E Beacon LLC v. Sonim Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Sonim Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00345, W.D. Tex., 08/08/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that certain of Defendant’s products infringe a patent related to determining and transmitting the physical location of a Voice over IP (VoIP) phone during an emergency call.
• Technical Context: The technology addresses the public safety challenge of locating VoIP users, who are not tied to a fixed physical address, when they dial emergency services.
• Key Procedural History: The asserted patent is subject to a terminal disclaimer, which may limit the patent's effective term. The patent claims priority to a 2005 provisional application through a 2006 parent application, which could be significant for assessing prior art. The complaint alleges knowledge for inducement and willfulness only as of the date the complaint was served.

Case Timeline

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

U.S. Patent No. 8,515,386, “Emergency services for voice over IP telephony (E-VoIP),” issued August 20, 2013

The Invention Explained

• Problem Addressed: The patent identifies a key limitation in VoIP telephony: unlike traditional landlines, VoIP phones can be used anywhere with an internet connection, making it difficult for emergency services to automatically identify a caller's true physical location. A pre-registered address may be incorrect if the user is traveling, potentially dispatching responders to the wrong place. (’386 Patent, col. 1:24-44).
• The Patented Solution: The invention is a system that equips a VoIP device with location-finding capabilities, such as GPS or cellular network triangulation. (’386 Patent, col. 2:37-44). When an emergency number is dialed, the system determines the device’s current physical coordinates and automatically transmits this location data to the emergency call center (also known as a Public Safety Answering Point, or PSAP), ensuring responders are sent to the correct location. (’386 Patent, Abstract; col. 2:46-56). The system is designed to use multiple different location detection technologies (LDTs) to enhance reliability. (’386 Patent, col. 7:51-66).
• Technical Importance: This technology aims to provide mobile VoIP users with the same level of automatic location identification during emergencies that is standard for fixed-line and cellular phones. (’386 Patent, col. 1:16-28).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," referring to them as the "Exemplary '386 Patent Claims," without specifying particular claim numbers (Compl. ¶11). Independent claim 1 is representative of the core method.
• Independent Claim 1: A method comprising the steps of:
  • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT")
  • if an attempt is successful, storing the physical location determined using the corresponding LDT
  • placing a call to the emergency services call center with the VoIP phone
  • automatically transmitting the physical location of the VoIP phone to the emergency services call center
• The complaint does not explicitly reserve the right to assert dependent claims, but its general allegation of infringing "one or more claims" leaves this possibility open (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products, referring to them generally as the "Exemplary Defendant Products" (Compl. ¶11). It states these products are identified in an attached Exhibit 2, which was not filed with the public complaint (Compl. ¶16).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '386 Patent" (Compl. ¶16). Based on these allegations, the accused functionality involves determining the physical location of a device and providing that location data during an emergency call. The complaint does not provide further technical detail about how the accused products operate or any information regarding their market position.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement by Defendant's making, using, selling, and testing of the accused products (Compl. ¶¶11-12). It states that detailed infringement allegations are contained in claim charts in Exhibit 2, which is incorporated by reference but was not included with the complaint (Compl. ¶¶16-17). The complaint's main body does not contain a narrative explanation of how the accused products meet the limitations of any specific claim.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Technical Questions: A central question will be whether the accused products, in fact, perform the steps recited in the asserted claims. For example, regarding claim 1, discovery will be needed to determine if the products make "a plurality of attempts" using "separate" location technologies (e.g., GPS and cellular triangulation) to find their location for an emergency call, and whether they "automatically" transmit that location data to an emergency call center.
• Scope Questions: The dispute may turn on the scope of claim terms. For instance, the parties may contest what qualifies as a "separate location detection technology ('LDT')." The interpretation of this term will define whether a device using a single, hybrid location method (like Assisted GPS, which uses cellular data to improve GPS performance) infringes a claim requiring a "plurality" of separate technologies.

V. Key Claim Terms for Construction

The Term: "a plurality of attempts ... each using a separate location detection technology ('LDT')" (from Claim 1)

Context and Importance

This limitation is at the heart of the invention's purported novelty and reliability. The infringement analysis for claim 1 will hinge on whether the accused products are found to use at least two distinct LDTs. Practitioners may focus on this term because its definition controls the factual predicate for infringement.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification lists a wide variety of technologies that can provide location data, including "GPS, CDMA and GSM technologies," "Assisted Global Positioning System ('A-GPS'), other Cellular systems, Wi-Fi, WiMAX, and other such technologies." (’386 Patent, col. 7:62-66). Plaintiff may argue this broad list indicates that any two of these should be considered "separate."
• Evidence for a Narrower Interpretation: Defendant may argue that some technologies are merely variations of one another and not "separate." The patent's own language sometimes groups technologies, such as "GPS or cellular technology" (’386 Patent, col. 2:37-38), which could be used to argue that these represent distinct categories, and that technologies within a single category (e.g., different types of cellular triangulation) are not "separate" from each other.

The Term: "automatically transmitting the physical location" (from Claim 1)

Context and Importance

This term defines how the location information must be communicated. The case may depend on whether the accused device's method of sending location data (e.g., via an IP data packet, SMS, or another channel) falls within the scope of "automatically transmitting."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: Plaintiff could argue the term simply means the transmission occurs without requiring additional user action after the emergency call is initiated, a process generally described in the patent's flow charts (e.g., ’386 Patent, Fig. 1, steps 16-17).
• Evidence for a Narrower Interpretation: Defendant could point to more specific descriptions in the specification, such as the transmission of a "High Priority packet" using a "Quality of Service (QoS) protocol," to argue for a narrower construction that excludes other transmission methods. (’386 Patent, col. 4:62-65).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that since being served with the complaint, Defendant has knowingly encouraged infringement by distributing "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's allegation of knowledge is based exclusively on the service of the complaint itself (Compl. ¶13). It does not allege any pre-suit knowledge by the Defendant. This frames the willfulness claim as being based entirely on alleged post-filing conduct.

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

1. An Evidentiary Question of Technical Operation: Can the Plaintiff, through discovery, produce evidence demonstrating that Defendant’s products actually perform the specific multi-step method of the asserted claims? The complaint's lack of factual detail places the entire burden of proof on evidence yet to be uncovered regarding the accused products' internal workings.
2. A Definitional Question of Claim Scope: How will the court construe the term "separate location detection technology ('LDT')"? The outcome of this construction will be dispositive for claim 1, as it will determine whether using a single hybrid location service can meet the "plurality" requirement, or if two technologically distinct systems must be proven.
3. A Culpability Question of Willfulness: By limiting the knowledge allegation to the date of service of the complaint, the case raises the question of whether Defendant’s continuation of its business post-suit, if found to be infringing, constitutes the type of "egregious" conduct necessary to support a finding of willfulness and justify enhanced damages.