Mobility Workx LLC v. Oracle Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobility Workx, LLC (Florida)
  • Defendant: Oracle Corporation and Oracle America, Inc. (Delaware)
  • Plaintiff’s Counsel: Zeisler PLLC
• Case Identification: 7:26-cv-00031, W.D. Tex., 01/29/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that certain of Defendant’s products and services infringe three patents related to proactive management of mobile device handoffs in wireless networks and the emulation of mobile network environments.
• Technical Context: The patents address technologies for improving the reliability of wireless communications for mobile users and for creating realistic testbeds to evaluate the performance of mobile networking protocols.
• Key Procedural History: U.S. Patent No. 8,213,417 was subject to an Inter Partes Review (IPR) proceeding, which concluded with asserted claims 3 and 6 being found patentable and remaining valid and enforceable.

Case Timeline

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

U.S. Patent No. 7,697,508 - "System, Apparatus, and Methods for Proactive Allocation of Wireless Communication Resources"

The Invention Explained

• Problem Addressed: The patent describes the problem of "registration delays and associated information losses" that occur when a mobile device moves from the coverage area of one wireless access point to another '508 Patent, col. 2:19-21 This handoff process can be slow, causing dropped data packets, especially for devices moving at high speeds '508 Patent, col. 2:47-54
• The Patented Solution: The invention proposes a "preemptive and predictive" system using "ghost entities" to make handoffs seamless '508 Patent, col. 2:36-37 A "ghost-mobile node," which is a virtual representation of the actual mobile device, predicts the device's future location and pre-registers with the next wireless access point (a "foreign agent") before the device physically arrives '508 Patent, col. 2:57-63 Concurrently, a "ghost-foreign agent" advertises the upcoming access point to the mobile device, making it aware of the next connection point in advance '508 Patent, col. 3:1-7; Fig. 2A This proactive resource allocation is intended to eliminate handoff delays.
• Technical Importance: This predictive approach was designed to enhance the performance of wireless communications for highly mobile users, a critical factor for maintaining reliable connections in applications like vehicle-based internet access or cellular data.

Key Claims at a Glance

• The complaint asserts at least independent claims 7 and 14 Compl. ¶13
• Independent claim 7 recites a "wireless node pair" comprising:
  • A mobile node with a current geographical state and one or more predicted future geographical states.
  • A "ghost mobile node" associated with the mobile node, which can announce its presence to a "foreign agent" (access point) to signal the agent based on the predicted future states.
  • The ghost mobile node is configured to predict the future state based on Global Positioning System (GPS) data.
• The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 7,231,330 - "Rapid Mobility Network Emulator Method and System"

The Invention Explained

• Problem Addressed: The patent background identifies shortcomings in tools for testing mobile networks. It states that software-based simulators can be slow and produce "misleading, if not erroneous results," while existing hardware-based "wire-line emulators" fail to account for the unique characteristics of wireless mobility and signal propagation '330 Patent, col. 1:49-55, col. 2:11-16
• The Patented Solution: The patent discloses a hybrid emulation system that uses actual hardware wireless nodes (e.g., access points) but simulates the movement of a mobile device '330 Patent, Fig. 1 A central controller simulates motion by "dynamically adjusting the signal reception sensitivity and signal transmission strength" of the fixed wireless nodes, for instance by using variable attenuators '330 Patent, col. 2:27-29, col. 4:55-61 This allows researchers to test how mobile network protocols behave under realistic, repeatable motion scenarios without the mobile device physically moving.
• Technical Importance: The invention provides a method for more efficient and realistic testing of mobile network performance, bridging the gap between slow, abstract software simulations and complex, real-world field testing.

Key Claims at a Glance

• The complaint asserts at least claims 1-19 Compl. ¶29
• Independent claim 1 recites a system for emulating mobile network communications, comprising:
  • A plurality of fixedly-located wireless network nodes configured to variably adjust wireless communication characteristics.
  • At least one mobile node configured to communicate with the wireless nodes.
  • A network emulator linked to the wireless nodes to emulate a wired network's attributes.
  • A controller linked to the wireless nodes, configured to control their wireless communication characteristics to simulate the conditions a mobile node would experience in actual operation.
• The complaint does not explicitly reserve the right to assert other dependent claims beyond claim 19.

U.S. Patent No. 8,213,417 - "System, Apparatus, and Methods for Proactive Allocation of Wireless Communication Resources"

Technology Synopsis

As a continuation of the application leading to the ’508 Patent, this patent addresses the same technical field of proactively managing wireless handoffs '417 Patent, col. 1:8-14 It similarly describes a system using "ghost" entities to predict a mobile node's movement and pre-allocate network resources to reduce latency and prevent data loss during the transition between wireless access points '417 Patent, col. 4:8-18

Asserted Claims

At least claims 3 and 6 Compl. ¶23

Accused Features

The complaint alleges infringement by "Accused Handover Products/Services" but does not identify features distinct from those accused of infringing the ’508 Patent Compl. ¶23

