DCT

2:25-cv-00842

CommWorks Solutions LLC v. U blox America Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02504, E.D. Va., 12/30/2025
  • Venue Allegations: Venue is based on Defendant maintaining its principal place of business in Reston, Virginia, within the Eastern District of Virginia.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless networking Systems-on-Chips (SoCs) and devices, which support industry standards such as Wi-Fi Protected Setup (WPS), Wi-Fi Multimedia (WMM), and Wi-Fi Mesh, infringe seven patents related to wireless network provisioning, priority traffic detection, and scalable network control.
  • Technical Context: The asserted technologies address foundational challenges in wireless networking, including simplifying device setup and managing data traffic efficiently, which are critical functions for components used in Internet of Things (IoT), consumer, and industrial applications.

Case Timeline

Date Event
1999-12-17 Earliest Priority Date for ’904, ’465 Patents
2002-05-13 Earliest Priority Date for ’304 Patent
2003-01-13 Earliest Priority Date for ’807, ’285, ’596, ’979 Patents
2005-05-10 ’807 Patent Issued
2006-04-11 ’465 Patent Issued
2007-02-13 ’285 Patent Issued
2008-12-09 ’596 Patent Issued
2011-03-22 ’979 Patent Issued
2014-05-20 ’904 Reissue Patent Issued
2017-01-24 ’304 Patent Issued
2025-12-30 Complaint Filing Date

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

U.S. Patent No. 7,177,285 - *Time Based Wireless Access Provisioning*

  • Issued: February 13, 2007

The Invention Explained

  • Problem Addressed: The patent describes conventional methods for adding new wireless devices to a secure network as "impractical" and "cumbersome," particularly for devices lacking a sophisticated user interface for entering security credentials or device identifiers like a MAC address (Compl. ¶25; ’596 Patent, col. 3:13-28).
  • The Patented Solution: The invention provides a time-based provisioning method. A network access point tracks an "operating parameter" of a new wireless device, such as its power-on time or the onset of its signal transmission. A user then activates a provisioning function on the access point (e.g., by pressing a button), which opens a short, defined time window. If the device's tracked event occurred within that window, the access point automatically provisions the device onto the network, eliminating the need for manual configuration (’596 Patent, Abstract; col. 4:54-65).
  • Technical Importance: This approach simplified the secure onboarding of simple wireless peripherals (e.g., printers, picture frames), a critical step for the expansion of home networking and the early IoT ecosystem (Compl. ¶26).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶28).
  • The essential elements of the process are alleged to include:
    • Tracking an operating parameter of the wireless device within a service area.
    • The operating parameter comprises an onset of a signal transmission of the wireless device.
    • Initiating provisioning of the wireless device if the tracked operating parameter occurs within a time interval (Compl. ¶30).

U.S. Patent No. 7,463,596 - *Time Based Wireless Access Provisioning*

  • Issued: December 9, 2008

The Invention Explained

  • Problem Addressed: As with the related ’285 Patent, this patent addresses the difficulty of provisioning wireless devices that lack a user interface suitable for communicating security or identification information to a network access point (’596 Patent, col. 3:13-26).
  • The Patented Solution: The invention claims a time-based process for associating devices. It involves tracking an operating parameter of a first device (such as power-on or signal transmission onset). If that event occurs within a specified time interval relative to an activation event, the system automatically associates the first device with at least one other device, such as a network access point (’596 Patent, Abstract; col. 6:27-40).
  • Technical Importance: The invention provided a user-friendly mechanism for securely connecting new devices to a network without requiring technical proficiency from the user, which the complaint characterizes as a "major technological advance" (Compl. ¶40).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (’596 Patent, cl. 1; Compl. ¶42).
  • The essential elements of the process are described as:
    • Tracking an operating parameter of a first device.
    • The operating parameter comprises any of a power on of the first device, and an onset of a signal transmission of the first device.
    • Automatically associating the first device with at least one other device if the tracked operating parameter occurs within a time interval (Compl. ¶44).

U.S. Patent No. 7,911,979 - *Time Based Access Provisioning System And Process*

  • Issued: March 22, 2011
  • Technology Synopsis: Belonging to the same family as the ’285 and ’596 patents, the ’979 Patent addresses the problem of impractical network provisioning for simple wireless devices (Compl. ¶53). The patented solution is a provisioning system with logic that tracks an operating parameter of a device (e.g., power-on or signal transmission) and sends a signal to initiate provisioning if the event occurs within a designated time interval (Compl. ¶58).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶56).
  • Accused Features: The accused features are the functionalities of Defendant's devices that support Wi-Fi Protected Setup ("WPS") (Compl. ¶¶ 47, 57).

