The Amazon complaint

The case is Avant Location Technologies LLC v. Amazon.com Services LLC, No. 2:26-cv-00934 (E.D. Tex., Marshall Division), an 89 page complaint for patent infringement filed October 16, 2026, ECF No. 1, with the claim charts set out in the body of the complaint. The complaint says Avant is a Texas limited liability company based in Marshall, Texas, and that Amazon.com Services LLC is a Delaware limited liability company based in Seattle, Washington and a wholly owned subsidiary of Amazon.com, Inc. The complaint is signed by Peter Lambrianakos and also lists Alfred R. Fabricant, Vincent J. Rubino, III, and Julian G. Pymento of Fabricant Rubino & Lambrianakos LLP in Rye, New York. The docket shows the case assigned to Judge Rodney Gilstrap.

Jurisdiction and venue

The complaint pleads venue under 28 U.S.C. 1391(b) through (d) and 1400(b). For venue, it points to Amazon fulfillment centers in Fort Worth and Richardson, Texas, and alleges acts of infringement in the district.

The six patents

The complaint asserts U.S. Patent Nos. 8,738,040 (issued May 27, 2014), 10,009,720 (June 26, 2018), 9,042,910 (May 26, 2015), 8,934,922 (January 13, 2015), 9,119,030 (August 25, 2015), and 9,485,621 (November 1, 2016). All six share the title Method and System for Monitoring a Mobile Station Presence in a Special Area. The complaint identifies the inventor as Carlos A. Perez LaFuente of Afirma Consulting & Technologies, S.L., and alleges that Avant owns all right, title, and interest in the patents. Each patent names Afirma Consulting & Technologies, S.L. as assignee on its face. The USPTO assignment entries that Google Patents lists for all six record an assignment from Afirma to Avant, effective May 19, 2023 and recorded July 17, 2023 (reel 064282, frame 0057), and Google Patents lists Avant as the current assignee.

Claim 1 of the '040 patent covers a method for monitoring the presence of a mobile station in one or more special areas. A radio communication defining device repeatedly transmits a radio distinctive defining signal whose coverage at least partially defines a special area. The mobile station processes received signals to determine whether a signal is a distinctive defining signal and whether the station is present in a special area. It sends an updating signal to a mobile telephone network that is uncorrelated to any phone call establishment, periodically, on entering or exiting a special area, or while remaining in one. The network routes the updating signal to special operating means that adapt at least one operating parameter, and the special areas are associated with the mobile station by transmitting checking data to it.

The complaint quotes claim 1 of each of the other five patents. As quoted, claim 1 of the '720 patent covers sending, via a mobile telephone network, an updating signal to servers of a provider of presence related services, used to adjust an operating parameter that comprises a tariff or a service flag, with the distinctive defining signal carrying information on whether the defining device is in a predetermined environment. Claim 1 of the '910 patent, as quoted, uses first and second distinctive defining signals that define a special area by the sum or intersection of their coverage. Claim 1 of the '922 patent, as quoted, stores first and second checking data for two defining devices, transmits them to the mobile station, receives updating signals for two special areas, and enables or disables a presence related service for each. Claims 1 of the '030 and '621 patents, as quoted, store checking data and a mobile station identifier, receive an updating signal, and enable or disable a presence related service, and the '621 claim adds that the provider of presence related services is different from the mobile telephone network.

The infringement allegations

The Accused Products, as the complaint defines them, are Echo and Ring devices that support the Sidewalk protocol, including Echo Dot, Echo Show, Echo Hub, Ring Floodlight Cam, and Ring Bridge models, and Amazon Sidewalk Cloud Servers. Each of Counts I through VI, one per patent, alleges direct infringement of at least claim 1 under 35 U.S.C. 271, literally or under the doctrine of equivalents. The complaint maps an Amazon Sidewalk mobile endpoint, such as an asset tracker, to the claimed mobile station, Sidewalk gateways such as Echo and Ring devices to the radio communication defining devices, and the gateway beacon to the distinctive defining signal, citing Amazon Sidewalk documentation.

Each count also alleges that Amazon induces infringement by its customers and end users through instructions, documentation, and marketing, and alleges contributory infringement under 35 U.S.C. 271(c). The complaint alleges Amazon had actual notice of the patents from related prior litigations accusing products with similar functionality involving direct competitors of Amazon, and alleges knowledge, intent, or willful blindness. It also alleges compliance with the marking statute, 35 U.S.C. 287.

The relief sought

The prayer asks for a judgment of infringement, a permanent injunction under 35 U.S.C. 283, damages no less than a reasonable royalty with interest and costs, a finding of willfulness with treble damages under 35 U.S.C. 284, and a finding that the case is exceptional with attorney fees under 35 U.S.C. 285. The complaint demands a jury.

Earlier Avant suits

Avant has sued on this patent family before. Its earlier Eastern District of Texas cases, each assigned to Judge Gilstrap, named Ecobee Technologies ULC (No. 2:23-cv-00354, filed July 31, 2023), Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (No. 2:24-cv-00133, February 23, 2024), Fibar Group S.A. and Nice S.p.A. (No. 2:24-cv-00165, March 8, 2024), Apple Inc. (No. 2:24-cv-00757, September 13, 2024), and ADT Inc. and ADT LLC (No. 2:26-cv-00011, January 6, 2026). Avant v. Apple dockets also appear in the Western District of Texas (No. 7:25-cv-00445, filed October 1, 2025) and the Northern District of Texas (No. 3:25-cv-02642, docketed September 30, 2025). Google Patents lists each of these cases against one or more of the six asserted patents.

What to watch next

Watch for service on Amazon.com Services LLC and for an answer, a Rule 12 motion, or a motion to transfer venue.

Also watch for petitions for inter partes review of any of the six patents at the Patent Trial and Appeal Board.