Lab Technology LLC v. Solera Holdings LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lab Technology LLC (New Mexico)
  • Defendant: Solera Holdings, LLC (Delaware)
  • Plaintiff's Counsel: Rabicoff Law LLC; Crewse Law Firm, PLLC
• Case Identification: 4:26-cv-00297, N.D. Tex., 03/12/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant maintains an established place of business in the district and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to automatically refreshing a telephone display with contextually relevant communication services based on factors such as time or location.
• Technical Context: The technology addresses user interface efficiency on communication devices by dynamically presenting services most likely to be used in a given situation, a foundational concept in context-aware computing.
• Key Procedural History: The asserted patent is subject to a terminal disclaimer.

Case Timeline

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

U.S. Patent No. 9,219,982 - Apparatus and method for automatically refreshing a display of a telephone

The Invention Explained

• Problem Addressed: The patent describes the problem of users having to navigate through numerous menu displays on a telephone to find a desired communication or information service, even though they tend to use the same services routinely at specific times or in particular locations '982 Patent, col. 1:29-41
• The Patented Solution: The invention proposes a telephone that automatically refreshes its display screen to present a set of commonly used communication services based on a "function" '982 Patent, abstract This "function" represents a given set of user conditions, such as time of day or the device's physical location, allowing the telephone to proactively display relevant services (e.g., traffic reports in the morning, restaurant directories in the evening) without manual navigation by the user '982 Patent, col. 2:11-28 '982 Patent, Fig. 4 '982 Patent, Fig. 5
• Technical Importance: The technology sought to improve the user experience by making device interfaces context-aware, reducing the number of steps required to access frequently needed services '982 Patent, col. 2:4-9

Key Claims at a Glance

• The complaint asserts one or more claims of the '982 Patent, but does not identify them specifically, referring to them as the "Exemplary '982 Patent Claims" Compl. ¶11 Independent claim 1 is representative of the invention.
• Essential elements of Independent Claim 1:
  • A telephone comprising a display panel, a processor, and a datastore.
  • The datastore comprises at least one "function" that includes information about the telephone's current location and a user.
  • The function is associated with at least one communication service.
  • The processor is operable to connect to a location server to obtain the telephone's current location.
  • The processor is operable to select a function from the datastore.
  • The processor is operable to refresh a screen on the display panel to include the communication service associated with the selected function, based at least in part on the current location.
• The complaint does not explicitly reserve the right to assert dependent claims.

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 describe the functionality of the accused products. It alleges that infringement details are contained in claim charts attached as Exhibit 2, which was not filed with the complaint Compl. ¶16 Compl. ¶17 No allegations regarding the products' commercial importance are made.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts (Exhibit 2) which were not provided with the publicly filed document Compl. ¶16 Therefore, a detailed claim chart summary cannot be constructed. The complaint's narrative theory is that the "Exemplary Defendant Products practice the technology claimed by the '982 Patent" and "satisfy all elements of the Exemplary '982 Patent Claims" Compl. ¶16

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the patent claims and the general nature of the technology, the infringement analysis may raise several questions.
  • Scope Questions: A central question may be how the term "telephone," as used in a 2006-priority-date patent, applies to modern multi-function devices. Similarly, the definition of a "communication service" could be a point of dispute.
  • Technical Questions: A key technical question will be whether the accused products perform the claimed steps of connecting to a "location server" to "obtain a current location" and then using that specific location data to "select a function from the datastore" to refresh the screen, as required by the claim '982 Patent, claim 1 The evidence must show that the accused system architecture maps onto this specific claimed process.

V. Key Claim Terms for Construction

• The Term: "function"

  • Context and Importance: This term is central to the claims, as it is the mechanism that links a user's context (like location) to a set of displayed services. Its construction will determine what types of contextual profiles or user states can meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that a function "represents a given set of conditions associated with a user" which "may be static, such as user ID, or variable, such as time, location, activity or the like" '982 Patent, col. 2:19-22 This language suggests a broad range of possible conditions.
    • Evidence for a Narrower Interpretation: The claims require the function to comprise "information relating to a current location of the telephone and a user" '982 Patent, claim 1 Embodiments describe specific examples, such as an "office worker on weekday morning" or a "shopper's role at a shopping mall," which could be used to argue that a "function" requires a pre-defined, role-based profile rather than any transient set of conditions '982 Patent, col. 4:34-35 '982 Patent, col. 5:3-4

• The Term: "current location"

  • Context and Importance: The infringement analysis will depend on the required precision and source of the "current location" data. Whether this term covers generalized location awareness (e.g., city-level) versus precise coordinates, or location derived from different sources (e.g., GPS, Wi-Fi, cell tower triangulation), will be critical.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a wide range of examples for "location information," including "the name of a geographical region, a city," "the identity of a shopping mall," or "cellular coverage information, such as an identity of a radio base station" '982 Patent, col. 5:45-60 This suggests the term is not limited to a specific type or precision of location data.
    • Evidence for a Narrower Interpretation: Claim 1 explicitly requires the processor to "connect the telephone to a location server to obtain a current location" '982 Patent, claim 1 A defendant may argue this requires a specific client-server architecture for obtaining location, potentially excluding systems where location is determined entirely on-device without an external "location server" query.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that allegedly infringes the '982 Patent Compl. ¶14
• Willful Infringement: The willfulness allegation is based on post-suit knowledge. Plaintiff alleges that the service of the complaint provides Defendant with "actual knowledge of infringement" and that any subsequent infringing activities are therefore willful Compl. ¶13 Compl. ¶14

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

• A core issue will be one of evidentiary support: Given the complaint's lack of specific allegations regarding the accused products, a primary question is what evidence Plaintiff will produce to demonstrate that the unidentified "Exemplary Defendant Products" actually perform the specific architecture claimed-namely, using a processor to query a location server, select a pre-defined "function" from a datastore based on that location, and refresh a display accordingly.
• A second key issue will be one of definitional scope: The case may turn on the construction of the term "function." The court will need to determine whether a "function" requires a discrete, stored profile linking a specific context to a set of services, as depicted in the patent's embodiments, or if it can be construed more broadly to cover any algorithm that dynamically changes a user interface based on contextual inputs like location.