DCT
5:25-cv-08727
Zoho Corp Pvt Ltd v. Orion Labs Tech LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zoho Corporation Pvt. Ltd. (India), Zoho Corporation (California), and Zoho Technologies Corporation (California)
- Defendant: Orion Labs Tech, LLC (Washington)
- Plaintiff’s Counsel: Marton Ribera Schumann & Chang LLP
- 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 same patents-in-suit against another company (Talkdesk, Inc.) and sending infringement-related correspondence directly to Zoho, which is located in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Zia" artificial intelligence assistant, when used with its communication products, does not infringe five of Defendant's patents related to the use of intelligent agents or "bots" within group communication systems.
- Technical Context: The technology at issue involves integrating automated software agents (bots) into group communication platforms to provide services such as audio transcription, recording, and voice-activated assistance.
- Key Procedural History: This action appears to be part of a "race to the courthouse." The complaint states that after receiving correspondence and claim charts from Orion Labs, Zoho filed an initial declaratory judgment complaint on October 10, 2025. Subsequently, on October 21, 2025, Orion Labs filed its own infringement action against Zoho in the Western District of Texas asserting two related patents. This amended complaint was filed on October 28, 2025.
Case Timeline
| Date | Event |
|---|---|
| 2015-05-27 | Earliest Priority Date (’430, ’003, ’339 Patents) |
| 2017-03-27 | Earliest Priority Date (’636 Patent) |
| 2017-10-03 | Earliest Priority Date (’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 sends claim charts to Zoho |
| 2025-03-XX | Zoho responds to Orion Labs |
| 2025-10-10 | Zoho files original declaratory judgment complaint in N.D. Cal. |
| 2025-10-21 | Orion Labs files infringement lawsuit against Zoho in W.D. Tex. |
| 2025-10-28 | Zoho files First Amended Complaint for Declaratory Judgment (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 conventional communication devices often require distracting user inputs and preferences before communication can occur, which can be difficult for users engaged in other tasks (’339 Patent, col. 1:21-40).
- The Patented Solution: The invention proposes integrating an "intelligent agent node" directly as a member of a communication group. This agent can be "instantiated" on instructions from a human group member to provide services like recording, auditing, or voice assistance to all members of the group (’339 Patent, Abstract; col. 1:41-57). Figure 1 illustrates this concept by showing an agent node (106) being added to an existing "Group A" to create a new "Group B" that includes the agent as a member (’339 Patent, Fig. 1).
- Technical Importance: The technology enables a shift from personal, one-to-one digital assistants to group-aware, service-oriented agents that can be programmatically and securely integrated into a collaborative communication session (’339 Patent, col. 4:29-48).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of Claim 1 (Compl. ¶27).
- The essential elements of independent claim 1 include:
- A method of managing a communication group comprising a plurality of personal communication member nodes;
- receiving instructions from at least one of the plurality of personal communication member nodes to instantiate an intelligent agent;
- instantiating the intelligent agent as a virtual assistant communication member node in the communication group; and
- the instantiated intelligent agent transcribing communications among and between the plurality of personal communication member nodes in the communication group.
U.S. Patent No. 11,127,636 - BOT GROUP MESSAGING USING BOT-SPECIFIC VOICE LIBRARIES
The Invention Explained
- Problem Addressed: The patent addresses the need for specialized bots in group messaging environments, where general-purpose bots may not be suitable for all tasks, and a system is needed to intelligently route audio messages to the correct bot using appropriate processing tools (’636 Patent, col. 1:46-56).
- The Patented Solution: The invention describes a group messaging service that receives a message containing recorded audio and a bot identifier. The service determines that the bot is a member of the group and accesses a "bot entry" in a data structure that indicates a specific "voice library" for that bot. The system selects and uses that voice library to process the audio into a format suited for the bot, which then performs a designated action (’636 Patent, Abstract; col. 2:1-11).
- Technical Importance: This approach allows for a more sophisticated, multi-bot environment where the platform can dynamically select specialized processing resources (voice libraries) tailored to the function of a specific bot, rather than using a single, generic speech-to-text engine for all interactions (’636 Patent, col. 2:1-11).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of Claim 1 (Compl. ¶30).
