DCT

1:24-cv-01027

ThroughTEK Co Ltd v. Reolink Innovation Inc

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2014-10-03 ’655 Patent Priority Date
2017-08-08 ’655 Patent Issue Date
2024-08-15 Notice of infringement sent to Reolink USA and most retailers
2024-08-29 Notice of infringement sent to Sam's West Inc.
2024-09-12 Complaint Filing Date

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

U.S. Patent No. 9,727,655 - Searching System, Method and P2P Device for P2P Device Community, issued August 8, 2017

The Invention Explained

  • Problem Addressed: The patent describes conventional centralized network systems, where a central server manages data storage and searching, as having fixed performance and capacity, which can lead to network transmission bottlenecks or excess, underutilized resources (’655 Patent, col. 1:20-27). It notes that while peer-to-peer (P2P) communities solve some of these limitations, data searching within such communities could be improved in efficiency and speed (’655 Patent, col. 1:47-54).
  • The Patented Solution: The invention proposes a hybrid system to improve searching in a P2P network. It combines a "P2P device community" (e.g., cameras) with two types of servers: an "online server" that maintains a "topology data table" of how the P2P devices are linked, and a "content management server" that maintains an "index database" of the content on those devices (’655 Patent, Abstract; col. 2:1-13). When a user searches, the system queries the index database to find relevant devices and then uses the topology table to establish a connection, aiming to increase search efficiency (’655 Patent, col. 2:6-13).
  • Technical Importance: The described architecture attempts to provide the scalability and resilience of a P2P network while adding a centralized-style indexing and search capability to more quickly locate specific data across a distributed environment (’655 Patent, col. 1:50-54).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶27).
  • Independent Claim 1 requires:
    • A searching system for a P2P device community that receives a search request.
    • At least one P2P device community with P2P devices, where each device has file data comprising content data and indexed data.
    • At least one online server connected to the community, which includes a topology data table with link data between the P2P devices.
    • At least one content management server connected to the community and the online server, which includes a search engine, an index database (recording the indexed data from the P2P devices), and a user's device management unit.
    • The system operates by receiving a search request, using the search engine to search the index database to generate a result, and returning the result, allowing the user's device to obtain the link data for the relevant P2P device.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The Accused Instrumentalities are "network monitoring devices," including P2P cameras and network devices that support searching content on a P2P device (Compl. ¶30-31). Specific product lines named include the Reolink Argus series IP camera, PoE camera, TrackMix series camera, and network video recorders (NVRs) (Compl. ¶34). These devices are used in conjunction with a software "App" provided by Reolink (Compl. ¶36).

Functionality and Market Context

  • The complaint alleges that the Accused Instrumentalities are P2P devices that, via the App and "intermediary servers," establish a P2P connection to a user's device (e.g., a cell phone) (Compl. ¶36-37). This system facilitates "content search on the P2P device" (Compl. ¶37). The complaint notes that these products are sold through major nationwide retail channels and e-commerce websites, including Amazon, Costco, and Walmart (Compl. ¶35). The complaint includes a diagram to illustrate how user devices can search content on P2P devices via an on-line server and a content management server, which it alleges is an exemplary embodiment of the invention (Compl. ¶28, referencing ’655 Patent, Fig. 2).

IV. Analysis of Infringement Allegations

The complaint references an attached claim chart (Exhibit B) mapping claim 1 to the accused Argus 2E IP camera; however, this exhibit was not provided with the filing (Compl. ¶39). The following analysis is based on the narrative allegations.

’655 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A searching system for a P2P (peer-to-peer) device community, for receiving a search request sent from at least one user's device... The system of Reolink P2P cameras, NVRs, intermediary servers, and the Reolink App is alleged to be a searching system that facilitates searching content on a P2P device. ¶30, ¶37 col. 10:31-34
at least one P2P device community, wherein each the P2P device community includes at least one P2P device, wherein each the P2P device respectively comprises at least one file data, and each the file data comprises a content data and an indexed data The accused Reolink cameras and NVRs are alleged to be P2P devices that form a P2P community. The complaint alleges these devices facilitate "content search," implying the existence of content data. ¶31, ¶34, ¶37 col. 10:35-39
at least one online server connecting to the P2P device community, each the online server includes a topology data table, the topology data table being recorded with a link data between each of the P2P devices of the P2P device community Reolink allegedly provides "intermediary servers" that a used with an App to establish a P2P connection between the user and the accused cameras/NVRs. ¶32, ¶36 col. 10:40-45
at least one content management server connecting to the P2P device community and the online server respectively, each the content management server includes a search engine, an index database, and a user's device management unit... The "intermediary servers" are alleged to facilitate content search on the P2P devices, which implies the functions of a content management server, search engine, and index database. ¶32, ¶36 col. 10:46-52
wherein the user's device obtains the link data of the P2P device within the P2P device community according to the topology data table of the online server and the search result. The complaint alleges that the accused system establishes a P2P connection and can transmit information to a user device, which suggests the user device obtains the necessary connection or link data to access the P2P device. ¶36, ¶38 col. 10:57-63

