DCT

4:25-cv-00859

Morris Routing Tech LLC v. DISH Network Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00859, E.D. Tex., 08/08/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant DISH has regular and established places of business in the district, has committed acts of infringement in the district, advertises its network coverage in the district, and employs individuals within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s nationwide 5G networks, which utilize Segment Routing (SR) technology for traffic management, infringe seven patents related to methods and systems for segment-based routing.
  • Technical Context: Segment Routing is a network routing paradigm that simplifies network protocols and enables advanced traffic engineering by embedding path information directly into data packet headers, a key technology for modern 5G and enterprise networks.
  • Key Procedural History: The complaint frames the dispute in the context of industry-wide adoption of Segment Routing technology through standards published by the Internet Engineering Task Force (IETF). It alleges that the accused networks implement functionality specified in these standards, suggesting the case may involve questions of whether practicing these standards results in infringement.

Case Timeline

Date Event
2012-12-27 Earliest Priority Date for all Patents-in-Suit
2019-08-20 U.S. Patent No. 10,757,010 Issued
2020-02-25 U.S. Patent No. 10,574,562 Issued
2020-05-12 U.S. Patent No. 10,652,133 Issued
2020-05-12 U.S. Patent No. 10,652,134 Issued
2020-10-13 U.S. Patent No. 10,805,204 Issued
2023-09-12 U.S. Patent No. 11,757,756 Issued
2023-10-10 U.S. Patent No. 11,784,914 Issued
2024-04-03 DISH hiring date in Plano, TX, noted in complaint
2024-06-17 DISH hiring date in Plano, TX, noted in complaint
2024-08-12 DISH hiring date in Plano, TX, noted in complaint
2025-08-08 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, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued May 12, 2020.
  • The Invention Explained:
    • Problem Addressed: The patent addresses the complexity, scalability problems, and inefficiencies of traditional IP-based network forwarding (Compl. ¶¶ 18, 31). In such networks, routing decisions are made on a hop-by-hop basis, requiring intermediate routers to maintain extensive per-flow state information, which is inefficient and difficult to scale (Compl. ¶¶ 18-19; ’133 Patent, col. 2:7-10).
    • The Patented Solution: The invention introduces a source-routing method where the path a data packet should take is determined by the source and encoded into the packet's header as a sequence of "segment identifiers" (Compl. ¶ 21). This allows intermediate network nodes to forward the packet based on the information it carries, rather than maintaining per-flow state, thereby reducing complexity and improving scalability (Compl. ¶ 21; ’133 Patent, col. 24:61-28:60).
    • Technical Importance: This approach significantly reduces the state management burden on network routers and enables precise traffic engineering, which is critical for network functions like load balancing and network slicing (Compl. ¶¶ 25, 30).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 12 (Compl. ¶ 66).
    • The complaint does not provide the full text of the asserted claims for analysis.
    • The complaint reserves the right to assert additional claims (Compl. ¶ 67).

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

  • Patent Identification: U.S. Patent No. 10,574,562, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued February 25, 2020.
  • The Invention Explained:
    • Problem Addressed: The patent family addresses the limitations of traditional network addressing and routing, where the Internet Protocol primarily deals with mapping names to addresses and leaves routing to other protocol layers, creating latency and management challenges as networks grow (Compl. ¶ 20; ’562 Patent, col. 2:7-59).
    • The Patented Solution: The invention establishes new relationships between names, addresses, and routes by using a "path-based protocol address" composed of "path segment identifiers" (Compl. ¶¶ 20, 26). The abstract describes a system where a node calculates a "segment identifier (segment ID)" based on a globally unique index value and a base value, allowing for efficient, state-reduced routing (’562 Patent, Abstract).
    • Technical Importance: This path-based addressing method provides a novel solution for improving network performance and creating scalable, dynamic packet routing (Compl. ¶ 34).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1 (Compl. ¶ 74).
    • The complaint does not provide the full text of the asserted claims for analysis.
    • The complaint reserves the right to assert additional claims (Compl. ¶ 75).

