Stingray IP Solutions, LLC v. Legrand

CourtDistrict Court, E.D. Texas
DecidedApril 14, 2022
Docket2:21-cv-00202
StatusUnknown

This text of Stingray IP Solutions, LLC v. Legrand (Stingray IP Solutions, LLC v. Legrand) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stingray IP Solutions, LLC v. Legrand, (E.D. Tex. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION STINGRAY IP SOLUTIONS, LLC, § § Plaintiff, § § NO. 2:21-CV-00201-JRG v. § (lead case) § LEGRAND, LEGRAND FRANCE, § NO. 2:21-CV-00202-JRG BTICINO SPA, and LEGRAND SNC, § (lead case) § Defendants. § _______________________________________§ § STINGRAY IP SOLUTIONS, LLC, § § Plaintiff, § NO. 2:21-CV-00193-JRG § (member case) v. § § NO. 2:21-CV-00194-JRG AMAZON.COM, INC., and AMAZON.COM § (member case) SERVICES LLC, § § Defendants. § CLAIM CONSTRUCTION MEMORANDUM OPINION AND ORDER Stingray IP Solutions, LLC, (“Stingray”) alleges infringement by Amazon.com, Inc., and Amazon.com Services LLC (together, “Amazon”) of eight patents in two different proceedings. See Dkt. No. 74 at 1. One of the proceedings between Stingray and Amazon is Case No. 2:21- cv- 00193-JRG, which was consolidated for pretrial purposes under lead Case No. 2:21- cv- 00201-JRG. The other proceeding between Stingray and Amazon is Case No. 2:21- cv- 00194-JRG, which was similarly consolidated for pretrial purposes under lead Case No. 2:21-cv-00202-JRG. Each of the asserted patents relates in some way to wireless networks. For claim construction, however, the parties dispute the scope of terms from only five of the eight patents. Accordingly, the Court ordered a combined Markman hearing to simultaneously address claim construction issues in both proceedings. Dkt. No. 83. Four of the patents—U.S.

Patents 6,961,310, 7,082,117, 7,027,426 and 7,616,961—relate to mobile ad hoc networks. ’310 Patent at 1:6–8; ’117 Patent at 1:7–9; ’426 Patent at 1:6–8; ’961 Patent at 1:6–8. The fifth patent, U.S. Patent 6,958,986, relates to “mobile communication systems operating with directional antennas.” ’986 Patent at 1:20–22. Despite some inventorship and subject-matter overlap, none of the patents claim the benefit of a prior-filed application, and the disclosures are different. The parties present five disputes for resolution. Having considered the parties’ briefing, along with arguments of counsel during a March 29, 2022 hearing, the Court resolves those disputes as follows. I. BACKGROUND A. U.S. Patent 6,958,986

The ’986 Patent relates to “a network of mobile communication systems operating with directional antennas.” ’986 Patent at 1:19–22. In particular, the patent introduces the notion of using directional (rather than omnidirectional) antennas in mobile communication systems with time division multiple access (TDMA) schemes, which assign each mobile device a specific time slot in which to communicate with other devices. Id. at 1:25–32. Because directional antennas increase the antenna gain in some directions and decrease the gain in others, “[s]cheduling time slots for wireless communication systems operating with directional antennas, particularly when the wireless communication systems are mobile, is complex.” Id. at 1:65–67. To address this complexity, the ’986 Patent teaches incorporating a controller in each of the network’s nodes. The controller can schedule time slots for data based on priority levels and “link utilization metrics.” Thus, rather than adhering to a fixed TDMA scheme, the inventions allocate time slots to use available bandwidth most efficiently. See generally id. at 2:35–49. B. U.S. Patent 6,961,310

The ’310 Patent is entitled “Multiple Path Reactive Routing in a Mobile Ad Hoc Network.” ’310 Patent at [54]. The patent describes a “mobile ad hoc network” as “a number of geograph ically-distributed, potentially mobile nodes wirelessly connected by one or more radio frequency channels.” Id. at 1:14–17. “The network is formed of mobile nodes only, and a network is created on the fly as the nodes transmit to or receive from other nodes.” Id. at 1:18–20. “The network does not in general depend on a particular node and dynamically adjusts as some nodes join and others leave the network.” Id. at 1:20–22. The patent explains: [d]ue to the lack of a fixed infrastructure, nodes must self-organize and reconfigure as they move, join or leave the network. All nodes could potentially be functionally identical and there may not be any natural hierarchy or central controller in the network. Many network-controlling functions are distributed among the nodes. . . . The bandwidth of the system is usually limited. The distance between two nodes often exceeds the radio transmission range, and a transmission has to be relayed by other nodes before reaching its destination. Consequently, a network has a multihop topology, and this topology changes as the nodes move around. Id. at 1:32–45. Because of the dynamic network topology, the routing protocols can be challenging. See id. at 1:56–60 (noting “routing in these networks is very different from others” and “[g]athering fresh information about the entire network is often costly and impractical”). There were, at the time of the underlying application’s filing date, conventional routing protocols that used a “best effort approach” to selecting a route between two nodes, often emphasizing the route with the lowest number of hops as preferred. See id. at 2:12–18. Other methods used quality-of-service (QoS) metrics, such as bandwidth and reliability, in choosing the route between two nodes. Id. at 2:18–41. Regardless, the ’310 Patent criticizes the existing routing protocols as limited, and then purports “to provide more reliable and more timely routes with less traffic load concentration.” Id.

at 2:53–56. C. U.S. Patent 7,082,117 The ’117 Patent relates to intrusion detection for mobile ad hoc networks. See ’117 Patent at [54]. Because “nodes in a mobile ad-hoc network all communicate wirelessly, there is a much greater risk of intrusion by unauthorized users.” Id. at 1:54–56. The patent suggests certain node characteristics might “reliably indicate whether a node is a rogue node attempting to intrude upon the network.” Id. at 2:18–21. In particular, the patent teaches using a “policing node” that monitors transmissions between the other network nodes and which generates an intrusion alert on the occurrence of certain conditions (e.g., frame check sequence errors, failed attempts to authenticate MAC addresses, mode of operation) indicative of mischief. Id. at 2:34–49.

D. U.S. Patent 7,027,426; U.S. Patent 7,616,961 The ’426 Patent concerns multi-channel mobile ad hoc networks. ’426 Patent at [54]. As the Background of the Invention explains, “[c]onventional mobile ad-hoc network routing protocols assume that all nodes are on the same channel permanently[,] . . . which is a factor in the bandwidth availability.” Id. at 2:29–32. “Although some networks may use a separate control channel to reduce overhead on the transmission channel, conventional mobile ad-hoc networks do not utilize multiple channels for transmitting packet data.” Id. at 2:32–36. “The method includes sending a route request over each of the plurality of channels to discover routing to a destination node, and selecting a route to the destination node on at least one of the plurality of channels.” Id. at [57]. The ’961 Patent also relates to channel allocation. ’961 Patent at [54]. In particular, the ’961 Patent provides dynamic channel allocation by having each node monitor link performance, but scouting other available channels when the link performance falls below an acceptability

threshold. Id. at [57]. II. LEGAL STANDARDS A. Generally “‘[T]he claims of a patent define the invention to which the patentee is entitled the right to exclude.’” Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2005) (en banc) (quoting Innova/Pure-Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1115 (Fed. Cir.

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Stingray IP Solutions, LLC v. Legrand, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stingray-ip-solutions-llc-v-legrand-txed-2022.