CommWorks Solutions, LLC v. Texas Instruments Incorporated

I'll research this case thoroughly before drafting the overview.

Let me dig into the complaint specifics, the patents, and TI's accused products.

Now let me verify the patent ownership lineage, NPE structure, and any PTAB/IPR activity on these specific patents.

CommWorks Solutions, LLC v. Texas Instruments Incorporated — Case Overview & Background

Parties. CommWorks Solutions, LLC is a Georgia limited liability company with its registered office in Alpharetta (Fulton County), and it is a non-practicing entity (NPE) — specifically a subsidiary/affiliate of Georgia monetization firm IP Investments Group LLC, founded in 2005 by Michael McLaughlin. CommWorks does not make or sell products; its asserted portfolio was acquired from Intellectual Ventures (IV), as part of a late-2019/early-2020 divestiture in which IV transferred thousands of patents to a group of Georgia LLCs associated with IP Investments Group. CommWorks launched its networking/Wi-Fi assertion campaign in May 2020 with a suit against Consolidated Communications Holdings and has since targeted cable/telecom operators (Charter, Comcast, RCN, Mediacom, Cable One), equipment makers (D-Link, ZyXEL, Extreme Networks, Technicolor, Axon Networks, EarthLink), and chipmakers (Broadcom, Qualcomm, STMicroelectronics, and here, TI). Texas Instruments is the Dallas-headquartered global semiconductor company and, for purposes of this campaign, the relevant actor is TI's wireless connectivity / SimpleLink Wi-Fi business (Wi-Fi SoCs and modules). CommWorks is represented by Rozier Hardt McDonough PLLC (James F. McDonough III, Jonathan L. Hardt, Carey M. Rozier, Kenneth A. Matuszewski); TI's counsel of record on the early filings was Amanda A. Abraham of The Roth Law Firm PC (per the docket and third-party reporting).

Accused technology and asserted patents. The case is a Wi-Fi-standards-style assertion: CommWorks accused TI connectivity products that implement Wi-Fi Protected Setup (WPS) and Wi-Fi Multimedia / 802.11-2007+ QoS (WMM) functionality — i.e., the TI Wi-Fi SoC/module families that carry those near-universal features. Third-party reporting (PatSnap) identifies the accused TI parts as the SimpleLink CC3xxx family (CC3100, CC3200, CC3220, CC3235, CC3300, CC3301) and WL18xx modules, spanning 70+ part numbers; I could not verify that specific part list against the complaint text itself, so treat the precise model list as unconfirmed. The complaint seeks monetary damages only (no injunction), with willfulness/treble-damages allegations — consistent with the patents' age. The case metadata lists four asserted patents, all with early-2000s priority that CommWorks acquired from IV:

• U.S. 7,177,285 – "Time Based Wireless Access Provisioning" — claims time-based provisioning/association of a device by tracking an operating parameter (power-on or onset of signal transmission) and triggering provisioning if it occurs within a defined interval. This is the WPS push-button concept.
• U.S. 7,463,596 – "Time Based Wireless Access Provisioning" — same family; a process for associating devices within a time interval. Also WPS-oriented.
• U.S. 7,911,979 – "Time Based Access Provisioning System and Process" — provisioning logic that tracks a device parameter and sends a provisioning signal within a designated time interval. WPS-oriented.
• U.S. RE44,904 – "Method for Contention Free Traffic Detection" (reissue of 7,027,465) — extracting a bit pattern at a predetermined frame position, comparing it to a search pattern, identifying/flooding priority frames to a high-priority queue, and adjusting the priority period. This is the WMM / 802.11e QoS concept. (Note: reporting on the broader campaign — including a PatSnap blog post — suggests CommWorks may have also pleaded 6,832,249, 6,891,807 and 7,027,465 against TI; that conflicts with the authoritative four-patent metadata and I have not verified a seven-patent theory.)

