Call Interface Patent Survives Early Section 101 Challenge in Delaware

Mod Stack accused Aculab of infringing U.S. Patent No. 7,460,520, which relates to "a system and method for simultaneously interfacing with different types of call controllers in a voice gateway." The patent specification states that although "call controllers may use different call control protocols, the voice gateway adapts each of these different control protocols to a common representation so that all can be interface simultaneously."

Aculab moved to dismiss the complaint, contending that (1) the asserted claims were directed to the abstract idea of using a common language to translate between two foreign languages; and (2) Mod Stack's allegations of direct infringement failed to state a claim upon which relief may be granted.

The court was not persuaded and, in a concise opinion, the court rejected both of the defendant's arguments. Concerning patent eligible subject matter, the court found that the defendant failed to propose a satisfactory abstract idea. The court, instead, found that the patent claims recite an allegedly new way for improving a voice gateway, such that it may simultaneously handle multiple call control protocols and messages. "It seems that [this claim] is directed to much more than just using a common language as a translation tool."

The court also found that the complaint alleged facts sufficient to meet a plausible infringement claim. For instance, the complaint identified a specific product, the overall purpose of the invention, a description of the elements of the claim, and provided representative infringement contentions. The complaint's allegations were also supported by various publicly-accessible documents.

For the above reasons, the court denied Aculab's motion to dismiss.

Claim 1 of the asserted patent reads:

An apparatus connecting a local packet network (LPN) and a circuit-switched network, the apparatus comprising:

a first protocol endpoint configured to receive at least one first external call control message of a first protocol from a first call controller associated with the circuit-switched network and to map the at least one first external call control message to at least one corresponding first internal call control message of an internal protocol;

a second protocol endpoint configured to receive at least one second external call control message of a second protocol from an integrated access device (IAD) associated with the LPN and to map the at least one second external call control message to at least one corresponding second internal call control message of an internal protocol; and

a protocol adapter configured to receive the first and the second internal call control messages and to route the at least one first internal call control message to the second protocol endpoint and the at least one second internal call control message to the first protocol endpoint;

wherein the first protocol endpoint is further configured to receive the at least one second internal call control message and to map the at least one second internal call control message to a third external call control message of the first protocol, and