IP Law Daily, PATENT—D. Del.: RingCentral partially defeats infringement claims in licensing entity’s lawsuit, (Mar 13, 2026)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

The court held that several allegations relying on Apache Kafka software were insufficiently pled under the Twombly/Iqbal plausibility standard.

The federal district court in Wilmington, Delaware, has granted in part and denied in part a motion to dismiss filed by cloud communications provider RingCentral, Inc., in a patent infringement lawsuit brought by a licensing entity. The court dismissed claims relating to five asserted patents because the complaint failed to plausibly allege direct infringement and contained substantive pleading deficiencies, but it allowed other claims to proceed after concluding that the licensing entity adequately alleged direct, induced, and contributory infringement. The court further granted the plaintiff leave to amend its complaint to cure the identified defects (Arlington Technologies LLC v. RingCentral, Inc., No. 1:25-cv-00613-JCG (D. Del. Mar. 10, 2026)).

Background. Arlington Technologies LLC, the plaintiff, is a Texas-based patent holding company. The defendant, RingCentral, Inc., is a Delaware corporation headquartered in California that develops and markets cloud-based communications, video conferencing, and collaboration services used by businesses worldwide.

The dispute concerned eight U.S. patents owned by Arlington: U.S. Patent Nos. 7,366,110 (the ’110 patent), 7,441,141 (the ’141 patent), 8,145,945 (the ’945 patent), 9,026,836 (the ’836 patent), 7,668,304 (the ’304 patent), 10,630,733 (the ’733 patent), 9,432,517 (the ’517 patent), and 9,094,572 (the ’572 patent). The patents generally relate to communication technologies, including systems for reconstructing phone calls, network device backup, conferencing systems, meeting recording permissions, and audio-triggered action detection in conversations.

Arlington filed the action alleging that RingCentral’s products—including Webinar, RingSense, Video Meetings, and Rooms—directly and indirectly infringed the patents under 35 U.S.C. § 271. The complaint alleged that the accused products relied on distributed messaging and conferencing technologies, including Apache Kafka software, and that these features performed methods claimed in Arlington’s patents. After Arlington filed a first amended complaint asserting direct, induced, contributory, and willful infringement, RingCentral moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that the allegations were speculative, internally inconsistent, and insufficient under modern pleading standards.

Direct infringement. The court first examined Arlington’s direct infringement claims relating to four patents—the ’110, ’141, ’945, and ’836 patents. Arlington alleged that RingCentral’s services incorporated Apache Kafka and Apache Kafka Streams software components and that those components implemented patented communication recovery and failover features.

Applying the pleading framework established in Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), the court concluded that these allegations lacked sufficient clarity and factual support. The court noted that although a plaintiff need not prove its case at the pleading stage, it must provide enough factual content to allow a reasonable inference of infringement. The Federal Circuit similarly emphasized this requirement in Bot M8 LLC v. Sony Corp. of America, 4 F.4th 1342 (Fed. Cir. 2021), which held that a complaint must plausibly explain how the accused product practices the patent claims.

Here, the court determined that Arlington’s complaint failed to adequately connect RingCentral’s products with the allegedly infringing Apache Kafka features. The complaint relied heavily on examples from Apache Kafka itself rather than explaining how RingCentral’s implementation of the software infringed the asserted claims. The court also found inconsistencies regarding whether the allegations concerned Apache Kafka generally or the separate “Kafka Streams” component.

Because of these pleading deficiencies, the court dismissed Counts I–IV but granted Arlington leave to amend its complaint.

Reliance on source code discovery. Arlington also argued that more detailed evidence of infringement would emerge once it obtained RingCentral’s confidential source code in discovery. The court rejected this justification as insufficient to satisfy pleading standards.

Although courts recognize that certain technical details may only become available during discovery, the complaint must still contain plausible factual allegations connecting the accused product to the patent claims. The court distinguished WiTricity Corp. v. Momentum Dynamics Corp., 563 F. Supp. 3d 309 (D. Del. 2021), where plaintiffs had attached detailed claim charts or other supporting materials.

