DCT

7:25-cv-00591

XR Communications LLC v. ARRIS Solutions LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00591, W.D. Tex., 12/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the district, specifically citing an office in Austin, and has committed acts of infringement in the district, including selling the accused products.
  • Core Dispute: Plaintiff alleges that Defendant’s Wi-Fi routers, access points, and related networking products infringe two patents related to directed wireless communication and signal coordination in multi-channel environments.
  • Technical Context: The dispute centers on advanced wireless networking technologies, specifically multi-user multiple-input, multiple-output (MU-MIMO) and beamforming, which are designed to improve the speed, range, and reliability of Wi-Fi networks by directing signals to specific users and managing interference.
  • Key Procedural History: The complaint alleges Defendant had pre-suit knowledge of the ’376 Patent based on citations made by its parent company, Commscope, during patent prosecution, as well as through due diligence conducted during Commscope’s 2019 acquisition of Arris. The complaint also references a prior case in the same district where Defendant allegedly admitted to maintaining an office in Austin.

Case Timeline

Date Event
2002-11-04 Earliest Priority Date Claimed by ’376 Patent and ’939 Patent
2012-10-16 ’939 Patent Issued
2019-01-03 Accused SURFboard mAX System Launch Date Mentioned
2019-04-04 Commscope Completes Acquisition of Arris
2020-03-17 ’376 Patent Issued
2025-12-24 Complaint Filing Date

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

U.S. Patent No. 10,594,376 - *"Directed Wireless Communication,"* issued March 17, 2020

The Invention Explained

  • Problem Addressed: The patent describes conventional wireless networks that use omni-directional antennas as having limitations in communication range, bandwidth, and susceptibility to electromagnetic interference and data corruption from signals taking multiple paths to a receiver (’376 Patent, col. 1:41-52).
  • The Patented Solution: The invention proposes a multi-beam directed signal system that coordinates wireless communication with multiple client devices. This system generates directed communication beams, transmits signals to client devices via these beams, receives feedback information from the devices regarding the beams, and modifies the beams based on this feedback (’376 Patent, Abstract). This allows the system to create transmission "peaks" of focused energy toward intended devices and "nulls" in other directions to reduce interference (’376 Patent, col. 6:1-10, 6:62-65).
  • Technical Importance: This approach of actively directing signals and adapting based on feedback was developed to overcome the inherent performance ceilings of omni-directional Wi-Fi systems, enabling greater range, higher data rates, and more reliable connections for multiple simultaneous users (Compl. ¶9).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶22).
  • Essential Elements of Claim 1:
    • A data-communications networking apparatus comprising a processor, a transceiver, and a smart antenna.
    • The processor is configured to generate a "probing signal" for transmission to at least a first and second client device.
    • The processor is also configured to generate first and second data streams for the respective client devices.
    • The transceiver is configured to transmit the probing signal via the smart antenna.
    • The processor, transceiver, or smart antenna is further configured to receive first and second "feedback information" from the respective client devices in response to the probing signal.
    • The apparatus is further configured to "determine where to place transmission peaks and transmission nulls" within spatially distributed patterns of electromagnetic signals based on the feedback.
    • The apparatus is further configured to transmit the first and second data streams to the respective client devices simultaneously, using the spatially distributed patterns to create a transmission peak at the location of each device.
  • The complaint reserves the right to assert claims 2-34 (Compl. ¶43).

U.S. Patent No. 8,289,939 - *"Signal Communication Coordination,"* issued October 16, 2012

The Invention Explained

  • Problem Addressed: The patent addresses inefficiencies and "packet collisions" that arise when multiple, co-located wireless access points (or multiple logical transceivers within a single device) operate simultaneously. A transmission from one access point can interfere with and corrupt a signal being received by another, especially if they are on the same or adjacent frequency channels (’939 Patent, col. 2:1-6).
  • The Patented Solution: The invention describes a "signal transmission/reception coordination logic" that monitors the activity of multiple access points. When the logic ascertains that one access point is receiving a signal, it is adapted to "restrain at least one other access point" from transmitting another signal to prevent interference (’939 Patent, Abstract). This coordination is managed by logic that can analyze receive indicators from multiple baseband units and issue instructions to the corresponding medium access controllers (MACs) (’939 Patent, col. 9:10-21).
  • Technical Importance: This coordination prevents signal "thrashing" and improves the overall performance and reliability of wireless networks in dense environments where multiple logical or physical transceivers operate in close proximity (Compl. ¶23).

