Atlas Global Tech LLC v. Walmart Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Atlas Global Technologies LLC (Texas)
  • Defendant: Walmart Inc. (Delaware)
  • Plaintiff's Counsel: Nelson Bumgardner Conroy PC
• Case Identification: 2:26-cv-00317, E.D. Tex., 04/21/2026
• Venue Allegations: Plaintiff alleges venue is proper because Walmart maintains regular and established places of business within the Eastern District of Texas and has committed acts of direct and induced infringement within the District.
• Core Dispute: Plaintiff alleges that Defendant's products that implement the Wi-Fi 6 (IEEE 802.11ax) standard infringe four patents related to wireless communication protocols, including methods for constructing training sequences and protecting transmissions.
• Technical Context: The lawsuit concerns technologies foundational to the Wi-Fi 6 standard, which was developed to improve the performance, efficiency, and capacity of wireless local area networks, particularly in high-density environments.
• Key Procedural History: The patents-in-suit were developed by Newracom, a company described as a major contributor to the 802.11ax standard. The complaint also notes that Defendant Walmart acquired Vizio Holding Corp. in December 2024, and that Vizio-branded products are among the accused instrumentalities.

Case Timeline

Date	Event
2015-03-25	Priority Date for U.S. Patent No. 9,628,310
2015-08-07	Priority Date for U.S. Patent Nos. 10,348,471 and 10,965,425
2015-10-12	Priority Date for U.S. Patent No. 10,020,919
2016-03-01	First draft of the 802.11ax (Wi-Fi 6) Standard published
2017-04-18	U.S. Patent No. 9,628,310 Issued
2018-07-10	U.S. Patent No. 10,020,919 Issued
2019-07-09	U.S. Patent No. 10,348,471 Issued
2021-02-09	IEEE approves final version of the 802.11ax-2021 Standard
2021-03-30	U.S. Patent No. 10,965,425 Issued
2024-12-03	Walmart completes acquisition of Vizio Holding Corp.
2025-12-31	Vizio-branded TVs allegedly began operating under Walmart's direction
2026-04-21	Complaint Filed

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

U.S. Patent No. 9,628,310 - "Long Training Field Sequence Construction" (Issued April 18, 2017)

The Invention Explained

• Problem Addressed: The complaint describes the evolution of Wi-Fi standards to address the need for higher throughput and better performance in dense wireless environments Compl. ¶16 The development of high-efficiency (HE) wireless networks required new methods for devices to accurately estimate the wireless channel.
• The Patented Solution: The '310 patent discloses specific methods for constructing High Efficiency Long Training Field (HE-LTF) sequences used for channel estimation in Wi-Fi communications Compl. ¶37 The invention defines a plurality of distinct HE-LTF sequences, with each sequence corresponding to a specific combination of channel bandwidth (e.g., 20, 40, or 80 MHz) and HE-LTF mode (e.g., 2x or 4x mode), enabling devices to generate and interpret the correct training symbols for reliable communication Compl. ¶¶38-42
• Technical Importance: Standardized training sequences are fundamental for interoperability and performance in modern WLANs, allowing devices to adapt to changing channel conditions efficiently.

Key Claims at a Glance

• The complaint asserts independent claims 1 and 15 Compl. ¶33 Compl. ¶43
• Claim 1 (Access Point Method):
  • determine a channel bandwidth among a plurality of bandwidths (20, 40, 80 MHz);
  • determine an HE-LTF mode among a plurality of modes (4x, 2x);
  • generate an HE-LTF symbol by using an HE-LTF sequence corresponding to the determined bandwidth and mode, where the sequence is one of a plurality of specific, defined sequences; and
  • transmit an HE PPDU including the HE-LTF symbol in the determined channel bandwidth.
• Claim 15 (Non-Access Point Station Method):
  • receive a downlink HE PPDU including an HE-LTF symbol in a channel bandwidth (one of 20, 40, 80 MHz); and
  • obtain from the symbol an HE-LTF sequence corresponding to the bandwidth and an HE-LTF mode (one of 4x, 2x), with specific structural requirements for the sequence at 40 MHz and 2x HE-LTF mode.
• The complaint also asserts dependent claims 2-3, 5-7, 9-14, and 18-20 Compl. ¶32 Compl. ¶52

U.S. Patent No. 10,020,919 - "Protection Methods for Wireless Transmissions" (Issued July 10, 2018)

