DCT

4:25-cv-00948

Competitive Access Systems Inc v. Motorola Mobility LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00948, N.D. Tex., 12/08/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant maintains a regular and established place of business in Fort Worth, employs personnel in the district, and has committed acts of infringement within the district by selling accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones and servers, which are capable of using multipath communication technologies such as E-UTRAN New Radio – Dual Connectivity (EN-DC) and Multipath TCP (MPTCP), infringe seven patents related to aggregating bandwidth from multiple data communication paths.
  • Technical Context: The technology concerns methods and devices for combining multiple, separate network connections (such as cellular and Wi-Fi) to increase data transfer speeds and reliability, a critical function for modern mobile devices and applications.
  • Key Procedural History: The complaint notes that asserted claims of U.S. Patent No. 10,868,908 have not been challenged in a reexamination proceeding that rejected other claims of that patent. Additionally, in prior litigation against Oracle Corp. in the Western District of Texas, a court ruled that claims of U.S. Patent No. 9,350,649, also asserted here, are "not directed to an abstract idea" under 35 U.S.C. § 101.

Case Timeline

Date Event
2002-10-15 Earliest Priority Date for all Asserted Patents
2009-10-20 U.S. Patent No. 7,606,156 Issued
2012-07-24 U.S. Patent No. 8,228,801 Issued
2014-10-14 U.S. Patent No. 8,861,349 Issued
2016-05-24 U.S. Patent No. 9,350,649 Issued
2020-05-01 Accused Product "Motorola Edge Plus" Commercially Released
2020-12-15 U.S. Patent No. 10,868,908 Issued
2022-08-16 U.S. Patent No. 11,418,641 Issued
2023-02-14 U.S. Patent No. 11,582,343 Issued
2023-06-07 W.D. Tex. Order on Patent Eligibility of ’649 Patent
2025-12-08 Complaint Filed

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

U.S. Patent No. 7,606,156 - "Residential communications gateway (RCG) for broadband communications over a plurality of standard POTS lines, with dynamic allocation of said bandwidth, that requires no additional equipment or modifications to the associated class 5 offices or the PSTN at large"

The Invention Explained

The complaint states that the Asserted Patents share the same specification (Compl. ¶59).

  • Problem Addressed: The patent specification describes prior art internet access methods, such as dial-up over Plain Old Telephone Service (POTS), DSL, and cable, as suffering from limitations including low bandwidth, high infrastructure costs, difficult deployment, and poor quality of service (QoS) (Compl. ¶¶64-69; ’156 Patent, col. 2:26-50). Standard POTS lines, for example, were noted to have a maximum data rate of 56 Kbps, which was insufficient for transferring large files (Compl. ¶68; ’156 Patent, col. 10:61-11:22).
  • The Patented Solution: The invention proposes a “Residential Communications Gateway” (RCG) that aggregates bandwidth from multiple standard POTS lines to achieve broadband speeds without requiring costly upgrades to the telephone network infrastructure (’156 Patent, Abstract). The system operates by allowing an “initiating RCG” that needs more bandwidth for a task like a large file transfer to wirelessly request assistance from other nearby RCGs, which then contribute their unused POTS line bandwidth to form a “multilink PPP bundle,” thereby increasing the total data transfer rate (Compl. ¶74; ’156 Patent, col. 11:50-59). The system is designed to dynamically manage this bundle, adding or removing RCGs as their local bandwidth demands change to maintain a minimum QoS (Compl. ¶¶75, 100).
  • Technical Importance: The technology provided a method to deliver broadband-equivalent speeds over the existing and ubiquitous POTS infrastructure, aiming to bypass the high costs and limited geographic availability of early DSL and cable modem services (Compl. ¶73; ’156 Patent, Abstract).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-5 (Compl. ¶¶180, 182).
  • Essential elements of independent claim 1 (a method) include:
    • Developing and updating a network table of nearby RCGs and their bandwidth capabilities.
    • Determining the optimal bandwidth needed for a data transfer.
    • Determining which nearby RCGs to contact for their unused bandwidth.
    • Sending a request to and receiving responses from supporting RCGs regarding shareable bandwidth.
    • Selecting supporting RCGs and contacting them with control information.
    • Receiving data packets from the selected RCGs at the requesting RCG.
    • Reassembling the data packets at the requesting RCG.
    • Relinquishing the bandwidth after the transfer.

