SLS Manager Tech LLC v. Oracle Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SLS Manager Technologies LLC (Delaware)
  • Defendant: Oracle Corp (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:23-cv-00520, W.D. Tex., 07/20/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has a regular and established place of business in the district, specifically an office in Austin, and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Communications Session Router infringes four patents related to managing and routing location-based service sessions in a multi-server network environment.
• Technical Context: The technology addresses routing challenges for Secure User Plane Location (SUPL) services, a protocol used for determining the geographic location of a mobile device, which is critical in carrier networks that use multiple, geographically diverse servers for redundancy and load balancing.
• Key Procedural History: The four asserted patents derive from a common provisional application and form a single family. Notably, a post-filing Ex Parte Reexamination Certificate for U.S. Patent No. 9,763,084 has cancelled independent claim 12, which is one of the claims asserted in this litigation. This event significantly impacts the viability of the infringement count related to that patent.

Case Timeline

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

U.S. Patent No. 7,974,235 - "Secure Location Session Manager," issued July 5, 2011

The Invention Explained

• Problem Addressed: In distributed network environments for location-based services, such as those using the Secure User Plane Location (SUPL) protocol, a mobile device's communications may be routed to the wrong server. Specifically, when a network with multiple redundant servers initiates a location request, the mobile device’s response might be sent to a server that did not initiate the transaction, causing the session to fail or time out (’235 Patent, col. 2:5-21).
• The Patented Solution: The invention proposes a "Secure Location Session Manager" (SLSM) or "Standalone Session Router" (SSR) that acts as an intelligent "middle-man" (’235 Patent, Abstract). For a network-initiated request, the router intercepts the initial message, creates a unique "SUPL session record," and stores routing information. When the mobile device responds, the router uses this session record to ensure all subsequent messages are routed to the correct, original server, thereby maintaining session integrity (’235 Patent, col. 3:5-15; FIG. 1).
• Technical Importance: The technology aimed to solve a fundamental reliability problem in early large-scale deployments of location-based services by providing a standardized method to ensure session integrity across complex, geo-diverse telecommunications networks (’235 Patent, col. 2:46-54).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶20).
• The essential elements of claim 1 are:
  • A location session manager comprising a secure user plane location (SUPL) session router and a session record manager.
  • The session record manager is configured to create a SUPL session record upon receiving a SUPL location request from a network agent for a mobile device.
  • The session record manager retrieves the record upon receiving subsequent messaging for that location request.
  • The session record provides routing information to direct the subsequent messaging to a selected server from a plurality of SUPL servers.
  • The session record is created, retrieved, and deleted for a single SUPL session.
• The complaint reserves the right to assert additional claims (Compl. ¶20).

U.S. Patent No. 8,687,511 - "Secure Location Session Manager," issued April 1, 2014

The Invention Explained

• Problem Addressed: The patent addresses the same core problem as the ’235 Patent: the risk of routing failures and session termination in multi-server SUPL environments (’511 Patent, col. 2:5-21).
• The Patented Solution: The invention is also an intelligent session router. However, the claims of the ’511 patent are structured to cover sessions initiated by the mobile device (a "SET-initiated" flow), as opposed to the network-initiated flow central to the ’235 Patent. The router creates a session record upon receiving the request from the mobile terminal and uses it to route communications to the server that ends up servicing the request (’511 Patent, Abstract; Claim 1).
• Technical Importance: This patent extends the session integrity solution to cover use cases where the mobile device itself, or an application on it, initiates the request for its own location, a common scenario for consumer-facing navigation and mapping applications (’511 Patent, col. 4:10-15).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶28).
• The essential elements of claim 1 are:
  • A SUPL session router comprising a session record manager.
  • The session record manager creates a SUPL session record upon receiving a SUPL location request from a SUPL enabled terminal (the mobile device).
  • The router retrieves the record upon receiving subsequent messaging to route it to the particular SUPL server that serviced the initial request.
  • The SUPL session record is created in and retrieved from a routing table for a single SUPL session.
• The complaint reserves the right to assert additional claims (Compl. ¶28).

U.S. Patent No. 9,398,449 - "Secure Location Session Manager," issued July 19, 2016

Technology Synopsis

This patent claims a method for managing a mobile device-initiated (SET-initiated) SUPL location request. The method involves a session router capturing the request, creating a session record, retrieving that record upon subsequent messaging, and routing communications to the correct server among a plurality of servers to maintain session integrity (’449 Patent, Abstract; col. 3:5-24).

Asserted Claims

At least independent claim 5 (Compl. ¶36).

Accused Features

The complaint alleges that the Oracle Communications Session Router performs the patented method of managing device-initiated location requests (Compl. ¶18, ¶36).

U.S. Patent No. 9,763,084 - "Secure Location Session Manager," issued September 12, 2017

Technology Synopsis

This patent claims a system for managing SUPL sessions, comprising a session router that establishes a connection with a mobile device in response to a location request. The system's key inventive step is selecting a servicing server from a plurality of available servers based on load-balancing logic (e.g., the number of requests currently being handled) and then facilitating the bi-directional communication for the session (’084 Patent, Abstract; Claim 1).

Asserted Claims

At least independent claim 12 (Compl. ¶44).

