DCT
4:25-cv-00948
Competitive Access Systems Inc v. Motorola Mobility LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Competitive Access Systems, Inc. (Texas)
- Defendant: Motorola Mobility LLC (Delaware)
- Plaintiff’s Counsel: Stinson LLP
- Case Identification: 4:25-cv-00948, N.D. Tex., 09/02/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant Motorola has transacted business, maintains a regular and established place of business, and has committed acts of direct infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones, which implement industry-standard 4G LTE and 5G dual connectivity (EN-DC), infringe five patents related to methods for aggregating bandwidth from multiple communication channels.
- Technical Context: The technology at issue involves combining multiple, potentially distinct network connections to increase data throughput, speed, and reliability for an end-user device.
- Key Procedural History: The complaint notes that four of the five asserted patents expired in 2023. For these patents, Plaintiff seeks only damages for infringement that occurred prior to their expiration dates.
Case Timeline
| Date | Event |
|---|---|
| 2002-10-15 | Earliest Priority Date for all Asserted Patents |
| 2012-07-24 | U.S. Patent No. 8,228,801 Issues |
| 2014-10-14 | U.S. Patent No. 8,861,349 Issues |
| 2016-05-24 | U.S. Patent No. 9,350,649 Issues |
| 2019-01-01 | Release of 3GPP 5G New Radio (NR) standard, enabling EN-DC |
| 2020-05-01 | Commercial release of Motorola Edge Plus, an accused product using EN-DC |
| 2022-08-16 | U.S. Patent No. 11,418,641 Issues |
| 2023-02-14 | U.S. Patent No. 11,582,343 Issues |
| 2023-10-14 | U.S. Patent Nos. 8,861,349, 9,350,649, and 11,582,343 Expire |
| 2023-12-11 | U.S. Patent No. 11,418,641 Expires |
| 2025-01-22 | U.S. Patent No. 8,228,801 Expires |
| 2025-09-02 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,861,349 - "Broadband Communications Device"
The Invention Explained
- Problem Addressed: The patent describes a market where Competitive Local Exchange Carriers (CLECs) struggle to compete with incumbent carriers because they cannot offer new, high-bandwidth services over the existing "last mile" of copper telephone lines (Plain Old Telephone Service or POTS) without costly infrastructure upgrades like those required for DSL (’801 Patent, col. 1:12-28, col. 2:5-11).
- The Patented Solution: The invention is a communications gateway device that allows a user to aggregate the bandwidth of their existing POTS line with one or more other connections, such as a wireless link to another gateway device, to achieve higher data speeds (’801 Patent, Abstract; col. 12:3-11). This is accomplished by establishing a "multilink" connection where data packets are concurrently received from multiple distinct network connections, thereby increasing overall throughput without requiring changes to the telephone company's central office equipment (’801 Patent, col. 11:4-11).
- Technical Importance: This approach aimed to provide broadband-like services over legacy infrastructure by leveraging multiple, independent, lower-bandwidth communication paths in parallel (’801 Patent, col. 2:61-65).
Key Claims at a Glance
- The complaint asserts independent claim 13 (Compl. ¶45).
- The essential elements of claim 13 are:
- A device comprising an interface that establishes a connection to a first network at a first location and receives first data packets.
- A wireless interface that establishes a connection to a remote communications device, which is connected to a second network at a second location.
- A processor that sends a multilink request to the remote communications device to join the multilink connection.
- The processor receives the first data packets from the first network and, once the request is accepted, concurrently receives second data packets from the second network via the remote communications device.
U.S. Patent No. 9,350,649 - "Multipath Communication Devices and Methods"
The Invention Explained
- Problem Addressed: As described in the related ’801 Patent, the invention addresses the technical and economic challenge of delivering high-speed data services to residences and small businesses that are limited by the bandwidth of a single POTS telephone line (’801 Patent, col. 1:12-28).
- The Patented Solution: The patent describes a "data-requesting device" that can connect concurrently to multiple "network-edge devices" to form a "multipath connection" (’649 Patent, Claim 18). The device sends information to these network-edge devices to enable them to join the connection and then receives different data from different network-edge devices simultaneously, effectively combining their bandwidths (’649 Patent, Claim 18).
- Technical Importance: This technology provides a framework for a single user device to aggregate data streams from multiple distinct network access points to enhance performance (’801 Patent, col. 11:4-11).
Key Claims at a Glance
- The complaint asserts independent claim 18 (Compl. ¶55).
