E Beacon LLC v. Singlewire Software LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Singlewire Software, LLC (Wisconsin)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 3:25-cv-00300, W.D. Wis., 04/17/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Western District of Wisconsin.
• Core Dispute: Plaintiff alleges that Defendant’s emergency notification software products infringe a patent related to determining and transmitting the physical location of a Voice over IP (VoIP) device to emergency services.
• Technical Context: The technology addresses the challenge of providing reliable E911 services for VoIP telephones, which, unlike traditional landlines, are not tied to a fixed physical address and can be used from any location with internet access.
• Key Procedural History: The patent-in-suit is a continuation-in-part of an earlier application that issued as a patent. The patent-in-suit is also subject to a terminal disclaimer, which may limit its enforceable term to that of the parent patent.

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)"

The Invention Explained

• Problem Addressed: The patent’s background section describes the unreliability of emergency services for VoIP telephone users, as a VoIP phone can be used in any location with internet access, making it difficult for a 911 operator to determine the caller's physical location, unlike a traditional landline phone tied to a specific address ( Compl. ¶9; ’386 Patent, col. 1:24-29).
• The Patented Solution: The invention is a system that determines the physical location of a VoIP device by using multiple location detection technologies, such as GPS or cellular network triangulation. When an emergency call is placed, the system automatically transmits the determined location data to the emergency call center (PSAP), ensuring first responders are dispatched to the correct location (’386 Patent, Abstract; col. 2:36-45). The system also includes logic for storing coordinates and attempting to re-acquire location if the initial attempt fails, as depicted in the flowchart of Figure 1 (’386 Patent, Fig. 1; col. 2:56-62).
• Technical Importance: The described technology provides a method for VoIP systems to comply with Enhanced 911 (E911) requirements, which mandate the automatic provision of a caller's location to emergency dispatchers, a critical feature for mobile and nomadic communication devices (’386 Patent, col. 1:11-23).

Key Claims at a Glance

• The complaint alleges infringement of "Exemplary '386 Patent Claims" identified in an exhibit, but does not specify claim numbers in the body of the complaint (Compl. ¶11). Independent claim 1 is representative of the patent's core method.
• Independent Claim 1:
  • A method for determining the physical location of a VoIP phone and transmitting it to an emergency services call center, comprising:
  • making a plurality of attempts to determine the physical location of the VoIP phone, each using a separate location detection technology ("LDT");
  • if an attempt is successful, storing the physical location determined using the corresponding LDT;
  • placing a call to the emergency services call center with the VoIP phone; and
  • 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 dependent claims, but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" without providing specific product names (Compl. ¶11).

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '386 Patent" (Compl. ¶16). The specific functionality of the accused products is detailed in claim charts provided as Exhibit 2 to the complaint; however, this exhibit was not publicly available for analysis (Compl. ¶16). The complaint does not provide further detail for analysis of the accused products' specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided with the filing; therefore, a detailed claim chart summary cannot be constructed (Compl. ¶17). The narrative infringement theory alleges that Defendant makes, uses, sells, and internally tests products that practice the patented method (Compl. ¶¶ 11-12). The core of the allegation is that Defendant's products determine the location of an emergency and transmit that information as part of a notification, thereby satisfying the elements of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question will be whether the different location-finding techniques used by the accused products qualify as separate "location detection technolog[ies] ('LDT')" as required by claim 1. The patent provides examples such as GPS, CDMA, and GSM, which are distinct radio-based systems (’386 Patent, col. 7:56-65). The dispute may turn on whether the accused product's methods (e.g., using Wi-Fi triangulation, IP address geolocation, or user-entered data) fall within the scope of this term.
• Technical Questions: A key factual question will be whether the accused products actually perform a "plurality of attempts" using separate LDTs as a sequential or parallel process to find a location, as claimed. The evidence will need to show not just that location is determined, but that it is determined via the specific multi-attempt, multi-technology process recited in the claim (’386 Patent, col. 15:25-30).

V. Key Claim Terms for Construction

• The Term: "location detection technology ('LDT')"
• Context and Importance: This term is the foundation of independent claim 1. Its construction will determine what types of location-finding methods can be combined to meet the "plurality of attempts" limitation. A narrow construction could limit the claim to distinct hardware-based radio systems, while a broader construction could encompass software or network-based methods. Practitioners may focus on this term because the infringement case depends on whether the accused product's features are considered separate "LDTs."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that in addition to GPS, CDMA, and GSM, "location data can also be obtained from...Wi-Fi, WiMAX, and other such technologies that can provide geolocation information" (’386 Patent, col. 7:62-65). This open-ended list suggests LDT is not limited to the specific examples given.
  • Evidence for a Narrower Interpretation: The primary examples provided are distinct, radio-frequency-based telecommunication standards (GPS, CDMA, GSM) that require different hardware and network interactions (’386 Patent, col. 7:58-62). An argument could be made that an "LDT" must be a technologically distinct system, not merely a different software algorithm using the same underlying data (e.g., two different ways of analyzing Wi-Fi signals).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’386 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of its infringement at least since being served with the complaint and has "actively, knowingly, and intentionally continued to induce infringement" (Compl. ¶¶ 13, 15). This frames the willfulness claim as being based on post-suit conduct.

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

This dispute appears to center on the specific implementation details of the accused emergency notification system. The key questions for the court will likely be:

• A core issue will be one of definitional scope: Can the term "location detection technology ('LDT')," which the patent illustrates with distinct radio systems like GPS and cellular, be construed to cover the potentially software-based or network-level location-finding methods allegedly used in Defendant's system?
• A key evidentiary question will be one of operational correspondence: What evidence demonstrates that the accused products perform the specific claimed method of making a "plurality of attempts" with separate LDTs, storing successful results, and automatically transmitting that location, as opposed to employing a more generalized location-reporting function?