DCT

1:24-cv-01288

UMBRA Tech Ltd Uk v. Juniper Networks Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01288, D. Del., 05/12/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Juniper Networks, Inc. is a Delaware corporation and is therefore a resident of the judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s network virtualization products and services infringe five U.S. patents related to software-defined wide area networking (SD-WAN), global virtual networks (GVNs), and multi-perimeter cloud security.
  • Technical Context: The technology at issue involves methods for improving the performance, security, and routing efficiency of large-scale computer networks, particularly for traffic that traverses the public internet between geographically distributed locations.
  • Key Procedural History: The complaint states that U.S. Patent No. 10,574,482 was previously litigated against VMware, Inc. (dismissed) and is part of a pending case against Cisco Systems, Inc. A petition for Inter Partes Review of the ’482 patent, filed by Cisco, was denied by the Patent Trial and Appeal Board. This denial may suggest the PTAB did not find a reasonable likelihood that the petitioner would prevail on at least one challenged claim, a factor that could be noted in future proceedings.

Case Timeline

Date Event
2015-04-07 Priority Date for U.S. Patent No. 10,574,482
2015-04-07 Priority Date for U.S. Patent No. 12,160,328
2015-04-07 Priority Date for U.S. Patent No. 11,799,687
2016-01-05 Priority Date for U.S. Patent No. 11,240,064
2016-01-05 Priority Date for U.S. Patent No. 12,289,183
2020-02-25 U.S. Patent No. 10,574,482 Issues
2022-02-01 U.S. Patent No. 11,240,064 Issues
2023-10-24 U.S. Patent No. 11,799,687 Issues
2024-01-01 IPR Petition on '482 Patent (IPR2024-00498) Denied (Approx. date based on filing)
2024-12-03 U.S. Patent No. 12,160,328 Issues
2025-04-29 U.S. Patent No. 12,289,183 Issues
2025-05-12 Complaint Filing Date

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

U.S. Patent No. 10,574,482 - MULTI-PERIMETER FIREWALL IN THE CLOUD (issued Feb. 25, 2020)

The Invention Explained

  • Problem Addressed: The patent’s background section describes the limitations of traditional firewalls, which are typically "placed at the edge between one network such as a local area network (LAN) and another network such as an uplink to a broader network" (Compl. ¶15; ’482 Patent, col. 1:47-51). This single-perimeter approach is less effective for securing complex, cloud-based virtualized networks (Compl. ¶15).
  • The Patented Solution: The invention proposes a distributed, multi-perimeter firewall system within a cloud or global virtual network (’482 Patent, Abstract). The system uses at least two firewalls located at different access points in the network: one firewall performs stateful packet inspection (SPI), which examines packet headers, while another performs deep packet inspection (DPI), which examines the payload or content of the packets (’482 Patent, col. 2:59-65). Crucially, these geographically separate firewalls are configured to communicate and "share threat information," creating a coordinated, multi-layered defense that extends security perimeters into the cloud (’482 Patent, Abstract; Compl. ¶15).
  • Technical Importance: This approach aims to improve network security by moving beyond a single, rigid firewall at the network edge and creating a more flexible and intelligent security architecture suited for virtualized environments (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts infringement of "at least one claim" but does not specify which claims are asserted (Compl. ¶45). Independent claim 1 is representative:
    • A multi-perimeter firewall system located in a cloud and forming part of a global virtual network, comprising:
    • an egress ingress point device;
    • a first access point server in communication with the egress ingress point device;
    • a second access point server in communication with the first access point server;
    • an endpoint device in communication with the second access point server;
    • a first perimeter firewall that performs stateful packet inspection;
    • a second perimeter firewall that performs deep packet inspection;
    • wherein the first and second perimeter firewalls share threat information.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,240,064 - SYSTEM AND METHOD FOR A GLOBAL VIRTUAL NETWORK (issued Feb. 1, 2022)

The Invention Explained

  • Problem Addressed: The patent and complaint identify security risks and performance limitations in conventional global virtual networks (GVNs) that rely on encrypted tunnels for communication (Compl. ¶16, ¶18). Problems include "long distance connectivity and throughput," protocol limitations, and security threats such as "stream hijacking, man-in-the-middle attacks, [and] poisoned information sources" within these tunnels (Compl. ¶16, ¶18; '064 Patent, col. 1:31-34, col. 13:37-43).
  • The Patented Solution: The invention solves these problems by creating a network system that selects a communication path based on security as a primary factor (Compl. ¶19). An endpoint device is configured to establish a communication path by identifying multiple candidate paths, determining a "plurality of determined security ratings" for those paths, and selecting a path based on those ratings ('064 Patent, col. 57:1-10). This introduces a security assessment into the route selection process for tunnel-based networks, which goes beyond conventional metrics like speed or latency (Compl. ¶19, ¶23).
  • Technical Importance: This method aims to enhance the security of GVNs by actively routing traffic through paths assessed to be more secure, rather than passively relying on encryption within a tunnel that may itself be compromised (Compl. ¶21).

