E Beacon LLC v. Greenlight Financial Technology Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: e-Beacon LLC (Delaware)
  • Defendant: Greenlight Financial Technology, Inc. (Delaware)
  • Plaintiff's Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01357, D. Del., 04/06/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and maintains an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant's products and services infringe a patent related to dynamically determining and transmitting the physical location of a Voice over IP (VoIP) device to emergency services using multiple location detection technologies.
• Technical Context: The technology addresses the public safety challenge of locating mobile VoIP users during emergencies, a problem that emerged as internet-based communication began to replace traditional, geographically-fixed telephone systems.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2005-08-05	U.S. Patent No. 8,515,386 Priority Date
2011-04-25	U.S. Patent No. 8,515,386 Application Date
2013-08-20	U.S. Patent No. 8,515,386 Issue Date
2026-04-06	Complaint Filing Date

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

U.S. Patent No. 8,515,386 - "Emergency services for voice over IP telephony (E-VoIP)"

• Patent Identification: U.S. Patent No. 8,515,386, "Emergency services for voice over IP telephony (E-VoIP)," issued August 20, 2013 (the "'386 Patent").

The Invention Explained

• Problem Addressed: The patent's background section describes a critical safety flaw in early Voice over IP (VoIP) telephone systems Compl. ¶¶10-11 Unlike traditional landlines where a phone number was tied to a fixed physical address, a VoIP phone could be used anywhere with an internet connection Compl. ¶11 '386 Patent, col. 1:24-29 This mobility meant that emergency services relying on static databases could dispatch responders to an incorrect, registered address instead of the user's actual location during a crisis Compl. ¶12 '386 Patent, col. 1:34-44
• The Patented Solution: The invention proposes a method and system to dynamically locate a VoIP device by using multiple, separate location detection technologies (LDTs) like GPS, cellular triangulation (CDMA, GSM), or Wi-Fi Compl. ¶16 '386 Patent, col. 7:55-65 The system makes a "plurality of attempts" to find the device's location, stores the coordinates from any successful attempt, and then automatically transmits this real-time location data to an emergency call center when an emergency number is dialed '386 Patent, abstract '386 Patent, claim 1 This multi-technology approach is intended to increase the reliability of location detection, even if one particular method fails '386 Patent, col. 7:66-8:1
• Technical Importance: The claimed invention provides a technical framework for E-911 (Enhanced 911) services for mobile and nomadic internet telephony, aiming to provide a level of location-based safety comparable to that of traditional telephone networks Compl. ¶17

Key Claims at a Glance

• The complaint asserts infringement of exemplary claims, with a focus on independent Claim 1 and dependent Claims 12 and 27 Compl. ¶27
• Independent Claim 1 recites a method with the following essential elements:
  • 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 other claims, but its reference to "exemplary claims" suggests additional claims may be asserted later Compl. ¶27

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in charts which are incorporated by reference but not included with the filed complaint document Compl. ¶27 Compl. ¶32

Functionality and Market Context

The complaint does not provide a technical description of how the accused products operate. It alleges, on information and belief, that "numerous other devices that infringe the claims of the '386 Patent have been made, used, sold, imported, and offered for sale by Defendant and/or its customers" Compl. ¶27 Without further detail, the specific functionality and market context of the accused instrumentalities cannot be analyzed from the complaint alone.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an "Exhibit 2" to detail its infringement allegations; however, this exhibit was not provided Compl. ¶32 Compl. ¶33 The narrative allegations in the complaint form the basis for the following summary.

Plaintiff's core infringement theory is that Defendant's products and services practice the patented method for providing emergency location services Compl. ¶32 The complaint alleges that Defendant directly infringes by making, using, selling, or importing products that embody the claimed invention Compl. ¶27 The allegations center on the use of multiple LDTs to find a user's location and automatically transmit it to emergency services (Compl. ¶15; Compl. ¶16). The complaint specifically highlights that the inventive concepts of Claim 1 are embodied in the steps of "making a plurality of attempts to determine the physical location" and "automatically transmitting" that location Compl. ¶18 It further alleges that dependent Claim 12 (related to comparing location data from different LDTs) and dependent Claim 27 (related to assessing network reliability) are also infringed Compl. ¶23 Compl. ¶24

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "VoIP phone"

• Context and Importance: This term appears throughout the claims, including the preamble of Claim 1. The patent was filed when dedicated VoIP hardware was more common. Its construction will be central to determining whether the patent's claims can read on modern multi-function devices, such as smartphones running software applications, which may be the accused instrumentalities in this case.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the term is not limited to dedicated hardware, stating the present invention can be used with "soft phones", which are described as "a software based VoIP phone which uses the computer's internet connection" Compl. ¶¶25 '386 Patent, col. 7:43-46 This could support an interpretation that covers software applications on general-purpose devices.
  • Evidence for a Narrower Interpretation: The detailed description and figures often depict a discrete "VoIP phone" as a hardware component connected to other network hardware like a modem or Ethernet MAC '386 Patent, Fig. 3 '386 Patent, col. 6:50-54 This could support an argument that the claims are directed to a specific type of telephony device rather than general-purpose computing devices.

The Term: "making a plurality of attempts to determine the physical location ... each using a separate location detection technology ('LDT')"

• Context and Importance: This limitation defines the core technical process of the invention. The infringement analysis will depend on whether the accused product's method of determining location qualifies as making multiple "attempts" with "separate" technologies as envisioned by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent lists a wide range of LDTs, including "GPS, CDMA and GSM technologies," "Wi-Fi, WiMAX, and other such technologies" '386 Patent, col. 7:59-65 The claim language does not require the attempts to be simultaneous, which could support a reading on systems that use technologies sequentially (e.g., trying GPS first, then falling back to Wi-Fi).
  • Evidence for a Narrower Interpretation: The specification discusses "simultaneously detect[ing] the current location" and describes comparing data from individual LDTs "to determine if any discrepancies exist" '386 Patent, col. 7:52-54 '386 Patent, col. 8:1-5 This could support a narrower construction requiring the "plurality of attempts" to occur in a manner that allows for contemporaneous comparison and validation, rather than just as a series of independent fallbacks.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct and encourage end users to use the accused products in a manner that infringes the '386 Patent Compl. ¶30 The allegation of knowledge for inducement is based on the service of the complaint and its accompanying (but not provided) claim charts Compl. ¶31
• Willful Infringement: The complaint alleges Defendant had "actual knowledge" of its infringement from the service of the complaint Compl. ¶29 It alleges that despite this knowledge, Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" the infringing products, which may form the basis for a claim of post-suit willfulness Compl. ¶30

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

This case appears to present three central questions for the court to resolve, contingent on the specific nature of the accused products which are not yet detailed in the pleadings.

• A core issue will be one of definitional scope: can the term "VoIP phone," which is rooted in the context of dedicated internet telephony devices from the mid-2000s, be construed to cover a modern smartphone running a financial services application that incorporates location-based features?
• A second issue will be one of technical mechanism: what is the precise operational sequence of the accused product's location-finding feature? The case may turn on whether its functionality constitutes a "plurality of attempts" using "separate" technologies as claimed, or if it operates in a fundamentally different manner that falls outside the claim scope.
• A crucial evidentiary question will be the nexus to emergency services: the claims require placing a call and transmitting location to an "emergency services call center." Plaintiff will need to provide evidence that the accused financial technology products perform this specific function, a point on which the complaint is currently silent.