In this case, Arlington alleged that claim charts had been provided during pre-suit discussions but did not attach them to the complaint. Without such supporting material, the court held that Arlington’s allegations were insufficient to plausibly demonstrate infringement.

Conferencing patents. The court reached a different conclusion regarding Arlington’s claims involving three other patents—the ’304, ’733, and ’572 patents—which concern conferencing and meeting-management technologies.

For those claims, the complaint identified specific RingCentral products and provided an element-by-element explanation of how the products allegedly practiced the patented methods. The complaint quoted the relevant claim language and described the accused features—such as participant hierarchy displays, meeting recording permissions, and conferencing system authentication modules. Thus, the court concluded that these allegations provided RingCentral with sufficient notice of the infringement claims and therefore satisfied Rule 8 pleading requirements. Accordingly, the court denied RingCentral’s motion to dismiss Counts V, VI, and VIII.

Error in pleading action-item patent claim. However, the court dismissed Count VII relating to the ’517 patent after finding that Arlington had incorrectly identified the asserted claim in the complaint.

Although Arlington alleged infringement of Claim 8 of the ’517 patent, the complaint quoted and analyzed the limitations of Claim 1 instead. The court determined that this was not merely a typographical error but a substantive defect that prevented the court from evaluating whether the claim had been plausibly pleaded. Because the mistake affected the substance of the infringement allegations, the court dismissed Count VII while granting Arlington leave to amend the pleading.

Induced and contributory infringement. The court next addressed Arlington’s claims for indirect infringement under 35 U.S.C. § 271(b) and § 271(c). Under Federal Circuit precedent, such claims require proof of an underlying act of direct infringement, as explained in In re Bill of Lading Transmission and Processing System Patent Litigation, 681 F.3d 1323 (Fed. Cir. 2012). Because Arlington plausibly alleged direct infringement for the ’304, ’733, and ’572 patents, the court proceeded to evaluate the associated indirect infringement allegations.

The court concluded that Arlington sufficiently alleged induced infringement by describing extensive pre-suit communications between the parties beginning in March 2024. According to the complaint, Arlington informed RingCentral of the asserted patents, provided claim charts and evidence-of-use materials, and engaged in licensing discussions under a nondisclosure agreement.

The court held that these allegations plausibly showed that RingCentral had knowledge of the patents and continued to market and support the accused products despite being aware of the alleged infringement. It noted that under Global-Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (2011), such knowledge can support a claim for induced infringement.

The court also allowed Arlington’s contributory infringement claims to proceed, finding that the complaint plausibly alleged that the accused conferencing features were specially adapted for infringing uses and lacked substantial non-infringing alternatives.

Willful infringement. Finally, the court declined to dismiss Arlington’s willful infringement allegations. Enhanced damages for willful infringement are governed by the Supreme Court’s decision in Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. 93 (2016), which permits increased damages for egregious infringement behavior.

The court found that Arlington’s allegations, including detailed notice of the patents and continued marketing of the accused products, were sufficient at the pleading stage to support a plausible inference of willful infringement.

Disposition. In conclusion, the court dismissed the direct, indirect, and willful infringement claims relating to the ’110, ’141, ’945, ’836, and ’517 patents, but allowed Arlington an opportunity to file a second amended complaint correcting the deficiencies. The court denied the motion to dismiss with respect to the claims involving the ’304, ’733, and ’572 patents.

The Case is No. 1:25-cv-00613-JCG.

Judge: Choe-Groves, J.

Attorneys: Stephen B. Brauerman (Bayard, P.A.) for Arlington Technologies LLC. Ben Yenerall (Morris Nichols Arsht and Tunnell LLP) for RingCentral, Inc.

Companies: Arlington Technologies LLC; RingCentral, Inc.

Cases: Patent DelawareNews