Reframe Tech LLC v. Marriott Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Reframe Technologies LLC (NM)
  • Defendant: Marriott International, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00251, W.D. Tex., 05/28/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of patent infringement there, causing harm.
• Core Dispute: Plaintiff alleges that Defendant’s products and services, by which customers are provided network access, infringe a patent related to a system for trading network resources.
• Technical Context: The technology concerns systems for authorizing and settling payments for network access, particularly Wi-Fi, by allowing users to trade credits earned from providing access on their own network for access on other networks.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,552,870 - “Trading network resources”

Issued June 30, 2009

The Invention Explained

• Problem Addressed: The patent identifies a problem with the state of public Wi-Fi access at the time, noting that coverage from any single provider was geographically sparse and that high costs discouraged users from signing up for multiple services. This fragmentation made it difficult for hotspot operators to generate revenue and for users to find reliable roaming access ('870 Patent, col. 2:1-17).
• The Patented Solution: The invention proposes a "Network Resource Trading Exchange" that enables operators of access gateways (e.g., a small business or individual with a Wi-Fi router) to trade their underutilized network resources for access on other gateways within the exchange ('870 Patent, Abstract). Instead of direct financial payment for each session, a user can earn credits by providing access to others and then spend those credits to "pay" for access when they are roaming, creating a barter-like system for network connectivity ('870 Patent, col. 2:18-28). The system is managed by a central "Trading System" that handles the authorization, accounting, and settlement of these traded credits ('870 Patent, col. 4:21-27; Fig. 1).
• Technical Importance: This approach sought to create a more ubiquitous and lower-friction market for Wi-Fi access by monetizing the vast number of privately owned, underutilized wireless access points, turning them into potential revenue-generating hotspots for their owners ('870 Patent, col. 2:18-28).

Key Claims at a Glance

• The complaint asserts infringement of one or more claims of the ’870 Patent without specifying them, referring to them as the "Exemplary '870 Patent Claims" (Compl. ¶11). Claim 1 is the first independent claim.
• Independent Claim 1 Breakdown:
  • storing data in first type accounts, each representing a network resource user with a balance;
  • storing data in second type accounts, each representing a network resource access gateway operator;
  • wherein credit on at least one of said second type accounts acts as credit on at least one of said first type accounts;
  • receiving a request from a requestor to authorize network resources, with the request identifying a specific first type account and a specific second type account;
  • sending a reply authorizing or denying the provision of resources based at least in part on the balance of the identified first type account; and
  • adjusting the balances of the identified first and second type accounts based on the network resources used.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general language does not preclude it (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific product or service by name. It refers generally to "Exemplary Defendant Products" (Compl. ¶11). Given the defendant is Marriott and the patent relates to network access, these instrumentalities are presumably hotel Wi-Fi systems, guest internet services, and associated loyalty programs that provide or manage such access.

Functionality and Market Context

The complaint alleges that Defendant makes, uses, sells, and imports products that practice the technology claimed by the ’870 Patent (Compl. ¶11). It further alleges that Defendant's employees internally test and use these products (Compl. ¶12). The complaint does not provide further technical detail on how the accused instrumentalities operate or any allegations regarding their market position.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, an Exhibit 2 containing claim charts that allegedly compare the "Exemplary '870 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16). Without this exhibit, a detailed element-by-element analysis is not possible. The complaint’s narrative theory is that the "Exemplary Defendant Products practice the technology claimed by the '870 Patent" and "satisfy all elements of the Exemplary '870 Patent Claims" (Compl. ¶16). This suggests Plaintiff's theory is that Marriott's system for providing network access to guests functions as a "trading system." For example, a guest's loyalty status or direct payment might be treated as a "first type account" (user account), while a specific hotel's network infrastructure might be treated as a "second type account" (gateway operator account), with the overall Marriott system managing the authorization and settlement between them.

No probative visual evidence provided in complaint.

Identified Points of Contention

• System Architecture Question: The central dispute may turn on whether Marriott's systems for providing guest internet access constitute the specific "trading exchange" architecture required by the claims. This raises the question: Does Marriott's system feature distinct "first type accounts" for users and "second type accounts" for gateway operators, and does credit from one "act as credit" on the other in the manner claimed?
• Functional Question: A key question will be whether the internal accounting within Marriott's corporate structure and loyalty programs performs the same function as the claimed "adjusting" of balances between a distinct user account and a distinct gateway operator account. The court may need to determine if a centrally managed corporate system is equivalent to the claimed exchange between different economic actors (users and gateway operators).

V. Key Claim Terms for Construction

• The Term: "credit on at least one of said second type accounts acts as credit on at least one of said first type accounts" (’870 Patent, col. 22:1-4).
• Context and Importance: This limitation appears to be the central inventive concept, defining the "trading" mechanism. Its construction will be critical to determining infringement. If construed narrowly to require a direct, barter-like transfer of credits earned by a gateway operator to a user's account, it may be difficult to prove infringement. If construed broadly to cover any system where providing access generates value that can be used to obtain access elsewhere within a closed ecosystem, Plaintiff's case may be stronger. Practitioners may focus on this term because it links the two types of accounts and embodies the core "trading" function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent summary defines the invention as allowing users to "trade access to Network Resources via their own Access Gateway for access via others' when roaming" ('870 Patent, col. 2:21-23). This could be argued to support a broader concept of exchange within a system, not necessarily a literal credit transfer. The term "acts as" may suggest functional equivalence rather than a specific transactional mechanism.
  • Evidence for a Narrower Interpretation: Claim 2, which depends on Claim 1, specifies that credit on a second type account can be "transferred automatically" or "under the control of the holder" to a first type account ('870 Patent, col. 22:5-13). Under the doctrine of claim differentiation, this may imply that Claim 1 itself does not require such a direct transfer mechanism, but a defendant could argue these dependent claims simply clarify the specific type of "acting as" envisioned by the inventor. Furthermore, the detailed description focuses heavily on a system where distinct operators earn credits that are then used by distinct users, suggesting a more decentralized, peer-to-peer model than a typical corporate loyalty program ('870 Patent, col. 2:23-28).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct end users to use the products in a manner that infringes the ’870 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges knowledge of infringement based on the service of the complaint and its attached (but un-provided) claim charts (Compl. ¶13). Willfulness is predicated on Defendant’s alleged continued infringement after receiving this notice (Compl. ¶14-15).

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

1. A core issue will be one of architectural equivalence: Does Marriott’s system for providing and managing guest internet access, which is likely a centrally controlled corporate infrastructure, map onto the patent’s claimed architecture of a "trading exchange" with distinct "first type" user accounts and "second type" gateway operator accounts?
2. The case will also turn on a question of functional interpretation: Can the phrase "credit... acts as credit," which underpins the patent's trading concept, be construed to read on the value exchange within a customer loyalty program (e.g., hotel stay points or elite status granting internet access), or does it require a more direct, barter-like system where credits are explicitly earned by providing network access and spent to consume it?