Procedural posture, venue, and disposition. Filed April 24–25, 2025 in the U.S. District Court for the Eastern District of Texas, Marshall Division, Case No. 2:25-cv-00439, assigned to Judge Rodney Gilstrap — one of the district's busiest patent jurists on a plaintiff-favored "rocket docket." Venue is notable because TI is a Dallas/North Texas company, so E.D. Tex. was a plaintiff-selected forum rather than TI's home district. TI was served April 29, 2025 and obtained an extension of time to answer (due July 12, 2025). Before any answer or substantive motion practice, the parties filed a joint motion to stay all deadlines and notice of settlement (Dkt. 12, July 1, 2025), which Judge Gilstrap granted (Dkt. 13, July 8, 2025); the July 16 case-management conference was cancelled. The parties then filed a Stipulation of Dismissal under Fed. R. Civ. P. 41(a)(1)(A)(ii) (Dkt. 14), and Judge Gilstrap entered an order dismissing the case with prejudice on July 15, 2025 (Dkt. 15), with each side bearing its own costs. The case thus ran roughly 81 days from filing to termination, with no claim construction, no invalidity ruling, and no judicial finding on infringement.

Why it matters. Three themes make this case a useful marker of 2025 NPE behavior. First, speed and no-risk monetization: a with-prejudice dismissal at day 81 — before any merits ruling — is the classic signature of an early confidential settlement/license, and it leaves CommWorks' patents at "full presumptive strength" with no adverse precedent, potentially encouraging further assertions against other WPS/WMM-capable chip vendors (MediaTek, NXP, Broadcom, Qualcomm were flagged by commentators as remaining potential targets). Second, parallel-campaign coordination: CommWorks filed a cluster of 2025 suits against chipmakers — Qualcomm (E.D. Tex., Feb. 2025; voluntarily dismissed in March 2025 after Qualcomm moved to dismiss for improper venue under Rule 12(b)(3)), Broadcom (C.D. Cal., Apr. 2025), TI (E.D. Tex., Apr. 2025), and STMicroelectronics (W.D. Tex., Aug. 2025) — a coordinated sweep of the semiconductor layer of the Wi-Fi supply chain stemming from the IV patent transfer. Third, IPR/PTAB linkage: the CommWorks/IP Investments Group portfolio is under an active defensive attack by Unified Patents, which has pursued ex parte reexamination and IPR challenges on related CommWorks patents (e.g., the '249 patent reexam, Unified's 90/014,909, granted Dec. 2021; IPR2021-01297 on U.S. 8,923,846), so the value CommWorks extracts in quick settlements is partly a function of the validity risk being litigated elsewhere. The recurring commercial takeaway for IoT/embedded Wi-Fi teams is that WPS and WMM compliance — features baked into essentially every Wi-Fi Alliance–certified SoC — is the asserted hook.

Sourcing caveats: The docket events, judge, filing/serving dates, and the July 15, 2025 dismissal-with-prejudice are confirmed by the E.D. Tex. docket (Justia/PACER, Dkt. 12–16) and RPX Empower. Party identity, the IP Investments Group/IV lineage, and the campaign history are confirmed by RPX/Mondaq, Unified Patents, and IPWatchdog reporting. The specific accused TI part numbers, the "seven patents" characterization, and the settlement/license inference are from third-party/AI-generated analysis (PatSnap) and are not independently verified; the patents assumed here are the four in the authoritative case metadata. The docket demonstrates the case ended by stipulated dismissal, not by any merits or validity holding, and the dismissal terms are undisclosed.

I'll research this case across the docket, PTAB, and legal news sources.

CommWorks Solutions, LLC v. Texas Instruments Inc., No. 2:25-cv-00439-JRG (E.D. Tex.)

Bottom line: This was a short-lived, pre-answer case. It never produced an answer, counterclaims, a Rule 12 motion, a transfer or IPR-stay motion, claim construction, discovery, or trial. It was filed in late April 2025 and terminated on 2025-07-15 by a joint stipulation of dismissal with prejudice under FRCP 41(a)(1)(A)(ii), following a 2025-07-01 notice of settlement. The entire docket is 16 entries.

