The complaint

The case is E2E Systems LLC v. Cable One, Inc., No. 2:26-cv-00969-JRG-RSP (E.D. Tex.), filed October 28, 2026, in the Marshall Division. The case number on the filed complaint carries the initials JRG-RSP, for Judge Rodney Gilstrap and Magistrate Judge Roy S. Payne. Plaintiff E2E Systems LLC is a Texas limited liability company with its registered office in Austin, Texas. Defendant Cable One, Inc. is a Delaware corporation with its principal place of business in Phoenix, Arizona. The complaint says Cable One operates and markets its services through brands including Sparklight, which it describes, quoting Sparklight's terms and conditions, as a "doing business as" name of Cable One. A jury trial is demanded.

Jurisdiction and venue

The complaint pleads subject-matter jurisdiction under 28 U.S.C. 1331 and 1338(a) for an action arising under 35 U.S.C. 271, 281, and 284-285. It alleges personal jurisdiction from Cable One's substantial business in the district, including at least a portion of the alleged infringements and regularly doing or soliciting business in, or deriving substantial revenue from goods and services provided to individuals in, Texas and the district. Venue is pleaded under 28 U.S.C. 1400(b) on the theory that Cable One maintains a regular and established place of business in the district, including locations in Marshall and Longview, Texas, and has committed acts of infringement there, including use of the accused products.

The patents and claims

Count I asserts U.S. Patent 8,037,041, titled "System for dynamic keyword aggregation, search query generation and submission to third-party information search utilities," issued October 11, 2011. Count II asserts U.S. Patent 7,826,567, titled "Method and apparatus for coarse and fine frequency and timing synchronisation," issued November 2, 2010. Count III asserts U.S. Patent 7,725,128, titled "Integrated instant messaging and web browsing client and related methods," issued May 25, 2010. Count IV asserts U.S. Patent 7,400,640, titled "Partitioned medium access control implementation," issued July 15, 2008. Count V asserts U.S. Patent 7,933,293, titled "Link margin notification using return frame," issued April 26, 2011. Count VI asserts U.S. Patent 8,565,164, titled "Wireless mesh architecture," issued October 22, 2013. Count VII asserts U.S. Patent 7,574,553, titled "Digital component power savings in a host device and method," issued August 11, 2009. Count VIII asserts U.S. Patent 7,643,480, titled "Method and system for reliably and efficiently transporting data over a network," issued January 5, 2010.

The complaint says E2E Systems owns all substantial rights in each Asserted Patent, including the exclusive right to sue for infringement. It asserts at least claim 1 of the '041, '567, '128, '640, '293, and '164 patents, at least claim 12 of the '553 patent, and at least claim 44 of the '480 patent, as detailed in Exhibits A through H.

What the patents cover

U.S. Patent 8,037,041 covers methods that receive real-time textual input entered into a document, parse that input in a background processing mode to aggregate keywords or phrases into search submissions, submit those searches to a search facility distinct from the computing device, receive responsive search results, and display the results. Claim 1 covers a method of receiving by a computing device real-time textual input entered into a document; contemporaneously parsing that input in a background processing mode to aggregate keywords or phrases based on parsing rules and formatting the aggregated keywords into one or more search submissions; submitting the searches to a search facility distinct from the computing device; receiving search results responsive to the submitted searches; and displaying the search results.

U.S. Patent 7,826,567 covers a receiver that converts frequency signals into baseband signals comprising preamble symbols and data symbols and that synchronises processing with coarse and fine time synchronization stages. Claim 1 covers a receiver with a processing stage for converting frequency signals into baseband signals comprising preamble symbols and data symbols, and a synchronization stage comprising a first part for coarse time synchronization with an autocorrelating unit for autocorrelating samples of a group of preamble symbols, and a second part for fine time synchronization with a crosscorrelating unit for crosscorrelating samples of a further group of preamble symbols with predefined samples, where the autocorrelating result is not used by the crosscorrelating unit.

U.S. Patent 7,725,128 covers computer storage media with program instructions for receiving and sending instant messages and receiving web page content through an integrated single application on a mobile-device screen. Claim 1 covers computer storage media with instructions for receiving instant messages, sending instant messages, and receiving web page content, enabling a user to view the instant messages and/or web page content via an integrated single application on a screen of a mobile device simultaneously, with a control module that includes instant messaging and web browser submodules and manages separate threads of those submodules in parallel.

U.S. Patent 7,400,640 covers an apparatus with a processor that generates an outgoing message and partitioned medium-access-control circuits that generate successive protocol data units for transmission to a remote terminal. Claim 1 covers an apparatus with a processor for generating an outgoing message to be transmitted to a remote terminal via a first service data unit; a first circuit providing a first medium-access-control service and generating a first protocol data unit based on that service data unit; a second circuit providing a second medium-access-control service and generating a second protocol data unit based on the first protocol data unit; a physical control generating a third protocol data unit based on the second and transmitting a first signal based on the third to the remote terminal; and a bus transferring signals between the processor and a peripheral and transferring the first protocol data unit from the first circuit to the second circuit; wherein the first, second, and third protocol data units are different.

