E Beacon LLC v. FrontPoint Security Solutions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (DE)
  • Defendant: FrontPoint Security Solutions, LLC (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-00719, E.D. Va., 04/26/2025
• Venue Allegations: Venue is alleged to be proper because Defendant maintains 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 security products, which incorporate Voice over IP (VoIP) telephony, infringe a patent related to providing emergency services for VoIP users by determining and transmitting their physical location.
• Technical Context: The technology addresses the challenge of locating nomadic VoIP users for 911 emergency services, a critical public safety issue that arose with the shift from fixed-location landlines to internet-based calling.
• Key Procedural History: The asserted patent is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent. The complaint does not identify any prior litigation or other proceedings involving the patent-in-suit.

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)"

• Patent Identification: 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’s background section describes the unreliability of traditional 911 services for VoIP phone users (Compl. ¶9; ’386 Patent, col. 1:24-34). Unlike traditional landlines with fixed addresses, a VoIP phone can be used anywhere with an internet connection, making it difficult for emergency dispatchers to determine the caller's actual physical location during an emergency (Compl. ¶9; ’386 Patent, col. 1:24-34).
• The Patented Solution: The invention is a method and system that uses "multiple location detection technologies" (LDTs), such as GPS or cellular triangulation, to determine a VoIP device's current physical coordinates ('386 Patent, Abstract; col. 7:52-56). When a user dials an emergency number, the system automatically transmits this location data to the emergency call center (Public Safety Answering Point or "PSAP"), ensuring dispatchers know where to send help even if the caller cannot speak or does not know their location ('386 Patent, col. 2:39-44). The system is designed to periodically attempt to find its location and can use multiple network types (e.g., VoIP, cellular) as a fallback to ensure the emergency call connects ('386 Patent, Fig. 1).
• Technical Importance: The described technology provides a solution for a critical regulatory and public safety gap known as E911 (Enhanced 911) for nomadic VoIP services, which traditional systems were not equipped to handle ('386 Patent, col. 1:11-13).

Key Claims at a Glance

• The complaint does not identify specific claims, instead referencing "one or more claims" and "exemplary claims" identified in an external exhibit (Compl. ¶11). Independent claim 1 is representative of the invention's core method.
• Independent Claim 1 Elements:
  • 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 physical location of the VoIP phone, with each attempt using 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 physical location of the VoIP phone to the emergency services call center.
• The complaint does not explicitly reserve the right to assert other claims, but its general reference to "one or more claims" leaves this possibility open (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint refers generally to "Exemplary Defendant Products" identified in an attached exhibit but does not name any specific products or services in the body of the complaint (Compl. ¶11). It also references "FrontPoint Security Solutions, LLC" products more broadly (Compl. ¶1).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It alleges that the "Exemplary Defendant Products practice the technology claimed by the '386 Patent" but offers no description of how they operate, their technical features, or their market positioning, relying instead on an incorporated exhibit that was not provided with the complaint itself (Compl. ¶16-17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or a narrative description of the infringement theory, instead incorporating by reference "charts comparing the Exemplary '386 Patent Claims to the Exemplary Defendant Products" contained in Exhibit 2 (Compl. ¶16). As Exhibit 2 was not provided, a detailed analysis of the infringement allegations is not possible.

The core of the infringement theory, as can be inferred from the general allegations, is that Defendant’s products and services for home security, which may include VoIP-based communication features for emergency monitoring, perform a method of locating the user's device and transmitting that location to an emergency service, thereby practicing the method claimed in the ’386 Patent (Compl. ¶11, ¶16). The viability of this theory will depend entirely on the specific functionality of the accused products, details for which are not present in the complaint.

V. Key Claim Terms for Construction

The following analysis is based on a representative independent claim (Claim 1) as the complaint does not specify asserted claims.

• The Term: "a separate location detection technology ("LDT")"
• Context and Importance: This term is central to the scope of infringement. The claim requires making a "plurality of attempts" using "separate" LDTs. An infringement finding may hinge on whether the accused system uses at least two distinct technologies (e.g., GPS and Wi-Fi triangulation) or merely uses a single technology multiple times. Practitioners may focus on this term because it appears to be a point of novelty and a key limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification lists a wide array of potential LDTs, including "geolocation, location based service (LBS), GSM localization, triangulation, automatic location information (ALI) database correlation, coordinate information and other systems," as well as "A-GPS..., other Cellular systems, Wi-Fi, WiMAX, and other such technologies" ('386 Patent, col. 7:57-67). A party might argue that any two distinct methods from this list, even if related (e.g., two different types of cellular triangulation), qualify as "separate."
  • Evidence for a Narrower Interpretation: A party could argue that "separate" implies technologies that operate on fundamentally different principles (e.g., satellite-based vs. network-based). The patent’s repeated pairing of "GPS or cellular technology" throughout the detailed description could be used to argue that the invention contemplated distinct, non-overlapping categories of technology ('386 Patent, col. 2:37-38, col. 2:49-51).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" ('386 Patent, Compl. ¶14). The allegation of knowledge and intent is based on the service of the complaint itself (Compl. ¶15).
• Willful Infringement: The complaint does not use the term "willful." It alleges "Actual Knowledge of Infringement" commences with the service of the complaint, which could form the basis for a post-filing willfulness or enhancement claim (Compl. ¶13). No allegations of pre-suit knowledge are made.

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

1. A central pleading sufficiency question arises: does the complaint, which lacks any factual detail about the accused products or the mechanism of infringement in its main body and relies entirely on an incorporated but un-filed exhibit, provide the defendant with fair notice as required by federal pleading standards?
2. A core technical question for infringement will be whether the accused products, once identified, actually perform the claimed step of making attempts to find location using a "plurality" of "separate" location detection technologies. The case may turn on whether the accused system uses at least two distinct LDTs or a single LDT, which would present a straightforward non-infringement argument.
3. A key claim construction dispute will likely focus on the meaning of "separate location detection technology." The outcome of this construction will define the factual evidence needed to prove infringement and could be dispositive.