DCT

1:25-cv-01253

Morris Routing Tech LLC v. Arista Networks Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01253, W.D. Tex., 08/07/2025
  • Venue Allegations: Venue is based on allegations that Arista Networks maintains a regular and established place of business, including an R&D facility, within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s network routing products and software, which implement segment routing capabilities, infringe seven patents related to path-based routing methods.
  • Technical Context: Segment routing is a network traffic-engineering technology that simplifies routing protocols by embedding path information directly into the data packet header, which is significant for scaling modern cloud and 5G networks.
  • Key Procedural History: The complaint references extensive activity within standards-setting organizations, including the Internet Engineering Task Force (IETF) and the European Telecommunications Standards Institute (ETSI), which have published numerous standards (RFCs) related to segment routing. It also notes Arista’s participation in interoperability testing with other vendors, suggesting the accused technology is intended to be standards-compliant.

Case Timeline

Date Event
2012-12-27 Earliest Priority Date for Patents-in-Suit
2016-01-01 Arista allegedly introduces Segment Routing
2020-02-25 U.S. Patent No. 10,574,562 Issues
2020-05-12 U.S. Patent No. 10,652,133 Issues
2020-05-12 U.S. Patent No. 10,652,134 Issues
2020-08-25 U.S. Patent No. 10,757,010 Issues
2020-10-13 U.S. Patent No. 10,805,204 Issues
2023-09-12 U.S. Patent No. 11,757,756 Issues
2023-10-10 U.S. Patent No. 11,784,914 Issues
2025-08-07 Complaint Filing Date

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

U.S. Patent No. 10,652,133 - "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS"

  • Issued: May 12, 2020

The Invention Explained

  • Problem Addressed: The patent describes limitations in traditional Internet Protocol (IP) routing, noting that as networks grew, maintaining state information for every data flow at every router created scalability and latency problems (’133 Patent, col. 2:7-59; Compl. ¶¶ 14-15). This approach was complex and inefficient for precise traffic engineering (Compl. ¶15).
  • The Patented Solution: The invention proposes a path-based routing method where the path a packet should take is encoded as a sequence of "segment identifiers" (SIDs) within the packet itself (’133 Patent, Abstract; ’133 Patent, col. 3:5-13). Intermediate nodes (routers) no longer need to maintain per-flow state; they simply read the current SID, forward the packet to the destination indicated by that SID, and advance to the next SID in the sequence (’133 Patent, Fig. 2). This simplifies the network's control plane by moving path intelligence to the source node and the packet itself (Compl. ¶17).
  • Technical Importance: This source-routing approach reduces the state-management burden on network routers, which simplifies network architecture and enhances scalability and flexibility (Compl. ¶¶ 18, 21).

Key Claims at a Glance

  • The complaint asserts at least independent claim 12 (Compl. ¶61).
  • Essential elements of claim 12 include:
    • A first node configured to receive a packet comprising an internet protocol (IP) header.
    • The node is further configured to add a first extension header to the packet, where the header comprises a list of elements, each element comprising a respective segment identifier (SID).
    • The node is further configured to update the packet by writing information to the destination IP address field of the IP header, where the information comprises one of the SIDs from the list.
  • The complaint reserves the right to assert additional claims (Compl. ¶62).

U.S. Patent No. 10,805,204 - "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS"

  • Issued: October 13, 2020

The Invention Explained

  • Problem Addressed: Like the ’133 Patent, this patent addresses the complexity and scalability issues of traditional IP/MPLS networks, where routing decisions require maintaining extensive state information throughout the network, hindering efficient and flexible traffic engineering (’204 Patent, col. 2:7-59; Compl. ¶15).
  • The Patented Solution: The invention describes a system where a node in an access network receives a data packet and, based on instructions from a centralized controller, encapsulates it for routing through a larger, subdivided network (’204 Patent, Abstract). The instructions are contained in a "segment identifier data structure" which encodes a path from an "area edge node" onward, effectively initiating a segment-routed path for the packet (’204 Patent, Abstract; Compl. ¶¶ 17, 27).
  • Technical Importance: This method allows network operators to define explicit, engineered paths for traffic from a centralized point of control, simplifying network management and enabling capabilities like service chaining and network slicing (Compl. ¶21, ¶27).

