WebSock Global Strategies LLC v. Stirista LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: Stirista, LLC (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00242, W.D. Tex., 05/22/2025
• 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, has allegedly committed acts of patent infringement there, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to methods for enabling symmetrical, bi-directional communication between network nodes over protocols that are inherently asymmetrical, such as HTTP.
• Technical Context: The technology addresses limitations in standard client-server network protocols (like HTTP), particularly the inability of a server to initiate communication with a client, which hinders peer-to-peer applications, especially when network address translation (NAT) is involved.
• Key Procedural History: The patent-in-suit is a continuation of a prior application that issued as U.S. Patent No. 7,403,995. This shared specification may be relevant for claim construction purposes. The complaint does not mention any other prior litigation, licensing history, or administrative proceedings related to the patent.

Case Timeline

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

• Patent Identification: U.S. Patent No. 7,756,983, "Symmetrical bi-directional communication," issued July 13, 2010.
• The Invention Explained:
  • Problem Addressed: The patent addresses a "fundamental problem" in network communications based on the HyperText Transfer Protocol (HTTP) ('983 Patent, col. 2:6-9). Under the standard HTTP model, network nodes have rigid, asymmetric roles: a "client" initiates requests, and a "server" can only respond ('983 Patent, col. 2:10-13). This prevents a server from initiating a spontaneous connection to a client, a significant obstacle for peer-to-peer applications, especially when a client is on a private network behind a firewall or Network Address Translator (NAT) ('983 Patent, col. 2:45-53). Inefficient workarounds like constant "polling" by the client waste network bandwidth ('983 Patent, col. 3:4-6).
  • The Patented Solution: The invention proposes a method to reverse the client-server roles within an established communication session. First, a client establishes a standard connection with a server (e.g., over TCP/IP). Then, the nodes "negotiate" a role reversal. This involves terminating the initial HTTP-layer session while deliberately preserving the underlying network connection (e.g., the TCP socket) ('983 Patent, col. 11:40-46). A new HTTP-layer session is then created over the same, preserved connection, but with the roles "flipped": the original server now acts as a client, able to initiate requests to the original client, which now acts as a server ('983 Patent, col. 11:47-56). This process, illustrated in the flowchart of FIG. 9, allows for true bi-directional, peer-to-peer communication.
  • Technical Importance: This method provided a way to build robust peer-to-peer applications using the ubiquitous HTTP protocol while overcoming its inherent architectural asymmetries and the challenges posed by private networks and firewalls.
• Key Claims at a Glance:
  • The complaint refers to "Exemplary '983 Patent Claims" contained in an unprovided exhibit (Compl. ¶13). Based on the patent, independent claim 1 is representative of the core invention.
  • Independent Claim 1: A method of computer network node communication comprising:
    • first and second network nodes engaging in an asymmetric hypertext transfer protocol (HTTP) transactional session with an underlying network connection, each node enacting distinct initial transactional roles
    • terminating said asymmetric HTTP transactional session while maintaining said underlying network connection
    • said first and second network nodes negotiating transactional role reversal
    • said first and second network nodes further communicating under a reversed asymmetric transactional protocol, wherein each network node enacts the initial transactional role of the other
  • The complaint does not explicitly reserve the right to assert other claims, but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint does not identify the accused instrumentalities by name. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within an "Exhibit 2" (Compl. ¶13). This exhibit was not attached to the publicly filed complaint.
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context, as all such information is allegedly contained in the unprovided Exhibit 2 (Compl. ¶13, 14).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made entirely by reference to claim charts in an "Exhibit 2" which was not provided with the filing (Compl. ¶¶13-14). The body of the complaint contains no specific factual allegations mapping any feature of a Defendant product to any element of a patent claim. The narrative theory is limited to the assertion 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" them (Compl. ¶¶11-12). Without the referenced exhibit, a detailed analysis of the infringement allegations is not possible.

V. Key Claim Terms for Construction

• The Term: "negotiating transactional role reversal" (from Claim 1)
• Context and Importance: This term is the central inventive step of the claimed method. The definition of what actions constitute "negotiating" a "role reversal" will be critical to the infringement analysis. Practitioners may focus on this term because its scope will determine whether infringement requires a specific, explicit protocol exchange (as shown in the patent's embodiments) or could be met by a more general or implicit process that achieves the same outcome.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses the general term "negotiating," which does not on its face require a specific command or message format. This may support an argument that any communication sequence between two nodes that results in the reversal of their client/server roles over a persistent underlying connection meets the limitation.
  • Evidence for a Narrower Interpretation: The specification describes a specific implementation of this negotiation, where a client sends an "HTTP FLIP request" and the server responds affirmatively ('983 Patent, col. 10:61-63, FIG. 9). One embodiment shows a specific HTTP header, "TACT:DFLIP," used to declare the role reversal ('983 Patent, FIG. 13, col. 12:43-46). A party could argue that "negotiating" should be construed to require a similar, explicit request-and-acceptance protocol for the role reversal, as this is the only method fully described and enabled by the patent.

VI. Other Allegations

• Willful Infringement: The complaint does not explicitly allege "willful infringement." However, in the Prayer for Relief, it requests a judgment that the case be "declared exceptional within the meaning of 35 U.S.C. § 285" (Compl. p. 4, ¶E.i). The complaint pleads no specific facts to support this request, such as allegations of pre-suit or post-suit knowledge of the patent by the Defendant.

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

1. Evidentiary Sufficiency: The complaint's infringement theory relies entirely on an unprovided exhibit. A primary question will be what factual evidence Plaintiff possesses and will present to demonstrate that the accused products perform each step of the asserted claims, particularly the core steps of terminating an HTTP session while maintaining the underlying connection and subsequently reversing communication roles.
2. Definitional Scope: The case will likely turn on a question of claim construction: what is the scope of "negotiating transactional role reversal"? The court will need to determine whether this phrase is limited to the explicit "FLIP" request protocol detailed in the patent's embodiments or if it can be interpreted more broadly to cover any mechanism that achieves a functional role-swap over a persistent network socket. The answer to this question will likely dictate the outcome of the infringement analysis.