Reframe Tech LLC v. Tesla Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Reframe Technologies LLC (NM)
  • Defendant: Tesla, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00258, W.D. Tex., 06/02/2025
• Venue Allegations: Venue is asserted based on Defendant having an established place of business in the district and having allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems for trading access to network resources.
• Technical Context: The technology concerns peer-to-peer or decentralized networks where users can exchange credits for access to resources like Wi-Fi, creating a broader roaming network than centralized providers offer.
• 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

Date	Event
2006-03-16	U.S. Patent No. 7,552,870 Priority Date (Filing)
2009-06-30	U.S. Patent No. 7,552,870 Issued
2025-06-02	Complaint Filed

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 addresses the problem of sparse geographical coverage from individual paid Wi-Fi hotspot providers in the mid-2000s. This limited coverage discouraged users from subscribing to services they could only use in a few locations, making it difficult for hotspot operators to generate revenue ('870 Patent, col. 2:2-17).
• The Patented Solution: The invention proposes a "Network Resource Trading System" where an owner of an "Access Gateway" (e.g., a home Wi-Fi router) can earn credits by providing network access to other users. These earned credits can then be used to pay for network access when that owner is "roaming" and needs to use a different Access Gateway elsewhere in the system ('870 Patent, Abstract; col. 2:21-28). The system is designed to create a large-scale, decentralized roaming network by enabling users to trade their underutilized home internet connections for access on the go, without traditional financial payment for each session ('870 Patent, col.4:1-7). Figure 1 illustrates the architecture, showing a Network User Device connecting to an Access Gateway, which communicates with a central "Trading System" to handle authorization and credit exchange ('870 Patent, Fig. 1).
• Technical Importance: The technology proposed a method to monetize and expand the utility of the millions of privately owned, Internet-connected wireless access points that were being deployed, transforming them from isolated private networks into a collaborative, trade-based roaming network ('870 Patent, col. 2:14-17).

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Independent Claim 1 (Method) Elements:
  • Storing data in "first type accounts" for a network resource user.
  • Storing data in "second type accounts" for a network resource access gateway operator.
  • Wherein credit on a second type account acts as credit on a first type account.
  • Receiving a request from a requestor to authorize provision of 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, where the decision is at least partially dependent on the balance of the identified first type account.
  • 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 refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name. It refers generally to "Exemplary Defendant Products" that are detailed in an incorporated Exhibit 2, which was not filed with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not describe the functionality of the accused products. It alleges in a conclusory manner that the unspecified "Exemplary Defendant Products practice the technology claimed by the '870 Patent" (Compl. ¶16). Given the defendant and the patent's subject matter, the allegations may relate to Tesla's vehicle connectivity and Supercharger networks. However, the complaint provides no specific facts to support this inference.

IV. Analysis of Infringement Allegations

The complaint references but does not include its "Exhibit 2," which purportedly contains "charts comparing the Exemplary '870 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16). The complaint alleges that these charts demonstrate that the accused products "satisfy all elements of the Exemplary '870 Patent Claims" (Compl. ¶16). Without this exhibit, the complaint's infringement theory is limited to the general assertion that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" products that practice the patented technology (Compl. ¶11). No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A primary question will be what specific feature in any Tesla product could be argued to perform the "trading" of network resources as claimed. The patent describes a system where an Access Gateway Operator earns credits for providing access, which are then spent by a Network User ('870 Patent, cl. 1). The complaint provides no evidence of such a credit-based, quid-pro-quo system in any Tesla product or service.
• Scope Questions: The case may turn on whether the entities involved in Tesla's ecosystem can be mapped to the claimed roles. For instance, it raises the question of who constitutes the "network resource access gateway operator" and the "network resource user" in the context of the accused products, and whether they maintain the distinct "first type" and "second type" accounts required by the claims ('870 Patent, cl. 1).

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a definitive analysis of claim construction disputes. However, based on the patent's subject matter, certain terms are likely to be central.

Term: "trading of network resources"

(from title; see also claim 1 preamble "authorizing usage and trading of network resources")

• Context and Importance: This term appears foundational to the invention's purpose. The infringement analysis will depend heavily on whether the functionality of the accused products constitutes "trading." Practitioners may focus on this term because the patent's specification consistently frames the invention as an exchange where credits are "earned" for providing a resource and "traded" for using a resource elsewhere ('870 Patent, col. 2:21-28, col. 14:44-56).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any system facilitating access to a network resource in exchange for some form of consideration (monetary or otherwise) falls within a plain and ordinary meaning of "trading."
  • Evidence for a Narrower Interpretation: The specification repeatedly describes a specific type of trade: "allowing credits earned for provision of access to Network Resources to be applied...to support authorization and settlement of charges" ('870 Patent, col. 2:61-64). This, along with the detailed description of "Earned Balance" and "Cash Balance" accounts ('870 Patent, col. 8:26-34), could support a narrower construction requiring a system of earned, stored, and spent credits, as opposed to a simple service-for-payment transaction.

Term: "network resource access gateway operator"

('870 Patent, cl. 1)

• Context and Importance: Claim 1 requires a "second type account" that represents an account of this "operator." Identifying which entity, if any, performs this role in the accused system is critical to infringement. The dispute may focus on whether this "operator" must be a distinct entity from the "user," and whether it must both provide and consume resources within the same trading ecosystem.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent defines the term broadly as "the operator of one or more Network Resource Access Gateways" ('870 Patent, col. 1:26-28). This could be argued to include large corporate entities that operate many gateways.
  • Evidence for a Narrower Interpretation: The abstract and background strongly imply that the system is designed for individuals who are "usually also Network User Device Users" to "trade usage of Network Resources (e.g. Internet access) via their Access Gateway for usage...via other Access Gateway Operators' Access Gateways" ('870 Patent, Abstract). This suggests the "operator" and "user" are often the same person acting in different capacities within a peer-to-peer system, a model that may not align with the functionality of the accused products.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The specific content of this literature is not detailed.
• Willful Infringement: The complaint bases its willfulness allegation on Defendant's continued infringement after gaining "actual knowledge" of the '870 Patent through the service of the complaint itself (Compl. ¶13-¶14).

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

1. A central issue will be one of definitional scope: can the patent’s concept of "trading network resources," which is described as a system for earning and spending credits between users and gateway operators, be construed to cover the architecture and payment model of the accused (but unspecified) Tesla products and services?
2. A key evidentiary question will be one of technical and factual mapping: can Plaintiff demonstrate that the accused system actually contains the specific components and performs the specific steps required by the asserted claims, including the maintenance of distinct "first type" (user) and "second type" (operator) accounts and the adjustment of their balances based on resource usage? The complaint's lack of specificity on this point suggests it will be a primary focus of discovery and litigation.