Identified Points of Contention

  • Technical Questions: The complaint alleges the existence of a system for "content search" (Compl. ¶37) but does not provide specific evidence that the accused Reolink system utilizes "indexed data" separate from "content data" as required by claim 1. It is an open question whether the search function described operates on pre-generated indices or performs a more general file-level search.
  • Scope Questions: A central question will be whether Reolink's "intermediary servers" (Compl. ¶36) can be mapped to the distinct "online server" with a "topology data table" and "content management server" with an "index database" recited in claim 1. The complaint does not describe the architecture of these servers, raising the question of whether a single server infrastructure performs all functions or if the claimed two-server architecture is present.
  • Evidentiary Questions: The complaint relies on high-level functional descriptions (e.g., "facilitating content search") without detailing the underlying mechanism. The case may turn on evidence produced during discovery regarding the specific architecture and data handling protocols of the Reolink servers and App.

V. Key Claim Terms for Construction

  • The Term: "indexed data"

    • Context and Importance: This term is critical because claim 1 requires each P2P device to have "file data" comprising both "content data" and "indexed data." Further, the "content management server" must have an "index database" that "records the indexed data." The infringement case depends on showing that the accused system creates and uses such indices, as distinct from simply searching raw content. Practitioners may focus on this term to determine if the accused system's search functionality meets this specific architectural requirement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests "indexed data" can be created by a search engine based on corresponding "content data" (’655 Patent, col. 1:39-41), which could support an argument that any metadata used for searching qualifies.
      • Evidence for a Narrower Interpretation: The claims and figures consistently depict the "indexed data" (e.g., 4113) as a distinct component from the "content data" (e.g., 4111) within a "file data" structure (e.g., 411) on the P2P device itself (’655 Patent, Fig. 2; col. 5:26-28). The specification also states the index database "records and manages all the indexed data" from the P2P devices, suggesting a specific, transferable data object (’655 Patent, col. 4:59-62).

  • The Term: "topology data table"

    • Context and Importance: Claim 1 requires an "online server" that includes a "topology data table" recorded with "link data." The complaint alleges the use of "intermediary servers" to establish P2P connections (Compl. ¶36), but does not explicitly mention a "topology data table." The viability of the infringement allegation hinges on whether the function of Reolink's servers can be construed to meet this specific structural limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that the "link data 49 refers to the connection relationship between the P2P devices 41-46, which includes, but is not limited to, the connection structure, connection data and/or locations of connection" (’655 Patent, col. 4:53-57). This could support an argument that any server function that manages device locations and connection availability meets the limitation.
      • Evidence for a Narrower Interpretation: The term "table" suggests a specific data structure. The patent describes the table as being "mainly recorded with a link data 49 between each of the P2P devices" (’655 Patent, col. 4:51-53), which may require evidence of a persistent, structured record of inter-device relationships, not just on-the-fly connection brokering.

VI. Other Allegations

  • Indirect Infringement:
    • Inducement: The complaint alleges that Defendants induce infringement by selling the Accused Instrumentalities to consumers and encouraging their use of the patented technologies (Compl. ¶53-54). It further alleges that providing the App for operating the cameras induces infringement, as the App is for "practicing the patented methods for establishing the P2P connection" (Compl. ¶61). User manuals for the accused products are also referenced (Compl. ¶39-40).
    • Contributory Infringement: The complaint alleges that the App provided to consumers is a "material part of the patented technologies" that is "specially made or especially adapted for use in an infringement" and is "not a staple article or commodity of commerce suitable for substantial non-infringing use" (Compl. ¶62).
  • Willful Infringement: The complaint alleges willful infringement based on Defendants' continued infringement after receiving explicit notice. The complaint cites a cease-and-desist letter sent to Reolink USA on August 15, 2024, and subsequent notices sent to the retailer defendants (Compl. ¶41, ¶44, ¶51, ¶66).

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

  • A core issue will be one of architectural mapping: can the functions of Reolink's "intermediary servers" be mapped onto the patent’s distinct two-part architecture of an "online server" with a "topology data table" and a "content management server" with an "index database"? The complaint's lack of detail on the accused server infrastructure makes this a central evidentiary question.
  • The case will also turn on a question of definitional scope: does the search function in the accused Reolink system rely on "indexed data" as that term is used in the patent, or does it perform a search using a different mechanism? Proving the existence and use of "indexed data" that is distinct from "content data" will be a critical hurdle for the plaintiff.
  • A third key question will be one of infringing use: assuming the system is capable of infringement, what evidence demonstrates that consumers, guided by Defendants' instructions, actually operate the system in a way that practices every step of the claimed method, particularly the steps related to generating and searching an index database?