Key Claims at a Glance

  • The complaint asserts at least independent claim 30 (Compl. ¶55).
  • The complaint does not provide a narrative breakdown of the infringement theory for the ’939 Patent but references a claim chart attached as Exhibit 3, which was not included with the complaint document (Compl. ¶56).
  • The complaint reserves the right to assert other claims (Compl. ¶61).

III. The Accused Instrumentality

Product Identification

The complaint identifies a broad range of Defendant's Wi-Fi networking products, including the SURFBoard mAX, SURFboard, and Touchstone series of routers, gateways, extenders, and cable modems that support MU-MIMO technology under the IEEE 802.11ac, 802.11ax (Wi-Fi 6), and Wi-Fi 7 standards (Compl. ¶¶22, 55). The Arris SURFboard mAX Plus W130 is used as an exemplary accused product for the ’376 Patent, and the G54 SURFboard DOCSIS 3.1 Wi-Fi 7 Cable Modem is identified for the ’939 Patent (Compl. ¶¶23, 55).

Functionality and Market Context

The accused products are alleged to be data-communications networking apparatuses that operate on IEEE 802.11ax or similar networks (Compl. ¶24). The complaint alleges these products incorporate advanced features like MU-MIMO and beamforming, which allow the devices to communicate with multiple client devices simultaneously (Compl. ¶23). The infringement allegations rely heavily on the products' compliance with the IEEE 802.11ax standard, which defines protocols for channel "sounding" (transmitting signals to probe the channel), receiving feedback from client devices, and using that feedback to create steered transmissions (Compl. ¶¶27, 29, 31). This functionality is marketed as providing "seamless coverage" and a "performance boost" for home Wi-Fi networks (Compl. ¶¶25, 27). The complaint includes a marketing image from Defendant's webpage illustrating a mesh Wi-Fi system providing coverage throughout a home (Compl. p. 10).

IV. Analysis of Infringement Allegations

’376 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a processor configured to: generate a probing signal for transmission to at least a first client device and a second client device... The accused product's processor (e.g., 1.8GHz Quad-core ARM) is configured to generate probing signals, such as NDP Announcement and HE sounding NDP frames, pursuant to the IEEE 802.11ax High Efficiency (HE) channel sounding protocol, to elicit responsive transmissions from multiple client devices. The complaint references a diagram from the IEEE standard showing an example of this sounding protocol with more than one device. ¶¶28, 29; p. 18, Fig. 26-7 col. 24:20-30
...receive a first feedback information from the first client device...and receive a second feedback information from the second client device... The accused product's processor and transceiver are configured to receive channel state information and MIMO-related feedback (e.g., HE Compressed Beamforming/CQI frames) from multiple client devices in response to the probing signal, as part of the HE MU-MIMO sounding procedures. ¶35 col. 24:53-59
...determine where to place transmission peaks and transmission nulls within one or more spatially distributed patterns of electromagnetic signals based in part on the first and the second feedback information; Based on the received feedback (channel state information), the accused product's processor determines a beamforming "steering matrix," which is used to configure spatially distributed patterns of signals with transmission peaks directed at client devices and nulls in other directions. ¶37 col. 24:60-66
transmit the first data stream...and transmit the second data stream...wherein transmission of the first data stream and transmission of at least part of the second data stream occur at the same time; The accused product is configured to perform simultaneous High Efficiency Downlink (HE DL) MU-MIMO transmissions, transmitting data streams to multiple client devices at the same time using the beamforming steering matrix. ¶38 col. 25:48-54
...wherein the one or more spatially distributed patterns of electromagnetic signals are configured to exhibit a first transmission peak at a location of the first client device and a second transmission peak at a location of the second client device. Through HE MU-MIMO beamforming, the radio energy is directed at each client device to form a transmission peak at its respective location, with a first space-time stream intended for the first client device and a second for the second client device. ¶¶38, 39 col. 26:1-5

’939 Patent Infringement Allegations

The complaint alleges that the accused Wi-Fi 7 products infringe at least claim 30 of the ’939 Patent and states that an exemplary claim chart comparison is provided in an attachment, Exhibit 3 (Compl. ¶56). However, Exhibit 3 was not included with the filed complaint. The body of the complaint does not provide a narrative summary of the infringement theory for the ’939 Patent sufficient for analysis.