- The essential elements of claim 18 are:
- A data-requesting device comprising at least one interface capable of connecting concurrently to a plurality of network-edge devices during a multipath connection.
- At least one processor that sends multipath information to each network-edge device capable of joining the connection.
- The processor receives different data from different network-edge devices that are able to join the multipath connection.
U.S. Patent No. 11,418,641 - "Devices and Methods for Multipath Communications"
- Technology Synopsis: This patent describes a communications device that aggregates data from a primary network connection with data from at least one remote communications device. The device sends requests and control information to the remote device to participate in a "multilink communication" to increase total data bandwidth (’641 Patent, Claim 1).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶65).
- Accused Features: The complaint alleges Motorola smartphones use EN-DC to aggregate data from a 4G-LTE base station and a 5G-NR base station, with 3GPP signaling protocols allegedly constituting the claimed requests for assistance and control information (Compl. ¶¶68-74).
U.S. Patent No. 11,582,343 - "Devices and Methods for Multipath Communications"
- Technology Synopsis: This patent claims a device that establishes a "first connection" to a first network and a "second connection" to a second network. These are combined into a "third connection" with an effective bandwidth that includes allocated portions of the first and second bandwidths, allowing the device to receive portions of a response from a remote device over both networks simultaneously (’343 Patent, Claim 12).
- Asserted Claims: Independent claim 12 is asserted (Compl. ¶78).
- Accused Features: The complaint alleges the accused smartphones’ 4G-LTE link is the "first connection" and its 5G-NR link is the "second connection," which are aggregated in the EN-DC "split bearer" configuration to form the "third connection" for communicating with a remote server (Compl. ¶¶81-84).
U.S. Patent No. 8,228,801 - "Broadband Communications Device"
- Technology Synopsis: This patent describes a device that requests the use of a portion of "unused bandwidth" from a remote communications device. After receiving a response and selecting a device, it sends control information for participating in a "multilink connection" and aggregates data from that connection with its primary connection to increase bandwidth (’801 Patent, Claim 1).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶88).
- Accused Features: The complaint alleges the accused smartphones’ 3GPP signaling messages constitute requests for unused bandwidth from 4G/5G base stations, which are then used in a "split bearer" configuration to aggregate data and increase bandwidth (Compl. ¶¶91-96).
III. The Accused Instrumentality
Product Identification
- Motorola smartphones that implement 3GPP standards for simultaneous use of 4G LTE and 5G New Radio (NR) connections, including but not to models in the Moto E, G, S, X, Z, Razr, Edge, and One series (Compl. ¶¶1, 36, 42).
Functionality and Market Context
- The complaint alleges the accused smartphones employ a technology called E-UTRAN New Radio Dual Connectivity (EN-DC) (Compl. ¶13). This technology allows a device to connect simultaneously to a "Master Node" in a first network (e.g., a 4G-LTE base station) and a "Secondary Node" in a second network (e.g., a 5G-NR base station) (Compl. ¶39).
- By using a "split bearer" configuration, the device can allegedly receive data packets concurrently from both the 4G and 5G networks, thereby aggregating the bandwidth of both connections to achieve higher speeds and increased reliability (Compl. ¶¶51, 61, 74). The complaint identifies the Motorola Edge Plus, released in May 2020, as an early example of a commercially available product using this technology (Compl. ¶40).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,861,349 Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an interface that establishes a network connection at a first location to a first network and receives first data packets over the network connection; | The smartphone connects to a "Master Node" (e.g., a 4G-LTE base station) which constitutes the first network at a first location, receiving data packets over the 4G-LTE connection. | ¶47 | col. 13:40-45 |
| a wireless interface that is configured to establish a wireless connection to a remote communications device, the remote communications device being connected at a second location to a second network; | The smartphone connects to one or more "Secondary Nodes" (e.g., a 5G-NR base station), which are alleged to be the "remote communications device" connected to the second network at a second location. | ¶48 | col. 12:25-30 |
| a processor that sends a multilink request over the wireless interface to the remote communications device to join the multilink connection, | The smartphone processor executes a series of 3GPP signaling messages (e.g., RRC Connection Setup, UE Capability Information, GNB Addition Request) to establish the dual connectivity with the 5G-NR base station. | ¶49 | col. 12:48-55 |
| ...when the multilink request is accepted..., concurrently receives from the wireless interface second data packets from the second network... | Once the dual connection is established, the smartphone uses a "split bearer" configuration to simultaneously receive data packets from both the first network (4G-LTE) and the second network (5G-NR). | ¶51 | col. 12:45-48 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the term "remote communications device", which the patent specification often describes as another peer residential gateway (’801 Patent, col. 12:25-30), can be construed to read on a cellular network base station (a "Secondary Node" like a GNB) as alleged in the complaint.
