DCT

2:25-cv-00519

Fractal Networks LLC v. DeepSig Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00519, E.D. Va., 08/20/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Virginia.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to computing systems for advanced wireless networks that utilize steerable antennas and edge processing.
  • Technical Context: The technology at issue addresses performance demands in 5G wireless networks by using localized "edge" computing to provide low-latency data processing for applications like autonomous vehicles and the Internet of Things (IoT).
  • Key Procedural History: The patent-in-suit is a continuation of U.S. Application No. 16/404,853, which issued as U.S. Patent No. 10,461,421. The complaint does not specify any other relevant procedural history.

Case Timeline

Date Event
2019-05-07 Earliest Patent Priority Date ('142 Patent)
2019-09-21 '142 Patent Application Filing Date
2020-04-28 '142 Patent Issue Date
2025-08-20 Complaint Filing Date

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, titled “Computing system,” issued on April 28, 2020 (the “’142 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the challenge of deploying 5G networks, which require a "huge number of 5G towers" to provide the necessary coverage and speed. This proliferation of small cell antennas, often requiring a direct line of sight to devices, creates logistical complexity and aesthetic concerns ("more eyesores nearly everywhere") (’142 Patent, col. 1:35-48).
  • The Patented Solution: The invention proposes a system architecture that combines steerable antennas with a local "edge processing module" to deliver low-latency computation directly at the network edge, such as on a light pole or in the antenna housing itself (’142 Patent, Abstract; col. 2:9-11). This module, which can include components like GPUs, neural networks, and FPGAs, is designed to optimize 5G parameters and support demanding applications by processing data closer to the end-user, rather than in a distant data center (’142 Patent, col. 1:57-65). The overall architecture is depicted in Figure 2J, which distinguishes between processing at the "ACCESS/EDGE," "CORE," and "CLOUD/DATA CENTER" levels (’142 Patent, Fig. 2J).
  • Technical Importance: This approach of integrating intelligent computing at the network edge aims to solve the latency and bandwidth challenges inherent in 5G, enabling real-time applications that are otherwise not feasible with traditional, centralized cloud processing (’142 Patent, col. 1:52-61).

Key Claims at a Glance

  • The complaint alleges infringement of "exemplary claims" but does not specify them in the body of the complaint, instead referring to an external exhibit not provided with the filing (Compl. ¶11). Claim 1 is the first independent claim of the patent.
  • Independent Claim 1 elements:
    • A transceiver to communicate with a predetermined target;
    • One or more antennas coupled to the transceiver, each electrically or mechanically steerable to the predetermined target;
    • An edge processing module coupled to the transceiver and antennas to provide low-latency computation for the predetermined target; and
    • A quantum computer coupled to the edge processing module.
  • The complaint alleges infringement of "one or more claims" of the ’142 Patent (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

  • The complaint does not provide any description of the accused products' functionality, features, or market position. It only makes the conclusory statement that the products "practice the technology claimed by the '142 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint makes conclusory allegations of infringement and incorporates by reference claim charts from an unprovided Exhibit 2 (Compl. ¶16-17). The complaint body itself does not describe how the accused products allegedly meet the limitations of any asserted claim. As such, a claim chart summary cannot be constructed from the provided documents.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the language of claim 1 of the ’142 Patent, the infringement analysis raises several key questions.

  • Scope Questions: A central dispute may concern the definition of a "quantum computer." The question will be whether the accused instrumentality includes a component that meets the legal and technical definition of a "quantum computer" as required by claim 1. Another point of contention may be the scope of an "edge processing module," specifically its required physical location and computational capabilities.
  • Technical Questions: The complaint provides no factual basis to assess the technical operation of the accused products. A key technical question will be what evidence, if any, demonstrates the presence of a "quantum computer" coupled to an "edge processing module" in the accused systems. Further, evidence will be required to show that the accused module provides "low-latency computation" and that the accused antennas are "electrically or mechanically steerable."

V. Key Claim Terms for Construction

  • The Term: "edge processing module"

  • Context and Importance: This term is central to the claimed invention, as it defines the system's distributed computing architecture. Its construction will be critical for determining whether the defendant's system, which may use various forms of distributed or localized processing, falls within the scope of the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of components that the module can comprise, including "at least a processor, a graphical processing unit (GPU), a neural network, a statistical engine, or a programmable logic device (PLD)" (’142 Patent, col. 2:5-8). It also lists "cryogenic processors, quantum processors, neuromorphic processors, learning machines, GPUs, and FPGA" as examples of edge processing (’142 Patent, col. 1:62-65), suggesting the term covers a wide range of computational hardware.
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the module as being physically co-located with the antenna, for instance, "embedded in the antenna housing" or as part of "a pole, a building, or a light" (’142 Patent, col. 2:9-11). A party might argue this language limits the term to hardware physically integrated with or immediately adjacent to the antenna structure.

  • The Term: "quantum computer"

  • Context and Importance: This limitation appears in independent claim 1 and is a highly specific technical requirement. Proving that an accused product contains a "quantum computer" is a significant hurdle, and the construction of this term will likely be determinative for infringement of this claim.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent does not provide a standalone definition for "quantum computer." However, it lists "quantum processors" as a component of the edge processing module (’142 Patent, col. 1:63). A party could argue that this suggests a functional interpretation, where any component leveraging quantum principles for computation would suffice.
    • Evidence for a Narrower Interpretation: Figure 8 and its corresponding description detail a "hybrid classical/quantum computer" architecture (’142 Patent, Fig. 8; col. 15:9-12). A party could argue that this detailed embodiment informs the meaning of "quantum computer" and requires a similarly complex and specific implementation, rather than any component that merely uses quantum effects.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that the Defendant sells its products to customers and provides "product literature and website materials" that instruct them to use the products in an infringing manner (Compl. ¶14-15). Knowledge is alleged to exist at least from the date the complaint was served (Compl. ¶15).
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It alleges "Actual Knowledge of Infringement" arises from the service of the complaint itself, which would only support a claim for enhanced damages based on post-suit conduct (Compl. ¶13). No facts supporting pre-suit knowledge are alleged.

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

  • A primary issue will be one of evidentiary sufficiency: As the complaint’s infringement theory relies entirely on an unprovided exhibit, a core question is what specific evidence Plaintiff will produce to demonstrate that the accused products contain every element of the asserted claims, particularly the highly technical requirement of a "quantum computer."
  • A key question will be one of technical and definitional scope: The case will likely turn on whether the accused system's architecture can be shown to incorporate a "quantum computer," as that term is construed in the context of the ’142 Patent, or if there is a fundamental mismatch between the specific technology claimed and the accused products.