Telsync Tech LLC v. Siemens Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Telsync Technologies LLC (Delaware)
  • Defendant: Siemens Corporation (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00150, W.D. Tex., 04/01/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that certain unidentified Siemens products infringe a patent related to maintaining communication sessions for mobile devices in a wireless network.
• Technical Context: The technology concerns methods for ensuring continuous connectivity for mobile devices as they move between different wireless access points, a foundational process for applications like mobile video conferencing and voice calls.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit. The allegations of knowledge and inducement are based on the filing of the instant complaint.

Case Timeline

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

U.S. Patent No. 8,897,263 - Interactions among mobile devices in a wireless network

• Patent Identification: U.S. Patent No. 8,897,263, issued November 25, 2014.

The Invention Explained

• Problem Addressed: In wireless networks, mobile devices are assigned different identification information as they move between locations, which can disrupt real-time applications like video conferencing that require stable connections (U.S. Patent No. 8,897,263, col. 1:33-44).
• The Patented Solution: The invention describes a method for maintaining a communication session for a mobile device as it moves from a first wireless range to a second. A stationary device (e.g., a base station or switch center) determines a "first identification information" for the mobile device (e.g., a "home IP address"). When the device moves to a new wireless range and registers with a new stationary device, it is assigned a "second identification information" (e.g., a "guest IP address"). The system then accesses and utilizes this second ID in a signaling protocol to maintain the original communication session, facilitating a seamless handoff (U.S. Patent No. 8,897,263, col. 4:40-65, FIG. 3).
• Technical Importance: This technology aims to provide persistent connectivity for mobile users, a critical requirement for the reliable operation of interactive mobile applications in cellular and other wireless network environments (U.S. Patent No. 8,897,263, col. 4:36-39).

Key Claims at a Glance

• The complaint asserts "one or more claims" of the ’263 Patent, identifying them as "Exemplary '263 Patent Claims" contained in an exhibit not attached to the complaint filing (Compl. ¶11). Independent Claim 1 is a representative method claim.
• Independent Claim 1: A method to maintain a communication session, comprising:
  • determining a first identification information associated with a mobile device;
  • in response to the mobile device leaving a first wireless range, accessing a second identification information associated with the first, where the second ID is assigned when the device registers in a second wireless range; and
  • maintaining the communication session by utilizing the second identification information in a signaling protocol.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within "Exhibit 2" (Compl. ¶11, ¶16). This exhibit was not filed with the complaint.

Functionality and Market Context

• The complaint alleges that the accused products are made, used, sold, or imported by Defendant and its customers (Compl. ¶11). It further alleges that Defendant’s employees internally test and use these products (Compl. ¶12). No specific functionalities or market context for any Siemens product are described in the complaint itself; instead, the complaint alleges that the accused products "practice the technology claimed by the '263 Patent" and incorporates details from the unattached Exhibit 2 by reference (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made by incorporating by reference an unattached exhibit containing claim charts (Compl. ¶16, ¶17). The following summary is based on the narrative infringement theory and the elements of representative Independent Claim 1.

’263 Patent Infringement Allegations

• Identified Points of Contention:
  • Evidentiary Questions: As the complaint lacks specific factual allegations tying any Siemens product feature to a claim element, a primary issue will be whether discovery reveals evidence that Siemens’ products perform the claimed steps. The plaintiff’s case appears to depend entirely on the content of the unattached "Exhibit 2."
  • Technical Questions: A key question will be whether the handoff mechanisms in Siemens' products operate in the manner described by the claims. Specifically, do they use a two-part identification scheme ("first identification information" and "second identification information") that is accessed and utilized as claimed, or do they employ a different technical approach for session continuity?

V. Key Claim Terms for Construction

• The Term: "first identification information" / "second identification information"
• Context and Importance: The entire claim hinges on this two-part identification scheme. The patent provides "home IP address" and "guest IP address" as examples (U.S. Patent No. 8,897,263, col. 4:60-65; Claim 12). The scope of what qualifies as "first" and "second" identification information will likely be a central dispute. Practitioners may focus on this term because its construction will determine whether the claim reads on modern network handoff protocols that may not use a formal "home/guest" IP address architecture.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim term itself, "identification information," is broad and not explicitly limited to IP addresses in the independent claims. A party could argue it encompasses any set of network identifiers used to manage a mobile device's session during a handoff.
  • Evidence for a Narrower Interpretation: The specification repeatedly uses the "home IP address" and "guest IP address" paradigm to describe the invention (e.g., U.S. Patent No. 8,897,263, col. 5:1-5). Dependent claim 12 explicitly recites these terms, which could be used to argue the invention is limited to this specific type of IP-based handoff mechanism.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The claim is based on knowledge acquired "at least since being served by this Complaint" (Compl. ¶15).
• Willful Infringement: The complaint asserts willfulness based on Defendant's alleged continued infringement after receiving "actual knowledge" of the patent via the service of the complaint and its attached claim charts (Compl. ¶13, ¶14). This is a post-filing willfulness allegation.

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

1. Definitional Scope: A central issue will be the construction of "first identification information" and "second identification information." Can these terms be construed broadly to cover any set of identifiers used in modern wireless handoffs, or are they limited by the specification's examples to a "home IP" and "guest IP" architecture?
2. Evidentiary Sufficiency: Given the complaint’s reliance on an unattached exhibit, a threshold question is whether Plaintiff can produce sufficient factual evidence to demonstrate that any specific Siemens product actually performs the claimed method, particularly the sequential process of accessing and utilizing a distinct "second identification information" to maintain a session.
3. Technical Mismatch: The case may turn on a question of technical operation: does the accused technology, once identified, achieve session continuity through a mechanism that maps onto the claimed two-ID signaling protocol, or does it use a fundamentally different, non-infringing method for managing mobile device handoffs?