Reframe Tech LLC v. Radisson Hospitality Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Reframe Technologies LLC (New Mexico)
  • Defendant: Radisson Hospitality, Inc. (Minnesota)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00256, W.D. Tex., 06/02/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a system for trading network resources, such as internet access.
• Technical Context: The technology enables operators of network access points (e.g., Wi-Fi hotspots) to earn credits for providing access to users, which can then be traded or used by those operators to gain access to other network points within the system.
• 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

• Patent Identification: U.S. Patent No. 7,552,870, "Trading network resources," issued June 30, 2009 (’870 Patent). (Compl. ¶¶ 8-9).

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

The Invention Explained

• Problem Addressed: The patent describes a market failure in paid-for wireless internet access, where sparse geographic coverage from any single provider discourages user adoption. This results in millions of privately-owned, underutilized wireless access gateways that are inaccessible to roaming users. (’870 Patent, col. 2:1-17, 2:48-59).
• The Patented Solution: The invention proposes a "Network Resource Trading Exchange" that allows owners of access gateways to offer access to their network (e.g., their home Wi-Fi) and, in return, earn credits. These credits can then be used to pay for network access when roaming through other access gateways participating in the same system, creating a barter-like economy for connectivity without direct financial payment for each session. (’870 Patent, Abstract; col. 2:18-28). The overall architecture is depicted in Figure 1, showing communication between a user device, an access gateway, and a central "Trading System." (’870 Patent, Fig. 1).
• Technical Importance: The described system aims to aggregate millions of disparate, private internet access points into a cohesive, global roaming network, thereby increasing the value and utility of each individual access point. (’870 Patent, col. 4:1-6).

Key Claims at a Glance

• The complaint does not identify any specific asserted claims, instead referring to "Exemplary '870 Patent Claims" contained in an unattached exhibit. (Compl. ¶¶ 11, 16). For analytical purposes, independent claim 1 is representative of the patented method.
• Essential Elements of Claim 1:
  • A method of authorizing usage and trading of network resources.
  • Storing data in "first type accounts" for network resource users.
  • Storing data in "second type accounts" for network resource access gateway operators.
  • A crediting mechanism where credit in a second type account "acts as credit" on a first type account.
  • Receiving an authorization request that identifies specific first and second type accounts.
  • Sending a reply that authorizes or denies access based at least in part on the balance of the identified first type account.
  • Adjusting the balances of both the first and second type accounts based on the network resources used. (’870 Patent, col. 21:32-22:1).
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any accused products or services. (Compl. ¶11).

Functionality and Market Context

• The complaint refers generically to “Exemplary Defendant Products” and incorporates by reference an “Exhibit 2” that allegedly identifies them and describes their functionality. This exhibit was not provided with the complaint document, and the complaint body contains no factual descriptions of any accused product, service, or feature. (Compl. ¶¶ 11, 16).

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis of infringement. It makes conclusory statements that unspecified products infringe unspecified claims and incorporates all substantive allegations by reference to an unattached claim chart exhibit. (Compl. ¶¶ 11, 14, 16).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on an analysis of representative independent claim 1, the following terms may be central to the dispute.

• 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. 21:43-46).

  • Context and Importance: This phrase defines the core "trading" function of the invention. The outcome of the case may depend on whether the accused system’s method for rewarding resource providers and enabling them to consume resources elsewhere falls within the scope of this language. Practitioners may focus on whether this requires a fungible, transferable credit system or if a more abstract system of earned entitlements would suffice.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language "acts as" suggests a functional relationship rather than a specific transactional mechanism. The specification describes that the system allows earned credits to be used for consumption, which could support a broad reading covering various forms of value exchange. (’870 Patent, col. 2:59-64).
    • Evidence for a Narrower Interpretation: The detailed description discloses specific embodiments with distinct "Earned Balance" and "Cash Balance" accounts, governed by configurable rules such as whether earned balances are used "First," "Last," or "Never." (’870 Patent, col. 8:58-65). This detailed implementation could be used to argue that the term implies a structured accounting system with such defined rules, not merely any barter-like arrangement.

• The Term: "network resource" (’870 Patent, col. 21:34).

  • Context and Importance: The scope of infringing activities depends heavily on the definition of this term. A broad definition could extend the patent’s reach beyond internet access to other digital services.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent explicitly defines the term at the outset: "any service or facility that can be made available and accepted for use or delivery by digital transmission over a network... May include Internet or other network access, data storage and data processing, among others." (’870 Patent, col. 1:5-10). This express definition provides strong support for a broad construction.
    • Evidence for a Narrower Interpretation: The "BACKGROUND OF THE INVENTION" section focuses almost exclusively on the problem of roaming access for "wireless Network User Devices" via "Internet-connected, wireless Access Gateways." (’870 Patent, col. 2:48-56). An argument could be made that the context of the invention limits the scope of "network resource" to the types of connectivity services described as the solution to the stated problem.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner. (Compl. ¶¶ 14-15).
• Willful Infringement: The complaint does not use the term "willful." It alleges that the service of the complaint itself provides Defendant with "Actual Knowledge of Infringement," which may form a basis for seeking enhanced damages for any post-filing infringement. (Compl. ¶13). No allegations of pre-suit knowledge are made.

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

The complaint's lack of factual detail presents immediate procedural questions regarding its sufficiency. Assuming the case proceeds to the merits, the dispute will likely center on the following core issues for the court:

1. A primary question will be one of evidentiary sufficiency: what specific products or services are accused, and what factual evidence demonstrates that they perform the claimed method of creating, storing, and trading credits between distinct "user" and "gateway operator" accounts as required by the patent?
2. A central issue of claim construction will be one of definitional scope: does the claim phrase "credit... acts as credit," which underpins the patent's trading concept, require a direct, fungible accounting system as detailed in the patent's embodiments, or can it be construed more broadly to cover any system where providing a network resource generates a benefit that can be redeemed for network access elsewhere?