Multi-Patent Capsule: U.S. Patent No. 10,652,134

  • Patent Identification: U.S. Patent No. 10,652,134, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGAM PRODUCTS," issued May 12, 2020 (Compl. ¶ 79).
  • Technology Synopsis: This patent, part of the same family, also relates to segment-based routing. It claims methods and systems that improve network operations by using path information encoded in packet headers, reducing reliance on traditional hop-by-hop routing tables and complex control protocols (Compl. ¶¶ 17-21).
  • Asserted Claims: At least independent claim 1 (Compl. ¶ 82).
  • Accused Features: The accused features are the DISH Networks that support Segment Routing functionality as specified in the SR RFCs (Compl. ¶¶ 61, 82).

Multi-Patent Capsule: U.S. Patent No. 10,757,010

  • Patent Identification: U.S. Patent No. 10,757,010, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued August 20, 2019 (Compl. ¶ 87).
  • Technology Synopsis: This patent relates to the same field of segment-based routing, where a packet's path is identified within the packet itself. This approach simplifies network architecture, improves scalability, and allows for more precise control over packet forwarding (Compl. ¶¶ 21-23).
  • Asserted Claims: At least independent claim 2 (Compl. ¶ 90).
  • Accused Features: The DISH Networks are accused of infringement based on their alleged implementation of Segment Routing technology conforming to IETF standards (Compl. ¶¶ 61, 90).

Multi-Patent Capsule: U.S. Patent No. 10,805,204

  • Patent Identification: U.S. Patent No. 10,805,204, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued October 13, 2020 (Compl. ¶ 95).
  • Technology Synopsis: This patent covers inventions for improving network routing by encoding a sequence of segment identifiers in a packet header. This source-routing technique is alleged to reduce the per-flow state that network nodes must maintain, leading to efficiency and cost savings (Compl. ¶¶ 21, 25).
  • Asserted Claims: At least independent claim 15 (Compl. ¶ 98).
  • Accused Features: The accused instrumentalities are the DISH Networks that allegedly utilize Segment Routing functionality as defined by various SR RFCs (Compl. ¶¶ 61, 98).

Multi-Patent Capsule: U.S. Patent No. 11,757,756

  • Patent Identification: U.S. Patent No. 11,757,756, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued September 12, 2023 (Compl. ¶ 103).
  • Technology Synopsis: This patent discloses inventions in segment-based routing that provide advantages over the prior art, including reducing the need for state information in network nodes and eliminating the need for additional complex protocols by embedding path information in the packet header (Compl. ¶¶ 26-27).
  • Asserted Claims: At least independent claim 10 (Compl. ¶ 106).
  • Accused Features: The DISH Networks' alleged use of standardized Segment Routing technology is the basis for the infringement allegation for this patent (Compl. ¶¶ 61, 106).

Multi-Patent Capsule: U.S. Patent No. 11,784,914

  • Patent Identification: U.S. Patent No. 11,784,914, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued October 10, 2023 (Compl. ¶ 111).
  • Technology Synopsis: This patent also concerns segment-based routing, with claimed inventions that allow network operators to specify explicit paths for packets, optimize bandwidth, and simplify the network control plane by reducing the amount of state information maintained by network nodes (Compl. ¶¶ 24-25).
  • Asserted Claims: At least independent claim 1 (Compl. ¶ 114).
  • Accused Features: Infringement is alleged based on the DISH Networks' implementation of Segment Routing functionality specified in SR RFCs (Compl. ¶¶ 61, 114).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are the "DISH Networks," which collectively refers to DISH's nationwide 5G network (operated under the Boost Mobile brand) and its enterprise 5G networks (Compl. ¶ 49). The complaint further specifies that the accused instrumentalities are those DISH Networks that support the functionality detailed in various Segment Routing (SR) standards, or "SR RFCs" (Compl. ¶ 61).
  • Functionality and Market Context: The complaint alleges that DISH's networks are 5G stand-alone networks that utilize an Open Radio Access Network (O-RAN) architecture (Compl. ¶ 50). The network is built with components from multiple third-party suppliers, including Nokia, Cisco, Samsung, and AWS (Compl. ¶ 51). A network architecture diagram provided in the complaint illustrates the multi-vendor, cloud-based structure of the DISH Wireless Open RAN 5G Network (Compl. p. 13). Plaintiff alleges that these networks utilize SR for "automated traffic management and network slicing" and employ SR-MPLS technologies, citing DISH press releases and job postings (Compl. ¶¶ 52-53, footnotes 30, 31).

