstract, describing calculation from an index and base value), potentially excluding other methods of generating or using segment identifiers.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain formal counts for indirect infringement. However, the direct infringement count for the '133 Patent alleges Defendant is "providing and causing to be used the Accused Instrumentalities," language which may suggest a future claim for induced infringement (Compl. ¶56).
  • Willful Infringement: Willful infringement is not explicitly alleged in any count. The prayer for relief requests a declaration that the case is "exceptional under 35 U.S.C. § 285" and an award of attorneys' fees, but does not explicitly request enhanced damages for willful infringement (Compl. p. 22, ¶C).

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

  • A core issue will be one of definitional scope: can the patent claims, which use terms like "path-based protocol address," be construed broadly enough to cover the industry-standard implementations of Segment Routing (SR-MPLS and SRv6) that Defendant allegedly practices, or are they limited to the specific embodiments disclosed in the patent specifications?
  • A central validity question may be one of patent eligibility: are the claims directed to a patent-eligible improvement in network functionality, or to the abstract idea of encoding routing information in a data packet? The complaint’s pre-emptive arguments against ineligibility suggest this will be a contested issue (Compl. ¶¶28-32).
  • A key evidentiary question will be one of technical proof: beyond alleging compliance with SR standards, what specific evidence will Plaintiff provide to demonstrate that the accused Ribbon products perform each and every step of the asserted methods as claimed?