U.S. Patent No. 8,228,801 - "Broadband Communications Device"

The Invention Explained

As this patent shares a common specification with the ’156 Patent, it addresses the same technical problems and proposes a similar solution (Compl. ¶59).

  • Problem Addressed: The inadequacy of prior art internet connections, which were characterized by low bandwidth, high cost, and limited availability (Compl. ¶¶64-69).
  • The Patented Solution: The patent claims a physical communications device, rather than a method, capable of providing broadband services by aggregating bandwidth from other remote devices. The device includes a processor configured to request assistance from remote devices, inquire about their unused bandwidth, select appropriate devices based on their responses, send them control information to join a "multilink connection," and then receive and aggregate data packets from them to increase the device's total data bandwidth (’801 Patent, Claim 1). This mirrors the functionality described in the ’156 Patent but is claimed as a device.
  • Technical Importance: This device-centric approach encapsulates the bandwidth aggregation solution into a tangible product designed to be deployed in a user's home or business to upgrade existing POTS lines to broadband capability (Compl. ¶73).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims, asserting claims 1-17 for accused MPTCP products and claims 1-4, 7-10, 12, and 14 for accused EN-DC products (Compl. ¶¶186, 188-189).
  • Essential elements of independent claim 1 (a device) include:
    • At least one connection to a communications network.
    • At least one wireless interface to connect to at least one remote communications device.
    • A processor configured to:
      • Request assistance from the remote device(s).
      • Send a request for use of a portion of the remote device's unused bandwidth.
      • Receive a response with information about that unused bandwidth.
      • Select the remote device.
      • Send control information for participating in a multilink connection.
      • Receive packets from the remote device and aggregate the data to increase bandwidth.

U.S. Patent No. 8,861,349 - "Broadband Communications Device"

  • Patent Identification: U.S. Patent No. 8,861,349, “Broadband Communications Device,” issued October 14, 2014 (Compl. ¶22).
  • Technology Synopsis: This patent claims a method for increasing bandwidth by having a first device send a "multilink request" to a second, geographically separate device. Upon acceptance, the first device concurrently receives a primary data stream from the network at its location and a secondary data stream wirelessly from the second device, which receives its data from the network at its own separate location (Compl. ¶112).
  • Asserted Claims: Independent claim 13 is recited; the complaint references exhibits for claims 1-20 (Compl. ¶¶193-196).
  • Accused Features: The MPTCP and EN-DC functionalities of Defendant's products (Compl. ¶¶195, 196).

U.S. Patent No. 9,350,649 - "Multipath Communication Devices and Methods"

  • Patent Identification: U.S. Patent No. 9,350,649, “Multipath Communication Devices and Methods,” issued May 24, 2016 (Compl. ¶26).
  • Technology Synopsis: This patent claims a method from the perspective of a central "data-source device" (e.g., a server). The device receives multipath connection requests, assigns a connection ID, notifies various "network-edge devices" to participate in the connection, and sends data associated with that ID to the participating devices (Compl. ¶116).
  • Asserted Claims: Independent claim 18 is recited; the complaint references exhibits for claims 1-23 (Compl. ¶¶200-203).
  • Accused Features: The MPTCP and EN-DC functionalities of Defendant's products (Compl. ¶¶202, 203).

U.S. Patent No. 10,868,908 - "Devices and methods for multipath communications"

  • Patent Identification: U.S. Patent No. 10,868,908, “Devices and methods for multipath communications,” issued December 15, 2020 (Compl. ¶30).
  • Technology Synopsis: This patent claims a "client device" with first and second network interfaces. The device's processor is configured to establish a multilink session by transmitting a first message with a multilink request and a second message with a unique session ID to a server, and then to concurrently receive data packets through both interfaces to achieve an increased data transfer rate (Compl. ¶120).
  • Asserted Claims: Independent claim 17 is recited; the complaint references an exhibit for claims 8-12 and 16-17 (Compl. ¶¶207-209).
  • Accused Features: The MPTCP functionality of Defendant's products (Compl. ¶209).