Sourcing note: the docket below is drawn from the Justia/RPX mirrors of the PACER docket for 2:25-cv-00439. The full complaint text was not retrievable in full; where I rely on secondary (AI-generated litigation-summary) sources for counsel, accused products, or patent counts, I flag it. Party names, court, case number, and the four asserted patents are taken as authoritative from the case metadata.

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Chronological developments

1. Pre-filing campaign context (2021–2025)
CommWorks Solutions, LLC is a Georgia LLC based in Alpharetta, GA, described in IPWatchdog's filings roundups as affiliated with IP Investments Group. It is a serial Wi-Fi/802.11 licensor asserting a stable portfolio (e.g., U.S. 6,832,249; 7,027,465; 7,177,285; 7,760,664; 8,923,846) against networking OEMs, ISPs, and chipmakers — Comcast (W.D. Tex. 6:21-cv-00366), Technicolor (1:22-cv-02827), D-Link (6:22-cv-00806), Adtran (N.D. Ala. 5:23-cv-01327), and, in 2025, a large wave including AVM (2:25-cv-00026), Qualcomm/Marvell-related entities (W.D. Tex. 7:25-cv-00101; 7:25-cv-00354), STMicroelectronics (7:25-cv-00363), NXP USA (7:25-cv-00395), u‑blox (E.D. Va. 1:25-cv-02504), and EarthLink (E.D. Tex. 2:25-cv-00716).

2. 2025-04-24/25 — Complaint filed (Dkt. 1)
CommWorks filed a § 271 patent infringement complaint against TI in the Marshall Division, E.D. Tex. (Case metadata gives filing date 2025-04-24; the Justia docket mirror shows the complaint docketed 2025-04-25.) Four patents asserted:

• U.S. 7,177,285 and 7,463,596 and 7,911,979 (wireless access/WPS provisioning family, descending from U.S. 6,891,807)
• U.S. RE44,904 (reissue of the "Method for Contention Free Traffic Detection" family; WMM/802.11e QoS)

Relief sought was monetary damages only (no injunction request), consistent with the other CommWorks complaints.

Venue was pleaded on TI's own Texas footprint — the complaint points to TI's Richardson, Texas 300-mm wafer fabs and offices, and expressly notes that TI "has not contested the propriety of venue in this District for patent infringement actions" (citing Led Apogee, LLC v. Texas Instruments Inc., 2:24-cv-0996-JRG). Accused products: secondary (PatSnap) summaries describe them as TI Wi‑Fi SoCs (CC3x00/WL18xx families), but I could not verify the accused-product list from the primary complaint and would not rely on it.

3. 2025-04-25 — Plaintiff's counsel appearances (Dkt. 4, 5, 6)
Jonathan Lloyd Hardt, Carey Matthew Rozier, and Kenneth Andrew Matuszewski appeared for CommWorks. The lead firm is Rozier Hardt McDonough PLLC; James F. McDonough III (same firm) signed the later stipulation.

4. 2025-04-28 — Summons issued and case assigned (Dkt. 7)
Summons issued; Judge Rodney Gilstrap assigned; standard magistrate-judge consent notice entered.

5. 2025-04-29 — Service on TI (Dkt. 8)
TI served 2025-04-29; return filed 2025-04-30.

6. 2025-05-12 — Unopposed extension of TI's answer deadline (Dkt. 9, 10)
TI entered its first (and only) appearance through counsel and obtained an agreed extension: the motion recites an agreed answer date of 2025-07-03, and the order (Dkt. 10) set TI's response due 2025-07-12. Secondary sources identify TI's counsel as Amanda Aline Abraham of The Roth Law Firm PC (Marshall, TX) — unverified.

Significance: TI never answered, never counterclaimed for declaratory judgment of invalidity/non-infringement, and never filed a Rule 12(b) motion. There were therefore no counterclaims, no motions to dismiss, no § 1404 transfer motion, no § 1400(b) venue challenge, and no motion to stay pending IPR in this case. The extensions are what kept the case in a purely pre-answer posture.

