Focus Global Solutions LLC v. Rockwell Automation Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Focus Global Solutions LLC (Delaware)
  • Defendant: Rockwell Automation, Inc. (Delaware)
  • Plaintiff’s Counsel: Phillips, McLaughlin & Hall, P.A.
• Case Identification: 1:23-cv-00782, D. Del., 07/18/2023
• Venue Allegations: Venue is asserted based on Defendant’s incorporation in Delaware and its maintenance of an established place of business within the district.
• Core Dispute: Plaintiff alleges that certain of Defendant's products infringe a patent related to using a universal, template-based system for configuring network devices from different manufacturers.
• Technical Context: The technology addresses the operational challenges of managing heterogeneous computer networks, where devices from multiple vendors require distinct, proprietary commands for configuration.
• Key Procedural History: The complaint does not reference any prior litigation or administrative proceedings involving the patent-in-suit. The patent-in-suit is a continuation-in-part of several applications filed in December 2000, which may be relevant to defining the scope and priority of the invention.

Case Timeline

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

U.S. Patent No. 6,978,301 - “System and method for configuring a network device,” issued December 20, 2005

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty and technical skill required for network administrators to configure and reconfigure networks composed of devices from different manufacturers (e.g., Cisco, Juniper) (’301 Patent, col. 1:36-48; col. 2:20-39). Each vendor uses device-specific commands, forcing administrators to learn multiple complex interfaces and increasing the chance of error, which slows network expansion (’301 Patent, col. 2:40-48).
• The Patented Solution: The invention proposes a unified system that abstracts away this vendor-specific complexity. It uses a "global graphical user interface (GUI)" coupled with a "template library" (’301 Patent, col. 4:2-12). An administrator can select a network device and populate a generic template with configuration data. The system then uses the template, which contains the required attribute fields and formatting rules for that specific device, to automatically generate and provide the correct device-specific commands to the target device (’301 Patent, Abstract; col. 4:20-35). Figure 9 illustrates a directory tree for organizing such templates by device type and manufacturer (’301 Patent, Fig. 9).
• Technical Importance: The described system aimed to centralize and simplify network management, reducing reliance on administrators having specialized knowledge of multiple, disparate hardware platforms.

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and refers to "Exemplary '301 Patent Claims" in an unattached exhibit, without specifying them in the complaint body (Compl. ¶11).
• Independent claim 1 is a representative method claim and recites the following essential elements:
  • Receiving a network device identifier corresponding to a network device.
  • Retrieving a "command-format template" from a repository, where the template indicates how to construct a device-specific command and includes an "attribute field."
  • Identifying attribute data for the attribute field.
  • Generating the device-specific command using the template and the attribute data.
  • Providing the generated command to the network device.

III. The Accused Instrumentality

Product Identification

The complaint does not name specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in "charts incorporated into this Count" via an "Exhibit 2" (Compl. ¶11, ¶13). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '301 Patent" and "satisfy all elements of the Exemplary '301 Patent Claims" (Compl. ¶13). The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market position.

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating claim charts from an unprovided exhibit (Compl. ¶14). As this exhibit is not available, a detailed claim chart summary cannot be constructed. The infringement theory, as stated in the complaint, is that the "Exemplary Defendant Products" practice the patented technology, thereby satisfying all elements of the asserted claims (Compl. ¶13).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Evidentiary Question: A threshold issue is the identification of the accused products and their specific architecture and functionality. Without the complaint’s Exhibit 2, the factual basis for the infringement claim is not detailed in the public filing.
• Technical Question: Assuming the accused products are identified, a central question will be whether they operate using a "template"-based system as claimed. The dispute may center on whether the accused products' configuration mechanism functions by retrieving a "command-format template" from a "repository" to "generate" device-specific commands, or if they use a different technical approach to achieve device configuration.

V. Key Claim Terms for Construction

The Term: "command-format template"

• Context and Importance: This term is the central concept of the asserted claims. Its construction will likely define the scope of the patent and be dispositive for infringement, as the dispute will turn on whether the accused Rockwell Automation products utilize a structure that meets this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself defines the term functionally, requiring only that it "indicates how to construct a device-specific command for the network device and includes an attribute field" (’301 Patent, col. 12:50-52). This could support an argument that any data structure providing guidance for command creation qualifies.
  • Evidence for a Narrower Interpretation: The specification describes the template as part of a "template library" that stores "both the attribute fields required for device configuration and the format for communicating those attribute fields" (’301 Patent, col. 4:12-15). This suggests a specific structure containing both data fields and formatting rules, potentially limiting the term to more than a simple data map.

The Term: "generating the device-specific command"

• Context and Importance: This term defines the primary action of the claimed method. Practitioners may focus on this term because its definition will distinguish between merely passing through pre-formed commands and the inventive act of creating them based on a template.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "generating" could be argued to encompass any automated process that creates a specific output (the command) from a more abstract input (the attribute data).
  • Evidence for a Narrower Interpretation: The detailed description explains that the system "generates the device-specific commands by retrieving the appropriate template and filling in the variable fields" and then formats the data into a "frame" for transmission (’301 Patent, col. 5:62-66; col. 11:41-51). This could support a narrower construction limited to a process of populating a data structure and formatting it, rather than more complex logical creation or compilation.

VI. Other Allegations

Indirect Infringement

The complaint does not include specific factual allegations to support claims of induced or contributory infringement. It focuses on allegations of direct infringement (Compl. ¶11).

Willful Infringement

The complaint does not explicitly allege willful infringement or plead facts related to pre-suit knowledge of the patent. However, the prayer for relief requests a judgment that "this case be declared exceptional within the meaning of 35 U.S.C. § 285" (Compl. ¶E.i).

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

1. Factual Foundation: The primary open question is evidentiary: which specific Rockwell Automation products are accused of infringement, and what is their precise technical operation? The complaint’s reliance on an unattached exhibit leaves the factual predicate for the lawsuit undefined in the initial pleading.

2. Claim Scope and Technical Applicability: A core issue will be one of definitional scope: can the term "command-format template", which is described in the context of managing enterprise IT network devices like routers, be construed to read on the configuration mechanisms within Rockwell Automation's products, which are often geared toward industrial control and automation systems?

3. The Nature of "Generation": A key technical question will be one of functional operation: assuming a relevant software component is identified, does it "generate" commands by using a template to translate abstract data into device-specific instructions, as claimed in the patent? Or does it operate through a different mechanism, such as direct command-line entry, API calls with pre-structured data, or loading a complete pre-compiled configuration file, which may fall outside the scope of the claims?