Fractal Networks LLC v. DeepSig Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fractal Networks LLC (New Mexico)
  • Defendant: DeepSig, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:25-cv-01373, E.D. Va., 08/20/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to computing systems for wireless communication, particularly those using steerable antennas and edge processing.
• Technical Context: The technology relates to advanced 5G network architecture, which uses localized "edge" computing and intelligent antenna control to deliver the low-latency, high-bandwidth performance required for applications like autonomous vehicles and virtual reality.
• Key Procedural History: The complaint does not allege any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 10,637,142 - “Computing system”

• Patent Identification: U.S. Patent No. 10,637,142, “Computing system,” issued April 28, 2020 (’142 Patent).

The Invention Explained

• Problem Addressed: The patent describes the challenge of deploying 5th Generation (5G) wireless technology, which requires a "huge number of 5G towers" to be installed frequently, particularly in dense urban and business areas, to support superfast speeds that require a direct line of sight to the receiving device (ʼ142 Patent, col. 1:35-44). This creates a need for small, efficient systems that can be placed on ordinary infrastructure like light poles and intelligently manage communications (ʼ142 Patent, col. 1:44-47).
• The Patented Solution: The invention proposes a computing system for a cellular network that places significant computational resources at the "edge" of the network, close to the antennas (ʼ142 Patent, Abstract). The system uses a transceiver, one or more steerable antennas, and an "edge processing module" containing components like GPUs or neural networks to provide "low-latency computation" (ʼ142 Patent, col. 2:51-65). This architecture, depicted in the patent’s overview of an access/edge network (ʼ142 Patent, Fig. 2J), is designed to enable rapid, localized processing for tasks like antenna beam sweeping, reducing reliance on distant cloud data centers and minimizing delay.
• Technical Importance: By moving processing from a centralized cloud to the network edge, the patented approach addresses the critical need for low latency in 5G applications, which is essential for real-time services like autonomous vehicle control or augmented reality (ʼ142 Patent, col. 2:59-63).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referencing an unprovided exhibit (Compl. ¶11, ¶16). Independent claims 1 and 6 are representative of the technology.
• Independent Claim 1 includes the following essential elements:
  • A transceiver to communicate with a predetermined target
  • One or more antennas coupled to the transceiver, each electrically or mechanically steerable
  • An edge processing module coupled to the transceiver and antennas to provide low-latency computation
  • A quantum computer coupled to the edge processing module
• Independent Claim 6 includes the following essential elements:
  • An edge processing module with a learning machine or neural network
  • A beam sweeping module controlling one or more antennas based on criteria such as a service level agreement, performance requirement, or prior beam sweeping history
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services from Defendant DeepSig, Inc. (Compl. ¶11). It refers to "Exemplary Defendant Products" that are identified in charts within an "Exhibit 2," which was not filed with the complaint (Compl. ¶16).

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '142 Patent" (Compl. ¶16). No specific technical functionalities, features, or market positions of the accused products are described in the complaint.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an unprovided "Exhibit 2" but does not contain a narrative infringement theory beyond conclusory statements (Compl. ¶16-17). It alleges that the "Exemplary Defendant Products" directly infringe by satisfying all elements of the asserted claims of the ’142 Patent (Compl. ¶16). The complaint does not provide any specific facts explaining how any feature of an accused product meets any specific limitation of an asserted patent claim.

• Identified Points of Contention: The lack of detail in the complaint prevents a granular analysis, but the language of the patent’s independent claims suggests potential areas of dispute.
  • Scope Questions: A central dispute for any assertion of Claim 1 will be definitional: does an accused product contain a "quantum computer" as that term is understood in the art and described in the patent specification (ʼ142 Patent, col. 73:1-74:54)? The prosecution history and specification may be scrutinized to determine if this term can be read on classical processors performing specialized computations or if it requires a device that operates on quantum-mechanical principles.
  • Technical Questions: For an assertion of a claim like Claim 6, a key technical question will be evidentiary: what proof demonstrates that the accused product’s software or hardware performs the function of a "beam sweeping module" that controls antennas based on the specific criteria listed in the claim, such as "a service level agreement" or "prior beam sweeping history" (ʼ142 Patent, col. 93:10-14)?

V. Key Claim Terms for Construction

• The Term: "edge processing module" (Claim 1, 6, 8)

• Context and Importance: This term is foundational to the patent's contribution of providing low-latency computation near the antenna. Its construction will determine whether the accused functionality must reside in a specific physical location or can be a logical function distributed across general-purpose hardware. Practitioners may focus on this term because its scope could either limit the patent to specialized hardware configurations or allow it to cover a broader range of software-defined radio systems.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification defines the module by its components, stating it "comprises at least a processor, a graphical processing unit (GPU), a neural network, a statistical engine, or a programmable logic device (PLD)" (ʼ142 Patent, col. 2:5-8). This functional description could support an interpretation not strictly tied to location.
  • Evidence for a Narrower Interpretation: The specification states that the "edge processing module is embedded in the antenna housing" and "can be a pole, a building, or a light" (ʼ142 Patent, col. 2:8-10). These descriptions of specific physical embodiments could be cited to argue for a narrower construction requiring the module to be physically co-located with the antenna infrastructure.

• The Term: "quantum computer" (Claim 1)

• Context and Importance: The presence of this term in Claim 1 makes its construction dispositive for any infringement allegation based on that claim. Infringement will turn on whether the accused products contain a device meeting the definition of a "quantum computer," which is a highly technical and specific limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification lists "quantum processors" as one of several examples of processors that can be included in the edge processing module, alongside more common GPUs and FPGAs (ʼ142 Patent, col. 2:63-65). This placement in a list could suggest it is an alternative, rather than a fundamentally different type of required component.
  • Evidence for a Narrower Interpretation: The patent dedicates significant space to describing a "hybrid classical quantum computer," its components (e.g., qubits), and its operation, indicating a specific technical meaning (ʼ142 Patent, col. 73:1-74:54; Fig. 8). A defendant may argue that this detailed disclosure requires the term to be construed as a physical device leveraging quantum phenomena, not a classical computer simulating quantum algorithms.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on post-suit knowledge, stating that "at least since being served by this Complaint," Defendant has knowingly induced infringement by selling products to customers (Compl. ¶15). It further alleges that Defendant distributes "product literature and website materials" that direct end users to infringe, referencing the unprovided Exhibit 2 for substantiation (Compl. ¶14).
• Willful Infringement: The complaint does not contain a count for willful infringement. However, it alleges that service of the complaint constitutes "Actual Knowledge of Infringement," which could form the basis for seeking enhanced damages for any post-suit infringement (Compl. ¶13). No facts are alleged to support pre-suit knowledge.

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

1. Evidentiary Sufficiency: The primary question is whether the plaintiff can substantiate its bare-bones complaint with specific factual evidence. A court may first need to address whether the complaint, which relies entirely on an unprovided exhibit for its infringement theory, meets federal pleading standards required to proceed to discovery.
2. Technical Realism: A core issue will be one of technical mismatch: can the plaintiff demonstrate that the accused products—likely based on conventional AI/ML signal processing—incorporate the highly specific technologies recited in certain claims, most notably the "quantum computer" required by Claim 1?
3. Definitional Scope: The case may ultimately hinge on claim construction, particularly for the term "edge processing module." The dispute will likely focus on whether this term requires a specific, physically-located hardware component, or if it can be construed more broadly to cover logical functions performed by software in a distributed 5G network architecture.