Key Claims at a Glance

  • The complaint asserts at least independent claim 15 (Compl. ¶93).
  • Essential elements of claim 15 include:
    • Receiving, at a node in a first access network, a data packet.
    • Receiving, from a centralized controller for a subdivided network, a segment identifier data structure that encodes a path from a first area edge node to a second access network.
    • Encapsulating the data packet.
    • Forwarding the encapsulated data packet toward the first area edge node.
  • The complaint reserves the right to assert additional claims (Compl. ¶94).

Multi-Patent Capsules

  • U.S. Patent No. 10,574,562

    • Patent Identification: U.S. Patent No. 10,574,562, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued February 25, 2020.
    • Technology Synopsis: This patent, part of the same family as the other patents-in-suit, discloses methods for improving network routing by encoding path information as a sequence of identifiers within a data packet's header. This source-routing approach is intended to reduce the need for network nodes to maintain per-flow state information, thereby simplifying the control plane and enhancing network scalability (Compl. ¶¶ 17, 22).
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶69).
    • Accused Features: The complaint alleges that Arista’s SR-capable solutions, which support SR-MPLS and SRv6, infringe by implementing the claimed routing methods (Compl. ¶¶ 52-56, 69).

  • U.S. Patent No. 10,652,134

    • Patent Identification: U.S. Patent No. 10,652,134, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued May 12, 2020.
    • Technology Synopsis: This patent discloses methods for routing data packets using path-based protocol addresses composed of segment identifiers. The invention allows a source to define an explicit path, which is then embedded in the packet header, reducing reliance on traditional hop-by-hop routing tables and complex control protocols (Compl. ¶¶ 17, 23).
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶77).
    • Accused Features: The accused features are Arista’s networking products and software that provide segment routing functionality, allegedly practicing the patented methods (Compl. ¶¶ 52-56, 77).

  • U.S. Patent No. 10,757,010

    • Patent Identification: U.S. Patent No. 10,757,010, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued August 25, 2020.
    • Technology Synopsis: This patent describes routing systems where path information is carried within the packet header. This technique is designed to improve network operations by reducing the amount of state information that must be maintained by network nodes, thereby simplifying traffic engineering and improving performance (Compl. ¶¶ 21, 22).
    • Asserted Claims: At least independent claim 2 is asserted (Compl. ¶85).
    • Accused Features: Arista's SR-capable solutions, including its EOS software and various hardware platforms, are accused of infringing by implementing the claimed routing systems (Compl. ¶¶ 52-56, 85).

  • U.S. Patent No. 11,757,756

    • Patent Identification: U.S. Patent No. 11,757,756, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued September 12, 2023.
    • Technology Synopsis: This patent discloses a method where a transmitting node selects a sequence of segment identifiers based on a specified policy and available network topology information. The selected sequence, which defines a network path that includes at least one node not predetermined by the policy itself, is then used to route a packet through the network (’756 Patent, Abstract).
    • Asserted Claims: At least independent claim 10 is asserted (Compl. ¶101).
    • Accused Features: The accused features are Arista’s products that implement SR, which allegedly involves selecting and using sequences of segment identifiers to route traffic according to network policies (Compl. ¶¶ 52-56, 101).

  • U.S. Patent No. 11,784,914

    • Patent Identification: U.S. Patent No. 11,784,914, "ROUTING METHODS, SYSTEMS, AND COMPUTER PROGRAM PRODUCTS," issued October 10, 2023.
    • Technology Synopsis: This patent describes a method for generating and using a set of segment identifiers. The identifiers are generated based on information about a path from a first node to a second node, and at least one identifier is created within an address space specific to the current region of the first node for use in identifying a subsequent region (’914 Patent, Abstract).
    • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶109).
    • Accused Features: The complaint accuses Arista's SR-capable solutions of infringement, which allegedly generate and use segment identifiers to route packets across network segments (Compl. ¶¶ 52-56, 109).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Arista’s "SR-capable solutions," including but not limited to the Arista EOS (Extensible Operating System), CloudEOS, R-Series, X3 series, 7050, 7060, 7280, and 7500 platform hardware, Universal Leaf and Spine solutions, 5000 series solutions, and FlexRoute technology (Compl. ¶52).
  • Functionality and Market Context: The complaint alleges these products implement Segment Routing (SR) technology, including both SR over MPLS (SR-MPLS) and SR over IPv6 (SRv6) (Compl. ¶¶ 53-55). This functionality allows network operators to steer traffic along explicit paths by encoding a sequence of instructions (segments) in the packet header, which simplifies traffic engineering and is marketed by Arista as a "perfect paradigm for intelligent software-driven source routing" for Cloud WANs (Compl. ¶28). The complaint further alleges that these products support the functionality specified in the IETF's SR-related Requests for Comments (RFCs) (Compl. ¶56).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint references claim chart exhibits that were not provided. The following summary is based on the narrative infringement allegations in the complaint and the text of the patents-in-suit.

