Mobility Workx LLC v. Wipro Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobility Workx, LLC (Florida)
  • Defendant: Wipro Limited (India), Wipro Inc. (Delaware), and Wipro, LLC (Texas)
  • Plaintiff’s Counsel: Machat & Associates, PC; Zeisler PLLC
• Case Identification: 4:25-cv-01243, E.D. Tex., 11/18/2025
• 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 in Plano, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s network emulation and mobile handover products and services infringe three patents related to simulating mobile network conditions and proactively managing wireless resource allocation.
• Technical Context: The patents address technologies for testing mobile network performance and ensuring seamless connectivity for mobile devices as they move between different network access points, a critical function in mobile computing.
• Key Procedural History: U.S. Patent No. 8,213,417, one of the patents-in-suit, was the subject of an Inter Partes Review (IPR) proceeding (IPR2018-01150). A certificate issued on February 15, 2023, confirmed the patentability of claims 3 and 6 while cancelling claims 1, 2, 4, 5, and 7. The complaint asserts only the surviving claims (3 and 6) of the ’417 patent, indicating an awareness of this proceeding.

Case Timeline

Date	Event
2003-07-31	Priority Date for ’330 Patent
2003-07-31	Priority Date for ’508 and ’417 Patents
2007-06-12	U.S. Patent No. 7,231,330 Issues
2010-04-13	U.S. Patent No. 7,697,508 Issues
2012-07-03	U.S. Patent No. 8,213,417 Issues
2018-06-01	Inter Partes Review (IPR) filed against ’417 Patent
2023-02-15	IPR Certificate issues for ’417 Patent, cancelling several claims
2025-11-18	Complaint Filed

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

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

The Invention Explained

• Problem Addressed: The patent’s background describes the challenges in testing mobile network protocols and applications. Software-based simulators are noted as being time-consuming and costly, while existing hardware-based "wire-line emulators" fail to adequately model the complex characteristics of rapid mobility and wireless signal propagation (’330 Patent, col. 1:28-col. 2:17).
• The Patented Solution: The invention proposes a hybrid hardware and software system to emulate a mobile network environment. It utilizes multiple fixed wireless nodes, each equipped with a variable attenuator that can dynamically adjust signal strength. A central controller manages these attenuators to simulate the movement of a physically stationary mobile device, mimicking the signal degradation and handoffs that occur in a real-world scenario. A network emulator is linked to the wireless nodes to replicate the conditions of a wired back-end network, such as packet delay and loss (’330 Patent, Abstract; Fig. 1).
• Technical Importance: This approach enabled researchers and developers to conduct realistic, repeatable, and efficient testing of mobile network performance without the logistical challenges of physically moving devices through a network (’330 Patent, col. 2:59-62).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-19 (Compl. ¶15).
• Independent Claim 1 requires:
  • A plurality of fixedly-located wireless network nodes capable of variably adjusting wireless communication characteristics.
  • At least one mobile node configured to communicate wirelessly with the wireless nodes.
  • A network emulator linked to the wireless nodes to emulate attributes of a packet-based wired network.
  • A controller linked to the wireless nodes to control their communication characteristics, thereby simulating different wireless conditions for the mobile node.
• The complaint reserves the right to assert additional claims (Compl. ¶15).

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

The Invention Explained

• Problem Addressed: The patent identifies registration delays and data loss during "handoffs"—when a mobile device moves from the coverage area of one network access point (a "foreign agent") to another—as significant obstacles in wireless communications. The time required to establish a new connection can lead to dropped data packets and a poor user experience (’508 Patent, col. 2:20-34).
• The Patented Solution: The invention discloses a predictive system to make handoffs seamless. It introduces the concepts of a "ghost-mobile node" and a "ghost-foreign agent." The ghost-mobile node is a virtual entity that predicts the physical mobile node's future location and pre-registers with the next foreign agent on its behalf before the device arrives. The ghost-foreign agent advertises the presence of an upcoming foreign agent to the mobile device while it is still in the current coverage area, enabling proactive resource allocation (’508 Patent, Abstract; col. 2:42-54).
• Technical Importance: This predictive and preemptive approach was designed to eliminate the setup delay inherent in reactive handoff systems, thereby improving the performance and reliability of communications for mobile devices, particularly those moving at high speeds (’508 Patent, col. 2:48-51).

Key Claims at a Glance

• The complaint asserts independent claims 7 and 14 (Compl. ¶21).
• Independent Claim 14, a method claim, requires:
  • Identifying a mobile node and determining its current geographical state.
  • Predicting one or more future geographical states of the mobile node based on GPS data.
  • Identifying a foreign agent for each future state.
  • Creating a "ghost foreign agent" for each identified foreign agent.
  • While the mobile node is in its current state, registering it (or a "ghost mobile node") with the upcoming foreign agent.
  • Linking the mobile node with that new foreign agent when it enters the new geographical state.

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

Technology Synopsis

As a continuation of the application that led to the ’508 Patent, this patent addresses the same technical problem of reducing delay and data loss during mobile network handoffs (’417 Patent, col. 2:20-37). The solution is likewise based on a predictive system using a "ghost-mobile node" to pre-register with network access points and a "ghost-foreign agent" to provide advance notification of upcoming network nodes (’417 Patent, Abstract).

Asserted Claims

Claims 3 and 6 are asserted (Compl. ¶28).