U.S. Patent No. 11,418,641 - "Devices and Methods for Multipath Communications"

  • Patent Identification: U.S. Patent No. 11,418,641, “Devices and Methods for Multipath Communications,” issued August 16, 2022 (Compl. ¶34).
  • Technology Synopsis: This patent claims a communications device that increases its bandwidth by requesting assistance from remote devices. The device's processor sends a request for "availability for participating in a multilink communication" and, if available, sends control information to the remote device to establish the connection and begin aggregating data (Compl. ¶122).
  • Asserted Claims: Independent claim 1 is recited; the complaint references exhibits for claims 1-3 (Compl. ¶¶213-216).
  • Accused Features: The MPTCP and EN-DC functionalities of Defendant's products (Compl. ¶¶215, 216).

U.S. Patent No. 11,582,343 - "Devices and Methods for Multipath Communications"

  • Patent Identification: U.S. Patent No. 11,582,343, “Devices and Methods for Multipath Communications,” issued February 14, 2023 (Compl. ¶38).
  • Technology Synopsis: This patent claims a method where a first device connects to a first network via a second device and a second network via a third device. It then establishes a connection to a fourth device (e.g., a server) by concurrently using portions of bandwidth from both networks, thereby creating a connection with a higher "effective bandwidth" (Compl. ¶124).
  • Asserted Claims: Independent claim 12 is recited; the complaint references exhibits for claims 1-20 (Compl. ¶¶220-223).
  • Accused Features: The MPTCP and EN-DC functionalities of Defendant's products (Compl. ¶¶222, 223).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies a broad range of Defendant's products, including numerous smartphone models from the Moto E, G, S, X, Z, Razr, Edge, and One series, as well as Motorola's servers that provide services such as Moto AI and App Cloud (Compl. ¶¶14, 52).

Functionality and Market Context

  • The infringement allegations center on two key technologies implemented in the accused products: E-UTRAN New Radio – Dual Connectivity (EN-DC) and Multipath TCP (MPTCP) (Compl. ¶¶13, 51).
    • EN-DC Functionality: The complaint alleges that accused smartphones utilize EN-DC to connect simultaneously to a 4G-LTE network (as a “Master Node”) and a 5G-NR network (as a “Secondary Node”) (Compl. ¶45). This dual connectivity allegedly allows the devices to aggregate throughput from both networks, thereby increasing the overall data transfer rate for the user (Compl. ¶42).
    • MPTCP Functionality: The complaint alleges that accused products implement MPTCP, as specified within the 3GPP ATSSS (Access Traffic Steering, Switching, and Splitting) feature, to enable multi-access connectivity (Compl. ¶49). This allegedly allows traffic to be split and transmitted concurrently across both 3GPP (e.g., 5G cellular) and non-3GPP (e.g., Wi-Fi) network connections (Compl. ¶¶49-50). The complaint uses an annotated diagram based on the patent's figures to illustrate how a user's device establishes a primary path and then requests a secondary path via a remote device (e.g., a Wi-Fi router) to participate in a "multilink session" (Compl. ¶87, p. 29).

IV. Analysis of Infringement Allegations

The complaint references external claim chart exhibits (Exhibits M, N, O, etc.) that were not provided for this analysis. The narrative infringement theories are summarized below.

Infringement Theory Summary for '156 and '801 Patents

  • The complaint alleges that Motorola's products directly infringe by practicing the methods and embodying the devices of the Asserted Patents when they utilize EN-DC or MPTCP functionalities (Compl. ¶¶51, 182-183, 188-190).
    • For the '156 Patent's method claims, the theory appears to be that the sequence of operations in establishing and managing an MPTCP or EN-DC connection maps onto the claimed steps. This would involve the smartphone (the "requesting RCG") identifying and communicating with network elements like cell towers or Wi-Fi access points (the "supporting RCGs") to establish multiple data paths, allocate bandwidth, and aggregate the resulting data streams (Compl. ¶182).
    • For the '801 Patent's device claims, the theory is that an accused smartphone is the claimed "communications device." Its processor, when executing software to manage EN-DC or MPTCP, allegedly performs the claimed functions of requesting bandwidth from remote network elements (e.g., a 5G base station or Wi-Fi router), selecting them, sending control information to establish a multilink session, and aggregating the data received from these multiple paths (Compl. ¶¶188-189). The complaint provides a series of annotated diagrams to illustrate this process, showing a "Computer Network Device (e.g., phone)" sending a "multilink request to one or more remote communications devices" (Compl. ¶86, p. 28).