The Invention Explained

• Problem Addressed: The patent's background section notes that as wireless networks perform multi-user (MU) communications, protection mechanisms are needed to prevent one station's transmissions from interfering with another's '919 Patent, col. 1:17-25 Efficiently managing these mechanisms, such as Request-to-Send/Clear-to-Send (RTS/CTS) exchanges, is critical to maintaining high network throughput '919 Patent, col. 1:17-25
• The Patented Solution: The patent describes a method for a wireless device to participate in a "sounding" procedure to measure channel state. The device receives a Null Data Packet Announcement (NDPA) frame, which indicates how many stations are involved. If it is the only station, it transmits Channel State Information (CSI) feedback after receiving a subsequent Null Data Packet (NDP). If multiple stations are involved, it waits for a trigger frame before transmitting its feedback, often as part of a coordinated multi-user uplink '919 Patent, col. 3:61-col. 4:24 This provides an orderly method for an access point to collect channel information from one or multiple devices without collisions.
• Technical Importance: This structured sounding protocol allows an access point to efficiently gather channel state information, a prerequisite for advanced multi-user technologies like MU-MIMO and OFDMA that are central to Wi-Fi 6's performance gains.

Key Claims at a Glance

• The complaint asserts independent claims 1 and 11 Compl. ¶62 Compl. ¶67
• Claim 1 (Receiving Station Method):
  • receive a Null Data Packet Announcement (NDPA) including one or more station information fields;
  • determine the number of station information fields;
  • receive a Null Data Packet (NDP); and
  • when the number of station information fields is one, transmit first Channel State Information (CSI) feedback in response to receiving the NDP.
• Claim 11 (Transmitting Station Method):
  • transmit a Null Data Packet Announcement (NDPA) including one or more station information fields;
  • transmit a Null Data Packet (NDP); and
  • when the number of station information fields in the NDPA is one, receive first Channel State Information (CSI) feedback transmitted in response to the NDP.
• The complaint also asserts dependent claims 2-10 Compl. ¶69 Compl. ¶71

Multi-Patent Capsule: U.S. Patent No. 10,348,471

• Patent Identification: U.S. Patent No. 10,348,471, "Control Information for Multi-User Transmissions in WLAN Systems," Issued July 9, 2019.
• Technology Synopsis: The patent addresses the need for efficiently signaling resource allocation in multi-user Wi-Fi transmissions. It discloses a frame structure for an access point that uses High-Efficiency Signal-B (HE-SIG-B) fields to allocate resources to multiple stations, including an "additional indication" for allocating a special resource unit (like a center 26-tone RU) only when the channel bandwidth is sufficiently large (e.g., 80 MHz) '471 Patent, abstract '471 Patent, col. 1:1-12
• Asserted Claims: Independent claim 1 is asserted Compl. ¶81
• Accused Features: The complaint alleges that access point devices sold by Walmart, such as the NETGEAR AX1600 router, generate and transmit multi-user frames that use the claimed HE-SIG-B field structure to allocate resources in compliance with the Wi-Fi 6 standard Compl. ¶¶82-85

Multi-Patent Capsule: U.S. Patent No. 10,965,425

• Patent Identification: U.S. Patent No. 10,965,425, "Control Information for Multi-User Transmissions in WLAN Systems," Issued March 30, 2021.
• Technology Synopsis: As a continuation of the application leading to the '471 patent, this patent also relates to control information for multi-user transmissions. It describes a frame structure with first and second HE-SIG-B fields, each containing common information fields (for resource allocation) and station-specific information fields, which are transmitted to a plurality of stations '425 Patent, abstract
• Asserted Claims: Independent claims 1 and 8 are asserted Compl. ¶104 Compl. ¶117
• Accused Features: The complaint alleges that Wi-Fi 6 access points sold by Walmart generate frames with the claimed HE-SIG-B structure, while non-AP stations (like Vizio smart TVs) receive and process these frames to determine their resource unit assignments Compl. ¶¶105-108 Compl. ¶¶118-121

III. The Accused Instrumentality

Product Identification

• The complaint broadly accuses any and all products sold by Walmart that "comply with, implement, support, or utilize the Wi-Fi 6 Standard" Compl. ¶26 Exemplary products listed include Vizio and Onn-branded smart TVs and streaming devices, as well as third-party Wi-Fi 6-enabled routers, laptops, and other devices from brands like NETGEAR, Roku, Hisense, TCL, and MSI Compl. ¶27, pp. 15-19