7. 2025-06-26/30 — Scheduling/Case Management Conference set (Dkt. 11)
Judge Gilstrap set a scheduling/case-management conference for 2025-07-16, 09:30 — the first substantive case-management step.

8. 2025-07-01 — Joint motion to stay all deadlines + notice of settlement (Dkt. 12)
Filed by CommWorks jointly with TI, disclosing that the parties had settled and asking to stay all deadlines.

9. 2025-07-08 — Stay granted (Dkt. 13)
Judge Gilstrap granted the stay.

10. 2025-07-09 — 7/16 conference cancelled
Docket entry cancels the case-management conference in light of Dkt. 13.

11. 2025-07-15 — Stipulation of dismissal with prejudice, order, and AO 120 (Dkt. 14, 15, 16)
CommWorks filed a Stipulation of Dismissal invoking FRCP 41(a)(1)(A)(ii) ("dismissing all claims in this action with prejudice"); Judge Gilstrap entered Dkt. 15, ORDER DISMISSING CASE WITH PREJUDICE, the same day; the AO 120 patent form was sent to the USPTO (Dkt. 16). Per the case summary, each party bears its own costs; the settlement's terms are undisclosed.

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Stages that never occurred

Parallel PTAB proceedings

• No IPR/PGR petition on U.S. 7,177,285; 7,463,596; 7,911,979; or RE44,904 in connection with this case was identified in my searches. Because TI never answered and the case settled in under three months, no Fintiv/§ 315(b)-driven IPR strategy had time to develop.
• The only confirmed CommWorks-side PTAB proceeding I located is Unified Patents, LLC v. CommWorks Solutions, LLC, IPR2021-01297, challenging U.S. 8,923,846 — a different patent, asserted in the Comcast case, not in the TI case. It was filed 2021-07-30 by Unified Patents, went to an oral hearing (transcript 2022-12-22), and reached a Final Written Decision on 2023-02-13 (outcome not confirmed from the sources retrieved). Treat this as campaign background, not as a parallel challenge to the TI patents.
• Closest substantive history on these patents: the Comcast litigation (W.D. Tex. 6:21-cv-00366, Judge Albright) did reach claim construction — CommWorks's Patent Owner Response in IPR2021-01297 cites a Claim Construction Order dated 2022-03-08 (ECF No. 35) and the associated Markman briefing — and the case was later dismissed on 2022-07-01 on a motion to dismiss (ECF No. 50). So the asserted family has prior claim-construction exposure in another forum, but nothing in this case.

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Strategic read

• Repeat-player, fast-settlement pattern. This is the second CommWorks case in this portfolio to end pre-answer in 2025 (cf. NXP USA, 7:25-cv-00395, voluntarily dismissed with prejudice on an October 2025 Rule 41(a)(1)(A)(i) notice; STMicroelectronics, 7:25-cv-00363, dismissed November 2025). Combined with the roughly 82-day life of the TI case, the pattern is consistent with demand-letter-driven licensing rather than merits litigation.
• With-prejudice + 41(a)(1)(A)(ii). The bilateral stipulation is self-effectuating (no judicial action required), so the practical release is the stipulation itself; Dkt. 15 is formally redundant. The with-prejudice label bars CommWorks from re-suing TI on these patents for the same accused products, but it produces no invalidity, unenforceability, or non-infringement adjudication and no estoppel on the patents against anyone else. TI bought peace, not precedent.
• No collateral estoppel or IPR estoppel risk created. Because no claims were construed and no invalidity contentions were served, the dismissal leaves the four patents intact for assertion against other chipmakers (MediaTek, Qualcomm, Broadcom, NXP, Microchip, etc.), which is precisely what CommWorks' 2025 docket shows it doing.

Open/uncertain items (not established by sources reviewed)

• Exact complaint filing date (metadata: 2025-04-24; PACER mirror: 2025-04-25).
• The accused-product list and whether TI's local counsel was in fact The Roth Law Firm (secondary source only).
• Whether the four asserted patents are the complete set — an AI-generated summary asserts seven patents including U.S. 7,027,465, 6,891,807, and 9,554,304, which conflicts with the authoritative metadata's four. I have treated the metadata (7,177,285; 7,463,596; 7,911,979; RE44,904) as controlling.
• The substance and consideration of the settlement (undisclosed), and the outcome of the 2023-02-13 FWD in IPR2021-01297.