U.S. Patent 7,933,293 covers wireless methods in which a first device receives frames from a second device, determines an overall link margin from a moving average of individual link margins, and transmits that overall link margin for reception by the second device in a second frame. Claim 1 covers a method of receiving, at a first wireless device, a plurality of first frames from a second wireless device; determining an overall link margin by calculating a moving average of individual link margins for each of the plurality of frames received from the second wireless device; and transmitting the overall link margin for reception by the second wireless device in a second frame.

U.S. Patent 8,565,164 covers methods of establishing a wireless network communication channel between two end points by negotiating a rendezvous that includes selecting a rendezvous channel and rendezvous instance characteristic, and storing those values at each end point. Claim 1 covers a method in which two end points negotiate a rendezvous, including selecting at least one rendezvous channel and rendezvous instance characteristic of the link, and store the rendezvous channel and rendezvous instance characteristic at each of the end points of the link, where the rendezvous instance characteristic is a rendezvous duration, and selecting a rendezvous duration includes selecting a desired rendezvous duration, receiving a proposed rendezvous duration, and selecting as the rendezvous duration of the link the greater of the desired rendezvous duration and the proposed rendezvous duration.

U.S. Patent 7,574,553 covers a computer system in which a host outputs commands over a data bus to peripheral devices whose control sections turn operational-section power on and off. Claim 12 covers a computer system with a host device having a data bus and a plurality of peripheral devices each coupled to the data bus, the host configured to output commands to each peripheral device over the data bus; a first peripheral device includes a control section and an operational section; the control section is programmed to evaluate the commands and, if an address of one of the commands corresponds to the first device, to turn on power to the operational section; and the control section is configured to turn off power to the operational section and to draw no more than a leakage current following an idle time in which no commands addressed to the first device are output over the host bus.

U.S. Patent 7,643,480 covers a data transport system with a server that packages data into packets that include a sequence number field in the payload, and a receiving proxy cache that controls transmission, verification, retransmission, buffering, and forwarding of those packets. Claim 44 covers a data transport system comprising a server configured to package data into a plurality of data packets, including inserting a sequence number field into a payload of the data packets; and a receiving proxy cache configured to control transmission of those packets from the server to a first buffer over an efficient channel; verify transmission status using at least one of the sequence number field, a checksum field, and a timestamp field; control retransmission of a data packet from the server over a reliable channel in response to detecting a transmission error; transfer complete packets from the first buffer to a second buffer; store them in the second buffer; and forward them from the second buffer to a client receiver via at least one data stream connection in response to a request.

The accused products

The complaint defines the Accused Products as products and services Cable One makes, uses, sells, offers for sale, imports, provides, supplies, or distributes, including: (i) the Sparklight support website and its real-time text-entry search functionality; (ii) Wi-Fi devices supporting IEEE 802.11n (Wi-Fi 4) and later standards; (iii) the Sparklight App; (iv) IEEE 802.11be (Wi-Fi 7) devices, including eero Wi-Fi 7 devices; (v) wireless mesh network devices compliant with the Thread networking stack, including eero devices; (vi) wireless mesh network devices operating under IEEE 802.11; (vii) computing devices, including modems such as the Hitron CODA-5719, Hitron CODA-4782, and ARRIS DG3450; and (viii) the SparklightTV data transport system and app. It also says Cable One owns, operates, advertises, and/or controls cableone.biz and sparklight.com, including support.sparklight.com, and makes the Sparklight App and SparklightTV app available through smartphone app providers.

The infringement allegations

The complaint says that, apart from facts about E2E Systems itself, its allegations are made on information and belief. Each of Counts I through VIII alleges that Cable One has directly infringed the asserted claim, literally or under the doctrine of equivalents, by using, selling, offering to sell, providing, supplying, or distributing the Accused Products; Counts VII and VIII add making and importing. Each count points to one of Exhibits A through H as exemplary evidence of use. Each count also alleges induced infringement since at least the time Cable One received the original complaint, and contributory infringement, and says Cable One has known of the patent at least since it was notified of the filing of this action. The complaint alleges, on information and belief, that Cable One has a policy or practice of not reviewing the patents of others, including instructing its employees not to review them, and so has been willfully blind to E2E Systems' patent rights. It alleges willful infringement. It also alleges irreparable harm through loss of market share and goodwill and interference with E2E Systems' ability to license technology, and argues that the balance of hardships and the public interest support an injunction.

The relief sought

The prayer seeks judgment of infringement, literally or under the doctrine of equivalents; a permanent injunction or, in the alternative, a reasonable ongoing royalty; an award of all damages and costs caused by the alleged infringement; a finding of willfulness and treble damages under 35 U.S.C. 284; pre- and post-judgment interest; a declaration that the case is exceptional with attorneys' fees under 35 U.S.C. 285; further injunctive relief; and other just relief.

What to watch next

Watch for Cable One's answer or Rule 12 motion, any early willfulness or venue challenges, and claim-construction scheduling in the Marshall Division.