Lab Technology LLC v. Alaio Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Alaio, Inc. (Virginia)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-01234, E.D. Va., 08/27/2025
• Venue Allegations: Venue is alleged to be proper based on the defendant maintaining an established place of business within the Eastern District of Virginia and having committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for dynamically routing voice calls across different telephony networks using time-based rules and user-specific identifiers.
• Technical Context: The technology addresses the challenge of reaching individuals who use multiple phone numbers (e.g., office, mobile, home) by centralizing call-forwarding logic into a policy-based system.
• Key Procedural History: The First Amended Complaint alleges that the Defendant was put on actual notice of infringement upon service of an Original Complaint filed on July 24, 2025. This date is cited as the basis for allegations of knowing and willful infringement.

Case Timeline

Date	Event
2004-11-02	’102 Patent Priority Date
2007-10-29	’102 Patent Application Filing Date
2013-07-09	’102 Patent Issue Date
2025-07-24	Original Complaint Filing Date
2025-08-27	First Amended Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 8,483,102 ("the ’102 Patent"), "System and method for mapping a voice identity across multiple telephony networks with time attributes," issued July 9, 2013. (Compl. ¶9; ’102 Patent, front page).

The Invention Explained

• Problem Addressed: The patent’s background section describes the growing inefficiency callers face when trying to reach a user who is associated with multiple telephone numbers, such as an office phone, a mobile phone, and a home phone. This fragmentation can lead to a series of failed call attempts and redundant voicemails across different systems. (’102 Patent, col. 1:26-43).
• The Patented Solution: The invention proposes a centralized system that uses a "voice identity mapping policy" to automatically route an incoming call to the most appropriate device for a user at a given time. This policy maps a "search voice identity" (the number a caller dials) to a "target voice identity" (the number where the user can be reached) based on pre-defined rules, including "time attributes" that specify when a particular rule is valid (e.g., after-hours, weekends). (’102 Patent, Abstract; Fig. 2). A central "policy processor" consults this policy, stored in a database, to determine the correct call destination. (’102 Patent, Fig. 4a).
• Technical Importance: This approach allows for unified and intelligent call management, providing a single point of contact for a user regardless of their location or which of their multiple devices is active, a significant challenge with the proliferation of communication technologies. (’102 Patent, col. 1:20-29).

Key Claims at a Glance

The complaint asserts infringement of "one or more claims" without specifying them, instead referencing charts in an unattached exhibit. (Compl. ¶11, ¶16). The patent's independent claims are Claims 1 (a system claim) and 11 (a method claim).

Independent Claim 1 (System):

• One or more phone systems with telephony switches for call routing.
• At least one policy processor coupled to the switches.
• A voice identity mapping policy stored in a data storage accessible to the processor.
• The policy comprises a plurality of "search voice identities" mapped to "target voice identities," along with "time attributes" indicating when the mappings are valid.
• In response to a call, the processor matches the incoming voice identity to a "given search voice identity" and maps it to a "given target voice identity."
• Crucially, the received "voice identity," the "given search voice identity," and the "given target voice identity" each comprises a "username."
• The processor sends the target voice identity (comprising the username) to the switches, which then route the call "using the username."

Independent Claim 11 (Method):

• Receiving a voice identity for a recipient at a policy processor from telephony switches.
• Checking for an associated voice identity mapping policy containing search-to-target mappings and a time attribute.
• Matching the received voice identity to a "given search voice identity."
• Mapping the search identity to a "given target voice identity" based on the policy.
• The voice identity, search identity, and target identity each "comprise a username."
• Sending the target voice identity (comprising the username) to the switches.
• The switches routing the call "using the username."

The complaint alleges infringement "literally or by the doctrine of equivalents" and reserves the right to assert other claims, which may include dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint does not name the accused products or services in its main body, referring only to "Exemplary Defendant Products" identified in charts within Exhibit 2. (Compl. ¶11, ¶16). Exhibit 2 was not attached to the filed complaint.
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It alleges in a conclusory manner that the products "practice the technology claimed by the '102 Patent." (Compl. ¶16). It further alleges that the Defendant sells these products and distributes "product literature and website materials" related to them. (Compl. ¶14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided. (Compl. ¶17). It alleges that the "Exemplary Defendant Products" satisfy all elements of certain "Exemplary '102 Patent Claims." (Compl. ¶16). Without the charts or a detailed description of the accused products, a direct comparison is not possible.

• Identified Points of Contention: Based on the language of the independent claims, several key points of contention may arise.
  • Scope Questions: A central dispute may focus on whether the identifiers used in the accused system qualify as a "username" under the required claim construction. The interpretation will determine if the claims are limited to specific network types (like VoIP or IM systems where alphanumeric usernames are common) or can be read more broadly to cover purely numeric identifiers like corporate phone extensions.
  • Technical Questions: Claim 1 requires that the telephony switches "route the call using the username." This raises the technical question of how the accused system’s routing mechanism operates. What evidence does the complaint provide that the accused switches perform routing operations directly on a "username" data type, as opposed to first resolving any such identifier into a standard telephone number (e.g., E.164 format) and then routing based on that number? The distinction between routing based on a username versus routing using a username could become a critical point of technical non-infringement argument.

V. Key Claim Terms for Construction

• The Term: "username"
• Context and Importance: This term appears in both independent claims 1 and 11 and is a required component of the received voice identity, the search voice identity, and the target voice identity. The viability of the infringement case may depend heavily on the construction of this term, as it could either broaden or narrow the scope of the claims to cover different types of communication systems.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides several examples of what a "username" can be, including an "IM identity," an "email account identity," or an "employee's computer user identity." (’102 Patent, col. 3:31-35; col. 9:58-62). Practitioners may argue that this non-exhaustive list supports a broad construction covering any unique identifier assigned to a user within a communication system.
  • Evidence for a Narrower Interpretation: The patent frequently discusses the term "username" in the specific context of Voice over IP (VoIP) and Instant Messaging (IM) services. (’102 Patent, col. 3:25-35). This context may support a narrower construction, limiting the term to alphanumeric, text-based identifiers characteristic of such internet-based systems, and excluding traditional numeric phone numbers or extensions.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users on how to use the products in a manner that infringes the ’102 Patent. (Compl. ¶14, ¶15).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after gaining "actual knowledge" of the ’102 Patent and its alleged infringement upon service of the Original Complaint on July 24, 2025. (Compl. ¶13, ¶14). The allegations are based on post-suit knowledge.

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

The resolution of this case will likely depend on the court’s determination of several key technical and legal questions:

• A core issue will be one of definitional scope: can the term "username," which the patent describes in the context of VoIP and IM systems, be construed to cover the specific type of user identifiers employed in the Defendant's accused system?
• A key evidentiary question will be one of technical mechanism: does the accused system's architecture show that its switches "route the call using the username" as mandated by the claims, or does evidence demonstrate that routing is performed using a different data type, such as a traditional phone number resolved from an initial identifier?