DCT

3:25-cv-02304

Vision Sphere Labs LLC v. Teltonika United States Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-02304, N.D. Tex., 08/26/2025
  • Venue Allegations: Plaintiff asserts venue is proper in the Northern District of Texas because Defendant’s U.S. headquarters are located in the district and Defendant has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s network routers, switches, and platforms that include Quality of Service (QoS) features infringe two patents related to adaptive data prioritization and traffic management in computer networks.
  • Technical Context: The technology at issue addresses methods for managing data traffic in computer networks to provide Quality of Service (QoS), which guarantees performance levels for latency and data loss, a critical function for real-time and interactive applications in bandwidth-constrained environments.
  • Key Procedural History: The complaint alleges that Defendant has had actual knowledge of the patents-in-suit since at least July 19, 2024, based on pre-suit correspondence, which forms the basis for the willfulness allegations. The complaint also notes that one of the asserted patents, the ’028 patent, expired on September 5, 2022, limiting any potential damages for that patent to the pre-expiration period.

Case Timeline

Date Event
2006-06-16 U.S. Patent No. 7,990,860 Priority Date
2006-06-21 U.S. Patent No. 7,769,028 Priority Date
2010-08-03 U.S. Patent No. 7,769,028 Issue Date
2011-08-02 U.S. Patent No. 7,990,860 Issue Date
2022-09-05 U.S. Patent No. 7,769,028 Expiration Date
2024-07-19 Alleged date of correspondence to Defendant regarding patents
2025-08-26 Complaint Filing Date

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

U.S. Patent No. 7,990,860 - “Method and system for rule-based sequencing for QoS”

  • Patent Identification: U.S. Patent No. 7,990,860, “Method and system for rule-based sequencing for QoS,” issued August 2, 2011 (the “’860 Patent”) (Compl. ¶8).

The Invention Explained

  • Problem Addressed: The patent’s background section describes deficiencies in prior art Quality of Service (QoS) systems, noting that they often do not scale well because they require every node in a network to support QoS and cannot provide QoS based on message content at the transport layer (’860 Patent, col. 4:36-50, 5:2-3). This leads to an inability to differentiate between messages that may have different priorities based on their content, even if they otherwise appear identical to the network (Compl. ¶13).
  • The Patented Solution: The invention proposes a communication system that operates at the "edge" of a network to provide more granular, adaptive QoS without modifying every network node (’860 Patent, col. 5:19-22). The system analyzes the network to determine its current status, selects an operational "mode" corresponding to that status, and then applies a "user defined sequencing rule" associated with that mode to prioritize and sequence data at the transport layer of the protocol stack (’860 Patent, Abstract; Fig. 5). The system also meters inbound and outbound data flow based on the network's effective link speed (’860 Patent, col. 17:15-37).
  • Technical Importance: This approach provided a method for implementing adaptive QoS in volatile or bandwidth-constrained networks without requiring a costly, network-wide overhaul of all constituent nodes (Compl. ¶14-16).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 15 (Compl. ¶37).
  • The essential elements of independent claim 15 include:
    • A network analysis component configured to determine a network status and an effective link speed/proportion.
    • A mode selection component configured to select a mode based on the network status, where each mode has a user-defined sequencing rule.
    • A data prioritization component operating at the transport layer, which includes a sequencing component to sequence data based on the selected mode's rule.
    • A data metering component configured to shape inbound data and police outbound data.
    • A data communication component configured to communicate the data based on its priority and the network's link speed/proportion.
  • The complaint reserves the right to assert additional claims (Compl. ¶36).

U.S. Patent No. 7,769,028 - “Systems and methods for adaptive throughput management for event-driven message-based data”

  • Patent Identification: U.S. Patent No. 7,769,028, “Systems and methods for adaptive throughput management for event-driven message-based data,” issued August 3, 2010 (the “’028 Patent”) (Compl. ¶21).