- The essential elements of independent claim 1 include:
- A method comprising 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 based on the indicator;
- processing the recorded audio using the selected voice library to produce a modified message; and
- sending the modified message to the bot member.
U.S. Patent No. 11,258,733 - TRANSCRIPTION BOT FOR GROUP COMMUNICATIONS
Technology Synopsis
The patent describes a group communication service that, upon receiving an "audio transcription request" from a user, launches a "bot node member" of the group. This bot is specifically configured to receive an audio message, transcribe it into a content message, and deliver the transcribed message to one or more destination services on behalf of the user or group (’733 Patent, Abstract; Compl. ¶33).
Asserted Claims
Claim 1 (Compl. ¶34).
Accused Features
The complaint states Orion Labs alleges that the Zia feature, used with Zoho's communication products, infringes by transcribing audio in a group communication service using a bot (Compl. ¶¶ 33-34).
U.S. Patent No. 10,110,430 - INTELLIGENT AGENT FEATURES FOR WEARABLE PERSONAL COMMUNICATION NODES
Technology Synopsis
This patent, from the same family as the ’339 Patent, discloses systems and methods for providing intelligent agent features to communication groups. The technology centers on receiving instructions from a group member to "instantiate" an intelligent agent as a "virtual assistant communication member node" within the group to perform services like recording and auditing communications (’430 Patent, Abstract).
Asserted Claims
Claim 1 (Compl. ¶27).
Accused Features
The complaint states Orion Labs alleges that Zoho's Zia feature is an intelligent agent instantiated in 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
Also from the same family as the ’339 and ’430 patents, this patent describes instantiating an intelligent agent to perform a service for a communication group. The claimed method includes instantiating the agent as a "virtual assistant communication member node" that performs a service for one or more members of the group (’003 Patent, Abstract).
Asserted Claims
Claim 1 (Compl. ¶27).
Accused Features
The complaint states Orion Labs alleges that Zoho's Zia feature is instantiated as a bot in a communication group to perform services for group members (Compl. ¶¶ 26-27).
III. The Accused Instrumentality
Product Identification
The "Zia" feature when used in conjunction with the Zoho Voice, Zoho Meeting, and/or Zoho Cliq products (Compl. ¶2).
Functionality and Market Context
According to the complaint, Orion Labs asserts that Zia functions as a virtual assistant or bot that operates within Zoho's group communication products (Compl. ¶24). The services allegedly performed by Zia that are relevant to the patents include transcription and recording of communications within a group (Compl. ¶¶ 26, 33). Zoho's central argument for non-infringement is that its Zia assistant is not architecturally equivalent to the claimed invention, stating that "Zia is not a member of a communications group" and is not "instantiated" by a group member in the manner required by the patents (Compl. ¶¶ 25, 28). 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 | Orion Labs alleges a member of a communication group sends instructions to instantiate the Zia virtual assistant. Zoho denies that its products permit a group member to do this. | ¶28 | col. 13:45-49 |
| instantiating the intelligent agent as a virtual assistant communication member node in the communication group | Orion Labs alleges that Zia is instantiated as a member node within the communication group. Zoho denies this, asserting Zia is not a member of any communication group. | ¶¶24, 25 | col. 13:50-53 |
| the instantiated intelligent agent transcribing communications among and between the plurality of personal communication member nodes in the communication group | Orion Labs alleges that the Zia feature is used to transcribe communications for group members. | ¶26 | col. 13:54-58 |
'636 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, by a group messaging service... a message comprising recorded audio and a bot identifier for a bot member of the group | Orion Labs alleges that Zoho's accused system sends a message that includes an audio recording and a "bot identifier for a bot member of the group." Zoho denies its products include such a message. | ¶31 | col. 19:4-8 |
| accessing a bot entry in the data structure... the bot entry including an indicator of a voice library | Orion Labs alleges that Zoho's system accesses a bot entry with a voice library indicator. | ¶¶29, 32 | col. 19:15-18 |
| selecting which of a plurality of available voice libraries to use to process the recorded audio based on the indicator in the bot entry | Orion Labs alleges that Zoho's products select from a plurality of voice libraries. Zoho denies this functionality, stating its products do not support selection of a particular voice library. | ¶32 | col. 19:20-23 |
Identified Points of Contention
- Scope Questions: The primary dispute for the '339, '430, and '003 patents centers on definitional scope: does an integrated, system-level AI assistant like Zoho's Zia, which can interact with a group, meet the claim requirement of being "instantiated as a... member node in the communication group"? Zoho's complaint suggests a fundamental architectural mismatch (Compl. ¶¶ 24-25, 28).