Key Claims at a Glance

  • The complaint asserts infringement of "at least one claim" and quotes language from independent claim 1 (Compl. ¶22, ¶52). The essential elements of Claim 1 include:
    • A network system for connecting devices via a global virtual network, comprising:
    • a communication path connecting first and second endpoint devices;
    • the path comprising one or more intermediate tunnels connecting each endpoint to one or more intermediate access point servers and control servers;
    • wherein at least one endpoint device is configured to establish the path by:
    • identifying a plurality of candidate communication paths;
    • determining a plurality of security ratings for those paths;
    • selecting the communication path based on the plurality of security ratings.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

Multi-Patent Capsule: U.S. Patent No. 11,799,687

  • Patent Identification: U.S. Patent No. 11,799,687, SYSTEM AND METHOD FOR VIRTUAL INTERFACES AND ADVANCED SMART ROUTING IN A GLOBAL VIRTUAL NETWORK, issued Oct. 24, 2023.
  • Technology Synopsis: The patent addresses the problem of rigid, fixed point-to-point connections (like traditional VPNs) that perform poorly when network conditions change (Compl. ¶27, ¶28). The solution is a system that uses "virtual interfaces" (VIFs) at network nodes, which act as flexible "hook points" for multiple, dynamically selectable network tunnels, allowing traffic to be rerouted "on the fly" to avoid congestion or failures (Compl. ¶25, ¶28).
  • Asserted Claims: At least one unspecified claim (Compl. ¶59).
  • Accused Features: Juniper's network virtualization products and related services (Compl. ¶59).

Multi-Patent Capsule: U.S. Patent No. 12,160,328

  • Patent Identification: U.S. Patent No. 12,160,328, MULTI-PERIMETER FIREWALL IN THE CLOUD, issued Dec. 3, 2024.
  • Technology Synopsis: The complaint states this patent is in the same family and has matching specifications as the ’482 patent (Compl. ¶15). It resolves technical problems related to implementing a multi-perimeter firewall system, including stateful and deep-packet inspections, within a cloud-based virtualized network architecture (Compl. ¶15).
  • Asserted Claims: At least one unspecified claim (Compl. ¶66).
  • Accused Features: Juniper's network virtualization products and related services (Compl. ¶66).

Multi-Patent Capsule: U.S. Patent No. 12,289,183

  • Patent Identification: U.S. Patent No. 12,289,183, SYSTEM AND METHOD FOR A GLOBAL VIRTUAL NETWORK, issued Apr. 29, 2025.
  • Technology Synopsis: The complaint groups this patent with others related to "secure network optimization, virtual networks including... (GVNs), next generation software-defined wide area networking (SD-WAN), [and] advanced smart routing (ASR)" (Compl. ¶12). The technology aims to improve the performance and quality of service of internet connections and large networks by overcoming limitations of prior technologies like MPLS (Compl. ¶12, ¶13).
  • Asserted Claims: At least one unspecified claim (Compl. ¶73).
  • Accused Features: Juniper's network virtualization products and related services (Compl. ¶73).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities generally as "Juniper systems and methods, including one or more hardware and software products for network virtualization and related services" (Compl. ¶45, ¶52, ¶59, ¶66, ¶73). Specific products are identified in Exhibits 3, 5, 7, 9, and 11, which are referenced by the complaint but not attached to the provided filing (Compl. ¶45, ¶52, ¶59, ¶66, ¶73).

Functionality and Market Context

  • The complaint alleges that Juniper's products are implemented in "virtualized network architectures" to provide benefits like improved "convenience and efficiency for its customers" (Compl. ¶14). The accused functionalities are alleged to utilize the patented inventions in areas of SD-WAN, secure GVN operation, advanced smart routing, and multi-perimeter firewall security (Compl. ¶12). The complaint asserts these features have "significant commercial value" (Compl. ¶14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references separate, non-attached claim chart exhibits for each patent-in-suit (Compl. ¶46, ¶53, ¶60, ¶67, ¶74). In the absence of these exhibits, the infringement theory is summarized below in prose based on the complaint's narrative allegations.