Identified Points of Contention:

  • Scope Questions: A central question for the ’376 Patent may be whether the accused products' implementation of standardized IEEE 802.11ax protocols for calculating a "steering matrix" meets the claim language of "determin[ing] where to place transmission peaks and transmission nulls." The analysis may focus on whether calculating a matrix that results in peaks and nulls is the same as the claimed step of determining where to place them.
  • Technical Questions: For the ’376 Patent, a point of contention may arise regarding the evidence that the accused product's processor is specifically "configured to" perform the claimed steps, versus being a general-purpose processor that simply executes standard-compliant software. For the ’939 Patent, a threshold issue will be whether the complaint, lacking the referenced claim chart, pleads sufficient factual matter to state a plausible claim for infringement.

V. Key Claim Terms for Construction

  • The Term: "probing signal" (from ’376 Patent, Claim 1)

    • Context and Importance: The plaintiff’s infringement theory equates this term with standardized "sounding" frames (e.g., HE sounding NDP frames) used in the IEEE 802.11ax protocol (Compl. ¶29). The construction of this term will be critical to determining whether compliance with the standard is sufficient to meet this limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract describes generating "a plurality of sequences of symbols for transmission to a plurality of client devices" without imposing specific structural requirements on those sequences, which may support a broad definition covering various types of channel-sounding signals (’376 Patent, Abstract).
      • Evidence for a Narrower Interpretation: The detailed description discusses transmitting signals via "one or more beams focused toward the client devices" (’376 Patent, col. 2:13-14). A party could argue that the "probing signal" itself must be a focused beam, potentially narrowing the term's scope to exclude certain types of initial, less-directed sounding transmissions.

  • The Term: "determine where to place transmission peaks and transmission nulls" (from ’376 Patent, Claim 1)

    • Context and Importance: This term is the core of the beam-forming functionality. The plaintiff alleges that calculating a "beamforming steering matrix" as required by the 802.11ax standard satisfies this element (Compl. ¶37). Practitioners may focus on this term because the outcome could turn on whether "determining where to place" requires an explicit decision about spatial locations, rather than merely calculating a matrix of coefficients that has the effect of creating peaks and nulls.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification explains that the pattern formed by focused electromagnetic waves is termed a "beam pattern" and that this process results in "greater range and/or coverage" (’376 Patent, col. 6:40-48). This focus on the functional result could support an interpretation where any process that achieves this result, such as calculating a steering matrix, meets the claim limitation.
      • Evidence for a Narrower Interpretation: The claim uses the active phrase "determine where to place." A party might argue this implies a more direct and explicit act of selecting spatial locations or directions for peaks and nulls, pointing to specification language that the system is configured to "selectively place[] transmission nulls and/or peaks in certain directions" (’376 Patent, col. 6:63-65).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for both patents, asserting that Defendant provides user manuals and online instructions that encourage and instruct customers to use the accused MU-MIMO, beamforming, and Wi-Fi 7 functionalities in an infringing manner (Compl. ¶¶40, 58). Contributory infringement is also alleged on the basis that the accused products are not staple articles of commerce and are specially made for an infringing use (Compl. ¶¶41, 59).
  • Willful Infringement: The complaint alleges willful infringement of the ’376 Patent based on alleged pre-suit knowledge. This knowledge is asserted to arise from two sources: an earlier-filed complaint in the same district in June 2021, and knowledge imputed to Defendant through its parent company (Commscope), which allegedly cited the ’376 patent family during its own patent prosecutions and conducted intellectual property due diligence when acquiring Arris in April 2019 (Compl. ¶47). For the ’939 Patent, the complaint alleges Defendant’s infringement is "egregious" and "willful" based on its knowledge of the patent, though the basis for pre-suit knowledge is less specific than for the ’376 Patent (Compl. ¶¶66, 67).

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

  • A core issue will be one of definitional scope versus industry standards: Can the procedures mandated by the IEEE 802.11ax standard for channel sounding and calculating a "steering matrix" be read to meet the specific claim limitations of "generating a probing signal" and "determin[ing] where to place transmission peaks and transmission nulls" in the ’376 Patent, or is there a material difference between the standard's process and the patent's claims?
  • A key evidentiary question will be one of imputed knowledge: For the purposes of willfulness regarding the ’376 Patent, can Plaintiff establish that knowledge from a parent company’s patent prosecution activities and M&A due diligence can be legally imputed to a subsidiary, thereby constituting pre-suit notice of infringement?
  • A threshold procedural question will be one of pleading sufficiency: Does the complaint's reliance on a conclusory allegation and a reference to an unattached claim chart exhibit provide sufficient factual detail to state a plausible claim for infringement of the ’939 Patent under federal pleading standards?