DCT
3:25-cv-07099
Securonix Inc v. Speech Transcription LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Securonix, Inc. (Delaware)
- Defendant: Speech Transcription, LLC (Wyoming)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 3:25-cv-07099, N.D. Cal., 08/21/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the Northern District of California, having previously filed four separate infringement lawsuits in the district asserting the same patent-in-suit.
- Core Dispute: Plaintiff seeks a declaratory judgment that its cloud-based cybersecurity products and services do not infringe Defendant's patent related to a security apparatus for endpoint computing systems.
- Technical Context: The technology domain is cybersecurity, specifically the architecture for deploying and managing security functions (like firewalls and antivirus) to protect endpoint computers.
- Key Procedural History: The complaint notes that Defendant previously sued Plaintiff for infringement of the same patent in the Northern District of Texas on May 8, 2025. That case was transferred to the Eastern District of Texas, but Defendant allegedly failed to serve the complaint by the August 6, 2025 deadline. The complaint also highlights Defendant’s litigation campaign involving the patent-in-suit against at least 17 other defendants, with 14 of those cases having been dismissed without substantive litigation.
Case Timeline
| Date | Event |
|---|---|
| 2004-09-14 | ’799 Patent Priority Date |
| 2015-01-20 | ’799 Patent Issue Date |
| 2023-05-16 | Defendant begins litigation campaign asserting the ’799 Patent |
| 2025-05-08 | Defendant files infringement suit against Plaintiff in N.D. Texas |
| 2025-05-27 | Texas lawsuit is transferred to E.D. Texas |
| 2025-08-06 | Deadline for Defendant to serve Plaintiff in Texas lawsuit passes |
| 2025-08-21 | Plaintiff files this Complaint for Declaratory Judgment in N.D. Cal. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,938,799 - "Security Protection Apparatus and Method for Endpoint Computing Systems"
The Invention Explained
- Problem Addressed: The patent's background describes the conventional approach to endpoint security as inefficient and problematic (U.S. Patent No. 8,938,799, col. 4:41-65). Deploying multiple security software modules (e.g., antivirus, firewall) from different vendors directly onto a host computer's operating system can lead to software conflicts, performance degradation, registry corruption, and complex management (U.S. Patent No. 8,938,799, col. 4:13-26).
- The Patented Solution: The invention proposes a dedicated hardware and software "security subsystem," referred to as a "Security Utility Blade (SUB)," that is physically or logically positioned between the network and the host computer (U.S. Patent No. 8,938,799, col. 5:21-29; Fig. 2A). This SUB runs its own independent operating system and acts as a secure, isolated "open platform" for receiving, holding, and executing security software modules from various vendors (U.S. Patent No. 8,938,799, col. 6:50-56). By offloading security functions from the host, the invention aims to improve performance, reduce conflicts, and centralize management within a "Unified Management Zone" (U.S. Patent No. 8,938,799, col. 5:29-35).
- Technical Importance: This architectural approach seeks to decouple security functions from the primary operating system of the endpoint, a method intended to enhance security robustness and simplify multi-vendor software management. (U.S. Patent No. 8,938,799, col. 4:60-65).
Key Claims at a Glance
- The complaint indicates Defendant has asserted Claim 14 in the majority of its prior lawsuits and that its non-infringement contentions are directed to the elements of this claim (Compl. ¶¶26, 31).
- Independent Claim 14:
- A security subsystem configurable between a network and a host of an endpoint,
- the security subsystem comprising computing resources for providing:
- an open platform for receiving and executing security function software modules from multiple vendors
- for providing defense functions for protection of the host.
III. The Accused Instrumentality
Product Identification
- Plaintiff's "products and/or services," which are described as a portfolio of "advanced threat detection and response solutions" (Compl. ¶¶7, 21).
Functionality and Market Context
- The complaint describes the accused instrumentalities as a "cloud-native, AI-driven platform" (Compl. ¶7). The product portfolio includes capabilities such as security information and event management (SIEM), user and entity behavior analytics (UEBA), and security orchestration, automation and response (SOAR) (Compl. ¶7). These solutions are alleged to help organizations identify and respond to insider and external threats in real time using behavior-based analytics and machine learning (Compl. ¶7). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment of non-infringement, the following table summarizes Plaintiff's allegations as to why its products do not meet specific limitations of the asserted claim.
’799 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Non-Infringing Architecture/Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a security subsystem configurable between a network and a host of an endpoint | Plaintiff alleges its product or service does not meet or embody this limitation. (The complaint does not specify why, but implies its cloud-native architecture is distinct from the claimed "subsystem"). | ¶31 | col. 26:47-49 |
| the security subsystem comprising computing resources | Plaintiff alleges its product or service does not meet or embody this limitation. | ¶31 | col. 26:50 |
| an open platform for receiving and executing security function software modules from multiple vendors for providing defense functions for protection from the host | Plaintiff alleges its product or service does not meet or embody this limitation. | ¶31 | col. 26:50-54 |
- Identified Points of Contention: The central dispute appears to be a fundamental mismatch between the technology described in the patent and the architecture of the accused products.
- Scope Questions: A primary question will be whether the term "security subsystem," which the patent specification repeatedly describes as a hardware "Security Utility Blade (SUB)" (U.S. Patent No. 8,938,799, col. 5:22-24), can be construed to read on Plaintiff's "cloud-native, AI-driven platform" (Compl. ¶7). The complaint's non-infringement position suggests it cannot (Compl. ¶31).
- Technical Questions: The analysis may turn on the technical meaning of being "configurable between a network and a host of an endpoint" (U.S. Patent No. 8,938,799, col. 26:48-49). It raises the question of whether a cloud service, which does not sit physically inline like the hardware depicted in the patent's figures (e.g., Fig. 2A-2D), can satisfy this structural limitation.
V. Key Claim Terms for Construction
- The Term: "security subsystem"
- Context and Importance: This term is the preamble and core subject of the claim. Its construction will likely determine the outcome of the case, as Plaintiff's non-infringement theory appears to rest on its cloud-based services not constituting the "subsystem" claimed by the patent. Practitioners may focus on whether the term is limited to a hardware-based apparatus or can encompass a distributed, cloud-based software service.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself uses the general term "computing resources" without explicitly requiring a single piece of hardware (U.S. Patent No. 8,938,799, col. 26:50).
- Evidence for a Narrower Interpretation: The specification consistently and extensively describes the invention as a "Security Utility Blade (SUB)," which is a "hardware and software 'security subsystem'" (U.S. Patent No. 8,938,799, col. 5:21-24). The figures exclusively depict hardware embodiments, such as a blade installed in a motherboard slot (U.S. Patent No. 8,938,799, Fig. 2B) or a plug-in unit for a laptop (U.S. Patent No. 8,938,799, Fig. 2D). The abstract also refers to "apparatus and methods."
VI. Other Allegations
The complaint does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on a small number of critical, scope-defining questions for the court.
- A core issue will be one of definitional scope: Can the term "security subsystem," which the patent specification consistently describes in the context of a hardware "blade" (SUB) physically located at an endpoint, be construed broadly enough to encompass a "cloud-native" software platform that provides security services remotely?
- A second key question will be one of structural location: What is the proper construction of "configurable between a network and a host of an endpoint"? The case may turn on whether this requires a specific physical or logical in-line position, as depicted in the patent's embodiments, or if it can be satisfied by a cloud service that interacts with endpoints over the network.