  • ’482 Patent Infringement Allegations: The complaint alleges that Juniper's network virtualization products directly infringe the ’482 patent (Compl. ¶45). The underlying technical theory is that the accused products implement a "multi-perimeter firewall system in a cloud in a virtualized network" that utilizes "stateful and deep-packet inspections" in a manner covered by at least one claim of the patent (Compl. ¶15).
  • ’064 Patent Infringement Allegations: The infringement theory for the ’064 patent is that Juniper's products constitute a "network system for connecting devices via a global virtual network" (Compl. ¶22). This system allegedly establishes a communication path, which includes at least one tunnel, by selecting from multiple candidate paths based on determined security ratings, thereby infringing at least one claim (Compl. ¶16, ¶19, ¶22, ¶52).
  • Identified Points of Contention:
    • Scope Questions: For the ’064 patent, a central question may be the definition of "security rating." The dispute may turn on whether Juniper's path selection algorithms use a metric that can be construed as a "security rating," as claimed, or if they rely exclusively on non-security metrics like latency, packet loss, or bandwidth, which may not read on the claim term.
    • Technical Questions: For the ’482 patent, a key factual question will be the specific architecture of the accused products. What evidence does the complaint provide that Juniper's products create a "multi-perimeter" system with distinct firewalls that "share threat information" as required by the claims, versus implementing a single, multi-function security appliance? The complaint's general allegations do not provide sufficient detail for analysis of this element.

V. Key Claim Terms for Construction

  • Term: "security rating" (from ’064 Patent, Claim 1)

    • Context and Importance: This term appears to be the central inventive concept of the ’064 patent’s asserted claims. The infringement dispute will likely depend on whether the metrics used by Juniper's accused routing systems fall within the scope of this term. Practitioners may focus on this term because it distinguishes the invention from conventional performance-based routing.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that security ratings are based on "security tests, performance logging and other data points," which suggests the rating is not limited to a single type of security metric and could encompass a composite score ('064 Patent, col. 44:57-60).
      • Evidence for a Narrower Interpretation: The specification provides a specific example where a "value of 1.0 [as] secure, and a value of 0.0 indicates completely insecure" ('064 Patent, col. 44:54-56). Defendant may argue this implies a requirement for a quantitative, numerically-scaled rating specifically directed to security, rather than a general quality score that might indirectly reflect security.

  • Term: "share threat information" (from ’482 Patent, Claim 1)

    • Context and Importance: This term is critical for defining the interaction between the two claimed firewalls. The infringement analysis will require determining if the accused Juniper products contain separate firewall components that communicate specific "threat information" with each other, as opposed to operating independently or reporting to a central, non-firewall controller.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes sharing information including "heuristic patterns, signatures of known threats, known malicious source IP addresses, or attack vectors," suggesting a wide variety of data could qualify as "threat information" ('482 Patent, col. 2:55-58).
      • Evidence for a Narrower Interpretation: The specific embodiment in Figure 11 shows distinct SPI and DPI firewalls communicating with cloud firewall load balancers, which then communicate with each other ('482 Patent, Fig. 11). A defendant may argue this structure implies a specific architectural requirement where the firewalls themselves, or their dedicated load balancers, must directly or indirectly exchange this information, rather than merely reporting to a common logging server.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead facts to support, nor does it contain counts for, indirect infringement. Each count alleges "directly infringe" (Compl. ¶45, ¶52, ¶59, ¶66, ¶73).
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement or allege that Defendant had pre-suit knowledge of the patents-in-suit. However, the prayer for relief requests a "declaration that this case is exceptional under 35 U.S.C. § 285" (Compl. p. 22, ¶C).

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

  • A core issue will be one of definitional scope: can the term "security rating," as described in the ’064 patent, be construed to cover the performance and reliability metrics (e.g., latency, jitter, packet loss) that are typically used in modern SD-WAN path selection algorithms, or does it require a discrete metric specifically measuring security risk?
  • A key evidentiary question will be one of architectural correspondence: do the accused Juniper products, as they actually operate, contain the distinct, multi-perimeter firewall architecture described in the ’482 and ’328 patents, specifically the element of two different types of firewalls that "share threat information" with each other?
  • A central procedural question will be pleading sufficiency: given that the complaint's infringement allegations for all five patents rely entirely on incorporating by reference extrinsic exhibits that were not filed with the complaint, a threshold issue may be whether the pleading, standing alone, provides sufficient factual detail to state a plausible claim for relief under the Iqbal/Twombly standard.