Lab Technology LLC v. Lumen Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Lumen Technologies, Inc. (Louisiana)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00172, W.D. Tex., 04/17/2025
• Venue Allegations: Venue is alleged to be proper based on the defendant maintaining an established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s telecommunications products and services infringe patents related to unified call routing across multiple networks and methods for obtaining an emergency caller's location.
• Technical Context: The patents address challenges in telecommunications where users possess multiple phone numbers and devices (e.g., office, mobile, VoIP), creating complexity in both general reachability and emergency location services.
• Key Procedural History: The patents-in-suit claim priority to earlier applications. The '102 Patent is a continuation-in-part of a 2004 application, and the '973 Patent is part of a continuation chain originating with a 2005 application. The complaint itself serves as the notice of alleged infringement to the Defendant.

Case Timeline

Date	Event
2004-11-02	'102 Patent Earliest Priority Date
2005-07-14	'973 Patent Earliest Priority Date
2007-10-29	'102 Patent Application Filing Date
2011-12-23	'973 Patent Application Filing Date
2013-07-09	'102 Patent Issue Date
2013-08-06	'973 Patent Issue Date
2025-04-17	Complaint Filing Date

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

U.S. Patent No. 8,483,102 - “System and method for mapping a voice identity across multiple telephony networks with time attributes”

The Invention Explained

• Problem Addressed: The patent’s background describes the inefficiency and confusion that arises when a person has multiple telephone numbers (e.g., office, cellular, home). Callers must try several numbers to reach the person, and the user must check multiple voicemail systems for messages, leading to lost time and potential miscommunication (’102 Patent, col. 1:26-43).
• The Patented Solution: The invention proposes a centralized system where a user is assigned a single "voice identity." This identity is mapped to different target phone numbers through a "voice identity mapping policy" that can include time-based rules (e.g., forward to office phone during work hours, mobile phone otherwise). A "policy processor" consults this policy when a call is placed to the voice identity and automatically routes the call to the appropriate destination device based on the rules. (’102 Patent, Abstract; Fig. 2; col. 4:6-15).
• Technical Importance: This technology sought to provide a transparent and efficient way for a caller to reach a user without needing to know which of the user's multiple devices was currently active. (’102 Patent, col. 2:21-24).

Key Claims at a Glance

• The complaint asserts unspecified "Exemplary '102 Patent Claims" (Compl. ¶12). Independent claim 1 is representative.
• Independent Claim 1 recites a system comprising:
  • One or more phone systems with telephony switches for call routing.
  • At least one policy processor coupled to the switches.
  • A voice identity mapping policy stored in a data storage, which includes:
    • A plurality of "search voice identities" mapped to "target voice identities."
    • "time attributes" indicating when the mapping policies are valid.
  • The system operates by receiving a voice identity, matching it to a search identity, determining the corresponding target identity based on the policy, and routing the call, where the voice identities each comprise a "username." (’102 Patent, col. 10:10-44).
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "one or more claims" (Compl. ¶12).

U.S. Patent No. 8,503,973 - “Method and system for obtaining emergency caller location”

The Invention Explained

• Problem Addressed: The patent identifies a public safety problem with mobile and VoIP telephone services: unlike traditional landlines with fixed locations, it is difficult for emergency responders to automatically determine the physical location of a caller using a nomadic device. (’973 Patent, col. 2:22-39). A user making a 911 call from a VoIP phone at a hotel, for instance, might have emergency services dispatched to their home address. (’973 Patent, col. 2:40-55).
• The Patented Solution: The invention describes a method performed by a mobile phone to help solve this problem. The phone obtains the identity of its current wireless base station, compares it to a previously stored base station identity, and if they differ, it determines that its location has changed. The phone then obtains the "subscriber location" associated with the new base station and sends this updated location information to the phone system, allowing emergency services to have more current data. (’973 Patent, Abstract; Fig. 7).
• Technical Importance: The invention provides a mechanism to update a mobile user's location for emergency services, addressing a critical safety gap created by the shift away from fixed-location landlines. (’973 Patent, col. 2:56-60).

Key Claims at a Glance

• The complaint asserts unspecified "Exemplary '973 Patent Claims" (Compl. ¶21). Independent claim 1 is representative.
• Independent Claim 1 recites a method for a mobile phone comprising the steps of:
  • (a) obtaining a current wireless base station identity.
  • (b) obtaining a stored wireless base station identity.
  • (c) determining that the current and stored identities do not match.
  • (d) obtaining a subscriber location corresponding to the current wireless base station identity.
  • (e) sending the subscriber location to the phone system. (’973 Patent, col. 11:11-27).
• The complaint refers generally to "one or more claims" of the patent (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, services, or methods by name. It refers to them generically as "Exemplary Defendant Products" (Compl. ¶12, ¶21).

