E Beacon LLC v. IonIdea Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (DE)
  • Defendant: Ionidea Inc. (VA)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-00650, E.D. Va., 04/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed alleged acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to providing emergency location services for Voice over IP (VoIP) telephone systems.
• Technical Context: The technology addresses the challenge of automatically providing a 9-1-1 operator with the accurate physical location of a mobile VoIP user, a critical function not inherent to internet-based telephony.
• Key Procedural History: The patent-in-suit was issued subject to a terminal disclaimer over a parent patent, now U.S. Patent No. 7,933,580. This may limit the enforceable term of the patent-in-suit to that of the parent patent and could be relevant to any damages calculation.

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 public safety problem with VoIP telephone systems: unlike traditional landlines, a VoIP phone is not tied to a fixed physical address. When a user dials 9-1-1 from a VoIP phone, especially from a location other than their primary registered address, emergency services cannot automatically determine the caller's location. ('386 Patent, col. 1:24-44).
• The Patented Solution: The invention describes a method and system that, upon an emergency call being placed, uses multiple location detection technologies (LDTs)—such as GPS or cellular network triangulation—to determine the VoIP phone's current physical coordinates. This location information is then automatically transmitted to the emergency call center, enabling dispatchers to locate the caller even if the caller is unable to state their location. ('386 Patent, Abstract; col. 2:36-44). The system is designed to periodically attempt to find its location and store the most recent coordinates for use if a live determination fails. ('386 Patent, col. 2:53-59).
• Technical Importance: The described technology aims to provide VoIP users with the same level of E-911 reliability and automatic location identification that is standard for traditional and cellular telephone services. ('386 Patent, col. 1:11-14).

Key Claims at a Glance

• The complaint alleges infringement of one or more claims, referring to them as the "Exemplary '386 Patent Claims," but does not identify any specific claims. (Compl. ¶11).
• For illustrative purposes, independent claim 1 is central to the patent and requires:
  • A method for determining the physical location of a VoIP phone and transmitting it to an emergency services call center.
  • Making a plurality of attempts to determine the phone's physical location.
  • Each attempt uses a separate location detection technology ("LDT").
  • If an attempt is successful, storing the determined physical location.
  • Placing a call to the emergency services call center with the VoIP phone.
  • Automatically transmitting the stored physical location to the emergency services call center.
• The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any accused products. It refers to them as "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2. (Compl. ¶11, ¶16). This exhibit was not provided with the complaint.

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '386 Patent." (Compl. ¶16). Based on this allegation, the accused functionality involves systems or methods for providing location information for emergency calls made from VoIP devices.
• The complaint does not provide sufficient detail for analysis of the accused products' market context or commercial importance.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts (Exhibit 2), which were not provided. (Compl. ¶16, ¶17). The core of the infringement allegation, in narrative form, is that the "Exemplary Defendant Products" practice the patented technology and satisfy all elements of the asserted claims. (Compl. ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

• Factual Questions: Given the lack of detail, a primary factual question will be what the "Exemplary Defendant Products" are and how they technically operate. The Plaintiff will need to provide evidence showing that the accused products actually perform location detection using multiple, separate technologies as claimed.
• Scope Questions: A likely point of contention will surround the claim requirement of using "separate location detection technology" for a "plurality of attempts." (e.g., ’386 Patent, col. 15:25-30). The dispute may focus on whether the accused products' location-finding methods constitute distinct "technologies" under the patent's definition, or merely different modes of a single underlying technology.

V. Key Claim Terms for Construction

• The Term: "location detection technology ('LDT')" (e.g., Claim 1)
• Context and Importance: This term is the technological heart of the asserted claims. The definition of what constitutes a "separate" LDT will be critical to determining infringement. Practitioners may focus on this term because the infringement analysis depends entirely on whether the accused products are found to use more than one distinct LDT.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad, non-exhaustive list of examples, stating that LDTs "include geolocation, location based service (LBS), GSM localization, triangulation," and that in addition to GPS, CDMA, and GSM, location data can be obtained from "A-GPS, other Cellular systems, Wi-Fi, WiMAX, and other such technologies." ('386 Patent, col. 7:56-65). This language may support an interpretation that encompasses a wide range of current and future location-finding methods.
  • Evidence for a Narrower Interpretation: The patent frequently discusses GPS and cellular networks as distinct examples. ('386 Patent, col. 2:48-52). A party could argue that for two LDTs to be "separate," they must rely on fundamentally different infrastructures (e.g., satellite vs. terrestrial tower vs. local area network), not just different software-based techniques that utilize the same hardware or network.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement based on post-suit conduct. It claims that after being served with the complaint, Defendant "actively, knowingly, and intentionally continued to induce infringement" by selling the accused products and distributing "product literature and website materials" that instruct customers on how to use the products in an infringing manner. (Compl. ¶14, ¶15).

Willful Infringement

• The complaint does not use the term "willful." However, it alleges that service of the complaint constitutes "Actual Knowledge of Infringement" and that Defendant's continued infringement is despite this knowledge. (Compl. ¶13, ¶14). Plaintiff also requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is the statutory basis for awarding attorney's fees, often in cases of willful infringement or other litigation misconduct. (Compl., Prayer for Relief ¶i).

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

1. A Threshold Procedural Question: A threshold issue may be the sufficiency of the complaint itself. Will the court find that alleging infringement by incorporating an unprovided exhibit, without naming any specific products or detailing the infringing functionality in the body of the complaint, meets federal pleading standards?

2. A Core Definitional Question: The case will likely turn on a question of claim scope: how will the court construe the term "separate location detection technology ('LDT')"? The patent’s broad list of examples will be weighed against arguments for a more functionally distinct definition, and this construction will likely be dispositive for infringement.

3. A Key Evidentiary Question: Assuming the case proceeds, a central question will be one of technical proof: what evidence will Plaintiff present to demonstrate that Defendant's unspecified products practice the specific, multi-step method of the claims, particularly the requirement to make a "plurality of attempts" using what are determined to be "separate" LDTs?