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific Oracle products or services by name. It refers to the accused instrumentalities in generic terms as "Accused Handover Products/Services" and "Accused Emulation Products/Services" Compl. ¶¶13, 29

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentalities' specific functionalities or technical operations. It alleges that Defendant offers for sale, sells, and imports these products and services through its website, Defendant's website Compl. ¶7 No allegations regarding the products' specific commercial importance or market positioning are made beyond the general assertion that Defendant derives substantial revenue from them Compl. ¶9

IV. Analysis of Infringement Allegations

The complaint’s theories of infringement for the ’508, ’417, and ’330 patents are detailed in preliminary infringement claim charts attached as Exhibits 2, 4, and 6, respectively Compl. ¶¶13, 24, 29-30 As these exhibits were not provided with the complaint, and the complaint offers no corresponding narrative description of the alleged infringement, a detailed claim-based analysis is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the asserted patent claims and the generic categories of accused products, the infringement analysis raises several high-level questions for the court.

• Architectural Questions (’508 and ’417 Patents): A central dispute may concern whether Defendant's "Handover Products/Services" implement the specific architecture required by the claims. This raises the questions of whether the accused products utilize a "ghost mobile node" to predict a device's future geographical state using data sources like GPS and whether they employ a "ghost-foreign agent" to proactively advertise upcoming access points.
• Functional Questions (’330 Patent): The key technical question for the ’330 Patent will be one of operational methodology. The analysis will need to determine if Defendant's "Emulation Products/Services" operate by controlling "wireless communication characteristics" (such as signal strength and sensitivity) of fixed hardware access points to "simulate" device mobility, as claimed, or if they achieve emulation through an alternative, non-infringing mechanism such as pure software simulation.

V. Key Claim Terms for Construction

’508 Patent

• The Term: "ghost mobile node" (claim 7)
• Context and Importance: This term, which appears to be a neologism coined by the inventors, is foundational to the claimed predictive handoff system. The definition of this term will be critical to determining whether a software agent, process, or other component within Defendant’s accused system meets this claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the ghost-mobile node as a "virtual node" that "can be set of software instructions running on a device that is remote from the mobile node" '508 Patent, col. 6:20-25 This language may support a construction that encompasses a wide range of software components that manage mobility.
  • Evidence for a Narrower Interpretation: The claim language itself requires that the "ghost mobile node" be "configured to predict the future state based upon Global Positioning System (GPS) data" '508 Patent, claim 7 This explicit link to a specific data source (GPS) and predictive function could support a narrower construction limited to systems that perform this exact operation.

’330 Patent

• The Term: "control the wireless communication characteristics ... to simulate ... different wireless communication conditions experienced by said at least one mobile node in actual operation" (claim 1)
• Context and Importance: This phrase describes the core function of the claimed controller, which distinguishes the invention from prior art software simulators. Practitioners may focus on this term because the infringement analysis will likely turn on whether Defendant's accused emulation products achieve simulation by the specific means recited in the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The phrase "wireless communication characteristics" is not explicitly defined and could be argued to cover a range of parameters beyond just signal strength, potentially broadening the claim's scope.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the patented solution as "dynamically adjusting the signal reception sensitivity and signal transmission strength of each wireless node" using components like "variable attenuators" '330 Patent, col. 2:27-29, col. 4:20-21 This detailed description of a specific physical-layer mechanism may support a narrower construction that limits the claim to emulators that manipulate signal power and sensitivity.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced and contributory infringement for the ’508 Patent. The inducement allegation is based on claims that Defendant "actively encourage[s] users" to use the accused products in an infringing manner Compl. ¶14 The contributory infringement allegation states that the accused products "have no substantial non-infringing uses" Compl. ¶16 The complaint does not provide a specific factual basis for these allegations.

Willful Infringement

Willfulness is alleged for the ’508 Patent, based on Defendant’s alleged knowledge of the patent "Prior to, or at least through, the filing and service of this complaint" Compl. ¶14, ¶17 No facts are alleged to support pre-suit knowledge. The complaint also seeks a finding that the case is exceptional as to all three patents-in-suit, which could entitle Plaintiff to enhanced damages and attorneys' fees Compl. ¶¶20, 26, 32

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

• A core issue will be one of architectural congruence: Can Plaintiff provide evidence that Defendant's accused "Handover" products embody the specific "ghost mobile node" and "ghost-foreign agent" architecture for predictive handoffs recited in the ’508 and ’417 patents, or do they utilize a fundamentally different technical framework for managing mobility?
• A key technical question will be one of functional methodology: Does Defendant's accused "Emulation" product operate by controlling physical-layer "wireless communication characteristics" of fixed access points to simulate device motion, as required by the ’330 patent, or does it achieve network emulation through a distinct, purely software-based approach?
• A foundational evidentiary question is one of specificity: Given the complaint's complete reliance on un-provided claim charts and generic product descriptions, a threshold issue for the court will be whether the Plaintiff can substantiate its bare allegations with concrete evidence mapping the actual functionality of specific Oracle products to the detailed limitations of the asserted claims.