Accused Features

The Oracle Communications Session Router is alleged to constitute the claimed system that intelligently selects servicing servers and manages the resulting communication sessions (Compl. ¶18, ¶44).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Oracle's Communications Session Router" as the accused instrumentality (Compl. ¶18).

Functionality and Market Context

The complaint does not provide specific technical details about the operation of the accused product. It offers a URL to a general product marketing page and makes broad allegations that the product is used for managing and routing communication sessions (Compl. ¶18). The complaint alleges the product is commercially available to businesses throughout the United States (Compl. ¶24) but provides no further market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that claim charts are attached as Exhibits E and F for the ’235 and ’511 patents, respectively; however, these exhibits were not included with the filed complaint document (Compl. ¶26, ¶34). The infringement theory is therefore summarized from the complaint's narrative allegations.

Plaintiff’s infringement theory for the ’235 Patent is that the Oracle Session Router functions as the claimed "location session manager." It is alleged to perform the claimed method for network-initiated requests by creating, retrieving, and deleting a "SUPL session record" to route communications between a mobile device and the correct initiating server in a multi-server environment (Compl. ¶20, ¶26).

For the ’511 Patent, the infringement theory is analogous but focuses on device-initiated requests. The complaint alleges the Oracle Session Router performs the claimed steps for sessions initiated by a mobile device, creating a record in a routing table to ensure subsequent communications are directed to the server that serviced the initial request (Compl. ¶28, ¶34).

• Identified Points of Contention:
  • Technical Questions: A primary factual dispute will likely be whether the Oracle Session Router's architecture and operation align with the claimed invention. Key questions include whether the accused product actually creates, retrieves, and deletes a temporary, session-specific data structure corresponding to the claimed "SUPL session record," or if it uses a more generalized or persistent routing mechanism.
  • Scope Questions: The case may turn on the distinction between network-initiated sessions (’235 Patent) and device-initiated sessions (’511 Patent). The evidence will need to show that the accused product performs in the manner required by each respective claim set.

V. Key Claim Terms for Construction

The Term: "SUPL session record" (’235 Patent, Claim 1; ’511 Patent, Claim 1)

• Context and Importance: This term is the central data structure of the claimed invention, containing the "routing information" needed to solve the stated problem. The outcome of the infringement analysis will heavily depend on whether data structures used in the accused product meet the court’s construction of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the record’s function as providing "routing information" and states it can be stored in "internal tables" or a "database," which could support a broad interpretation covering any data structure that holds session-specific routing data (’235 Patent, col. 4:59-62; col. 6:38-40).
  • Evidence for a Narrower Interpretation: The specification discloses an exemplary table with specific fields for the session record, including "SSR SLP Session ID," "MSISDN," and "Serving SLP Address" (’235 Patent, col. 6:23-29). A defendant may argue the term should be limited to a data structure containing these specific fields or their clear equivalents, narrowing the claim scope.

The Term: "for a single SUPL session" (’235 Patent, Claim 1; ’511 Patent, Claim 1)

• Context and Importance: This limitation appears in the context of creating, retrieving, and deleting the session record. It suggests a temporary, one-to-one relationship between the record and a specific location-finding transaction. Practitioners may focus on this term because it distinguishes the claimed invention from systems that use more permanent or generalized routing tables.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff might argue this simply means the record is associated with one session at a time, without strictly mandating its lifecycle.
  • Evidence for a Narrower Interpretation: The claims and specification describe a lifecycle where the record is "created," "retrieved," and "deleted" upon "completion of said single SUPL session" (’235 Patent, Claim 1). The call flow diagram further illustrates this temporary nature (e.g., ’235 Patent, FIG. 1, steps 3 & 13), supporting an interpretation that the record must be ephemeral and tied to the life of one specific transaction.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Oracle induces and contributes to infringement by its customers, asserting that Oracle acts "with knowledge of the... patent" and "supplies the technology that allows its customers to infringe the patent" (e.g., Compl. ¶21, ¶29, ¶37, ¶45). These allegations are not supported by specific facts, such as references to user manuals or instructions that encourage infringing use.
• Willful Infringement: Willfulness is alleged based on the conclusory statements that Defendant "has made no attempt to design around the claims" and "did not have a reasonable basis for believing" the claims were invalid (e.g., Compl. ¶22-23, ¶30-31). The complaint does not allege facts to support pre-suit knowledge of the patents.

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

1. A dispositive procedural question concerns the viability of the '084 Patent claim: Given that asserted independent claim 12 was cancelled during an Ex Parte Reexamination that concluded after the complaint was filed, a central issue is whether the fourth count for infringement can survive a motion for dismissal or summary judgment.

2. A core issue will be one of technical implementation: Does the accused Oracle Communications Session Router actually perform the specific steps recited in the claims, particularly the creation, retrieval, and deletion of a temporary, session-specific "SUPL session record" for routing purposes? Or does it employ a different, more generalized routing architecture that falls outside the claims' scope?

3. The case will likely turn on a question of claim construction: How will the court define "SUPL session record"? A narrow construction requiring the specific data fields disclosed in the specification could significantly limit the scope of the claims, while a broader, more functional definition would favor the plaintiff’s infringement theory.