WebSock Global Strategies LLC v. Box Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WebSock Global Strategies LLC (Delaware)
  • Defendant: Box, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00338, W.D. Tex., 08/04/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district and having committed alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services infringe a patent related to methods for achieving symmetrical, bi-directional communication over traditionally asymmetric network protocols like HTTP.
• Technical Context: The technology at issue addresses limitations in the standard client-server model of internet communication, particularly for enabling peer-to-peer interactions between devices that may be separated by firewalls or Network Address Translation (NAT).
• Key Procedural History: The patent-in-suit is a continuation of an earlier application that issued as U.S. Patent No. 7,403,995. The patent-in-suit is also subject to a terminal disclaimer, which may limit its enforceable term to that of the parent patent.

Case Timeline

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

U.S. Patent No. 7,756,983 - "Symmetrical bi-directional communication"

• Patent Identification: U.S. Patent No. 7,756,983, "Symmetrical bi-directional communication", issued July 13, 2010.

The Invention Explained

• Problem Addressed: The patent describes a "fundamental problem" in network communications where protocols like HTTP enforce rigid, asymmetric roles: a "client" initiates requests and a "server" responds ('983 Patent, col. 2:6-12). This structure prevents a server from spontaneously initiating contact with a client, which hinders peer-to-peer applications, especially when a device is on a private network behind a Network Address Translator (NAT) ('983 Patent, col. 2:41-52).
• The Patented Solution: The invention discloses a method to create symmetrical communication over an asymmetric protocol. Two nodes first establish a standard client-server session. They then "negotiate transactional role reversal," which involves terminating the initial application-layer (HTTP) session while preserving the underlying transport-layer (TCP/IP) network connection ('983 Patent, Abstract; col. 5:21-32). A new, "flipped" HTTP session is then created over the preserved connection, allowing the original server to now act as a client and initiate requests to the original client, which now acts as a server ('983 Patent, Fig. 9, steps 512-514).
• Technical Importance: This technique was designed to enable true peer-to-peer communication using the ubiquitous HTTP protocol, effectively bypassing the protocol's inherent asymmetries and the connectivity barriers posed by common network architectures ('983 Patent, col. 3:20-24).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including "exemplary method claims," but does not specify any particular claims in its text (Compl. ¶11). The analysis below is based on Independent Claim 1, a representative method claim.
• Independent Claim 1: The essential elements of this method claim include:
  • First and second network nodes engaging in an initial asymmetric HTTP transactional session over an underlying network connection, with each node having a distinct role (client or server).
  • Terminating the asymmetric HTTP session while maintaining the underlying network connection.
  • The two nodes negotiating a "transactional role reversal."
  • The nodes further communicating under a "reversed asymmetric transactional protocol" where each node enacts the initial role of the other.
  • The session utilizing a network connection that traverses hardware enforcing asymmetric communication.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products or services by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in charts within an "Exhibit 2" (Compl. ¶11, 13). This exhibit was not provided with the complaint.

Functionality and Market Context

• The complaint alleges that the unspecified "Exemplary Defendant Products" practice the technology claimed in the '983 Patent (Compl. ¶13). It further alleges that Defendant infringes by making, using, selling, and importing these products, as well as by having its employees internally test and use them (Compl. ¶11-12). The complaint provides no specific details regarding the technical functionality or market context of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement through claim charts contained in an Exhibit 2, which is incorporated by reference but was not provided (Compl. ¶13-14). As the charts are unavailable, the infringement theory is summarized below in prose.

The complaint asserts that Defendant’s "Exemplary Defendant Products" directly infringe one or more claims of the '983 Patent, either literally or under the doctrine of equivalents (Compl. ¶11). The core of the allegation is that these products "practice the technology claimed by the '983 Patent" and that they "satisfy all elements of the Exemplary '983 Patent Claims" (Compl. ¶13). Without the specific product details or the claim charts, it is not possible to analyze the mapping of accused functionality to specific claim elements.

• Identified Points of Contention: Based on the patent and the general nature of the allegations, the dispute may focus on several key areas:
  • Scope Questions: A central question may be whether the accused products' communication protocol can be characterized as "negotiating transactional role reversal." The interpretation of this phrase will be critical.
  • Technical Questions: A key factual question will be whether the accused products actually perform the claimed sequence of terminating an application-layer (HTTP) session while explicitly maintaining and reusing the underlying transport-layer (TCP) connection for a reversed-role session. The Plaintiff will need to provide evidence that the accused systems operate in this specific manner, as opposed to using other methods for bi-directional data exchange, such as polling or establishing separate, parallel connections.

V. Key Claim Terms for Construction

• The Term: "negotiating transactional role reversal" (from Claim 1)

  • Context and Importance: This term appears to be the central inventive concept. Its construction will determine the specific actions a product must perform to infringe. Practitioners may focus on this term because the outcome of the case could depend on whether the accused product's communication protocol is found to meet this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes the concept in general terms, suggesting that the goal is to enable symmetrical communication ('983 Patent, col. 3:18-24). A party might argue that any message exchange between two nodes that results in a reversal of their client-server roles for subsequent communications falls within the scope of "negotiating."
    • Evidence for a Narrower Interpretation: The detailed description and flowcharts provide a specific embodiment of this step as sending an "HTTP FLIP request" from one node and receiving an acceptance from the other ('983 Patent, col. 10:61-63; Fig. 9, step 504; Fig. 10, step 534). A party could argue that the term requires an explicit request-and-acceptance sequence designed for the purpose of reversing roles.

• The Term: "terminating said asymmetric HTTP transactional session while maintaining said underlying network connection" (from Claim 1)

  • Context and Importance: This element distinguishes the claimed method from simply opening two independent connections. Infringement requires proof that the original transport-layer connection (e.g., a TCP socket) is kept alive and reused after the initial application-layer session ends.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that the term is met so long as the TCP/IP circuit remains logically open and available for a new HTTP session, regardless of the specific mechanism used to terminate the first session.
    • Evidence for a Narrower Interpretation: The flowcharts show an explicit sequence of extracting and saving the "raw TCP circuit information," terminating the HTTP session, and then creating a new HTTP session "using the preserved TCP circuit information" ('983 Patent, Fig. 9, steps 508, 510, 512, 514). A party could argue this requires an affirmative software process of preserving and referencing the specific circuit data for reuse.

VI. Other Allegations

• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. However, the prayer for relief requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees (Compl. p. 4, ¶E.i). Such a request is often predicated on allegations of willful infringement or other litigation misconduct. The complaint does not allege any facts to support pre-suit knowledge by the Defendant.

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

Given the limited detail in the complaint, the case will likely turn on the resolution of two fundamental questions:

1. A core issue will be one of evidentiary sufficiency: As the complaint provides no specific technical details about the accused products, a primary challenge for the Plaintiff will be to produce evidence demonstrating that the Defendant's systems perform the specific, multi-step process recited in the claims—namely, the negotiation of a role reversal followed by the termination of an HTTP session and the subsequent reuse of the preserved underlying network connection.

2. A second key issue will be one of definitional scope: The case will likely hinge on the court's construction of the term "negotiating transactional role reversal." The central question for the court will be whether this term requires an explicit, formalized "flip" command as described in the patent's embodiments, or if it can be construed more broadly to cover any protocol behavior that results in a de facto reversal of client-server communication roles.