ReadyComm LLC v. Vonage Holdings Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ReadyComm LLC (New Mexico)
  • Defendant: Vonage Holdings Corp. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:26-cv-00099, D. Del., 01/28/2026
• Venue Allegations: Venue is asserted based on Defendant having an established place of business in the District of Delaware and having committed alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s telephone communication products and services infringe a patent related to a system for managing a group of telephone devices by designating one as "active" for handling calls while others remain in a "stand-by" mode.
• Technical Context: The dispute is situated in the field of unified communications and Voice over IP (VoIP), where users often manage calls across multiple platforms, such as desk phones, mobile applications, and computer-based softphones.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,179,011 - "Telephone Communication System and Method of Using"

• Patent Identification: U.S. Patent No. 9,179,011, "Telephone Communication System and Method of Using," issued November 3, 2015.

The Invention Explained

• Problem Addressed: The patent's background describes the increasing difficulty of contacting individuals who use multiple communication devices (e.g., home phone, work phone, mobile phone), leading to a proliferation of telephone numbers and user inconvenience ('011 Patent, col. 1:20-32). Conventional call forwarding systems are described as having limitations '011 Patent, col. 1:33-54
• The Patented Solution: The invention proposes a system where a group of telephone devices are linked. At any given time, only one device is in an "active mode," capable of making or receiving calls. All other devices in the group are in a "stand-by mode," rendering them incapable of placing or receiving calls until a user actively switches which device is the active one '011 Patent, abstract '011 Patent, col. 2:58-63 This switch can be performed "on-the-fly," allowing a call to be transferred from a previously active device to a newly activated one '011 Patent, col. 3:16-24
• Technical Importance: The described technology aims to simplify call management for users with multiple devices by centralizing communication through a single, user-selectable active device at any given time '011 Patent, col. 2:38-44

Key Claims at a Glance

The complaint does not specify which claims of the ’011 Patent are asserted, referring only to "Exemplary '011 Patent Claims" detailed in an unprovided exhibit Compl. ¶11 For illustrative purposes, the elements of the first independent claim are presented below.

• Independent Claim 1:
  • A telephone communication system comprising a group of N telephones (where N is at least two).
  • Each telephone is configured to be placed in either an "activated mode" or a "stand-by mode," where a telephone in stand-by mode is "incapable of placing or receiving a call unless switched to active mode."
  • Each telephone is associated with a switch.
  • The switch is configured to activate one telephone, which places all other (N-1) telephones in stand-by mode.
  • At least one of the stand-by telephones is configured to be switchable to active mode during a telephone call.
• The complaint alleges infringement of one or more claims of the ’011 Patent Compl. ¶11

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products, referring to them generally as the "Exemplary Defendant Products" Compl. ¶11

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It states that infringement allegations and comparisons of the accused products to the patent claims are detailed in "charts of Exhibit 2," which was incorporated by reference but not included with the filed complaint document Compl. ¶16 Compl. ¶17 The complaint makes a conclusory allegation that these products "practice the technology claimed by the '011 Patent" Compl. ¶16

IV. Analysis of Infringement Allegations

The complaint incorporates by reference an external claim chart exhibit (Exhibit 2) that was not provided with the filed complaint document Compl. ¶17 As such, a detailed claim chart summary cannot be constructed. The complaint's narrative infringement theory is that the "Exemplary Defendant Products" satisfy all elements of the asserted claims Compl. ¶16 No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's claims and the nature of modern VoIP services, the infringement analysis may raise several technical and legal questions for the court.

• Scope Questions: A primary issue may be whether the term "telephone," as used in the patent, can be construed to cover software-based clients (softphones) on general-purpose devices like computers and smartphones, which are common in Defendant's industry. The patent specification contemplates a "computer" as a potential telephone device '011 Patent, col. 4:28-29, which may support a broader reading.
• Technical Questions: A key factual dispute may arise over whether the accused products implement a "stand-by mode" that renders a device "incapable of placing or receiving a call" as required by the claims '011 Patent, col. 15:46-48 The analysis may question whether the accused products truly disable non-active devices or instead use a functionally different call-routing architecture (e.g., simultaneous ringing or sequential forwarding) that does not align with the claim's specific requirements.

V. Key Claim Terms for Construction

The Term: "telephone"

• Context and Importance: The definition of this term is fundamental to the scope of infringement. Practitioners may focus on this term because its construction will determine whether modern software-based VoIP applications on multi-purpose hardware (e.g., PCs, smartphones) are covered by claims that frequently use traditional hardware examples like "landline" and "cellular" phones.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification explicitly lists a "computer, car telephone, etc. and equivalents thereof" as examples of telephone devices, suggesting the term is not limited to traditional handsets '011 Patent, col. 4:28-29
  • Evidence for a Narrower Interpretation: The detailed examples in the specification and figures primarily focus on distinct hardware devices like a "landline telephone" and a "cellular telephone," which could be used to argue for a construction limited to dedicated communication hardware '011 Patent, col. 6:3-5

The Term: "stand-by mode such that in stand-by mode a telephone is incapable of placing or receiving a call"

• Context and Importance: This limitation defines the core technical difference between the active and non-active devices. The dispute will likely center on the meaning of "incapable."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The system's overall description suggests a functional state where calls are simply not routed to the stand-by device by the network or system, rather than requiring the device's own hardware to be physically disabled. The patent explains that a stand-by device "cannot make or receive calls" within the context of the system's operation '011 Patent, col. 2:62-63
  • Evidence for a Narrower Interpretation: The word "incapable" could be argued to require a more absolute state of disability at the device level, beyond a mere server-side routing instruction. A defendant may argue that if a softphone application is merely minimized but still connected to the network, it is not truly "incapable" of receiving a call, even if the system is configured not to send one to it.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct and encourage end users to use the products in a manner that infringes the ’011 Patent Compl. ¶14

Willful Infringement

• The complaint does not contain a specific count for willful infringement. However, it alleges that service of the complaint constitutes actual knowledge of infringement Compl. ¶13 and asserts that Defendant's continued alleged infringement after this notice supports a claim for induced infringement Compl. ¶15 The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which could provide a basis for seeking enhanced damages or attorneys' fees Compl., Prayer E.i.

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

• A core issue will be one of definitional scope: Can the term "telephone" and its associated "active" and "stand-by" modes, which are described in the patent using examples of distinct hardware, be construed to read on the software-centric architecture of modern VoIP systems where applications on a single device may represent different communication endpoints?
• A key evidentiary question will be one of technical mechanism: Does the accused system's method for managing calls across multiple devices implement a true "stand-by mode" that renders non-primary devices "incapable" of communication as claimed, or does it rely on a different, non-infringing technical approach such as network-level call forwarding or simultaneous ringing logic?