DCT

1:24-cv-00169

ThroughTEK Co Ltd v. Reolink Innovation Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-00169, D. Del., 02/08/2024
  • Venue Allegations: Venue is based on defendants allegedly committing acts of infringement in the district and placing products into the stream of commerce with the expectation of purchase and use by consumers in Delaware. For the non-U.S. defendant, Reolink China, venue is asserted under 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiff alleges that Defendants’ network cameras and network video recorders infringe patents related to establishing peer-to-peer (P2P) network connections and remotely waking devices from a low-power sleep mode.
  • Technical Context: The technology enables remote access and control of Internet of Things (IoT) devices, such as smart security cameras, by facilitating direct network connections between a user's client device and the IoT device, even when the latter is in a power-saving state.
  • Key Procedural History: The complaint notes that Plaintiff sent cease-and-desist letters regarding the patents-in-suit to Defendant Reolink USA in November and December 2023. Notices of infringement were also sent to the other retailer defendants. These allegations may form the basis for claims of willful infringement.

Case Timeline

Date Event
2011-11-10 ’916 Patent - Earliest Priority Date
2016-08-29 ’448 Patent - Priority Date
2017-09-26 ’916 Patent - Issue Date
2020-03-24 ’448 Patent - Issue Date
2023-11-22 Cease-and-desist letter sent to Reolink USA re: ’448 Patent
2023-11-22 Notice of infringement sent to Micro Center re: ’916 & ’448 Patents
2023-12-05 Cease-and-desist letter sent to Reolink USA re: ’916 Patent
2023-12-05 Notice of infringement sent to Micro Center re: ’916 & ’448 Patents
2024-02-05 Notice of infringement sent to Amazon, eBay, Home Depot, Walmart re: ’916 & ’448 Patents
2024-02-08 Complaint Filing Date

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

U.S. Patent No. 9,774,916 - "Information concentrating center capable of making P2P connections with remote client devices" (issued Sep. 26, 2017)

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the limited use of conventional set-top boxes, which primarily provide information to a television, and notes the need for a more "effective and efficient way to explore the full capability of a set top box" (’916 Patent, col. 1:21-34).
  • The Patented Solution: The invention proposes an "information concentrating center" that not only receives information from a source (e.g., a cable feed) but also establishes a direct peer-to-peer (P2P) connection to a remote client device (e.g., a smartphone) via the Internet. This is facilitated by the center having a unique identification (UID) registered with a linking server, which allows a remote client—even one without its own registered UID—to initiate a connection by referencing the center's UID. (’916 Patent, Abstract; col. 2:37-53).
  • Technical Importance: This architecture simplifies remote access to networked home devices, a foundational concept for the smart home market, by using a server to broker connections, thereby obviating the need for end-users to perform complex network configurations like manual port forwarding (’916 Patent, col. 12:19-30).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶25).
  • Claim 1 recites an electronic device for concentrating information with four key components and several functional requirements:
    • A "first interface" for receiving information from a source.
    • A "second interface" for coupling to the Internet to connect with a remote client device.
    • A "third interface" for connecting to a television.
    • An embedded "unique identification (UID)" that the device registers with a "linking server."
    • Functionally, a remote client device, which "does not have a unique identification (UID) to register," contacts the linking server using the electronic device's UID to establish a P2P connection, through which information is delivered.

U.S. Patent No. 10,602,448 - "Remote wakeup method, connection server, and networking apparatus having sleep mode" (issued Mar. 24, 2020)