Key sources: PACER docket via Justia (https://dockets.justia.com/docket/texas/txedce/2:2025cv00439/[237533](/patent/237533)); RPX Empower docket (https://litigation.rpxcorp.com/litigation/txedce-237533-commworks-solutions-v-texas-instruments); RPX complaint copy (https://insight.rpxcorp.com/litigation_documents/16108218); PTAB IPR2021-01297 materials (https://www.docketalarm.com/cases/PTAB/IPR2021-01297/Unified_Patents_LLC_v._CommWorks_Solutions_LLC/); IPWatchdog Patent Filings Roundup (2022-07-29).

I'll research the counsel of record for CommWorks Solutions in this case.

Let me verify the firm affiliations and attorney details.

Let me confirm Kenneth Matuszewski's firm and RHM's office locations.

Counsel of Record for Plaintiff CommWorks Solutions, LLC

Case: CommWorks Solutions, LLC v. Texas Instruments Incorporated, No. 2:25-cv-00439 (E.D. Tex., Judge Rodney Gilstrap) — dismissed with prejudice July 15, 2025.

Bottom line: Four attorneys appeared for CommWorks, all from the same boutique — Rozier Hardt McDonough PLLC ("RHM"). The docket shows no separate Texas local counsel and no in-house counsel appearing for the plaintiff. The case terminated before any Rule 3-1(g)/lead-counsel designation was entered, so "lead counsel" below is inferred from the complaint signature, not from a formal court designation.

Attorneys appearing on the docket

Sources and corroboration

• Docket (Dockets.Justia / RPX Empower, Case 2:25-cv-00439): Complaint at Dkt. 1 (signed by McDonough); Notices of Attorney Appearance at Dkts. 4 (Hardt), 5 (Rozier), 6 (Matuszewski), all filed April 25, 2025 "on behalf of CommWorks Solutions, LLC." Dkt. 12 (Joint Motion to Stay, filed by CommWorks) and Dkt. 14 (Stipulation of Dismissal) followed before the July 15, 2025 dismissal order (Dkt. 15). https://dockets.justia.com/docket/texas/txedce/2:2025cv00439/237533
• RPX Empower docket page confirms the same case data (E.D. Tex., filed 4/25/2025). https://litigation.rpxcorp.com/litigation/txedce-237533-commworks-solutions-v-texas-instruments
• PatSnap litigation profile independently lists plaintiff counsel as Rozier, McDonough, Hardt, and Matuszewski, with plaintiff law firm "Rozier Hardt McDonough PLLC." (Third-party aggregator; consistent with the docket.)
• RHM firm website (attorney bios; patent-litigation and post-grant practice pages): https://rhmtrial.com/attorneys/
• USPTO PTAB filings confirm the Denver (Rozier) and Atlanta (McDonough) office addresses and Rozier/McDonough as lead/back-up counsel in RHM-represented IPRs (e.g., IPR2023-00815/816/817, Urban Intel).

Caveats

• No formal "lead counsel" designation appears in the record. In E.D. Tex., lead trial counsel is typically designated in the parties' Rule 3-1/3-2 disclosures or a Joint Claim Construction statement; this case settled and was dismissed within ~12 weeks, so no such filing exists. The roles above are inferred from who signed the complaint and who is described as lead in the firm's own materials.
• No separate local counsel, and no in-house counsel, appear for CommWorks on the retrieved docket. The RHM attorneys appear to have been admitted to practice before the E.D. Tex. (I did not locate pro hac vice motions on the public docket, which would be expected if they were not already admitted — the absence of PHV filings supports direct/admitted appearance, but I could not confirm that specific point in the retrieved record).
• Identity of the four attorneys is well sourced; the "lead vs. of counsel" labels and office locations are my characterization based on firm/PTAB documents rather than a court filing in this case. The dismissal terms are undisclosed, and I found no sealed filing relating to counsel.

