DCT

7:25-cv-00197

Calibrate Networks LLC v. Airbnb Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00197, W.D. Tex., 04/24/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s unidentified network communication systems infringe a patent related to methods for managing and changing network addresses without disrupting connections.
  • Technical Context: The technology concerns network architecture, specifically methods for reassigning addresses to network processes to support mobility and routing efficiency while avoiding the connection loss typical in traditional systems.
  • Key Procedural History: The patent-in-suit was originally assigned to Tria Network Systems, LLC. The complaint asserts that Plaintiff Calibrate Networks LLC is now the assignee of all rights, title, and interest in the patent.

Case Timeline

Date Event
2013-03-15 '633 Patent Priority Date
2014-03-14 '633 Patent Application Filing Date
2017-02-28 '633 Patent Issue Date
2025-04-24 Complaint Filing Date

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

U.S. Patent No. 9,584,633 - "Method and system for managing network communications," issued February 28, 2017

The Invention Explained

  • Problem Addressed: The patent describes traditional network architectures as inefficient, requiring incoming data packets (PDUs) to be passed through multiple protocol layers, entailing data copies and task switching ('633 Patent, col. 1:21-28). It also notes that changing the address of a network entity in conventional systems is difficult and can destroy active connections, which is a critical problem for supporting user mobility and network efficiency ('633 Patent, col. 1:54-62).
  • The Patented Solution: The invention proposes a method where a network process can be assigned a "new address" while its "old address" remains temporarily active. This allows the process to begin using the new address for outgoing communications immediately, while other network entities learn of the change over time and update their own routing information to use the new address ('633 Patent, col. 11:36-48). The patent describes a "flattened" processing architecture where a single protocol processor can handle multiple layers by treating each data packet as a "serial tape," thereby avoiding the inefficiencies of layered processing ('633 Patent, col. 3:3-9).
  • Technical Importance: This approach aims to provide seamless address changes, a feature critical for mobile devices moving between networks or for reconfiguring a large network without disrupting ongoing communications ('633 Patent, col. 1:56-62).

Key Claims at a Glance

  • The complaint asserts infringement of one or more "Exemplary '633 Patent Claims" without specifying them (Compl. ¶11). The first independent claim is Claim 1.
  • Independent Claim 1 (Method):
    • determining... an address change is desired for an Inter-Process Communication (IPC) process,
    • wherein the IPC process has been assigned an old address... only known in a layer,
    • and wherein the IPC process has an application name that is known globally;
    • assigning... a new address to the IPC process, wherein the new address is only known in the layer;
    • wherein the IPC process utilizes the new address as a source address in any Data Transfer Process (DTP) flows originating from the IPC process.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name. It refers generally to "Defendant products" and "Exemplary Defendant Products" that are purportedly identified in an exhibit not attached to the public filing (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products and by having its "employees internally test and use these Exemplary Products" (Compl. ¶11-12). The complaint does not provide any description of the accused products' technical functionality or market context.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided as Exhibit 2 (Compl. ¶16-17). However, Exhibit 2 was not filed with the complaint. The body of the complaint presents a conclusory infringement theory, stating that the "Exemplary Defendant Products practice the technology claimed by the '633 Patent" and "satisfy all elements of the Exemplary '633 Patent Claims" (Compl. ¶16). The complaint does not provide sufficient detail for analysis of how any specific accused product or service is alleged to meet the limitations of the asserted claims.

V. Key Claim Terms for Construction

  • The Term: "Inter-Process Communication (IPC) process"

    • Context and Importance: This term defines the type of entity to which the claimed address-changing method applies. Its construction is critical to determining the scope of the invention, as it will define whether the accused functionality at Airbnb involves a structure that qualifies as an "IPC process." Practitioners may focus on this term to determine if it is limited to specific networking architectures discussed in the patent (like RINA) or covers any generic software process communicating over a network.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term is used generally throughout the claims and specification, which could suggest it encompasses a wide range of software processes that communicate.
      • Evidence for a Narrower Interpretation: The specification states that "IPC Processes are Application Processes that are members of a DIF [Distributed IPC Facility]" and references ISO standards, suggesting a more specific, structured definition ('633 Patent, col. 5:52-56).

  • The Term: "application name that is known globally" / "address... only known in a layer"

    • Context and Importance: The distinction between a stable, "global" name and a transient, "layer-specific" address is the central inventive concept of Claim 1. The infringement analysis will depend entirely on whether the accused Airbnb system maintains two such distinct types of identifiers and whether they function as claimed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's abstract language is general, and one could argue that any system with a persistent identifier (e.g., a user account name) and a transient network identifier (e.g., an IP address) meets this limitation.
      • Evidence for a Narrower Interpretation: The specification provides a specific example: "A-Appl-name is known globally, while a-old and a-new are only known within the layer" ('633 Patent, col. 6:17-19). This may be used to argue that the terms require adherence to the specific architectural model (e.g., RINA) described, where "layers" have a precise meaning distinct from the TCP/IP model.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement based on Defendant distributing "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '633 Patent" (Compl. ¶14). The allegations are tied to knowledge obtained upon service of the complaint (Compl. ¶15).
  • Willful Infringement: The complaint's allegations supporting willfulness appear to be based on post-suit knowledge. It states that "at least since being served by this Complaint," Defendant has had knowledge and continued to infringe (Compl. ¶15). It further asserts that the service of the complaint itself "constitutes actual knowledge of infringement" (Compl. ¶13).

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

  1. A threshold issue will be one of identification and evidence: The complaint does not identify the specific Airbnb products, services, or internal systems that are accused of infringement. A primary question will be what evidence Plaintiff can produce to show that any specific Airbnb system performs the claimed method.

  2. A central question will be one of technical implementation: Assuming an accused system is identified, the case will likely turn on whether that system's architecture maps onto the specific claim elements. In particular, the court may need to determine if the accused system utilizes a two-tiered identification scheme corresponding to a "globally known application name" and a "layer-specific address" as those terms are defined within the context of the '633 patent.

  3. The dispute may also focus on definitional scope: The case could hinge on whether the term "Inter-Process Communication (IPC) process," as used in the patent, can be construed to read on the components of Airbnb's large-scale, web-based infrastructure, or if its meaning is confined to the more specialized network architectures described in the patent's specification.