Functionality and Market Context

• The accused products are alleged to operate as either access points (APs) or non-AP stations within a Wi-Fi 6 network Compl. ¶44 Compl. ¶82 Their accused functionality stems directly from their mandatory implementation of the IEEE 802.11ax (Wi-Fi 6) standard Compl. ¶26 This includes generating, transmitting, and receiving specific data packet structures (HE PPDUs) that contain HE-LTF symbols for channel estimation and HE-SIG-B fields for resource allocation (Compl. ¶37, Compl. ¶84). The complaint provides screenshots of product listings for a NETGEAR router and a Vizio TV, highlighting their advertised "WiFi 6" capability as a key feature for enabling faster streaming and better performance Compl. p. 21 This visual from the complaint shows a Vizio TV product page highlighting its "Dual-band WiFi 6" capability Compl. p. 23

IV. Analysis of Infringement Allegations

'310 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an access point (AP) determining a channel bandwidth among a plurality of bandwidths including a 20 megahertz (MHz) channel bandwidth, a 40 MHz channel bandwidth, and an 80 MHz channel bandwidth;	Accused AP devices determine a channel bandwidth (20, 40, or 80 MHz) for operation, as required by the Wi-Fi 6 standard. The standard specifies parameters like CBW20, CBW40, and CBW80 for these bandwidths.	¶38	col. 4:2-4
determining a high efficiency long training field (HE-LTF) mode among a plurality of HE-LTF modes including a 4×HE-LTF mode and a 2×HE-LTF mode;	Accused devices determine an HE-LTF mode (e.g., 1x, 2x, 4x) for the HE PPDU transmission, as mandated by the Wi-Fi 6 standard.	¶39	col. 4:5-7
generating an HE-LTF symbol by using an HE-LTF sequence corresponding to the determined channel bandwidth and the determined HE-LTF mode...	Accused devices generate an HE-LTF symbol using a specific sequence from a plurality of sequences defined in the Wi-Fi 6 standard, which corresponds to the chosen bandwidth and mode.	¶40	col. 4:8-11
wherein the HE-LTF sequence is among a plurality of HE-LTF sequences for the plurality of bandwidths and the plurality of HE-LTF modes...	The complaint alleges the standard specifies distinct HE-LTF sequences for different bandwidth/mode combinations, such as a first sequence for 20MHz/4x mode, a second for 20MHz/2x mode, a third for 40MHz/4x mode, etc.	¶42	col. 4:11-30
transmitting a high efficiency physical layer protocol data unit (HE PPDU) including the HE-LTF symbol in the determined channel bandwidth.	Accused devices transmit an HE PPDU containing the generated HE-LTF symbol, as illustrated in standard-defined formats like the HE SU PPDU format. The complaint includes a figure from the standard showing the structure of an HE PPDU which contains an HE-LTF field Compl. p. 27	¶41	col. 4:31-34

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the "plurality of HE-LTF sequences" defined in the Wi-Fi 6 standard, and allegedly practiced by the accused products, are structurally identical to the sequences defined and claimed in the '310 patent. The dispute may focus on whether minor differences in sequence construction or notation between the patent and the standard create a non-infringement defense.
  • Technical Questions: The infringement case appears to be a "standards case," where infringement is alleged by showing the accused products comply with a standard that practices the patent. A key evidentiary question will be whether Walmart's products, in fact, fully and correctly implement the relevant mandatory portions of the Wi-Fi 6 standard as alleged.

'919 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
at a wireless device, receiving a Null Data Packet Announcement (NDPA) including one or more station information fields;	An accused device (a beamformee) receives an NDPA frame from a beamformer, as part of the HE Sounding protocol defined in the Wi-Fi 6 standard.	¶64	col. 3:61-64
determining exactly a number of the one or more station information fields in the NDPA;	The device determines the number of "STA Info" fields in the received NDPA frame to ascertain the number of stations participating in the sounding procedure. The complaint provides a figure from the standard showing the NDPA frame format with "STA Info 1 ... STA Info n" fields Compl. p. 38	¶66	col. 3:65-66
receiving a Null Data Packet (NDP); and	After receiving the NDPA, the device receives an NDP frame from the beamformer, which is used for channel estimation.	¶65	col. 3:67-col. 4:1
in response to determining that the number of the one or more station information fields in the NDPA is one, transmitting first Channel State Information (CSI) feedback in response to receiving the NDP.	When the device determines there is only one "STA Info" field in the NDPA, it transmits CSI feedback to the beamformer. The complaint includes a diagram from the standard illustrating this single-beamformee sounding sequence Compl. p. 37	¶65; ¶66	col. 4:1-4

• Identified Points of Contention:
  • Scope Questions: The claim requires transmitting CSI feedback "in response to determining that the number of... station information fields... is one." A potential point of contention could be whether the accused device's logic for transmitting CSI is strictly contingent on this determination in the manner required by the claim, or if other conditions could also trigger the transmission.
  • Technical Questions: Does the "HE sounding NDP" described in the Wi-Fi 6 standard Compl. p. 37 function as the claimed "Null Data Packet"? Similarly, does the "HE Compressed Beamforming/CQI" function as the claimed "Channel State Information (CSI) feedback"? The analysis will likely involve mapping the terminology and technical steps of the standard to the specific language of the claim elements.

