Integral Wireless Tech LLC v. Sonim Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Integral Wireless Technologies LLC (Texas)
  • Defendant: Sonim Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough, PLLC
• Case Identification: 1:25-cv-00833, W.D. Tex., 05/30/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Western District of Texas and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s portfolio of ruggedized mobile communication devices, mobile hotspots, and server systems infringes eight patents related to a wide range of wireless technologies, including protocol co-existence, contextual search result generation, video coding, and advanced antenna techniques.
• Technical Context: The patents address various foundational technologies in modern wireless communications, from efficient data compression and power management to methods for managing signal interference and improving data throughput in devices that utilize multiple wireless standards like 5G, Wi-Fi, and Bluetooth.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history pertinent to the asserted patents.

Case Timeline

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

U.S. Patent No. 7,653,031 - “Advance Notification of Transmit Opportunities on A Shared-Communications Channel”

• Patent Identification: U.S. Patent No. 7,653,031, "Advance Notification of Transmit Opportunities on A Shared-Communications Channel," issued January 26, 2010 (’031 Patent).

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of enabling two or more distinct wireless communication protocols, such as IEEE 802.11 (Wi-Fi) and Bluetooth, to operate within a single device using the same frequency band without causing mutual interference (’031 Patent, col. 1:26-67; Compl. ¶35).
• The Patented Solution: The invention proposes a coordination method where a first air interface subsystem (e.g., the 802.11 transceiver) listens for network timing signals, such as a "beacon frame," to predict future idle periods on the shared channel. It then provides an "advance notification" of this upcoming "transmit opportunity" to a second air interface subsystem (e.g., the Bluetooth transceiver), allowing the second subsystem to transmit its data during that window without conflicting with the first (’031 Patent, Abstract; col. 2:1-24).
• Technical Importance: This method provides a framework for co-existence between different wireless standards, a critical function for modern multi-radio devices like smartphones and laptops to ensure reliable connectivity. (Compl. ¶35).

Key Claims at a Glance

• The complaint asserts independent claim 15 of the ’031 Patent (Compl. ¶38).
• Claim 15 recites an apparatus comprising:
  • a first air interface subsystem comprising a receiver configured for receiving a beacon frame in accordance with a first communications protocol, and a processor configured for determining a transmit opportunity based on the time the beacon frame is received and on the beacon interval.
  • an interface configured for notifying a second air interface subsystem of the transmit opportunity.
  • wherein the second air interface subsystem comprises a first transmitter configured to communicate in accordance with a second communications protocol using the shared-communications channel.
  • wherein the first and second air interface subsystems are both configured to be associated with a same host computer.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,483,878 - “Generation and presentation of Search Results Using Addressing Information”

• Patent Identification: U.S. Patent No. 7,483,878, "Generation and presentation of Search Results Using Addressing Information," issued January 27, 2009 (’878 Patent).

The Invention Explained

• Problem Addressed: The patent background describes the problem of end-users being "overwhelmed with irrelevant advertisements" which are not targeted to their specific, immediate interests while browsing the internet (’878 Patent, col. 1:29-34).
• The Patented Solution: The invention describes a method where a client computer receives "addressing information" (e.g., the URL of a website a user is visiting), processes that information to generate a relevant "keyword," performs a search based on that keyword, and then presents the search results to the end-user. This process is triggered by the user's navigation, aiming to provide contextually relevant information or advertisements (’878 Patent, Abstract; col. 2:40-48; FIG. 1).
• Technical Importance: The technology aims to improve the function of computer networks by shifting from generic, untargeted advertising to context-aware content delivery, which may enhance user experience and advertising effectiveness (Compl. ¶62).

Key Claims at a Glance

• The complaint asserts independent claim 1 of the ’878 Patent (Compl. ¶65).
• Claim 1 recites a method of providing search results, comprising:
  • receiving addressing information identifying a location in a computer network;
  • processing the addressing information to generate a keyword;
  • performing a search on the keyword to generate a search result; and
  • presenting an end-user the search result responsive to the keyword that is based on the addressing information in response to the end-user navigating to the location using a client computer.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,310,537 - “Communication on Multiple Beams Between Stations”

• Patent Identification: U.S. Patent No. 7,310,537, "Communication on Multiple Beams Between Stations," issued December 18, 2007 (’537 Patent).
• Technology Synopsis: The patent describes a communication system where signals are transmitted on multiple, geometrically distinct wireless beams. To manage communication, "beam identity information" is included in the signals, allowing a receiving station to identify which beams it is receiving and select an appropriate set of beams for subsequent communication (Compl. ¶88; ’537 Patent, Abstract).
• Asserted Claims: At least claim 26 is asserted (Compl. ¶91).
• Accused Features: The complaint alleges that the "Sonim 5G Devices" infringe by providing a station with an antenna unit that receives signals on multiple beams and a controller that identifies and selects beams based on beam identity information (Compl. ¶92).