Accused Features

The complaint alleges that Defendant's "Accused Handover Products/Services" infringe by enabling proactive resource allocation for mobile devices (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific products or services by name. It refers generally to "Accused Emulation Products/Services" in relation to the ’330 Patent and "Accused Handover Products/Services" in relation to the ’508 and ’417 Patents (Compl. ¶¶15, 21, 28).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentalities' specific functionalities. The allegations are made "upon information and belief" and lack descriptions of how any particular Wipro product or service operates (Compl. ¶¶15, 21, 28). No details regarding market positioning or commercial importance are provided.

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement claim charts (Exhibits 2, 4, and 6) that were purportedly attached but were not included with the filed document (Compl. ¶¶15, 21, 28). In the absence of these charts, the infringement theory is based on the general allegations in the complaint.

’330 Patent Infringement Allegations

The complaint alleges that Defendant’s "Accused Emulation Products/Services" directly infringe claims 1-19 of the ’330 Patent. The narrative theory is that these products and services embody the claimed system for emulating mobile network conditions (Compl. ¶15).

’508 Patent Infringement Allegations

The complaint alleges that Defendant indirectly infringes claims 7 and 14 of the ’508 Patent by inducing customers to use "Accused Handover Products/Services." The narrative theory is that these services perform the claimed method of proactively allocating wireless resources based on predicted mobile node movement (Compl. ¶21).

Identified Points of Contention

• Factual Basis: A primary point of contention will be whether Plaintiff can substantiate its "information and belief" allegations with evidence demonstrating that the vaguely accused products actually perform the functions required by the claims. The lack of specificity in the complaint suggests the factual basis for infringement may be a central dispute.
• Scope Questions: For the ’330 Patent, a key question is whether the accused systems, once identified, use "fixedly-located wireless network nodes" with variable characteristics managed by a "controller" to simulate motion, or if they employ a different, non-infringing architecture (e.g., purely software-based simulation).
• Technical Questions: For the ’508 Patent, the analysis will question whether the accused services perform the specific steps of predicting a "geographical future state" based on "GPS data" and creating "ghost" agents to pre-register the device, as required by claim 14.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of potential claim construction disputes. However, based on the technology, certain terms are likely to be central to the case.

’330 Patent

• The Term: "network emulator" (Claim 1)
• Context and Importance: This term is fundamental to the claimed system. Practitioners may focus on this term because its scope will determine whether the accused system falls within the claims. The defense may argue its product is a "simulator" rather than an "emulator" or that it lacks the specific capabilities described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification references existing tools like the "Ohio Network Emulator," which may suggest the term was intended to have a relatively broad meaning consistent with its use in the art at the time (’330 Patent, col. 2:2-10).
  • Evidence for a Narrower Interpretation: The patent defines the emulator’s purpose as replicating specific "attributes of a packet-based wired communications network," including "tunable packet-delay distribution, network congestion, bandwidth limitation, and packet re-ordering and duplication" (’330 Patent, Claim 1). This language could support an argument that the term is limited to devices performing these enumerated functions.

’508 Patent

• The Term: "ghost-mobile node" (Claim 7)
• Context and Importance: This is a key neologism invented for the patent. Its definition is critical because it describes the predictive entity that acts on behalf of the physical device. The dispute will likely center on whether the accused system contains a corresponding virtual component that performs the claimed predictive registration functions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the entity as a "virtual node" and a "virtual repeater," which could support a construction covering any software process that predicts future states and initiates registration on behalf of a mobile device (’508 Patent, col. 4:60-61; col. 6:20-21).
  • Evidence for a Narrower Interpretation: The specification provides specific implementation details, such as the use of a Kalman filter for location prediction and the creation of "spoofed" UDP packets for registration (’508 Patent, col. 7:13-21; col. 9:18-21). This may support a narrower construction limited to an entity that operates in this specific manner.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement for the ’508 and ’417 Patents. The basis for this allegation is that Defendant "actively encourage[s] customers" to use the accused services with knowledge and intent that this use constitutes direct infringement (Compl. ¶¶22, 29). No specific evidence, such as user manuals or marketing materials, is cited.

Willful Infringement

Willfulness is alleged for all three patents based on Defendant’s alleged infringement after gaining "knowledge of the" patents (Compl. ¶¶16, 23, 30). The complaint alleges this knowledge existed "[p]rior to, or at least through, the filing and service of this... complaint," which frames the allegation to cover potential pre-suit knowledge while primarily establishing a basis for post-filing willfulness (Compl. ¶¶22, 29).

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

1. Evidentiary Sufficiency: A foundational issue will be whether the plaintiff can produce evidence to support its infringement allegations. Given that the complaint fails to identify specific accused products or describe their operation, the case will hinge on discovery revealing a factual basis that connects Wipro's technology to the specific limitations of the patent claims.
2. Definitional Scope: The case will likely turn on the construction of neologisms central to the ’508 and ’417 Patents. A core question will be whether the terms "ghost-mobile node" and "ghost-foreign agent," which are tied to specific predictive functions in the patents, can be construed broadly enough to read on the predictive handoff mechanisms potentially used in modern wireless systems.
3. Technical Operation: For the ’330 Patent, a key question of technical fact will be whether any accused Wipro service operates by using the claimed architecture of fixed hardware nodes with variable signal characteristics to simulate motion, or if it relies on a fundamentally different and non-infringing technical approach to network emulation.