Lexington's Companion Telegram Suit Asserts Five Patents on Buffering, Messaging, and Calling.

The parties and the court

The case is Lexington Technologies, LLC v. Telegram Messenger Inc., No. 2:26-cv-00942 (E.D. Tex.), Marshall Division. The parties, the jurisdictional allegations, and the venue allegations match the companion complaint in No. 2:26-cv-00941. Lexington is a Texas limited liability company located in Allen, Texas. Telegram Messenger Inc. and Telegram Group Inc. are British Virgin Islands corporations with principal places of business in Dubai, United Arab Emirates. Telegram FZ-LLC is a United Arab Emirates company with offices in Dubai. The complaint alleges, on information and belief, that Telegram Group Inc. wholly owns Telegram Messenger Inc. and that Telegram FZ-LLC is an indirect subsidiary of Telegram Group Inc.

Subject matter jurisdiction is pleaded under 28 U.S.C. 1331 and 1338(a), and the complaint says the action arises under 35 U.S.C. 271, 281, 284, and 285. Venue is pleaded under 28 U.S.C. 1391(b) and (c) because each defendant is a foreign company, with an alternative allegation of personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2). The complaint says Telegram Group Inc. and Telegram Messenger Inc. acknowledged that they operate Telegram servers in Miami, Florida, citing a declaration filed August 17, 2026, in QR Switch, LLC v. Telegram Group Inc., No. 2:26-cv-00254 (E.D. Tex.).

The patents and the accused functions

The complaint alleges Lexington owns the five patents. U.S. Patent 10,136,441, titled Systems and methods of buffering application data operable at a delivery control server, issued November 20, 2018, from Application No. 14/485,700, filed September 13, 2014. The complaint alleges direct infringement of at least claim 4, and it accuses Telegram applications that provide content delivery, including the client applications for Android, iOS, Windows, Linux, macOS, and web browsers, and Telegram iOS client application version 12.9.4. U.S. Patent 11,240,816, titled Distributed implementation of dynamic wireless traffic policy, issued February 1, 2022, from Application No. 16/919,873, filed July 2, 2020. The complaint alleges direct infringement of at least claim 4 and accuses the same content-delivery applications.

U.S. Patent 11,695,877, titled System and method for providing a network service in a distributed fashion to a mobile device, issued July 4, 2023, from Application No. 17/385,988, filed July 27, 2021. The complaint alleges direct infringement of at least claim 1 and accuses applications that provide messaging and voice calling. U.S. Patent 11,800,018 has the same title, issued October 24, 2023, from Application No. 17/964,364, filed October 12, 2022. The complaint alleges direct infringement of at least claim 1 and accuses applications that provide messaging and Live Location. U.S. Patent 12,432,304 has the same title, issued September 30, 2025, from Application No. 18/406,731, filed January 8, 2024. The complaint alleges direct infringement of at least claim 1 and accuses applications that provide messaging and voice calling.

Google Patents lists all five patents as active. It lists July 8, 2031, as the anticipated expiration of the '816 patent, and it lists adjusted expirations of July 1, 2033, for the '441 patent, May 27, 2028, for the '877 patent, January 11, 2028, for the '018 patent, and March 29, 2028, for the '304 patent.

What the lead patents cover

Claim 4 of U.S. Patent 10,136,441 covers a method of buffering application data operable at a mobile device. The mobile device transmits, to a delivery control server, information that identifies applications used by the mobile device, and transmits a request to buffer application data for the identified applications. Buffering application data conserves signaling bandwidth. The method detects user activity at the mobile device, transmits an activity notification to the delivery control server upon detecting that activity, and receives buffered application data for at least one of the identified applications in response.

Claim 4 of U.S. Patent 11,240,816 covers a method of buffering application data operable at a mobile device with the same transmitting, detecting, and receiving steps, and it adds two limits. Transmitting the request to buffer application data is based on inactivity of the mobile device. Receiving the buffered application data includes receiving a notification message targeted to the mobile device. Buffering application data conserves signaling bandwidth.

Claim 1 of U.S. Patent 11,695,877 covers a system for providing communication services, with a memory and one or more processors. The system receives a unique authentication token from a first device and provides communication services associated with that token. The services are branded by a provider of the communication services that is other than a provider of a mobile network, and the application software on the first device is branded by that provider. An identifier, which is a phone number associated with the first device, is stored by both providers, and the services are associated with the identifier. The system provides the services through each of a Wi-Fi network and the mobile network. The services include a user generated message generated at the first device for transmission to a second device. The system monitors availability of a user of the second device, causes an indication of that availability to be displayed on the first device, and sends the user generated message to the second device.

What the complaint alleges

Each count alleges direct infringement under 35 U.S.C. 271(a) and induced infringement under 35 U.S.C. 271(b), literally or under the doctrine of equivalents. The complaint's illustration for claim 4 of the '441 patent describes buffering application data, including photos, and transmitting application identifiers to a delivery control server. The October 1, 2026 FedEx letter described in No. 2:26-cv-00941 is pleaded here as well: the complaint alleges the letter told Telegram that "the Telegram platform infringes numerous patents in Lexington's portfolio" and offered a data room with claim charts. The complaint alleges willful infringement and enhanced damages under 35 U.S.C. 284, compliance with 35 U.S.C. 287 to the extent necessary, and patent eligibility under 35 U.S.C. 101.

Relief requested

The prayer asks for judgment of infringement and willful infringement, an accounting, a reasonable ongoing post-judgment royalty, pre-judgment and post-judgment interest, and a judgment that the case is exceptional under 35 U.S.C. 285 together with enhanced damages. Lexington demands a jury under Federal Rule of Civil Procedure 38. Counsel are the same Dallas lawyers as in No. 2:26-cv-00941: Patrick J. Conroy, Ryan P. Griffin, T. William Kennedy Jr., Jonathan H. Rastegar, Nathan L. Levenson, and Brandon G. Moore of Nelson Bumgardner Conroy PC.

What it means

This complaint and No. 2:26-cv-00941 were filed the same day, against the same defendants, from the same October 1 letter, and they divide the accused Telegram functions. Google Patents lists the five patents in this case as active. The '816 patent's listed anticipated expiration is July 8, 2031. Under 35 U.S.C. 286, recovery is barred for infringement committed more than six years before the complaint.

What to watch next

Watch for Telegram's answer or a Rule 12 motion, any motion to coordinate the case with No. 2:26-cv-00941, and any petition for inter partes review. The case can end at any time, including by settlement or voluntary dismissal.

Related page: Lexington v. Telegram, No. 2:26-cv-00941.