The Invention Explained

  • Problem Addressed: The patent identifies similar problems as the ’860 Patent, stating that existing QoS systems struggle to scale, cannot provide QoS based on message content at the transport layer, and are not easily configurable for different network types or architectures (’028 Patent, col. 4:35-49, 5:1-2).
  • The Patented Solution: The invention describes a method for communicating data by first prioritizing it at or near the transport layer (’028 Patent, col. 23:12-18). The system then analyzes the network to determine its status, selects a "mode" based on that status, and dynamically changes the rules used for assigning priority based on the selected mode (’028 Patent, col. 23:20-25). Finally, it communicates the data at a transmission rate that is metered according to the network's current status (’028 Patent, col. 23:26-31). This process is depicted in the flowchart of Figure 6 (’028 Patent, Fig. 6).
  • Technical Importance: The invention offers a method for dynamically adapting data prioritization rules in response to real-time network conditions, providing a more flexible QoS solution for environments where bandwidth can change dramatically (Compl. ¶28, ¶30).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 (Compl. ¶31, ¶47).
  • The essential elements of independent claim 1 include:
    • Prioritizing data by assigning a priority, with the prioritization occurring in or at the top of the transport layer.
    • Analyzing a network to determine its status.
    • Selecting a mode based on the network status.
    • Changing rules for assigning priority to data based on the selected mode.
    • Communicating the data based on its priority and network status, where the transmission rate is metered based on the network status.
  • The complaint reserves the right to assert additional claims (Compl. ¶47).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "numerous Teltonika routers, switches, and/or platforms" that operate with a "QoS" or "QoS Configuration" feature (Compl. ¶36, ¶47). The Teltonika TSW202 Ethernet switch is provided as a specific, non-limiting example (Compl. ¶36, ¶47).

Functionality and Market Context

  • The complaint alleges that the accused products' QoS features allow for the configuration and management of data traffic to provide priority to certain types of data over others (Compl. ¶36). The complaint references publicly available documentation on Teltonika's website and wiki as containing descriptions of this allegedly infringing functionality (Compl. ¶36, ¶47). The complaint does not provide further detail on the products' market context.

IV. Analysis of Infringement Allegations

The complaint references Exhibit C, a claim chart exhibit, which was not provided with the complaint document. The infringement allegations are therefore summarized below in prose based on the complaint’s narrative. No probative visual evidence provided in complaint.

’860 Patent Infringement Allegations Summary

  • The complaint alleges that Teltonika products with the "QoS" feature, such as the TSW202 switch, infringe at least claim 15 of the ’860 Patent (Compl. ¶36-37). The narrative theory suggests that these products contain components that perform the functions recited in the claim: analyzing network conditions, selecting a corresponding operational mode with user-defined rules, prioritizing and sequencing data at the transport layer according to those rules, metering both inbound and outbound data flow, and ultimately communicating the prioritized data (Compl. ¶17, ¶36). The complaint relies on Teltonika's public documentation for its "QoS" feature as evidence of these infringing functionalities (Compl. ¶36).

’028 Patent Infringement Allegations Summary

  • The complaint alleges that Teltonika products with "QoS Configuration" features infringe the ’028 Patent (Compl. ¶47). The infringement theory, particularly for claim 1, is that these products execute a method of prioritizing data at the transport layer, analyzing the network's status, selecting an operational mode based on that status, dynamically changing the priority rules based on that mode, and communicating data at a metered rate determined by the network conditions (Compl. ¶31, ¶47). As with the ’860 Patent, publicly available product documentation is cited as evidence supporting these allegations (Compl. ¶47).