U.S. Patent No. RE44,904 - *Method For Contention Free Traffic Detection*

  • Issued: May 20, 2014
  • Technology Synopsis: This patent addresses the inefficiency of conventional methods for identifying high-priority data traffic in a wireless network, which required complex processing of all data frames and headers, a task too burdensome for low-cost access points (Compl. ¶¶ 67-68). The invention provides a method to detect priority traffic by extracting a bit pattern from a predetermined, fixed position in a data frame and comparing it with a known search pattern to identify it as a priority frame (Compl. ¶72).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶70).
  • Accused Features: The accused features are the functionalities of Defendant's devices supporting Wi-Fi Multimedia ("WMM") and the 802.11-2007+ standard (Compl. ¶¶ 61, 71).

U.S. Patent No. 7,027,465 - *Method For Contention Free Traffic Detection*

  • Issued: April 11, 2006
  • Technology Synopsis: As the original patent underlying the ’904 reissue patent, the ’465 Patent addresses the same problem of efficiently identifying priority traffic in wireless networks without complex, resource-intensive processing (’465 Patent, col. 1:53-2:4). The solution is a method that extracts a bit pattern from a predetermined position in a data frame, defined by an offset, and compares it to a search pattern to determine the frame's priority status (Compl. ¶86).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶84).
  • Accused Features: The accused features are the functionalities within Defendant's devices that support Wi-Fi Multimedia ("WMM") and the 802.11-2007+ standard (Compl. ¶¶ 75, 85).

U.S. Patent No. 6,891,807 - *Time Based Wireless Access Provisioning*

  • Issued: May 10, 2005
  • Technology Synopsis: As the parent to the ’285, ’596, and ’979 patents, the ’807 Patent discloses the core time-based provisioning invention. It addresses the impracticality of connecting wireless devices that lack a user interface to a secure network (’807 Patent, col. 3:5-28). The patented system involves a network access point with logic for tracking the operation of a wireless device and logic for provisioning that device if its operation occurs within an "activatable time interval" (Compl. ¶99).
  • Asserted Claims: At least independent claim 17 is asserted (Compl. ¶97).
  • Accused Features: The accused features are the functionalities of Defendant's devices that support Wi-Fi Protected Setup ("WPS") (Compl. ¶¶ 89, 98).

U.S. Patent No. 9,554,304 - *Scalable Media Access Control for Multi-Hop High Bandwidth Communications*

  • Issued: January 24, 2017
  • Technology Synopsis: This patent addresses the impracticality and performance degradation of existing media access control ("MAC") modules in multi-hop wireless mesh networks, which failed to account for end-to-end resource allocation (’304 Patent, col. 1:62-2:15). The invention provides a scalable MAC that avoids resource reservation conflicts and performs layer-2 routing to ensure optimal performance as the number of hops in the network increases (Compl. ¶109).
  • Asserted Claims: At least independent claim 1 is asserted (Compl. ¶110).
  • Accused Features: The accused features are the Wi-Fi Mesh functionalities of Defendant's chips and devices (Compl. ¶¶ 102, 111).

III. The Accused Instrumentality

Product Identification

The complaint identifies three categories of accused products: "u-blox Wi-Fi Multimedia Products," "u-blox WPS Products," and "Wi-Fi Mesh Products," all of which are Systems-on-Chips (SoCs), chips, and related devices manufactured and sold by Defendant (Compl. ¶16).

Functionality and Market Context

  • The accused products are alleged to incorporate functionality compliant with established industry standards. The "u-blox WPS Products" support Wi-Fi Protected Setup (WPS), a network security standard to simplify the process of connecting devices to a secure wireless network (Compl. ¶¶ 16, 29).
  • The "u-blox Wi-Fi Multimedia Products" support Wi-Fi Multimedia (WMM) and the IEEE 802.11-2007+ standard, which provide Quality of Service (QoS) features to prioritize data traffic for different applications like streaming media (Compl. ¶¶ 16, 71).
  • The "Wi-Fi Mesh Products" support Wi-Fi Mesh functionality, enabling wireless nodes to interconnect to form a single, extended network (Compl. ¶¶ 16, 102).
  • These SoCs and devices are foundational components for a wide array of modern electronics, including Internet of Things (IoT) devices, consumer electronics, and industrial wireless systems.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent but does not include them; therefore, the infringement allegations are summarized below in prose based on the complaint’s narrative descriptions (Compl. ¶¶ 28, 42, 56, 70, 84, 97, 110). No probative visual evidence provided in complaint.

