E Beacon LLC v. Match Group Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Match Group, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: e-Beacon LLC v. Match Group, Inc., 3:25-cv-00523, N.D. Tex., 03/01/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that unspecified products from Defendant infringe a patent related to providing location data to emergency services for Voice over IP (VoIP) telephone calls.
• Technical Context: The technology addresses the challenge of locating nomadic VoIP users during 911 calls, a critical public safety issue that arose with the shift away from fixed-line telephones.
• Key Procedural History: The patent-in-suit is a continuation-in-part of an earlier application that issued as U.S. Patent No. 7,933,580. The patent is also subject to a terminal disclaimer, which may limit its enforceable term and could be relevant to obviousness-type double patenting analyses.

Case Timeline

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

• Patent Identification: U.S. Patent No. 8,515,386 (Emergency services for voice over IP telephony (E-VoIP)), issued August 20, 2013. (Compl. ¶8-9).
• The Invention Explained:
  • Problem Addressed: The patent’s background section describes the unreliability of emergency services for VoIP telephony users. Unlike traditional landlines with fixed addresses, a VoIP phone can be used anywhere with an internet connection, making it difficult for a 911 operator to automatically determine the caller's physical location and dispatch emergency responders. (ʼ386 Patent, col. 1:16-29).
  • The Patented Solution: The invention is a system and method that determines a VoIP device's physical location using one or more location detection technologies (LDTs), such as GPS or cellular triangulation. When an emergency call is initiated, the system automatically transmits the determined location coordinates to the emergency services call center, also known as a Public Safety Answering Point (PSAP). The system is designed to periodically detect and store location coordinates to ensure that the most up-to-date information is available, even if a live location fix is not possible during the call itself. (ʼ386 Patent, col. 2:34-44, 2:56-62; Fig. 1).
  • Technical Importance: The described technology aims to provide VoIP users with a level of emergency location service comparable to that of traditional E-911 systems, addressing a significant public safety gap for a growing class of telecommunications users. (ʼ386 Patent, col. 1:45-56).
• Key Claims at a Glance:
  • The complaint does not specify which claims are asserted, instead referring to "Exemplary '386 Patent Claims" identified in an "Exhibit 2" that was not filed with the complaint. (Compl. ¶11, ¶16).
  • For the purpose of analysis, independent claim 1 is representative of the patented method:
    • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT")
    • if an attempt is successful, storing the physical location determined using the corresponding LDT
    • placing a call to the emergency services call center with the VoIP phone
    • automatically transmitting the physical location of the VoIP phone to the emergency services call center
  • The complaint states that Plaintiff infringes "one or more claims," suggesting the right to assert other independent or dependent claims is reserved. (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint does not name any specific accused products, referring to them only as the "Exemplary Defendant Products." (Compl. ¶11). The caption and parties section identify the Defendant as "Match Group, Inc. (Tinder)," suggesting the Tinder application may be an accused product. (Compl. ¶1).
• Functionality and Market Context: The complaint does not provide any description of the accused products' features or functionality. It makes only the conclusory allegation that the products "practice the technology claimed by the '386 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references but does not include the claim charts from its Exhibit 2 detailing its infringement theory. (Compl. ¶17). The narrative allegations state that the "Exemplary Defendant Products" satisfy all elements of the asserted claims. (Compl. ¶16). Due to the lack of specific factual allegations or an accessible claim chart, a detailed element-by-element analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: The sparsity of the complaint raises fundamental questions that will likely be the focus of early discovery and dispositive motions.
  • Scope Questions: A primary issue may be whether the accused instrumentality, presumably a social media application like Tinder, qualifies as a "VoIP phone" within the meaning of the claims. The patent appears to contemplate devices or software used for placing emergency voice calls, raising the question of whether an application with general location-sharing features for a different purpose (e.g., user matching or safety check-ins) falls within the claim scope.
  • Technical Questions: A key factual dispute will concern whether the accused products actually perform the specific steps of the claimed method. For example, what evidence demonstrates that the accused products: (1) make a "plurality of attempts" to determine location using "separate" technologies (e.g., both GPS and Wi-Fi triangulation); (2) place a call to a formal "emergency services call center"; and (3) "automatically" transmit location data to that center in the manner described by the patent. The complaint provides no technical evidence on these points.

V. Key Claim Terms for Construction

• The Term: "VoIP phone"

• Context and Importance: This term is foundational to the asserted claims. Its construction will be critical in determining whether the patent applies to the accused products, which may not be conventional telephony devices. Practitioners may focus on this term because its definition could either confine the patent to its core E-911 context or expand it to cover a broader range of location-aware internet applications.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification discusses "soft phones," which it describes as a "software based VoIP phone which uses the computer's internet connection to make and receive telephone calls." ('386 Patent, col. 7:40-43). Plaintiff may argue this language supports construing "VoIP phone" to encompass software applications that perform communications over IP.
  • Evidence for a Narrower Interpretation: The patent's background, summary, and detailed description consistently frame the invention in the context of placing emergency calls to a "911 Call Center" or "PSAP." ('386 Patent, col. 1:20-23; col. 2:38-44). Defendant may argue this context limits the term to devices or applications whose functionality includes placing emergency voice calls, not applications with other primary purposes.

• The Term: "emergency services call center"

• Context and Importance: The claims require placing a call and transmitting location to this entity. The identity of the receiving entity is therefore a critical limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint does not provide a basis for a broad interpretation.
  • Evidence for a Narrower Interpretation: The specification explicitly equates this term with a "Public Safety Answering Point ('PSAP')." ('386 Patent, col. 2:41-43). This suggests the term is limited to official government-run emergency dispatch centers (e.g., 911 operators) and would not cover transmissions to private security services, friends, or other contacts through an application's safety features.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant distributes "product literature and website materials" that instruct users to use the products in an infringing manner. (Compl. ¶14). Knowledge is alleged to exist at least from the date the complaint was served. (Compl. ¶15).
• Willful Infringement: The complaint does not explicitly allege willfulness but claims Defendant has "actual knowledge" of the '386 patent from the service of the complaint and continues to infringe. (Compl. ¶13-14). In its prayer for relief, Plaintiff requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is often predicated on findings of willful infringement or other litigation misconduct. (Compl. p. 5, ¶E.i.).

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

• A core issue will be one of definitional scope: can the term "VoIP phone", which is described in the patent in the specific context of E-911 voice calling, be construed to cover a social networking or dating application whose primary purpose is not voice telephony? The resolution of this question may determine whether the patent is applicable to the accused products.
• A key evidentiary question will be one of technical and factual mismatch: given the absence of factual allegations in the complaint, the case will likely turn on whether Plaintiff can produce evidence that the accused products actually perform the specific, multi-step method of Claim 1. This includes proving the use of a "plurality" of location technologies and the "automatic" transmission of location data to a formal "emergency services call center," as opposed to a different type of location sharing for a non-emergency purpose.