U.S. Patent No. 7,292,283 - “Apparatus and Method for Performing Sub-pixel Vector Estimations Using Quadratic Approximations”

• Patent Identification: U.S. Patent No. 7,292,283, "Apparatus and Method for Performing Sub-pixel Vector Estimations Using Quadratic Approximations," issued November 6, 2007 (’283 Patent).
• Technology Synopsis: This patent addresses motion estimation in video processing, a key component of video compression. The invention describes a method for generating more precise "sub-pixel" motion vectors by taking an initial coarse estimate and refining it using a quadratic approximation, which improves the accuracy of frame conversion and compression (Compl. ¶112; ’283 Patent, Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶115).
• Accused Features: The "Sonim HEVC Devices" are alleged to infringe by performing a method of estimating a refined sub-pixel vector position during frame conversion using the claimed steps of defining a minimum vector, determining correlation samples, and performing a correlation surface fitting with a quadratic approximation (Compl. ¶116).

U.S. Patent No. 7,548,592 - “Multiple Input, Multiple Output Communications Systems”

• Patent Identification: U.S. Patent No. 7,548,592, "Multiple Input, Multiple Output Communications Systems," issued June 16, 2009 (’592 Patent).
• Technology Synopsis: The patent relates to Multiple-Input, Multiple-Output (MIMO) communication systems, which use multiple antennas to increase data throughput. The invention describes optimizing transmitter and receiver weights to create and steer "beam nulls," which effectively decouples the signals from different antennas to reduce interference (Compl. ¶138; ’592 Patent, Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶141).
• Accused Features: The "Sonim HEVC Devices" are accused of infringing by providing a MIMO transmitter that uses a plurality of multipliers to weight input signals with a vector and combiners to create the signals transmitted from a plurality of antennas (Compl. ¶142).

U.S. Patent No. 7,398,408 - “Systems and Methods for Waking Up Wireless LAN Devices”

• Patent Identification: U.S. Patent No. 7,398,408, "Systems and Methods for Waking Up Wireless LAN Devices," issued July 8, 2008 (’408 Patent).
• Technology Synopsis: The technology provides a system for waking a computing device from a low-power "sleep mode" over a wireless network. A signal containing a specific "wake-up data sequence" is broadcast; the sleeping device periodically scans for this sequence and, upon detection, restores itself to full power (Compl. ¶164; ’408 Patent, Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶167).
• Accused Features: The complaint alleges the "Sonim Bluetooth Devices" infringe by performing a method of broadcasting a wake-up signal and, at the sleeping device, entering a detection mode to scan for the wake-up sequence and restore full power upon detection (Compl. ¶168).

U.S. Patent No. 7,668,258 - “Systems and Methods for Transmitter Diversity Expansion”

• Patent Identification: U.S. Patent No. 7,668,258, "Systems and Methods for Transmitter Diversity Expansion," issued February 23, 2010 (’258 Patent).
• Technology Synopsis: The patent describes a method for "transmitter diversity expansion," which involves applying a set of K data streams to a larger number of N antennas. This is achieved by applying K streams to K "base antennas" and then shifting and combining the K streams to generate N-K new streams for application to N-K "extension antennas," improving signal diversity and reliability (Compl. ¶190; ’258 Patent, Abstract).
• Asserted Claims: At least claim 7 is asserted (Compl. ¶193).
• Accused Features: The "Sonim 802.11n Devices" are accused of infringing by providing a system with a signal processor that generates a second set of data streams from a first set via matrix multiplication and transmits both sets of streams from a plurality of antennas (Compl. ¶194).

U.S. Patent No. 7,586,424 - “Data Coding Using an Exponent and A Residual”

• Patent Identification: U.S. Patent No. 7,586,424, "Data Coding Using an Exponent and A Residual," issued September 8, 2009 (’424 Patent).
• Technology Synopsis: The patent details a data coding method for audio or video data that improves compression efficiency. A data symbol is coded using two components: an "exponent" and a "residual." The exponent is coded using a variable-length code (like Huffman code), while the residual is coded separately, allowing for more efficient representation based on data characteristics (Compl. ¶216; ’424 Patent, Abstract).
• Asserted Claims: At least claim 1 is asserted (Compl. ¶219).
• Accused Features: The "Sonim HEVC Devices" are alleged to infringe by performing a method of coding a data symbol using an exponent value and a residual value, where the residual is coded with a fixed-length binary code and the exponent is coded with a variable-length code based on frequency of occurrence (Compl. ¶220).

III. The Accused Instrumentality

Product Identification

• The complaint names a wide range of Defendant’s products, which it groups into several categories: the "Sonim System" (a server system), "Sonim 802.11/BT Devices," "Sonim 5G Devices," "Sonim HEVC Devices," "Sonim 802.11n Devices," and "Sonim Bluetooth Devices" (Compl. ¶28). Specific product models identified include ruggedized smartphones (e.g., XP Pro Thermal 5G, XP10 5G) and mobile hotspots (e.g., Sonim Spot™ H500) (Compl. ¶28).