- Technical Questions: The analysis for the '636 patent may raise questions of technical implementation. For instance, what evidence does the complaint suggest Orion Labs has provided that Zoho's system uses a specific "bot identifier for a bot member" to route messages, as opposed to another technical mechanism (Compl. ¶31)? Similarly, does the accused system's use of a speech-to-text engine constitute "selecting which of a plurality of available voice libraries" as required by the claim (Compl. ¶32)?
V. Key Claim Terms for Construction
The Term: "instantiating the intelligent agent as a virtual assistant communication member node in the communication group" (’339 Patent, Claim 1)
- Context and Importance: This phrase is central to Zoho's non-infringement defense for the '339, '430, and '003 patents. Its construction will determine whether an always-available AI service that interacts with a group is the same as an agent that is specifically created and added as a new "member" to that group for the duration of a task. Practitioners may focus on this term because it appears to describe a specific architectural choice that may differ from how modern integrated AI assistants are implemented.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the agent can be executed as a "virtual node comprising software or firmware" and can be "instantiated upon demand by any of" the group member nodes, which could be argued to cover the act of invoking an existing service for a group task (’430 Patent, col. 5:35-40).
- Evidence for a Narrower Interpretation: Figure 1 and the accompanying description depict an agent (106) being added to an existing "Group A" to form a new "Group B," which explicitly includes the agent as a new member. This may suggest that "instantiating... as a member node" requires a discrete act of adding the agent to the group's formal structure, not merely interacting with an external service (’430 Patent, Fig. 1; col. 4:7-13).
The Term: "bot identifier for a bot member of the group" (’636 Patent, Claim 1)
- Context and Importance: Zoho explicitly denies that its accused products send a message containing this element (Compl. ¶31). The dispute will likely focus on whether the mechanism Zoho uses to direct a message to its Zia service is structurally equivalent to the claimed "bot identifier for a bot member."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to narrowly define the format of the "bot identifier." An opposing party might argue that any data within the message—whether in the header or payload—that serves to route the message to the bot would meet this limitation.
- Evidence for a Narrower Interpretation: The phrasing "for a bot member of the group" could be interpreted to require an identifier that is recognized within the context of the group's membership list, distinguishing it from a generic service endpoint address. Zoho's denial suggests it will argue its system uses a mechanism that does not meet this more specific interpretation (Compl. ¶31).
VI. Other Allegations
Indirect Infringement
The complaint seeks a judicial declaration that Zoho has not infringed "directly or indirectly" any claim of the patents-in-suit, but it does not provide details of any specific indirect infringement theory asserted by Orion Labs (Compl. ¶38).
Willful Infringement
The complaint does not address willfulness directly. However, it establishes that Orion Labs provided Zoho with pre-suit notice of the alleged infringement, including correspondence and claim charts beginning in January 2025 (Compl. ¶¶ 19-20). This pre-suit knowledge could potentially form the basis for a claim of willful infringement by Orion Labs if infringement is ultimately found.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural equivalence: Does Zoho's integrated "Zia" assistant, which is available to users within a group communication, meet the claim requirement of being "instantiated as a... member node in the communication group," or is there a fundamental technical distinction between an integrated platform service and a discrete, instantiated group "member" as described in the patents?
- A key evidentiary question will be one of functional specificity: For patents like the '636, does Zoho's system perform the precise functions recited in the claims, such as using a "bot identifier for a bot member" and "selecting which of a plurality of... voice libraries," or do the accused products achieve a similar outcome through a technically distinct, non-infringing method?
- A preliminary question will be procedural: With dueling first-filed lawsuits in the Northern District of California and the Western District of Texas, a threshold issue for the courts will be to determine the proper venue for the dispute and how to manage the different sets of asserted patents across the two actions.