DCT

4:26-cv-00053

Mobility Workx LLC v. Hewlett Packard Enterprisessss Co

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-00053, E.D. Tex., 01/15/2026
  • 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 wireless networking products and services infringe a patent related to the proactive allocation of network resources to improve handoffs for mobile devices.
  • Technical Context: The technology addresses seamless connectivity in mobile networks, a critical feature for user experience, by attempting to predict a user's movement and pre-establish connections with upcoming wireless access points.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date Event
2003-07-31 ’508 Patent Priority Date
2010-04-13 ’508 Patent Issue Date
2026-01-15 Complaint Filing Date

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: The patent describes the problem of "registration delays and associated information losses" that occur when a mobile device moves from the coverage area of one wireless access point (a "foreign agent") to another (’508 Patent, col. 2:20-23). Conventional systems must wait for the device to arrive in the new region before setting up the new connection, which can cause delays and dropped data packets (’508 Patent, col. 2:28-37).
  • The Patented Solution: The invention proposes a "preemptive and predictive solution" using "ghost-entities" to allocate network resources proactively (’508 Patent, col. 2:42-43, 58-59). A "ghost-mobile node" acts on behalf of the actual mobile device to predict its future location and pre-register it with the next anticipated foreign agent before the device physically arrives (’508 Patent, Abstract). Similarly, a "ghost-foreign agent" can advertise the presence of a future access point to the mobile device while it is still connected to its current one, facilitating a smoother transition (’508 Patent, col. 4:1-6). This architecture is depicted in Figure 2A of the patent.
  • Technical Importance: This predictive approach aims to solve a fundamental challenge in mobile networking by reducing handoff latency, which is especially critical for applications requiring continuous connectivity on devices moving at moderate or high speeds (’508 Patent, col. 2:48-52).

Key Claims at a Glance

  • The complaint asserts infringement of claims 7 and 14 of the ’508 Patent (Compl. ¶11).
  • Independent Claim 7 recites a "wireless node pair" comprising:
    • A mobile node for communicating with a wireless network, having a current geographical state and one or more predicted future states.
    • A "ghost mobile node" associated with the mobile node.
    • The ghost mobile node is configured to signal a "foreign agent" based on a predicted future state, which is predicted using Global Positioning System (GPS) data.
    • The ghost mobile node is remote from the mobile node.
    • The mobile node establishes another ghost mobile node in the new geographic region based on GPS data.
  • Independent Claim 14 recites a "computer-implemented method" for handling mobile devices, comprising the steps of:
    • Predicting one or more future geographical states of a mobile node based on GPS data.
    • Identifying a foreign agent for each future state.
    • Creating a "ghost foreign agent" for each foreign agent to announce its presence.
    • Registering the mobile node (or its ghost) with the foreign agent while the mobile node is still in its current location.
    • Linking the mobile node with the new foreign agent when it enters the new location.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities generically as "certain products and services ("Accused Handover Products/Services")" (Compl. ¶11). No specific product names, models, or software versions are provided.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused products. It makes a general allegation that the products infringe but does not describe how they operate or their position in the market (Compl. ¶11).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that a "preliminary infringement claim chart" is attached as Exhibit 2; however, this exhibit was not included with the filed complaint document (Compl. ¶11). Without the chart or a narrative description of the accused functionality, a detailed analysis of the infringement allegations is not possible. The complaint contains only conclusory allegations that the unspecified "Accused Handover Products/Services" infringe at least claims 7 and 14 (Compl. ¶11).

Identified Points of Contention

Based on the language of the asserted claims, several potential points of contention may arise.

  • Scope Questions: Claim 7 recites a "ghost mobile node" that is "remote from the mobile node." A central question may be whether a predictive software function integrated within a network controller or the mobile device itself can meet the "ghost" and "remote" limitations, or if the patent requires a physically or logically distinct entity as depicted in the specification.
  • Technical Questions: Both asserted claims require predictions "based upon Global Positioning System (GPS) data" (’508 Patent, col. 13:60, col. 14:40-42). A key factual dispute may be whether the accused systems use GPS data for handoff predictions, as opposed to other common location-determination technologies such as Wi-Fi signal strength, cell tower triangulation, or other network-based metrics.

V. Key Claim Terms for Construction

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

  • Context and Importance: This term is foundational to the patent's inventive concept. Its construction will be critical to determining infringement, as it defines the predictive entity that acts on behalf of the mobile device. Practitioners may focus on whether this term requires a distinct software or hardware component, or if it can read on a purely algorithmic function within a larger system.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests a "ghost-mobile node" can be a "virtual node" or a "set of software instructions running on a device that is remote from the mobile node," which could support an argument that it is not limited to a specific hardware implementation (col. 5:21-26).
    • Evidence for a Narrower Interpretation: The specification and figures consistently depict the "ghost mobile node" (220) as a distinct component of a "Wireless Node Pair" (202) alongside the "Mobile Node" (250), which may support an argument that it must be a discrete, associated entity rather than an integrated feature (’508 Patent, Fig. 2A; col. 4:25-26).

The Term: "based upon Global Positioning System (GPS) data" (from claims 7 and 14)

  • Context and Importance: This limitation specifies the source of data for predicting the mobile node's location. The dispute will likely center on whether infringement requires the exclusive or primary use of GPS data, or if systems that use a combination of location inputs (including GPS) meet this element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that any system that is capable of using or incorporates GPS data as one of several inputs for prediction meets the "based upon" requirement.
    • Evidence for a Narrower Interpretation: The patent repeatedly and specifically calls out GPS as the mechanism for prediction (e.g., col. 5:49-53, claims 7, 14). This emphasis could support an argument that GPS data must be an essential, rather than optional or secondary, component of the prediction process.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encourage[s] users of its products and services to make and use the Accused Handover Products/Services" (Compl. ¶12). It also pleads contributory infringement, alleging the accused products "have no substantial non-infringing uses" (Compl. ¶14).
  • Willful Infringement: Willfulness is alleged based on Defendant's purported knowledge of the ’508 Patent "Prior to, or at least through, the filing and service of this complaint" (Compl. ¶12, ¶15). The complaint does not plead specific facts supporting pre-suit knowledge.

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

  • A primary issue will be one of definitional scope: does the term "ghost mobile node," described in the patent as a distinct entity paired with a mobile device, read on a predictive software algorithm that may be integrated within a larger network management system or the mobile device's operating system?
  • A key evidentiary question will be one of technical implementation: will discovery show that the accused systems perform handoff prediction "based upon Global Positioning System (GPS) data" as required by the asserted claims, or do they rely on alternative location-sensing technologies prevalent in modern wireless networking, such as Wi-Fi or cellular network analysis?
  • An immediate procedural question will concern pleading sufficiency: given the complaint's failure to identify any specific accused products or provide a claim chart, early motion practice may focus on whether the allegations meet the plausibility standard for patent infringement claims.