The Invention Explained

  • Problem Addressed: The patent background explains that while Internet of Things (IoT) devices need to enter sleep modes to save power, remotely waking them up via the Internet can be difficult, with existing technologies requiring extensive network knowledge or using inefficient network broadcasting ('448 Patent, col. 1:31-48).
  • The Patented Solution: The patented method involves a client device (a "first apparatus") sending a "wakeup request packet" with the target device's identifier to a "connection server." The server then generates an "apparatus wakeup packet" and sends it to the sleeping device (a "second apparatus"). This packet contains "wakeup feature data," which is a specific segment of data the sleeping device uses to determine whether to awaken its entire system, allowing for targeted, power-efficient remote activation. ('448 Patent, Abstract; col. 2:24-28).
  • Technical Importance: This technology addresses a critical challenge for battery-powered and energy-conscious IoT devices by enabling a reliable, on-demand wakeup capability without requiring the device's main processor to be fully powered, a key enabler for the growth of the mobile-connected smart device ecosystem ('448 Patent, col. 1:31-35).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 11, and 19 (Compl. ¶46).
  • Claim 1, a representative method claim, recites the following steps:
    • A connection server receiving a wakeup request packet from a first apparatus, the packet containing a device identifier for a second apparatus.
    • The server obtaining stored "wakeup information" for the second apparatus.
    • The server generating an "apparatus wakeup packet" using the request and the stored wakeup information.
    • The server obtaining the network address for the second apparatus.
    • The server sending the apparatus wakeup packet to the second apparatus, where "wakeup feature data" within that packet is used "for determining whether the entire second apparatus be awoken."

III. The Accused Instrumentality

Product Identification

  • The Accused Instrumentalities are "network monitoring devices," including but not limited to network cameras and network video recorders (NVRs) (Compl. ¶1). Specific product lines named are the "Argus series IP Camera, the PoE (Power over Ethernet) Camera, TrackMix series Camera, battery-powered camera, and network video recorders (NVRs)" (Compl. ¶40).

Functionality and Market Context

  • The complaint alleges that these devices, in conjunction with an App provided by Defendants, are capable of establishing P2P connections via an intermediary server (Compl. ¶36, ¶42). This connection is used to transmit information, such as video streams, to a remote client device (Compl. ¶44). The system is also alleged to include a function to wake the device from a "sleeping mode" or "standby mode" to establish a connection (Compl. ¶43, ¶48). The complaint includes a diagram from the ’916 Patent, Figure 17, which illustrates the architectural relationship between an information source, an information concentrating center, a router, the Internet, and a remote client device in a P2P connection (Compl. ¶26, p. 8). The complaint also provides Figure 1A from the ’448 Patent, a network diagram showing a first apparatus (110, e.g., a phone), a connection server (150), and a second apparatus (130, e.g., a camera) connected via the Internet and a LAN (Compl. ¶34, p. 10).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits C and D) that are not included in the publicly filed document; therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

’916 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities (e.g., Reolink cameras and NVRs) function as the claimed "electronic device for concentrating information" (Compl. ¶25, ¶45). The infringement theory suggests these devices have interfaces to receive information (e.g., from an image sensor), connect to the Internet to communicate with a remote client device (e.g., a smartphone running the Reolink App), and possess an embedded UID (Compl. ¶25, ¶45). The system allegedly operates by having the device register its UID with an intermediary "linking server," which a remote client then contacts—without needing its own UID for registration—to establish a P2P connection for viewing information from the device (Compl. ¶25, ¶42-¶44).

  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the accused surveillance cameras and NVRs fall within the scope of an "information concentrating center," a term the patent's background describes in the context of a television "set top box" ('916 Patent, col. 1:21-34). The defense could argue for a narrow construction limited to that embodiment.
    • Technical Questions: The presence of a "third interface for connecting to a television" is an explicit limitation in claim 1. It raises the question of whether all accused products, particularly battery-powered, wireless cameras, contain such an interface.

’448 Patent Infringement Allegations

The complaint alleges that the Defendants' system, comprising the user's phone with the Reolink App, an intermediary server, and an accused camera/NVR, performs the remote wakeup method of claim 1 (Compl. ¶33, ¶46). The theory posits that the user's app (the "first apparatus") sends a request to wake a sleeping camera (the "second apparatus") to an intermediary server ("connection server"). This server is alleged to then send a specific "apparatus wakeup packet" to the camera, causing it to exit a low-power standby mode (Compl. ¶43, ¶48).