Functionality and Market Context

The complaint does not describe the functionality or operation of the accused products in its narrative sections. It alleges that the products "practice the technology claimed" by the patents-in-suit and that they "satisfy all elements" of the asserted claims, incorporating by reference claim charts in Exhibits 3 and 4, which were not filed with the complaint. (Compl. ¶17-18, ¶26-27). The complaint contains no allegations regarding the products’ commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits to detail its infringement allegations but does not include these exhibits in the public filing (Compl. ¶18, ¶27). The complaint’s narrative theory alleges that Defendant’s "Exemplary Defendant Products" directly infringe the '102 and '973 patents by practicing the claimed technology (Compl. ¶12, ¶21). It further alleges that Defendant’s employees directly infringe by internally testing and using these products (Compl. ¶13, ¶22).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Factual Specificity: A primary issue may be whether the complaint's allegations, which lack any identification of the accused products or a description of their operation, meet federal pleading standards. The complaint's reliance on un-provided exhibits for the substance of its infringement theory raises the question of whether it provides the defendant with sufficient notice of the claims against it.
• Technical Questions ('102 Patent): What evidence supports the allegation that the accused system uses "time attributes" to select a target identity, as opposed to other logic (e.g., user presence, device status)? How does the accused system's identifier for a user or device map to the claimed "username"?
• Technical Questions ('973 Patent): What evidence shows that the mobile device itself performs the claimed steps of comparing base station identities and sending its location, as required by claim 1? Does the accused system determine location at the network level, and if so, does this align with the method claimed in the patent?

V. Key Claim Terms for Construction

For the ’102 Patent

• The Term: "username"
• Context and Importance: This term appears in claim 1, which requires that the received, search, and target voice identities each "comprises a username" (’102 Patent, col. 10:35-44). The construction of this term will be critical to determining the scope of the claim. Practitioners may focus on this term because its definition will dictate whether the claim is limited to computer-network-style identifiers or if it can also read on traditional telephone numbers, directly impacting the range of accused technologies.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses that "the username can be an IM identity, or an email account identity" or an "employee's computer user identity," suggesting a meaning beyond traditional telephony identifiers (’102 Patent, col. 3:30-35).
  • Evidence for a Narrower Interpretation: The specification also states that "Typically, a voice identity is a telephone number or an extension number," which could be used to argue that the "username" component must be understood in a telephony context (’102 Patent, col. 2:57-59).

For the ’973 Patent

• The Term: "subscriber location"
• Context and Importance: Claim 1 requires the mobile phone to obtain and send a "subscriber location" corresponding to its current base station (’973 Patent, col. 11:22-27). The required specificity of this "location" will be a central issue. The case may turn on whether a general area (like a city or ZIP code) is sufficient, or if a dispatchable street address or precise coordinates are required, as this will determine if the defendant's system provides the type of information claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims and abstract do not specify the format or precision of the "location," which may support a broader construction that covers various forms of location data.
  • Evidence for a Narrower Interpretation: The background of the invention is framed entirely around the need for E911 services, discussing the "Automatic Location identity (ALI) database" which maps a phone number to the "street address of the subscriber's residence" to dispatch emergency personnel (’973 Patent, col. 1:49-54, col. 2:9-12). This context suggests "subscriber location" implies a specific, physically dispatchable address.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The factual basis is the allegation that Defendant distributes "product literature and website materials" that instruct end users to use the accused products in an infringing manner (Compl. ¶15-16, ¶24-25). The complaint alleges Defendant has had knowledge at least since the date of service of the complaint (Compl. ¶16, ¶25).
• Willful Infringement: The complaint asserts that service of the complaint itself provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶14, ¶23). This allegation appears intended to support a claim for post-filing willful infringement, as no facts suggesting pre-suit knowledge are alleged. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. p. 7).

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

1. Pleading Sufficiency: A threshold question will be procedural: do the infringement allegations, which fail to identify any accused product by name and rely entirely on incorporating un-filed exhibits, provide plausible grounds for relief and adequate notice to the Defendant, or will they be found deficient under federal pleading standards?
2. Definitional Scope ('102 Patent): A core substantive issue will be one of claim construction: can the term "username," which is given both broad (e.g., email ID) and narrow (e.g., phone extension) context in the specification, be construed to cover the identifiers used in Defendant's modern telecommunications systems?
3. Locus of Operation ('973 Patent): A key evidentiary question will be one of technical operation: does the accused system function as claimed, with the mobile device itself detecting a change in base stations and pushing its updated location to the network? Or is location determined and managed entirely by the network, which may create a fundamental mismatch with the specific method steps recited in claim 1?