Identified Points of Contention

  • Scope Questions: A central point of contention may be the construction of key terms like “Residential Communications Gateway (RCG)” and “remote communications device.” The patent specification heavily focuses on a system of residential gateways in neighboring houses aggregating bandwidth over separate POTS lines. The question will be whether these terms, in the context of the specification, can be construed broadly enough to read on the accused instrumentalities, which involve modern network components like 4G/5G cellular base stations, Wi-Fi access points, and remote servers.
  • Technical Questions: The infringement analysis will likely raise the question of whether the operation of standardized protocols like EN-DC and MPTCP matches the specific sequence of steps recited in the claims. For example, the claims recite a device-initiated “request...for requesting use of a portion of unused bandwidth.” It may be a point of contention whether network-managed procedures for adding a secondary carrier (in EN-DC) or establishing a secondary data flow (in MPTCP) constitute the specific type of user-device-initiated "request" contemplated by the patent.

V. Key Claim Terms for Construction

  • Term: "Residential Communications Gateway (RCG)" (from ’156 Patent, Claim 1)

    • Context and Importance: Plaintiff’s infringement theory requires this term to encompass modern network elements such as cellular base stations or Wi-Fi access points. The viability of the infringement case for the '156 patent may depend on whether the term is limited to the residential context disclosed in the specification.
    • Intrinsic Evidence for a Broader Interpretation: The body of claim 1 itself describes the RCG in functional terms (a device in a method for aggregating bandwidth from a plurality of networks) without an explicit structural limitation to a residence.
    • Intrinsic Evidence for a Narrower Interpretation: The patent’s title, abstract, and detailed description consistently frame the RCG as a device for use by a "residential user" or "POTS subscriber" to aggregate bandwidth from other nearby residences (’156 Patent, Abstract; col. 2:26-34). The patent's own figures, which the complaint reproduces, depict houses as the locations for the RCGs (Compl. p. 26, Diagram 1).

  • Term: "sends a request to the at least one remote communications device for requesting use of a portion of unused bandwidth" (from ’801 Patent, Claim 1)

    • Context and Importance: This limitation requires an active, device-initiated request for resources. Practitioners may focus on this term because modern cellular protocols like EN-DC often involve network-controlled resource allocation (e.g., the network instructs the device to add a secondary cell), which may not map directly onto this claim language.
    • Intrinsic Evidence for a Broader Interpretation: Plaintiff may argue that any signaling initiated by the device that results in the allocation of new bandwidth from a remote source satisfies this element, regardless of the specific protocol mechanics.
    • Evidence for a Narrower Interpretation: The plain language suggests a specific query-and-response mechanism where the device identifies a need, queries a remote device about its "unused" capacity, and receives a direct response with that information. The specification describes this sequence explicitly, where an initiating RCG "sends multilink PPP service requests" to remote RCGs, which then "respond back... with either an acceptance or denial" based on their "currently available POTS bandwidth" (’156 Patent, col. 12:19-32).

VI. Other Allegations

  • Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement. The counts for relief focus on direct infringement under 35 U.S.C. § 271(a) (Compl. ¶¶183, 190, 197, 204, 210, 217, 224).
  • Willful Infringement: This section is not applicable as the complaint does not contain allegations of willful infringement.

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

  • A core issue will be one of definitional scope: can the term "Residential Communications Gateway" (RCG), which is described in the patent's specification in the context of aggregating bandwidth from neighboring homes over POTS lines, be construed to cover modern, disparate network elements like 4G/5G base stations and Wi-Fi access points as required by the infringement allegations against EN-DC and MPTCP?
  • A key evidentiary question will be one of technical mechanism: do the accused EN-DC and MPTCP protocols, which are governed by industry standards, perform the specific, device-initiated sequence of "requesting unused bandwidth", receiving a granular "response" containing bandwidth information, and then "selecting" a remote device, as recited in the claims, or is there a fundamental mismatch in their technical operation compared to the claimed invention?
  • A significant legal question will be the precedential influence of the prior W.D. Texas ruling on patent eligibility for the ’649 patent. How will that court's finding—that claims directed to a "data-source device and a multipath connection" recite a specific technical solution—impact the present court's view on any § 101 challenges made against the asserted family of patents?