Lab Technology LLC v. Zendesk Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Zendesk, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 3:25-cv-00303, W.D. Wis., 04/17/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining an established place of business within the Western District of Wisconsin.
• Core Dispute: Plaintiff alleges that Defendant’s customer support platform infringes a patent related to dynamically routing communications based on user-defined policies and time attributes.
• Technical Context: The technology addresses unified communications, enabling a single point-of-contact identifier to intelligently route incoming calls to a user's various devices or numbers based on pre-set, time-sensitive rules.
• Key Procedural History: The patent-in-suit is a continuation-in-part of a prior application that issued as U.S. Patent No. 7,391,858, which may be relevant for determining the effective filing date of the claimed subject matter.

Case Timeline

Date	Event
2004-11-02	Priority Date for U.S. Patent No. 8,483,102
2007-10-29	Application Date for U.S. Patent No. 8,483,102
2013-07-09	Issue Date for U.S. Patent No. 8,483,102
2025-04-17	Complaint Filing Date

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

U.S. Patent No. 8,483,102 - "System and method for mapping a voice identity across multiple telephony networks with time attributes"

• Patent Identification: U.S. Patent No. 8,483,102, “System and method for mapping a voice identity across multiple telephony networks with time attributes,” issued 07/09/2013.

The Invention Explained

• Problem Addressed: The patent addresses the inefficiency and confusion that arises when a person has multiple telephone numbers (e.g., corporate extension, mobile phone, home office line), forcing callers to try several numbers and potentially leave redundant voicemails across different systems ('102 Patent, col. 1:26-43).
• The Patented Solution: The invention is a system that allows a user to create a "voice identity mapping policy," which is a set of rules for call routing ('102 Patent, col. 4:7-15). This policy maps a primary "search voice identity" to different "target voice identities" based on "time attributes" like the time of day or day of the week ('102 Patent, Fig. 2). A central "policy processor" consults these rules when a call is received and automatically forwards it to the user's currently active phone, transparently to the caller ('102 Patent, Abstract; col. 6:21-27).
• Technical Importance: This technology represents a method for creating a persistent, unified contact identity that is independent of any single physical device or network, a key concept in modern telecommunications and VoIP services ('102 Patent, col. 1:21-28).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," with specific claims identified in an exhibit not included with the complaint (Compl. ¶11). Independent claim 1 is representative of the system.
• Independent Claim 1 requires:
  • One or more phone systems with telephony switches for call routing.
  • At least one policy processor coupled to the switches.
  • At least one "voice identity mapping policy" stored in a data storage, which itself comprises:
    • A plurality of "search voice identities" mapped to "target voice identities."
    • "Time attributes" indicating when the mapping policies are valid.
  • The policy processor matches an incoming voice identity to a "given search voice identity" and maps it to a "given target voice identity" according to the policy.
  • A limitation that the "voice identity, the given search voice identity, and the given target voice identity each comprises a username."
  • The policy processor sends the target voice identity (comprising the username) to the telephony switches, which then route the call "using the username."
• The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

• The complaint does not name specific Zendesk products or describe their functionality. Instead, it incorporates by reference "charts" from an external "Exhibit 2" that allegedly detail the infringing products (Compl. ¶11, ¶16). Without this exhibit, the complaint itself provides no factual basis for analyzing the technical operation of the accused products.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided. The infringement theory is therefore summarized below in prose.

The complaint alleges that the "Exemplary Defendant Products" directly infringe the '102 Patent because they "practice the technology claimed by the '102 Patent" and "satisfy all elements of the Exemplary '102 Patent Claims" (Compl. ¶16). The complaint also alleges that Defendant's own internal testing and use of its products constitutes direct infringement (Compl. ¶12). However, the complaint does not provide specific factual allegations in its main body that map any particular feature of a Zendesk product to the specific limitations of the patent's claims. This comparison is purportedly contained entirely within the referenced Exhibit 2 (Compl. ¶17). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central issue may be the claim requirement that the "voice identity," "search voice identity," and "target voice identity" each "comprises a username" ('102 Patent, col. 12:33-35). The case may turn on whether a standard phone number or other identifier used by Defendant's system can be construed as a "username" within the meaning of the patent.
• Technical Questions: What evidence will be presented to show that the accused products implement "time attributes" ('102 Patent, col. 12:26-28) to create conditional, time-sensitive call routing, as opposed to a more static call-forwarding feature? The complaint does not provide facts to support the operation of this specific claimed functionality.

V. Key Claim Terms for Construction

• The Term: "username"
• Context and Importance: This term appears in the final, and arguably most specific, limitations of independent claim 1. The infringement analysis depends heavily on whether the identifiers used in Defendant's system (e.g., telephone numbers) fall within the scope of "username". Practitioners may focus on this term because if it is construed narrowly to exclude standard telephone numbers, Plaintiff's infringement theory for claim 1 could fail.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that in the context of the patent, "username" is simply a generic identifier for a user and should be read broadly enough to cover any unique designation, including a phone number, that allows the system to route a call to a specific person ('102 Patent, col. 2:28-29).
  • Evidence for a Narrower Interpretation: The specification provides specific examples of what a "username" can be, such as an "IM identity," an "email account identity," or an "employee's computer user identity" ('102 Patent, col. 12:15-22, referencing dependent claims 5 and 6; col. 3:34-35). This language suggests that "username" may refer to an identifier associated with a data network or corporate system, rather than a conventional telephone number from the public switched telephone network.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement "at least since being served by this Complaint" (Compl. ¶15). The basis for inducement is Defendant's alleged distribution of "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the '102 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges that service of the complaint itself provides Defendant with "Actual Knowledge of Infringement" (Compl. ¶13). It further alleges that despite this knowledge, Defendant continues to infringe, forming a basis for post-suit willfulness (Compl. ¶14). Plaintiff seeks enhanced damages under 35 U.S.C. § 284 and a finding that the case is exceptional under § 285 (Compl. Prayer for Relief ¶D, ¶E.i).

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

• A core issue will be one of definitional scope: can the term "username", which the patent’s specification links to computer, email, or IM identities, be construed to cover the telephone number-based identifiers presumably used in Defendant’s customer support platform?
• A key evidentiary question will be one of functional operation: what factual evidence will emerge to demonstrate that Defendant's products implement the specific "voice identity mapping policy" with conditional "time attributes" as required by the claims, rather than a more conventional or static call-forwarding system? The complaint itself is silent on these technical details.