- Technical Questions: The analysis will likely focus on whether the exchange of standardized 3GPP signaling messages (Compl. ¶49) for establishing dual connectivity constitutes the specific "multilink request" recited in the claim, or if there is a functional difference between the two.
U.S. Patent No. 9,350,649 Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A data-requesting device comprising: at least one interface capable of connecting concurrently to a plurality of network-edge devices during a multipath connection... | The smartphone is alleged to be the "data-requesting device," and its modem is capable of connecting concurrently to a 4G "Master Node" and a 5G "Secondary Node," which are alleged to be the "network-edge devices." | ¶¶57-58 | col. 18:20-25 |
| at least one processor... that sends multipath information to each of the network-edge devices that is capable of joining the multipath connection; | The smartphone's processor sends various 3GPP signaling messages and data structures (e.g., RRC Connection Setup, UE Capability Information) to the 4G and 5G base stations to establish and configure the dual connection. | ¶60 | col. 18:26-29 |
| and receives different data at the data-requesting device from different ones of the network-edge devices that are able to join the multipath connection. | The smartphone, operating in a "split bearer" configuration, receives different data packets from the 4G Master Node and the 5G Secondary Node simultaneously as part of the multipath EN-DC connection. | ¶61 | col. 18:30-33 |
- Identified Points of Contention:
- Scope Questions: A primary question for the court may be the proper construction of "network-edge device". The defendant may argue this term, in the context of the patent, does not encompass major cellular infrastructure components like 4G ENBs and 5G GNBs.
- Technical Questions: It raises the question of what evidence demonstrates that the standardized 3GPP messages (Compl. ¶60) constitute the specific "multipath information" required by the claim to enable joining the connection, as opposed to serving a different function within the 3GPP framework.
V. Key Claim Terms for Construction
The Term: "remote communications device" (’349 Patent, claim 13)
- Context and Importance: This term's definition is critical because the complaint's infringement theory equates it with a cellular base station (e.g., a 5G GNB). The viability of the infringement case for the ’349 Patent may depend on whether the patent's scope extends beyond the peer-to-peer device context suggested by the specification to cover public carrier network infrastructure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "device" without specifying its nature, which may support a construction not limited to a particular embodiment. The patent also mentions that its wireless scheme is not limited to 802.11 and that "any wireless transmission scheme can be used" (’801 Patent, col. 4:25-29), which could suggest applicability beyond a local Wi-Fi context.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the remote devices as other Residential Communications Gateways (RCGs) in a peer-to-peer or ad-hoc network (’801 Patent, FIG. 7; col. 12:25-31). The background focuses on solving problems for CLECs using existing POTS lines, a context far removed from modern cellular networks (’801 Patent, col. 1:12-28).
The Term: "network-edge device" (’649 Patent, claim 18)
- Context and Importance: Similar to the term above, the infringement case for the ’649 Patent hinges on this term covering 4G and 5G base stations. Practitioners may focus on this term because its definition will determine whether the accused EN-DC cellular architecture falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is not explicitly defined with limiting characteristics in the claim language. Plaintiff may argue that in a general networking sense, a base station is a device at the edge of the carrier's core network.
- Evidence for a Narrower Interpretation: The patent family's specification appears to use this term in the context of devices within a local or neighborhood-area network, such as other RCGs or Wi-Fi access points, rather than carrier-grade cellular nodes (’801 Patent, col. 14:40-42, referring to Neighborhood Access Point).
VI. Other Allegations
- Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement.
- Willful Infringement: The complaint does not provide sufficient detail for analysis of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to present fundamental questions of claim scope and technological mapping. The outcome may turn on the court's resolution of the following issues:
A core issue will be one of definitional scope: can terms like "remote communications device" and "network-edge device", which are described in the patents' specification in the context of residential gateways and local Wi-Fi networks, be construed broadly enough to cover the carrier-grade 4G and 5G base stations of a modern cellular network?
A key evidentiary question will be one of functional mapping: do the standardized, multi-stage signaling protocols used in 3GPP's EN-DC technology perform the specific functions of a "multilink request" or sending "multipath information" as recited in the claims, or is there a fundamental mismatch between the patented methods and the operation of the accused industry standards?