DCT

3:25-cv-08727

Zoho Corp Pvt Ltd v. Orion Labs Tech LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-8727, N.D. Cal., 10/28/2025
  • Venue Allegations: Plaintiff Zoho alleges venue is proper in the Northern District of California because Defendant Orion Labs has engaged in a patent enforcement campaign in the district, including litigating the patents-in-suit against another entity and sending infringement-related correspondence to Zoho, which is located in the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its "Zia" virtual assistant feature, used in its communication products, does not infringe five patents asserted by Defendant related to the integration of intelligent agents into group communication systems.
  • Technical Context: The technology concerns the integration of voice-activated intelligent agents, or "bots," as functional members within group-based communication platforms, enabling services like transcription and recording.
  • Key Procedural History: The complaint indicates this action follows pre-suit correspondence from Orion Labs demanding a license. Zoho filed an initial declaratory judgment action on October 10, 2025. Subsequently, on October 21, 2025, Orion Labs filed a separate infringement suit against Zoho in the Western District of Texas asserting two related patents. This amended complaint by Zoho adds those two patents to this declaratory judgment action, reflecting a procedural dispute over the proper forum for the litigation.

Case Timeline

Date Event
2015-05-27 Priority Date for ’430, ’003, and ’339 Patents
2017-03-27 Priority Date for ’636 Patent
2017-10-03 Priority Date for ’733 Patent
2018-10-23 ’430 Patent Issued
2019-10-29 ’003 Patent Issued
2021-02-16 ’339 Patent Issued
2021-09-21 ’636 Patent Issued
2022-02-22 ’733 Patent Issued
2025-01-XX Orion Labs sends initial correspondence to Zoho
2025-02-XX Orion Labs provides claim charts to Zoho
2025-10-10 Zoho files original declaratory judgment complaint
2025-10-21 Orion Labs files infringement suit in W.D. Texas
2025-10-28 Zoho files First Amended Complaint (Filing Date)

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,924,339 - INTELLIGENT AGENT FEATURES FOR WEARABLE PERSONAL COMMUNICATION NODES

The Invention Explained

  • Problem Addressed: The patent's background describes that using communication devices like smartphones often requires multiple inputs and can distract a user from a current task or situation, especially when the user is busy ('339 Patent, col. 1:21-38).
  • The Patented Solution: The invention proposes a system where an "intelligent agent node" can be created ("instantiated") and added as a member of a communication group, alongside human users. This agent, acting as a peer within the group, can then provide services such as recording, auditing, or transcribing the group's communications in a secure manner ('339 Patent, Abstract; col. 1:39-56). The system architecture is depicted in Figure 1, which shows an intelligent agent (106) being added to a group of user nodes (102, 103, 104) to form a new group ('339 Patent, Fig. 1).
  • Technical Importance: This approach embeds automated services directly into a group communication session as a secure, virtual participant, rather than relying on external, potentially non-secure third-party applications. (Compl. ¶26; ’339 Patent, col. 2:22-26).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as being asserted (Compl. ¶27).
  • Claim 1 of the ’339 Patent includes the following essential elements:
    • A method of managing a communication group comprising a plurality of personal communication member nodes.
    • Receiving instructions from at least one of the member nodes to instantiate an intelligent agent.
    • Instantiating the intelligent agent as a virtual assistant communication member node in the communication group.
    • The instantiated intelligent agent transcribing communications among and between the member nodes in the group.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,127,636 - BOT GROUP MESSAGING USING BOT-SPECIFIC VOICE LIBRARIES

The Invention Explained

  • Problem Addressed: The patent background acknowledges the proliferation of internet bots for automated tasks and notes the desire to create messaging services that allow user groups to interact with them ('636 Patent, col. 1:47-55).
  • The Patented Solution: The invention describes a group messaging service that can receive an audio message from a user and route it to a specific bot that is a member of the group. A central feature is that the system selects a "voice library" specifically associated with that bot to process the audio. This allows for specialized natural language processing tailored to the bot's function, rather than a one-size-fits-all approach ('636 Patent, Abstract; col. 10:3-13). Figure 10 illustrates a system with multiple distinct voice libraries (1004, 1008, 1012) that can be used to process audio for a bot (208) ('636 Patent, Fig. 10).
  • Technical Importance: This system allows for the deployment of multiple, functionally distinct bots within a single communication group, where each bot can use an optimized voice processing engine for its specific task (e.g., translation, scheduling, or technical support). (Compl. ¶29; ’636 Patent, col. 2:1-12).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as being asserted (Compl. ¶30).
  • Claim 1 of the ’636 Patent includes the following essential elements:
    • Receiving, by a group messaging service, a message with recorded audio and a bot identifier for a bot member of the group.
    • Searching a data structure to determine the bot is a member of the group.
    • Accessing a bot entry in the data structure that includes an "indicator of a voice library."
    • Selecting one of a plurality of available voice libraries to process the audio based on that indicator.
    • Processing the audio with the selected library to produce a modified message.
    • Sending the modified message to the bot member.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,258,733 - TRANSCRIPTION BOT FOR GROUP COMMUNICATIONS