I did not identify any other plaintiff-side appearances. (Defense counsel listed on the docket, for completeness, was Amanda Aline Abraham of The Roth Law Firm, P.C.)

I'll research the docket and counsel appearances for this case.

Let me dig into the actual docket entries and TI's counsel filings.

Let me find the actual filings by TI's counsel and check for any additional appearances.

Defendant's counsel of record — Texas Instruments Incorporated

Bottom line: Only one defense-side attorney is documented on the public docket of CommWorks Solutions, LLC v. Texas Instruments Inc., No. 2:25-cv-00439 (E.D. Tex.): Amanda A. Abraham of The Roth Law Firm, P.C. (Marshall, Texas). The case ended in a stipulated dismissal with prejudice on July 15, 2025 before TI ever answered or appeared through a formal notice of appearance, so no lead trial counsel from a national firm is documented. I did not find any other attorney appearance, pro hac vice motion, or corporate counsel entry, and I will not invent one.

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1. Amanda A. (Aline) Abraham — sole attorney of record for TI on this docket; Marshall-based local counsel

Sources: Justia Dockets docket sheet for 2:25-cv-00439 (https://dockets.justia.com/docket/texas/txedce/2:2025cv00439/237533); PatSnap/Eureka litigation profile of the case (derived from PACER docket) listing "Defendant counsel: Amanda Aline Abraham / Defendant law firm: The Roth Law Firm PC" (https://www.patsnap.com/de/resources/blog/litigation/commworks-solutions-v-texas-instruments-wi-fi-patent-dispute-patsnap/); TI appearance in Eolas v. Adobe, 6:09-cv-446, Dkt. 89 (https://docs.justia.com/cases/federal/district-courts/texas/txedce/6:2009cv00446/[118976](/patent/118976)/89); MoreLaw/Martindale directory entries for The Roth Law Firm.

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2. What the record does not show (important caveats)

• No notice of attorney appearance for TI is docketed. TI's only defense-side filings reflected on the public docket are the extension application (Dkt. 9) and, implicitly, participation in the Joint Motion to Stay All Deadlines and Notice of Settlement (Dkt. 12, July 1, 2025) and the Stipulation of Dismissal (Dkt. 14, July 15, 2025), each shown as filed by plaintiff's counsel (James F. McDonough, III). The TI signature blocks on Dkts. 12/14 are not visible in the public docket text I could retrieve — I did not verify them, so I cannot confirm which TI-side attorney signed.
• No pro hac vice applications or lead-counsel designations appear. This is consistent with the case posture: TI obtained an extension, the parties settled, and the case was dismissed under FRCP 41(a)(1)(A)(ii) on July 15, 2025 (Dkt. 15) before an answer or any appearance beyond the extension was required. If TI had national-firm lead counsel (the company routinely pairs a primary patent-litigation firm with Marshall local counsel), that engagement is not documented on this docket and I found no public confirmation for this case.
• Firm colleagues who historically appeared for TI — Carl R. Roth and Brendan C. Roth of the same firm — appeared for TI in Eolas and Blue Spike, but I found no evidence they appeared in No. 2:25-cv-00439. Treat them as firm context only, not as counsel of record here.
• In-house: The complaint's notice-letter allegations reference a TI in-house patent litigation attorney (rendered in the OCR text as "Britnee Reamy, Kreimach, Senior Counsel, Patent Litigation at TI") among the recipients of CommWorks' pre-suit notice letters. This is an in-house recipient of a demand letter, not counsel of record, and I could not independently verify the spelling of the name from a clean source — flagging it as a lead rather than a confirmed fact.

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3. Summary table

If you need the actual TI signature block on Dkt. 14 or the full CM/ECF "attorney to be noticed" list, that requires a PACER pull of the case (last docket retrieval in public mirrors: July 15, 2025) — the free mirrors I checked do not expose the parties' signature blocks for those filings.