V. Key Claim Terms for Construction

For the '310 Patent

• The Term: "an HE-LTF sequence corresponding to the determined channel bandwidth and the determined HE-LTF mode"
• Context and Importance: This term is the core of the invention. The infringement case hinges on whether the HE-LTF sequences mandated by the Wi-Fi 6 standard and used by the accused products are the same as the sequences defined by this claim term. Practitioners may focus on this term because the patent's definition of the required sequences must be shown to read on the sequences actually used by the accused devices.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent claims a method of using a sequence corresponding to a mode and bandwidth, which could be argued to cover any sequence that serves that function, as long as it is selected from the patent's disclosed plurality. The claim language "is among a plurality of HE-LTF sequences" suggests the invention is not limited to a single, rigid sequence for each scenario but a defined set of options.
  • Evidence for a Narrower Interpretation: Claim 15 provides a very specific structure for the HE-LTF sequence when the bandwidth is 40 MHz and the mode is 2xHE-LTF, detailing zero and non-zero values on specific subcarrier indices '310 Patent, col. 24:26-44 A defendant may argue this detailed embodiment limits the term's scope to only sequences with this exact mathematical construction, potentially excluding slightly different implementations in the final standard.

For the '919 Patent

• The Term: "determining exactly a number of the one or more station information fields in the NDPA"
• Context and Importance: The claim's logic depends on the outcome of this "determining" step; the device transmits CSI feedback only "in response to determining that the number... is one." Infringement requires showing the accused device performs this specific check. Practitioners may focus on this term to see if it implies a specific software or hardware process of counting or cardinality assessment that must be proven.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the process in functional terms: a wireless device receives an NDPA and, based on its contents, participates in a sounding procedure '919 Patent, col. 4:25-50 This could support an interpretation where any method of parsing the NDPA to ascertain the number of participating stations meets the "determining" limitation.
  • Evidence for a Narrower Interpretation: The term "determining exactly" could be argued to require more than just passively receiving the information. A defendant might suggest this requires a specific, discrete step of counting the fields and storing the result before proceeding, and that a more integrated or implicit process in the accused device does not meet this limitation. The patent does not appear to provide a specific algorithm, which may weaken arguments for a narrow construction.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for all four patents. The allegations are based on Walmart creating and disseminating advertisements and instruction manuals that promote and guide end-users on how to use the Wi-Fi 6 features of the accused products, thereby causing them to perform the infringing methods Compl. ¶53 Compl. ¶72 Compl. ¶95 Compl. ¶133 The complaint also alleges Walmart induces its affiliates and subsidiaries by having them manufacture and use the accused products Compl. ¶52 Compl. ¶132
• Willful Infringement: The complaint alleges willful infringement for all four patents, stating that Walmart's infringement has continued despite having knowledge of the patents Compl. ¶55 Compl. ¶74 Compl. ¶97 Compl. ¶135 The basis for this knowledge is alleged to be, at a minimum, the service of the complaint, suggesting the willfulness claim is based on post-suit conduct Compl. ¶53 Compl. ¶72 Compl. ¶95 Compl. ¶133

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

1. A central issue will be one of standards-essentiality and claim scope: The complaint asserts that compliance with the Wi-Fi 6 standard necessarily results in infringement. A primary question for the court will be whether the specific technical requirements of the asserted claims-such as the exact structure of the HE-LTF sequences in the '310 patent or the precise logic of the sounding protocol in the '919 patent-are identical to the mandatory implementations within the 802.11ax standard, or if there are material differences that could support a finding of non-infringement.
2. A key technical question will be one of operative functionality: Can the plaintiff demonstrate that the accused devices perform the claimed methods under normal operating conditions? For the '919 patent, this will involve showing that when a single device is being sounded, it follows the specific "NDPA -> NDP -> CSI Feedback" sequence as claimed. For the '310 patent, it will require proving that the devices generate and transmit HE-LTF symbols using sequences that are structurally indistinguishable from those defined in the patent's claims.
3. A significant legal question will relate to damages and liability for standards-compliant products: Given that the accused functionality is tied to a widely adopted industry standard, the case may raise complex questions regarding the appropriate royalty base and rate for patents alleged to be essential to that standard, as well as the extent of Walmart's liability as a seller of third-party compliant products.