Lab Technology LLC v. Usaa Alliance Services LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: USAA Alliance Services LLC (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00173, W.D. Tex., 04/17/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because the defendant maintains an established place of business in the district.
• Core Dispute: Plaintiff alleges that unspecified products and services offered by Defendant infringe a patent related to automatically refreshing a telephone's display with contextually relevant services based on the device's location.
• Technical Context: The technology addresses the field of user interface design for mobile devices, specifically aiming to reduce user navigation efforts by proactively presenting application shortcuts or services based on contextual cues like location and time of day.
• Key Procedural History: The patent-in-suit is part of a continuation chain originating from an application filed in 2006, suggesting a lengthy prosecution history. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent.

Case Timeline

Date	Event
2006-06-22	Earliest Priority Date ('982 Patent)
2015-12-22	U.S. Patent No. 9,219,982 Issues
2025-04-17	Complaint Filed

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

• Patent Identification: U.S. Patent No. 9,219,982, "Apparatus and method for automatically refreshing a display of a telephone," issued December 22, 2015.

The Invention Explained

• Problem Addressed: The patent identifies the problem that as telephones gain more features and services, users must navigate through increasingly complex menus to find a desired function. This is inefficient, particularly because users often access the same services repeatedly at specific times or in specific locations ('982 Patent, col. 1:28-32).
• The Patented Solution: The invention proposes a telephone that automatically changes, or "refreshes," the services displayed on its screen based on the user's current context. The system uses a "function"—a profile representing a set of conditions like time of day, location, or user activity (e.g., "office worker on weekday morning")—to determine which communication services are most relevant ('982 Patent, col. 2:20-28). The telephone's processor connects to a "location server" to obtain its current location, selects the appropriate function from a datastore, and then displays the services associated with that function ('982 Patent, col. 8:25-39; Fig. 5).
• Technical Importance: The technology represents an early approach to context-aware computing on mobile devices, aiming to create a more predictive and personalized user experience by anticipating user needs without explicit input ('982 Patent, col. 2:4-8).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "Exemplary '982 Patent Claims" (Compl. ¶11). The analysis below focuses on independent claim 1 as a representative claim.
• Independent Claim 1:
  • A telephone comprising a display panel, a processor, and a datastore;
  • the datastore comprising at least one "function" containing information related to a telephone's current location and a user;
  • the function is associated with at least one communication service;
  • the processor is operable to connect the telephone to a "location server" to get the telephone's current location;
  • the processor selects a function from the datastore; and
  • refreshes a screen on the display panel to show the communication service associated with the selected function, based at least partly on the telephone's current location.
• The complaint does not explicitly reserve the right to assert dependent claims, but infringement allegations are made as to "one or more claims" of the patent (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products or services. It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint alleges that the accused products are made, used, offered for sale, sold, and/or imported by the Defendant (Compl. ¶11). It further alleges that the Defendant's employees internally test and use these products (Compl. ¶12). Without Exhibit 2, the specific functionality accused of infringement cannot be determined from the complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits to detail its infringement allegations, but these exhibits are not provided (Compl. ¶16-17). The narrative theory is that the "Exemplary Defendant Products practice the technology claimed by the '982 Patent" and "satisfy all elements of the Exemplary '982 Patent Claims" (Compl. ¶16). In the absence of specific allegations mapping product features to claim elements, a claim chart cannot be constructed.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the language of claim 1 and the general nature of the allegations, the infringement analysis raises several questions:

• Technical Questions: A primary factual dispute will concern the architecture of the accused products. The court will need to determine if the accused systems contain a "datastore" with pre-defined "functions" that are selected by a "processor" which, in turn, connects to a distinct "location server," as recited in the claim.
• Scope Questions: The analysis may turn on whether the accused product's method for providing location-based suggestions can be mapped onto the specific claim elements. For example, does a software application that makes an API call to a device's operating system for location data meet the limitation of a "processor" that "is operable to connect the telephone to a location server"?

V. Key Claim Terms for Construction

The Term: "function"

• Context and Importance: This term is central to the invention's structure. Its definition will determine what kind of contextual data profile in an accused product can meet the limitation. Practitioners may focus on this term because the patent defines it as representing "a given set of conditions associated with a user" and ties it to "commonly used communication services" ('982 Patent, col. 2:21-28), which may be narrower than a modern app's general-purpose use of contextual data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states conditions "may be static, such as user ID, or variable, such as time, location, activity or the like," suggesting a non-exhaustive list ('982 Patent, col. 4:32-34).
  • Evidence for a Narrower Interpretation: The patent provides specific, role-based examples like "an office worker on weekday morning," "a hotel guest in evenings," or "a vehicle driver," which could be used to argue that a "function" requires a pre-defined, user-centric profile rather than just raw contextual data ('982 Patent, col. 4:35-37).

The Term: "location server"

• Context and Importance: Claim 1 requires the processor to connect to a "location server" to obtain the telephone's location. The interpretation of "location server" is critical to determining whether modern mobile architectures, which may get location data from on-device GPS hardware or operating system services, infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes connecting to the server over various networks, including "a WiFi hotspot, or a short-distance wireless network, such as a Bluetooth network," which could suggest that the "server" can be a local or integrated component ('982 Patent, col. 7:1-3).
  • Evidence for a Narrower Interpretation: The patent repeatedly depicts the location server as an external entity separate from the telephone, connected over a network like the internet or a cellular network (e.g., GPRS) ('982 Patent, Fig. 5; col. 6:64-68). This could support an argument that the term requires a physically distinct server and does not read on integrated GPS chipsets or internal OS services.

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 a manner that infringes the '982 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges knowledge of infringement based on the service of the complaint itself (Compl. ¶13). It asserts that Defendant's continued infringement "at least since being served by this Complaint" supports a claim for induced infringement, which forms a basis for potential post-suit willfulness (Compl. ¶15).

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

The resolution of this dispute will likely depend on the answers to two central questions:

1. An Evidentiary Question of Architecture: As the complaint lacks specific technical details, a threshold issue will be whether discovery reveals that the accused products possess an architecture corresponding to the patent's claims. Specifically, can the plaintiff demonstrate that the accused systems utilize a "datastore" of discrete "functions" that are selected based on data retrieved from a "location server," as those terms are construed?

2. A Definitional Question of Scope: The case will heavily rely on claim construction. A core issue will be whether the term "location server," as described in a 2006-priority patent, can be construed to cover modern methods of obtaining location data, such as from an integrated GPS module or an operating system's location services API, or if it is limited to a distinct, network-connected server entity.