  • Identified Points of Contention:
    • Technical Questions: Claim 1 requires that "wakeup feature data" be a specific "segment" of the wakeup packet used "for determining whether the entire second apparatus be awoken." A key factual dispute may be whether the accused system's wakeup signal meets this specific functional definition, or if it is a more generic command that does not perform the claimed determination step.
    • Legal Questions: The method claims of the ’448 Patent appear to require actions from three distinct entities (the user's phone, the server, and the camera). This raises the question of whether any single defendant can be held liable for direct infringement, or if the allegations may be vulnerable to a defense of divided infringement.

V. Key Claim Terms for Construction

For the ’916 Patent

  • The Term: "information concentrating center" (from Claim 1)
  • Context and Importance: This term defines the accused device itself. Its construction is critical to determining if the accused cameras and NVRs are covered by the claim. Practitioners may focus on this term because its interpretation could either limit the patent to its set-top box origins or broaden it to cover a wide range of modern IoT devices.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself uses the general phrase "An electronic device for concentrating information," which is not explicitly limited (’916 Patent, col. 15:5-6). The specification also refers to the device more broadly as a "service device" (’916 Patent, col. 10:38).
    • Evidence for a Narrower Interpretation: The "Background of the Invention" section frames the problem and solution specifically around the capabilities of a "set top box" (’916 Patent, col. 1:21-34). An embodiment depicted in Figure 18 explicitly shows a "Set Top Box (1730)," which may support a narrower construction.

For the ’448 Patent

  • The Term: "wakeup feature data" (from Claim 1)
  • Context and Importance: Infringement of the wakeup method hinges on whether the signal sent to the sleeping device contains data that performs the function recited in this limitation. Practitioners may focus on this term because it requires not just a wakeup signal, but one with a specific structure and purpose—"a segment of data" that is used "for determining whether the entire second apparatus be awoken."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract broadly describes the wakeup method without extensive detail on the data itself, and the specification notes it can include "entire data or partial data of the device identifier and the wakeup information" ('448 Patent, col. 2:21-23).
    • Evidence for a Narrower Interpretation: The specification describes a detailed process where a network module in the sleeping device "compares the wakeup feature data with the pre-stored feature data" to decide whether to "wake[] up the entire second apparatus" ('448 Patent, col. 7:28-41; FIG. 8). This suggests a specific comparison and determination function, not a generic command.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants provide consumers with the Accused Instrumentalities and an associated App, along with user manuals and instructions that allegedly direct users to operate the products in an infringing manner (Compl. ¶47, ¶62-63). Contributory infringement is also alleged on the basis that the App is a material component "specially made or especially adapted for use in an infringement" and is not a staple article of commerce suitable for substantial non-infringing use (Compl. ¶71).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge of the patents. The complaint specifically pleads that Defendant Reolink USA received cease-and-desist letters identifying the ’448 Patent on November 22, 2023, and the ’916 Patent on December 5, 2023 (Compl. ¶49-50). The complaint also pleads that all other defendants received notice of infringement (Compl. ¶53-54). Allegations of continued infringement after these dates form the basis of the willfulness claim (Compl. ¶60, ¶66, ¶73).

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

  1. A core issue will be one of definitional scope: can the term "information concentrating center" from the ’916 Patent, rooted in the patent’s description of a television set-top box, be construed broadly enough to encompass the accused IP surveillance cameras and NVRs?
  2. A key evidentiary question will be one of functional specificity: does the accused system's remote wakeup signal contain "wakeup feature data" that performs the specific determination function required by Claim 1 of the ’448 Patent, or does it operate as a more generic command that falls outside the claim’s narrow functional language?
  3. The case may also turn on the issue of attribution of conduct: for the method claims of the ’448 Patent, which require coordinated actions by a user's device, an intermediary server, and the accused camera, can the Plaintiff establish that a single defendant directs or controls all the claimed steps to avoid a challenge on grounds of divided infringement?