  • Technology Synopsis: This patent addresses the automated transcription of audio from a group communication session for delivery to external "destination services." The system receives a transcription request from a user, launches a "bot node member" to handle the task, transcribes the audio, and delivers the resulting text to the destination service (e.g., a collaborative workspace or social media feed) ('733 Patent, Abstract).
  • Asserted Claims: Claim 1 (Compl. ¶34).
  • Accused Features: The complaint alleges that Orion Labs has asserted the ’733 patent is directed to transcribing audio using a bot and that Zoho's "Zia" feature is accused of infringing this patent (Compl. ¶¶33-34).

U.S. Patent No. 10,110,430 - INTELLIGENT AGENT FEATURES FOR WEARABLE PERSONAL COMMUNICATION NODES

  • Technology Synopsis: As a parent to the ’339 patent, this patent shares the same core specification. It describes a system for instantiating an intelligent agent as a member of a communication group to provide services like recording and auditing communications, thereby solving the problem of distracting and complex user interfaces on communication devices ('430 Patent, Abstract; col. 1:21-38).
  • Asserted Claims: Claim 1 (Compl. ¶27).
  • Accused Features: The "Zia" feature is accused of infringing by allegedly acting as an intelligent agent instantiated within a communication group to perform services for group members (Compl. ¶¶26-27).

U.S. Patent No. 10,462,003 - INTELLIGENT AGENT FEATURES FOR WEARABLE PERSONAL COMMUNICATION NODES

  • Technology Synopsis: This patent, also in the same family as the ’339 and ’430 patents, shares the same specification. It claims a method of managing a communication group where instructions are received to instantiate an intelligent agent, which then performs a service (such as recording, transcription, or search) for the group members ('003 Patent, Abstract; Claims).
  • Asserted Claims: Claim 1 (Compl. ¶27).
  • Accused Features: The "Zia" feature is accused of infringing by allegedly acting as an intelligent agent instantiated within a communication group to perform services for group members (Compl. ¶¶26-27).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the "Zia" feature, described as a virtual assistant, when used in conjunction with the Zoho Voice, Zoho Meeting, and/or Zoho Cliq software products (Compl. ¶2, ¶24).

Functionality and Market Context

The complaint alleges that Zia is a "virtual assistant" that provides services to users of Zoho's communication products (Compl. ¶24). The central technical allegation regarding its functionality is architectural: the complaint asserts that Zia is not an independent "member" or "node" within a communication group (Compl. ¶24). Instead, it is alleged that Zia is assigned to a single user and is not instantiated by group members as required by the patents' claims (Compl. ¶¶25, 28). The complaint does not provide sufficient detail for analysis of the product's market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’339 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving instructions from at least one of the plurality of personal communication member nodes to instantiate an intelligent agent; The complaint alleges that the accused Zoho products do not permit a member of a communication group to send instructions to instantiate the Zia virtual assistant. ¶28 col. 13:46-50
instantiating the intelligent agent as a virtual assistant communication member node in the communication group; The complaint alleges that Zia is not a member of a communications group, but is instead assigned to a single user and is not an independent member of such a group. ¶¶24-25 col. 13:51-54
the instantiated intelligent agent transcribing communications among and between the plurality of personal communication member nodes in the communication group. The complaint's primary non-infringement argument rests on the preceding architectural limitations. It characterizes this family of patents as being directed to using a bot for services like transcription. ¶26 col. 13:55-59

Identified Points of Contention:

  • Scope Questions: A primary dispute may concern the construction of "communication member node" and what it means to be "in the communication group." The analysis will question whether this language requires a specific peer-to-peer system architecture, as Zoho alleges, or if it can be read more broadly to cover any virtual assistant providing services to a group, regardless of its underlying architecture.
  • Technical Questions: A factual question is whether Zoho's products, in operation, ever receive instructions from one user to provide a "Zia" service to other users in a group, which could be framed by the patentee as "instantiating" an agent for the group.

