DCT

4:26-cv-00051

Mobility Workx LLC v. HP Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-00051, E.D. Tex., 01/15/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has committed acts of infringement and maintains regular and established places of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unnamed products and services infringe a patent related to proactively allocating wireless communication resources to improve network handoffs for mobile devices.
  • Technical Context: The technology addresses reducing latency and data loss when a mobile device moves between different wireless network access points, a critical function for maintaining seamless connectivity in mobile computing.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2003-07-31 U.S. Patent No. 7,697,508 Priority Date
2010-04-13 U.S. Patent No. 7,697,508 Issues
2026-01-15 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"*

The Invention Explained

  • Problem Addressed: In conventional mobile networks, when a device moves from one wireless access point (a "foreign agent") to another, there are "registration delays and associated information losses" because the new connection setup can only begin after the device arrives in the new coverage area, which can lead to dropped data packets (’508 Patent, col. 2:20-35).
  • The Patented Solution: The invention proposes a "preemptive and predictive solution" using "ghost entities" to manage network handoffs ('508 Patent, col. 2:42-43). A "ghost-mobile node" predicts the mobile device's future location and pre-registers it with the next foreign agent before the device physically arrives in that agent's coverage area ('508 Patent, Abstract; col. 2:58-62). This proactive allocation of resources is intended to make handoffs seamless, reducing delays and preventing data loss by ensuring the new connection is ready in advance ('508 Patent, col. 4:8-17). Figure 2A illustrates this architecture, showing the ghost-mobile node (220) communicating with foreign agents (215, 230) on behalf of the mobile node (250).
  • Technical Importance: This approach sought to improve the performance of Mobile IP protocols, which was critical for supporting real-time applications like voice and video on mobile devices moving between networks.

Key Claims at a Glance

  • The complaint asserts independent claims 7 and 14 ('508 Patent, Compl. ¶11).
  • Claim 7 (a "wireless node pair"):
    • A mobile node for communicating with a wireless communications network, having a current state and predicted future states.
    • A ghost mobile node associated with the mobile node.
    • The ghost mobile node announces its presence to a foreign agent and signals the agent based on a predicted future state of the mobile node.
  • Claim 14 (a method):
    • Identifying a mobile node and determining its current geographical state.
    • Predicting one or more future geographical states based upon Global Positioning System (GPS) data.
    • Identifying a foreign agent for each future state.
    • Creating a "ghost foreign agent" for each foreign agent.
    • Registering the ghost or mobile node with the foreign agent while the mobile node is still in its current state.
    • Linking the mobile node with the new foreign agent when it enters the new future state.
  • The complaint alleges infringement of "one or more claims... including at least claims 7 and 14," thereby reserving the right to assert other claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "certain products and services ('Accused Handover Products/Services')" made, used, or sold by HP (Compl. ¶11).

Functionality and Market Context

The complaint does not provide any technical description of the functionality of the accused products or services, nor does it detail their market context beyond alleging they are sold in the United States (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint references a "preliminary infringement claim chart attached as Exhibit 2"; however, this exhibit was not provided (Compl. ¶11). The complaint body itself contains no specific factual allegations mapping claim elements to features of an accused instrumentality. It states only that HP's "Accused Handover Products/Services" directly infringe the ’508 Patent (Compl. ¶11). Without the referenced exhibit or more detailed allegations, a substantive analysis of the infringement theory is not possible.

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Given the lack of specific infringement allegations, any points of contention must be inferred from the claim language itself.
    • Scope Questions: A central question will be whether the patent's unique terms, such as "ghost mobile node" and "ghost-foreign agent," can be construed to read on the components or software functions of modern wireless networking technologies. For instance, does a software process that manages roaming and pre-authentication in a modern Wi-Fi system constitute a "ghost mobile node"?
    • Technical Questions: Claim 14 explicitly requires "predicting... future states... based upon Global Positioning System (GPS) data." A key factual question will be whether any accused HP product or service uses GPS data for the specific purpose of predicting and preparing for a network handoff, as opposed to for other location-based services.

V. Key Claim Terms for Construction

  • The Term: "ghost mobile node" (claim 7)

    • Context and Importance: This term is a neologism central to the patent's inventive concept. The outcome of the case may depend on whether this term is construed to require a distinct, separate software entity or can cover a more distributed set of functions within a larger system. Practitioners may focus on this term because its unique nature makes it a likely point of non-infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the ghost-mobile node as a "virtual node" that can be a "set of software instructions running on a device that is remote from the mobile node," suggesting it is not necessarily a single, co-located hardware or software component ('508 Patent, col. 6:21-26).
      • Evidence for a Narrower Interpretation: Claim 7 recites a "wireless node pair" comprising the mobile node and the "ghost mobile node." The patent figures also depict the ghost-mobile node as a discrete block (e.g., FIG. 2A, element 220), which could support an argument that it must be an identifiable and distinct component.

  • The Term: "predicting one or more geographical future states... based upon Global Positioning System (GPS) data" (claim 14)

    • Context and Importance: This limitation anchors the predictive method of claim 14 to a specific technology (GPS). The infringement analysis for this claim will turn on whether the accused systems use GPS data for this predictive purpose.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue that "based upon" does not require GPS data to be the sole or primary input, potentially allowing systems that use GPS in combination with other location data (e.g., Wi-Fi network analysis, cellular triangulation) to meet the limitation.
      • Evidence for a Narrower Interpretation: The explicit recitation of "GPS data" could be interpreted as a significant limitation, excluding systems that rely on other methods for location prediction. The specification directly links the use of a GPS unit to the prediction of the mobile node's future state ('508 Patent, col. 6:49-53).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement, asserting that HP encourages users of its products to directly infringe the ’508 Patent with knowledge and intent (Compl. ¶12-13). It also alleges contributory infringement, claiming the accused products have no substantial non-infringing uses (Compl. ¶14). The complaint does not, however, plead specific facts to support these allegations.
  • Willful Infringement: The complaint alleges that HP knew of the ’508 Patent "Prior to, or at least through, the filing and service of this complaint" and that its continued infringement is "deliberate, knowing, and willful" (Compl. ¶12, 15).

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

  • A core issue will be one of definitional scope: can the patent’s specialized, non-standard terms, particularly "ghost mobile node" and "ghost-foreign agent," be construed to cover the architecture and functions of modern, standardized technologies for managing wireless network roaming and handoffs?
  • A key evidentiary question will be one of technical mechanism: what evidence will discovery yield to show that the accused HP systems perform the specific predictive functions recited in the claims? In particular, does any accused system use "GPS data" to proactively "predict" a future network access point and pre-register a device with it, as required by claim 14?