Functionality and Market Context

• The accused products are described as enterprise-grade, rugged mobile devices and related hardware that incorporate various wireless communication standards, including 5G cellular, 802.11 Wi-Fi (including 802.11n), and Bluetooth (Compl. ¶¶ 4, 28). They are also alleged to be compatible with High Efficiency Video Coding (HEVC) (Compl. ¶28). The complaint alleges that these devices are sold through major U.S. wireless carriers such as AT&T, T-Mobile, and Verizon (Compl. ¶18).
• The "Sonim System" is identified as a server system that performs a method of providing search results to an end-user over a computer network (Compl. ¶66). The complaint alleges Defendant provides instructions to customers on how to use its products, citing as an example a quick start guide for the Sonim Spot H500 5G Mobile Hotspot (Compl. ¶29).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’031 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The analysis may focus on whether the standard co-existence mechanisms in off-the-shelf Wi-Fi and Bluetooth chipsets meet the specific requirements of an "interface configured for notifying" as claimed. The dispute could concern whether the patent requires a dedicated, explicit notification mechanism beyond the default behavior of such chipsets.
  • Technical Questions: A key question may be what evidence shows that the processor in the accused devices performs the specific claimed function of "determining a transmit opportunity" based on the beacon frame timing, as opposed to using other, potentially non-infringing, collision avoidance techniques.

’878 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central issue may be the construction of "processing the addressing information to generate a keyword." The dispute could turn on whether a simple URL-to-category lookup constitutes "generating a keyword," or if the claim requires a more sophisticated parsing or semantic analysis of the address.
  • Technical Questions: The complaint does not specify how the "Sonim System" operates. An evidentiary question will be what proof exists that the accused server system actually performs these steps, particularly the link between a user navigating to a specific location and the subsequent presentation of a search result generated from that navigation data.

V. Key Claim Terms for Construction

• Patent: ’031 Patent

  • The Term: "transmit opportunity"
  • Context and Importance: This term is the central output of the claimed processor and the subject of the "notification." Its definition determines what the first subsystem must calculate and what the second subsystem is notified of. Practitioners may focus on whether this requires a guaranteed, reserved, interference-free time slot, or if it can be construed more broadly to mean any calculated period of likely channel availability.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the opportunity as a time when the first protocol "is not expected to be active" (’031 Patent, col. 5:58-60), which may support a construction based on prediction rather than a guarantee.
    • Evidence for a Narrower Interpretation: Embodiments describe the use of control frames like "Request to Send/Clear to Send" to reserve the channel (’031 Patent, col. 5:6-12), which could be argued to limit the "opportunity" to a formally reserved and cleared time period.

• Patent: ’878 Patent

  • The Term: "generate a keyword"
  • Context and Importance: This term defines the core transformation of the inventive method: turning a web address into a search query. The case may hinge on whether this term covers a simple mapping (e.g., categorizing a URL and assigning a pre-set keyword for that category) or requires a more dynamic process of extracting a word or phrase from the address itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that a human operator may "categorize popular web-sites" and "assign a keyword for each category" which is then stored in a database (’878 Patent, col. 3:12-17). This suggests that "generating" could encompass retrieving a pre-assigned keyword.
    • Evidence for a Narrower Interpretation: The description of a keyword being "derived from addressing information" (’878 Patent, col. 2:45-46) could support an interpretation requiring some form of direct extraction or analysis of the URL string itself, rather than a simple lookup based on categorization.

VI. Other Allegations

• Indirect Infringement: For each asserted patent, the complaint alleges induced infringement, stating that Defendant provides instructions (e.g., user manuals, quick start guides), advertising, and technical support that encourage and enable end-users to operate the Accused Products in an infringing manner (Compl. ¶¶ 29, 42-45, 69-72). Contributory infringement is also alleged, based on the assertion that the products have special features designed for infringing use with no substantial non-infringing uses (Compl. ¶¶ 49-52, 75-78).
• Willful Infringement: Willfulness is alleged for all asserted patents. The allegations are based on two grounds: first, that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness; and second, that Defendant has had "actual knowledge" of the patents since, at least, the date of service of the complaint, making any subsequent infringement willful (Compl. ¶¶ 40-41, 67-68).

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

• A primary issue will be one of evidentiary proof across a diverse portfolio: Plaintiff accuses a broad range of products of infringing eight distinct patents covering varied technologies, from video coding to contextual advertising. A central challenge for the case will be demonstrating with sufficient technical specificity how the accused functionalities of each product group practice the particular claim limitations of each asserted patent.
• A second core issue will be one of definitional scope versus industry standards: Several of the patents claim methods for solving common industry problems (e.g., Wi-Fi/Bluetooth co-existence, waking a device from sleep). The litigation will likely focus on whether the claims, when properly construed, cover the standard, off-the-shelf methods used in Defendant’s products, or if they are limited to the specific, potentially non-standard implementations described in the patent specifications.
• A third key question will be one of system-level infringement: For claims directed at system-wide methods (such as in the ’878 patent), a significant question will be whether Plaintiff can demonstrate that Defendant's server-side "Sonim System" and its client-side devices operate together to perform all steps of the claimed method, and who controls the performance of that system.