IV. Analysis of Infringement Allegations

The complaint references exemplary infringement analysis charts in Exhibits H through N but does not attach them (Compl. ¶¶ 67, 75, 83, 91, 99, 107, 115). In lieu of a claim chart summary, the narrative infringement theory is summarized below.

The complaint's central infringement theory is that the accused DISH Networks practice the patented inventions by implementing standardized Segment Routing (SR) technology (Compl. ¶ 52). The complaint alleges that DISH utilizes equipment and software that support SR and specifically operate according to a set of technical standards known as SR RFCs, published by the IETF (Compl. ¶¶ 53-61). The core allegation is that by building and operating a network that conforms to these SR standards, DISH necessarily uses the methods and systems claimed by the Patents-in-Suit (Compl. ¶ 61, 66, 74).

  • Identified Points of Contention:
    • Standards-Mapping Questions: A primary question will be whether practicing the functionalities described in the cited SR RFCs (e.g., RFC 8402, RFC 8660) inherently infringes the specific limitations of the asserted patent claims. The patents' priority date of 2012 precedes the publication of many of these RFCs, which may raise questions about whether the claim scope was intended to, or does, cover these later-developed standards.
    • Evidentiary Questions: The complaint relies on public-facing documents, such as press releases with partners like Cisco and job postings for network engineers, to evidence DISH's use of SR and SR-MPLS (Compl. ¶¶ 52-53, footnotes 30, 31). A point of contention may be what technical evidence demonstrates that DISH's networks actually implement the specific functionalities from the RFCs that are alleged to map to the claim elements, beyond these high-level marketing and recruitment materials.

V. Key Claim Terms for Construction

The complaint does not provide the full text of the asserted claims. However, based on the technological description in the complaint and the patents, the following terms may be central to the dispute.

  • The Term: "segment identifier"
  • Context and Importance: This term appears to be the fundamental unit of the claimed invention, representing a portion of a network path encoded in a packet header (Compl. ¶ 21). The definition of this term will be critical to determining infringement, particularly how it relates to the concept of a "segment" as used in the SR RFCs that DISH allegedly practices. Practitioners may focus on this term because the plaintiff's case appears to depend on mapping the standardized implementation of a "segment" directly onto the patented "segment identifier."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint's general description suggests a broad meaning, defining a segment identifier as an element in a sequence that identifies a path, which could be embodied as an MPLS label or an IPv6 address (Compl. ¶¶ 21-23).
    • Evidence for a Narrower Interpretation: The abstract of the ’562 Patent describes calculating a "segment identifier (segment ID) based on the index value and the base value," which suggests a specific method of generation (’562 Patent, Abstract). The dispute may turn on whether the claims require this specific calculation method or can be read more broadly to cover any token or label representing a network path segment.

VI. Other Allegations

  • Willful Infringement: The complaint does not contain a specific count for willful infringement or allege pre-suit knowledge of the patents. However, the prayer for relief requests a declaration that the case is "exceptional under 35 U.S.C. § 285" (Compl. p. 22, ¶ C). The complaint does not provide sufficient detail for analysis of willfulness.

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

The resolution of this case may depend on the court’s answers to two central questions:

  • A core issue will be one of definitional scope and standards-mapping: Can the term "segment identifier," as defined and used within the context of the 2012-priority patents, be construed to cover the specific, standardized implementations of "segments" in the later-published IETF SR RFCs that DISH’s network allegedly practices?
  • A key evidentiary question will be one of proof of implementation: Beyond high-level press releases and job descriptions, what technical evidence will be required to demonstrate that DISH’s multi-vendor 5G network actually operates in a manner that performs the specific functions required by the asserted claims?