DCT

3:25-cv-02310

Fractal Networks LLC v. Mavenir Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-02310, N.D. Tex., 08/27/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed alleged acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s unidentified telecommunications products infringe a patent related to computing systems for 5G networks.
  • Technical Context: The technology concerns methods for providing low-latency computation at the edge of a 5G wireless network to support high-speed, time-sensitive applications.
  • Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2019-05-07 ’142 Patent - Earliest Priority Date
2020-04-28 ’142 Patent - Issue Date
2025-08-27 Complaint Filing Date

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

U.S. Patent No. 10,637,142 - "Computing system"

  • Patent Identification: U.S. Patent No. 10,637,142, “Computing system,” issued April 28, 2020 (’142 Patent).

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of deploying 5th Generation (5G) cellular technology, which requires a large number of small cell towers to provide ultra-fast speeds and low delays for applications like smartwatches, vehicles, and farms, particularly in high-traffic areas like cities (Compl. ¶9; ’142 Patent, col. 1:33-47).
  • The Patented Solution: The invention proposes a system to meet these demands by placing computational power closer to the end-user. It describes a system with a cellular transceiver, one or more steerable antennas, and a dedicated "edge processing module" coupled to the antennas to provide "low-latency computation" for a specific target device or user (’142 Patent, Abstract; col. 2:51-62). This architecture, depicted in system diagrams like FIG. 2J, aims to reduce delays by processing data locally at the network edge rather than sending it to a distant data center.
  • Technical Importance: This edge computing approach is intended to enable the real-time responsiveness required for advanced 5G applications such as autonomous vehicle communication and virtual reality (’142 Patent, col. 2:16-18).

Key Claims at a Glance

  • The complaint does not identify specific claims in the body of the complaint but incorporates by reference an unattached exhibit (Exhibit 2) containing claim charts (Compl. ¶¶11, 16-17). Independent claim 1 is the broadest claim of the patent.
  • Essential elements of Independent Claim 1 include:
    • a transceiver to communicate with a predetermined target;
    • one or more antennas coupled to the transceiver each electrically or mechanically steerable to the predetermined target;
    • an edge processing module coupled to the transceiver and one or more antennas to provide low-latency computation for the predetermined target; and
    • a quantum computer coupled to the edge processing module.
  • The complaint notes that "numerous other devices" may infringe and refers to "exemplary claims," suggesting the right to assert additional claims is reserved (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring to them generally as "Exemplary Defendant Products" identified in the unattached Exhibit 2 (Compl. ¶11).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the ’142 Patent" but provides no specific details about their features, functionality, or market position in the complaint itself (Compl. ¶16).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an unattached exhibit (Exhibit 2) but does not provide them, precluding a detailed claim-chart summary (Compl. ¶17). The complaint’s narrative infringement theory states globally that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '142 Patent Claims" (Compl. ¶16).

Identified Points of Contention

  • Evidentiary Question: A primary question will be what specific evidence Plaintiff proffers to demonstrate that the accused, but unidentified, products incorporate each element of the asserted claims. The absence of a specific technical mapping in the complaint leaves the factual basis for the infringement allegation entirely unspecified.
  • Scope Question: A central dispute may arise over the claim limitation requiring "a quantum computer coupled to the edge processing module" (’142 Patent, col. 92:49-51). The analysis will question whether Defendant's commercial telecommunications products contain a component that meets the technical definition of a "quantum computer," a highly specialized and non-conventional computing device.
  • Technical Question: What evidence does the complaint provide that the accused products feature an "edge processing module" that performs the "low-latency computation" as required by the claims? The complaint does not offer facts to support this functional allegation.

V. Key Claim Terms for Construction

The Term: "quantum computer"

  • Context and Importance: This term appears in independent claim 1 and is dispositive for infringement. Practitioners may focus on this term because quantum computers are not known to be integrated into commercial 5G network products, making this element a likely point of non-infringement argument for the Defendant. The case may turn on whether Plaintiff can establish that some component in the accused products meets this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of evidence supporting a broader interpretation. The patent specification itself appears to treat the term as having its conventional, technical meaning.
    • Evidence for a Narrower Interpretation: The specification discusses the quantum computer in the context of advanced processing, referencing a "hybrid classical/quantum computer supporting edge computing" and detailing its components in FIG. 8 and the associated description, which describes manipulating "quantum data (measured in units of qubits)" (’142 Patent, FIG. 8; col. 73:58-74:12). This suggests the term should be construed narrowly to mean a device that operates on principles of quantum mechanics, not a conventional classical computer.

The Term: "edge processing module"

  • Context and Importance: This term is central to the patent's description of providing low-latency computation at the network edge. The definition will be critical to determining whether the accused products' processing architecture infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the module is for providing "low-latency computation," which could be interpreted broadly to cover various forms of processing performed locally within a network architecture (’142 Patent, col. 2:59-62).
    • Evidence for a Narrower Interpretation: The specification provides a specific list of exemplary components for the module: "cryogenic processors, quantum processors, neuromorphic processors, learning machines, GPUs, and FPGA" (’142 Patent, col. 2:62-65). A defendant may argue the term should be limited to this class of high-performance, specialized processors rather than general-purpose CPUs.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement based on Defendant distributing "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14). It also alleges inducement starting from the date of service of the complaint (Compl. ¶15).
  • Willful Infringement: The complaint asserts that service of the complaint and its attached (but missing) claim charts provides Defendant with "Actual Knowledge" of infringement (Compl. ¶13). The basis for willfulness is therefore alleged post-suit conduct (Compl. ¶14).

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

  • A core issue will be one of evidentiary support: Can Plaintiff produce evidence showing that Defendant’s commercial 5G products contain "a quantum computer," a claim limitation that appears to require a highly advanced and non-conventional technology not typically found in such products? The answer will likely determine the viability of the infringement claim.
  • A key threshold question will be one of factual specificity: Which of Defendant’s products are actually accused of infringement? The complaint’s failure to identify the accused instrumentalities or provide the referenced claim charts leaves the fundamental basis of the lawsuit unclear.
  • A central legal question will be one of definitional scope: How will the court construe the term "edge processing module"? The outcome will determine whether the architecture of Defendant’s products falls within the scope of the claims, or if there is a fundamental mismatch between the patented invention and the accused technology.