Identified Points of Contention

  • Scope Questions: A potential point of contention may be whether the term "mode," as used in the patents to describe a comprehensive set of rules tied to a network state, can be read to cover the user-selectable QoS profiles or priority queue settings in the accused commercial products (’860 Patent, col. 8:30-40).
  • Technical Questions: The infringement analysis may raise the question of where in the network protocol stack the accused QoS functionality operates. The claims require prioritization to occur "at a transport layer," whereas QoS in commercial switches often operates at the network (Layer 3) or data-link (Layer 2) layers (’860 Patent, col. 24:41-43; ’028 Patent, col. 23:14-16). Evidence will be required to establish the specific operational layer of the accused features.

V. Key Claim Terms for Construction

The Term: "mode" (’860 Patent, Claim 15; ’028 Patent, Claim 1)

  • Context and Importance: This term is central to the adaptive nature of the claimed inventions, where the system selects a "mode" based on network status, and that mode dictates the rules for prioritization. The infringement dispute may turn on whether the accused products' various QoS settings or profiles constitute a "mode" as claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a "mode or profile" as including "a set of rules related to the operational needs for a particular network state of health or condition" (’860 Patent, col. 7:26-30). This language could support construing "mode" broadly to encompass any distinct, user-selectable set of QoS configurations.
    • Evidence for a Narrower Interpretation: The specification also details "commanded profile switching" where a profile contains multiple, distinct identifiers for different types of rules (e.g., sequencing rule, differentiation rule, transport identifier) (’860 Patent, col. 8:30-56). This could support a narrower construction requiring a "mode" to be a specific, multi-part structure rather than a simple selection of a priority queue.

The Term: "sequencing... based at least in part on... a user defined sequencing rule" (’860 Patent, Claim 15)

  • Context and Importance: This term defines the specific logic for ordering data for transmission. The core question will be whether standard QoS queuing disciplines (e.g., Weighted Fair Queuing, Strict Priority) available in the accused products meet the definition of sequencing based on a "user defined sequencing rule."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent provides examples of sequencing rules, including "starvation, round robin, relative frequency, etc." (’860 Patent, col. 8:6-8), which are common queuing algorithms. This may support an interpretation where any user-configurable queuing discipline is a "user defined sequencing rule."
    • Evidence for a Narrower Interpretation: The claim requires the component to be "configured to sequence the data," which could be argued to imply more than just assigning packets to a pre-defined priority queue. The context of creating a "data stream in an order dictated by the user-configured sequencing rule" could suggest a more active process of arranging data than what standard QoS features provide (’860 Patent, col. 8:5-8).

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement for the ’860 and ’028 patents (Compl. ¶38, ¶40, ¶49, ¶50). The allegations are based on Defendant providing products and software components allegedly known to be "specially made or adapted for use in an infringing manner" and not being staple articles with substantial non-infringing uses (Compl. ¶40, ¶50). It is further alleged that end-user customers directly infringe by using the accused products in their intended manner (Compl. ¶39).

Willful Infringement

  • Willfulness is alleged for both patents based on pre-suit knowledge. The complaint asserts that Defendant has had "actual knowledge" of the patents since "at least as early as July 19, 2024, the date of correspondence to Teltonika informing it of the inventions disclosed" in the patents (Compl. ¶41, ¶51).

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

  • A central issue will be one of architectural location: does the Quality of Service (QoS) functionality in the accused commercial switches and routers, which often operates at the network (Layer 3) or data-link (Layer 2) layers, perform the claimed "prioritization" and "sequencing" at the specific "transport layer" (Layer 4) of the protocol stack as required by the patents?
  • A key evidentiary question will be one of functional specificity: does the accused products' implementation of standard QoS queuing mechanisms constitute the claimed adaptive system of selecting a "mode" based on network analysis and then applying a corresponding "user defined sequencing rule," or is there a fundamental mismatch between the general-purpose nature of the accused feature and the specific, multi-step adaptive logic claimed by the inventions?
  • Given that the ’028 patent expired in September 2022, a significant question for damages will be the temporal scope: what portion of the total accused sales can be attributed to the pre-expiration period of the ’028 patent, and can the plaintiff successfully prove that the accused features were present in products sold during that specific timeframe?