DCT

3:24-cv-02247

CelluPlex LLC v. Uniden America Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-02247, N.D. Tex., 09/03/2024
  • Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business in the Northern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to a Bluetooth interface for connecting cellular phones to wired telephone networks.
  • Technical Context: The technology enables the use of conventional wired telephones to make and receive calls via a nearby cellular phone's network, unifying the two communication methods within a home or office.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2003-11-10 ’664 Patent Application Filed
2007-02-13 ’664 Patent Issued
2024-09-03 Complaint Filed

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

U.S. Patent No. 7,177,664 - "Bluetooth interface between cellular and wired telephone networks," issued February 13, 2007

The Invention Explained

  • Problem Addressed: The patent addresses the inconvenience faced by cellular telephone owners who, when at home or in the office, would prefer to use a conventional wired telephone but still need to make or receive calls directed to their cellular number. This often required locating the cellular phone, which might be inconveniently placed or charging in another room. (’664 Patent, col. 1:11-29).
  • The Patented Solution: The invention is an "interconnect device" that wirelessly links a cellular phone to a local wired telephone network using a short-range radio protocol like Bluetooth. (’664 Patent, col. 2:34-38). This device emulates a standard telephone line, allowing a user to pick up any connected wired phone to answer an incoming cellular call or to place an outgoing call through the cellular network. The system architecture is depicted in Figure 1, which shows the interconnect device (10) as a bridge between a cellular phone (40) and standard wired telephones (21, 22, 23). (’664 Patent, Fig. 1; col. 3:11-23).
  • Technical Importance: This approach allowed users to leverage the superior ergonomics and features of wired telephones, such as higher quality speakerphones or multi-handset systems, for calls made over the cellular network. (’664 Patent, col. 2:39-44).

Key Claims at a Glance

  • The complaint does not identify specific claims asserted against the Defendant. It refers to "Exemplary '664 Patent Claims" that are purportedly identified in an Exhibit 2, which was not filed with the complaint. (Compl. ¶¶11, 13).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name.

Functionality and Market Context

The complaint refers to "Exemplary Defendant Products" but provides no description of their functionality, instead incorporating by reference the contents of an unfiled Exhibit 2. (Compl. ¶¶11, 13). Consequently, the complaint does not provide sufficient detail for analysis of the accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe by practicing the technology claimed in the ’664 Patent. (Compl. ¶13). It incorporates by reference "charts comparing the Exemplary '664 Patent Claims to the Exemplary Defendant Products" contained in an Exhibit 2. (Compl. ¶13). As this exhibit was not provided, a detailed claim chart analysis is not possible. The complaint’s narrative theory is limited to the conclusory statement that the accused products "satisfy all elements of the Exemplary '664 Patent Claims." (Compl. ¶13). Figure 1 of the ’664 patent, incorporated by reference, illustrates the general system for linking a cellular phone to a wired telephone network. (Compl. ¶9; ’664 Patent, Fig. 1).

Identified Points of Contention

The complaint's lack of specificity prevents the identification of concrete technical or legal disputes. The primary threshold issue is whether the complaint provides sufficient notice of the infringement theory under federal pleading standards. Assuming the case proceeds, key questions may include:

  • Scope Questions: How might claim terms drafted for early-2000s Bluetooth and telephony standards be applied to the technology in modern communication devices?
  • Technical Questions: Does the architecture of the accused products align with the specific "interconnect device" structure described in the patent, or do they achieve a similar result through a fundamentally different technical implementation?

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as it fails to identify the specific patent claims being asserted. (Compl. ¶¶11, 13).

VI. Other Allegations

Willful Infringement

The complaint does not contain an explicit count for willful infringement or allege any facts regarding pre-suit knowledge of the patent. However, the prayer for relief requests a judgment that the case is "exceptional" and an award of enhanced damages and attorneys' fees under 35 U.S.C. §§ 284 and 285. (Compl. ¶¶D, E.i).

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

The initial phase of this litigation will likely focus on the adequacy of the complaint itself. Beyond that, the case presents two central questions:

  1. A central procedural question will be whether the complaint, which fails to identify any specific accused products or asserted patent claims and relies entirely on an unfiled exhibit, satisfies the plausibility pleading standard required for patent cases.
  2. Should the case proceed to the merits, a key issue will be one of technological relevance: How can the limitations of a patent with a 2003 priority date, directed at bridging early-generation cellular phones with wired telephone systems, be mapped onto the features of contemporary communication products, and what evidence will be required to prove that the specific technical operations are equivalent?