’636 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving...a message comprising recorded audio and a bot identifier for a bot member of the group... The complaint alleges the accused products do not send a message that includes a "bot identifier for a bot member of the group," tying this back to the assertion that Zia is not a group member. ¶31 col. 19:4-8
selecting which of a plurality of available voice libraries to use to process the recorded audio based on the indicator in the bot entry; The complaint alleges that the accused Zoho products do not support the selection of a particular voice library or multiple natural languages. ¶32 col. 19:20-24
processing, by a selected voice library, the recorded audio to produce a modified message... Zoho's non-infringement argument for this element is predicated on the failure of the preceding "selection" limitation. ¶32 col. 19:25-28

Identified Points of Contention:

  • Scope Questions: The interpretation of "selecting which of a plurality of available voice libraries" will be critical. The question is whether this requires an explicit, user-facing choice or a pre-configured, bot-specific routing mechanism, or if it could be met by any system that supports more than one language model and chooses one based on context.
  • Technical Questions: The complaint's assertion that the products do not support "multiple natural languages" raises a factual question about the technical capabilities of the Zoho platform's speech-to-text engine.

V. Key Claim Terms for Construction

The Term: "instantiating the intelligent agent as a virtual assistant communication member node in the communication group" (or variations thereof in the '339, '430, and '003 patent claims).

  • Context and Importance: This term is central to the dispute. Zoho’s non-infringement position is based on the argument that its "Zia" assistant does not meet this architectural requirement. Practitioners may focus on this term because its construction could resolve the infringement question for three of the five asserted patents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the agent as potentially being a "virtual node comprising software or firmware executed by one or more of [the user] nodes or management system" or as "virtualized software executed by a virtual machine that is instantiated upon demand" ('430 Patent, col. 5:35-44). This language may support a broader, more flexible interpretation of the agent's form and location.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to the agent as a "member" of the communication group ('430 Patent, col. 4:4-8). Furthermore, Figure 1 consistently depicts the intelligent agent (106) as a peer node, alongside user nodes (102-104), inside the boundary of "Group B," suggesting it is an independent entity on par with other members ('430 Patent, Fig. 1). This could support a narrower construction requiring a peer-to-peer architecture.
      The Term: "selecting which of a plurality of available voice libraries" ('636 Patent, Claim 1).
  • Context and Importance: This term is critical to the infringement analysis for the ’636 patent, as Zoho alleges its products do not perform this function. The dispute will likely focus on what constitutes "selecting" and a "plurality" of libraries in this context.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "selecting" is not explicitly defined, which may support an argument that any automated or system-level choice between different language processing options (e.g., based on user language settings) meets the limitation. The patent also discusses generic and specialized natural language units, suggesting a "plurality" could exist at a system level ('636 Patent, col. 14:5-12).
    • Evidence for a Narrower Interpretation: The claim requires the selection to be "based on the indicator in the bot entry." This ties the selection to a specific piece of data associated with the bot itself. This language could support a narrower reading that requires a more deliberate, bot-specific routing and processing mechanism, rather than a general system capability to handle different languages.

VI. Other Allegations

  • Indirect Infringement: Zoho seeks a declaratory judgment that it has not indirectly infringed any claim of the patents-in-suit (Compl. ¶39). The complaint does not provide details of the defendant's specific allegations of knowledge or intent that would form the basis of an indirect infringement claim.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of architectural scope: can the claim term "communication member node," which is described in the patents' figures and specification as a peer entity within a group, be construed to cover a virtual assistant that the complaint alleges is architecturally assigned to a single user and not an independent group member?
  • A key evidentiary question will be one of functional operation: does Zoho's platform, in practice, perform the function of "selecting which of a plurality of available voice libraries" to process audio as required by the '636 patent, or is there a fundamental mismatch in how the accused technology operates, as the complaint alleges?
  • The case's procedural posture, with competing lawsuits in the Northern District of California and the Western District of Texas, presents a threshold jurisdictional question: which court will ultimately preside over the substantive patent dispute, a decision that could be influenced by factors such as the timing of the filings and the parties' connections to each forum.