  • ’285 Patent Infringement Narrative: The complaint alleges that Defendant’s "u-blox WPS Products" infringe by performing a time-based provisioning process (Compl. ¶30). The functionality associated with the Wi-Fi Protected Setup (WPS) standard, such as its Push-Button-Connect method, is alleged to practice the claimed steps. This involves an access point tracking an operating parameter of a new device (e.g., the onset of its signal transmission) and initiating provisioning if that event occurs within a specified time interval activated by the user (Compl. ¶¶ 29-30).
  • ’596 Patent Infringement Narrative: The infringement theory against the "u-blox WPS Products" is similar to that for the ’285 patent. The complaint alleges that the process of associating devices using WPS infringes claim 1 of the ’596 patent (Compl. ¶¶ 43-44). The accused process allegedly involves tracking an operating parameter of a first device (such as power-on or signal transmission) and automatically associating it with another device if that event occurs within a defined time interval, mirroring the operation of WPS push-button setup (Compl. ¶44).
  • Identified Points of Contention:
    • Scope Questions: The infringement analysis for the '285 and '596 patents may raise the question of whether implementing the standardized WPS protocol constitutes "tracking an operating parameter" as required by the claims. A potential dispute is whether the accused products actively monitor for a specific physical event like a "power on," or if they passively listen for a protocol-level WPS setup request during a pre-defined two-minute window.
    • Technical Questions: A key technical question may be what evidence demonstrates that the accused products perform the specific act of correlating the timing of a device's signal onset with the user's activation of the provisioning window. The analysis may hinge on whether the accused functionality is merely a time-gated acceptance of a protocol request, or if it performs the specific temporal tracking logic described in the patents.

V. Key Claim Terms for Construction

  • The Term: "tracking an operating parameter" (from claim 1 of the ’285 and ’596 patents)

  • Context and Importance: This term appears central to the infringement allegations for the time-based provisioning patents. The case may turn on whether the accused WPS products perform an active "tracking" of a physical event, as the patent specification may suggest, or a more passive, protocol-level listening function that is part of the WPS standard.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Claim 1 of the ’596 patent defines "operating parameter" to include "any of a power on of the first device, and an onset of a signal transmission," which could be argued to encompass a range of detectable events, including the transmission of a standardized WPS probe request (’596 Patent, col. 14:1-5).
    • Evidence for a Narrower Interpretation: The specification repeatedly uses the phrase "tracks the power on time" and depicts flowcharts and timelines centered on monitoring the moment a device is powered on (e.g., ’596 Patent, Fig. 3, step 54; col. 6:30-34). This could support a narrower construction limited to the observation of specific physical-layer events rather than protocol-level messages.

  • The Term: "occurs within a time interval" (from claim 1 of the ’285 and ’596 patents)

  • Context and Importance: This limitation defines the temporal relationship that qualifies a device for provisioning. The dispute will likely focus on whether the standard two-minute window in WPS PBC functions in the same way as the claimed "time interval," which is linked to a "tracked operating parameter."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims do not limit the duration of the interval, and the specification provides "a 5 minute interval" only as an example (’596 Patent, col. 6:64-65). This flexibility could support an argument that the WPS window is an infringing "time interval."
    • Evidence for a Narrower Interpretation: Figures in the patent depict a specific sequence where the device event (power-on) happens first, followed by the user's activation of the provisioning logic, which then checks if the device event was recent (i.e., within the "acceptance time interval") (’596 Patent, Fig. 5). If the WPS standard operates on a different sequence (e.g., user activates router, then activates device), this could be a basis to argue non-infringement.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant provides "information and assistance to its customers to enable them to use the Accused Products in an infringing manner," which suggests a claim for induced infringement (Compl. ¶17).
  • Willful Infringement: The complaint's prayer for relief seeks a finding of willful infringement and an award of treble damages (Compl. ¶115.c). The body of the complaint does not, however, plead specific facts supporting pre-suit knowledge of the asserted patents.

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

  • A core issue will be one of standards equivalence: Does the implementation of standardized protocols—specifically Wi-Fi Protected Setup (WPS) and Wi-Fi Multimedia (WMM)—inherently practice the specific methods claimed in the asserted patents? The case will likely require a deep technical comparison between the exact steps required by the claims versus the operational steps defined by the industry standards.
  • A second key issue will be one of definitional scope: Can terms rooted in the patents' specific embodiments, such as "tracking an operating parameter" like a "power on," be construed broadly enough to cover the protocol-level message exchanges that occur in the accused WPS and WMM functionalities?
  • Finally, the case will present an evidentiary question of technical operation: What specific evidence will show how the accused SoCs actually perform their functions at a granular level, and does that operation map onto the claimed steps of, for example, extracting bit patterns from fixed offsets or temporally correlating physical-layer events with user-initiated time windows?