The infringement theory asserts that Arista's SR-capable products directly perform the methods claimed in the patents-in-suit. The core allegation is that when Arista's products are configured to use segment routing, they create and process packets whose headers contain a list of segment identifiers (SIDs) that dictate the packet's path through the network. This act of encoding a path in the packet header, and the subsequent processing of those headers by network nodes to forward the packet, is alleged to map directly onto the elements of the asserted claims (Compl. ¶¶ 17-19, 56, 61, 93).

Identified Points of Contention:

  • Scope Questions: A primary question may be whether the term "extension header" as claimed in the ’133 Patent can be construed to read on both an MPLS label stack and an IPv6 Segment Routing Header (SRH), two different technologies Arista’s products are alleged to use (Compl. ¶¶ 18, 19). Similarly, for the ’204 Patent, a question is whether an SR Policy, as defined by industry standards and implemented by Arista, constitutes a "segment identifier data structure" as claimed (Compl. ¶¶ 27, 42).
  • Technical Questions: A key technical question may be whether the functions performed by Arista’s products, which are alleged to comply with public IETF standards, are identical to the specific steps recited in the claims. For example, the complaint alleges Arista’s products practice the claimed invention by supporting RFC-specified functionality (Compl. ¶56), raising the question of whether there are material differences between the patented methods and the standardized methods Arista implements.

V. Key Claim Terms for Construction

  • The Term: "first extension header" (from Claim 12 of the ’133 Patent)

    • Context and Importance: This term is critical because infringement depends on whether Arista's different methods for carrying segment information—specifically MPLS label stacks and IPv6 Segment Routing Headers (SRH)—are both considered an "extension header" added to the packet. Arista may argue one or both of these standard-compliant structures is technically distinct from the claimed "extension header."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification of the ’133 Patent and its family members discusses the invention in the context of both MPLS and IPv6 data planes, suggesting the inventor contemplated multiple ways to carry the segment information (Compl. ¶13; ’133 Patent, col. 20:11-45). This may support a construction broad enough to cover different technological implementations.
      • Evidence for a Narrower Interpretation: The detailed description describes adding "a first extension header to the packet" and then "writing information to the destination IP address field of the IP header" (’133 Patent, col. 3:21-28). A defendant could argue this language, particularly the modification of the main IP header's destination field, describes a specific mechanism that is distinct from how standard SR-MPLS (label swapping) or SRv6 (SRH processing) operates.

  • The Term: "segment identifier data structure" (from Claim 15 of the ’204 Patent)

    • Context and Importance: The infringement analysis for the ’204 Patent turns on whether the "SR Policy" used in Arista's products and defined by IETF RFC 9256 (Compl. ¶42) is equivalent to the claimed "segment identifier data structure." Practitioners may focus on this term to determine if the patent covers the industry-standard approach or a more specific, proprietary structure.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract describes the structure simply by its function: it "encodes a path extending from the first area edge node to a second access network" (’204 Patent, Abstract). This functional language may support a broad interpretation that covers any data structure performing that role, including a standards-based SR Policy.
      • Evidence for a Narrower Interpretation: Claim 15 requires receiving this structure from a "centralized controller" (’204 Patent, claim 15). Arista could argue that its systems can be configured or receive policies in ways that do not involve a "centralized controller" as envisioned by the patent, potentially narrowing the claim's applicability.

VI. Other Allegations

This section is omitted as the complaint does not contain allegations of indirect or willful infringement.

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

  • A core issue will be one of definitional scope and standards-essentiality: Can the patent claims, which use terms like "extension header" and "segment identifier data structure" and claim priority to 2012, be construed broadly enough to cover the later-standardized implementations of SR-MPLS and SRv6 as defined in IETF RFCs? The case may turn on whether the patented inventions are coextensive with the industry standards Arista implements, or if they represent a distinct, non-standard approach.
  • A key validity question will be one of timing and prior art: Given that segment routing concepts were developed within standards bodies like the IETF during the 2010s (Compl. ¶¶ 13, 36), the litigation will likely examine what specific contributions the inventor made and when. The ultimate question for the court will be whether the asserted claims cover novel inventions or attempt to claim concepts that were already in the public domain or under development by the broader networking community at the time of filing.