DCT
1:25-cv-00137
Applied Capital Inc v. LTS Associate Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Applied Capital, Inc. (New Mexico)
- Defendant: LTS Associate, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Offor Evans PLLC
- Case Identification: 1:25-cv-00137, D. Del., 01/31/2025
- Venue Allegations: Venue is asserted in the District of Delaware based on Defendant being a corporation formed and existing under the laws of the State of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s video surveillance management software and servers infringe a patent related to systems for monitoring premises and dispatching enhanced, graphically-based alarm information.
- Technical Context: The technology concerns enhancing traditional alarm systems by integrating alarm data with visual information, such as interactive floor plans, to provide first responders with improved situational awareness.
- Key Procedural History: The asserted patent claims priority through a chain of applications to a provisional application filed in January 2009. The complaint notes the inventor, Rodney Fox, developed the technology following the events of September 11, 2001, to address the need for first responders to better visualize emergency situations in real time.
Case Timeline
| Date | Event |
|---|---|
| 2009-01-28 | Earliest Priority Date (U.S. Provisional No. 61/147,948) |
| 2017-08-08 | U.S. Patent No. 9,728,082 Issues |
| 2018-10-31 | Defendant LTS Associate, Inc. Incorporates |
| 2019-01-01 | Approximate Accused Product Launch (on or about 2019) |
| 2025-01-31 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,728,082 - “Premises monitoring system,” issued August 8, 2017
The Invention Explained
- Problem Addressed: The patent’s background, as reflected in the complaint, identifies a problem for first responders who, at the time of the invention, lacked a way to visualize in real-time the layout and conditions of a building during an emergency, having to rely on non-visual information from on-site alarm panels (Compl. ¶5).
- The Patented Solution: The invention is a system that supplements existing alarm monitoring by receiving a standard alarm signal (containing a device identifier and its condition) and then retrieving and dispatching "enhanced information" to designated recipients (’082 Patent, Abstract). This enhanced information is primarily graphical, including maps, floor plans, and images overlaid with "superimposed meaningful audio and/or visual indicators" to provide context, such as the location of an alarm, access paths, and hazards ('082 Patent, col. 5:8-21).
- Technical Importance: The technology aims to "reduce response time by promptly providing critical information to a first responder," transforming a simple alarm into actionable, visual intelligence (Compl. ¶11).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 ('082 Patent, Compl. ¶23).
- The essential elements of independent claim 1 include:
- A non-volatile and non-transient computer-readable medium comprising machine-executable code.
- Code for receiving one or more signals containing a device identifier and a device condition from a remote alarm monitoring system.
- Code for retrieving enhanced information based on the device identifier and device condition.
- Code for determining one or more communication methods and destinations based on the device identifier and device condition.
- Code for dispatching the enhanced information to the destinations using the determined methods.
- A "wherein" clause specifying that the retrieved enhanced information comprises images selected from the group of "superimposed visual indicators, hierarchically organized graphical images, and vector-based graphical images."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are surveillance management software and servers sold under the names or identifiers X-VMS, VSVMS-10K, and VSVMS-2000 (collectively, "X-VMS Product") (Compl. ¶21).
Functionality and Market Context
- The X-VMS Product is a client/server software system for monitoring events from devices like cameras, NVRs, and security and access control devices (Compl. ¶25).
- A key accused feature is the ability for users to associate a triggered alarm with an "e-map." This e-map is described as a static map on which a user can place "hot spots" to show the locations of devices. The complaint alleges these e-maps can be organized into hierarchies by linking "hot regions" on one map to another "child e-map," allowing navigation from large to detailed perspectives (Compl. ¶29, ¶12). A promotional graphic included in the complaint shows computer monitors displaying multi-level building schematics and a separate floor plan with a "YOU ARE HERE" indicator (Compl. p.5).
- The complaint alleges the X-VMS Products have been promoted and sold since approximately 2018 or 2019 to customers including security system resellers, designers, and installers (Compl. ¶2, ¶21).
IV. Analysis of Infringement Allegations
'082 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| code receiving one or more signals containing a device identifier and a device condition from one or more remote alarm monitoring systems | The X-VMS Product’s "Control Client" software receives alarm details from devices (e.g., cameras, NVRs). This alarm data includes an "event source," which allegedly serves as the "device identifier," and a "triggering event," which allegedly serves as the "device condition" (Compl. ¶25). | ¶25 | col. 2:7-10 |
| code retrieving enhanced information based on the device identifier and the device condition | When an alarm is detected that has an associated e-map, the X-VMS Product's "Control Client" retrieves the map, including its hot spots, hot regions, and any linked child e-maps (Compl. ¶29, ¶31). | ¶29 | col. 2:10-12 |
| wherein the retrieving enhanced information... comprises retrieving images... consisting of superimposed visual indicators, hierarchically organized graphical images, and vector-based graphical images | The complaint alleges that specific features of the accused e-maps meet these limitations: "Hot spots" on an e-map embody "superimposed visual indicators." "Hot regions or hot zones" that link to child e-maps embody "hierarchically organized graphical images." "Hot regions or hot zones" defined on an e-map embody "vector-based graphical images" (Compl. ¶29). The complaint includes a graphic of a floor plan with icons and layered displays to support this theory (Compl. p.5). | ¶29 | col. 4:5-18 |
| code determining one or more communication methods and communication destinations based on the device identifier and the device condition | An alarm rule within the X-VMS Product includes a "recipient" property that defines which users (the "communication destinations") can receive notification of a triggered alarm via the "Control Client" (the "communication method"). The system checks user roles and permissions associated with the alarm rule to determine who receives the notification (Compl. ¶27). | ¶27 | col. 2:12-14 |
| and code dispatching the enhanced information to the one or more communication destinations using the one or more communication methods | The "Control Client" software dispatches the retrieved e-map and its associated information to the user designated as the recipient in the alarm rule (Compl. ¶31). | ¶31 | col. 2:14-16 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern whether the accused features fall within the patent's definitions. For example: Does a user-placed "hot spot" on a static map constitute a "superimposed visual indicator" as contemplated by the patent? Does linking one static "e-map" to another constitute "hierarchically organized graphical images"?
- Technical Questions: The infringement theory for "determining... destinations based on the device identifier and the device condition" may raise questions. The complaint alleges the system checks user roles assigned to an alarm rule (Compl. ¶27). The court may need to consider whether this pre-configured, rule-based routing is sufficiently "based on the" specific, incoming device identifier and condition, or if the claim requires a more dynamic determination at the time the alarm is received.
V. Key Claim Terms for Construction
The Term: "superimposed visual indicators"
- Context and Importance: This term is critical, as the complaint alleges that "hot spots" on the accused e-maps meet this limitation (Compl. ¶29). The viability of the infringement claim depends on whether a user-defined icon or clickable area on a map image qualifies.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states an indicator "may include one or more icons or one or more designators superimposed on a map, picture, floor plan, and/or site plan" ('082 Patent, col. 5:11-14). This language may support a broad definition covering various icons.
- Evidence for a Narrower Interpretation: The specification provides examples of what these indicators "illustrate or instruct," such as "device position, condition type, hazardous material position, emergency exit position," and more ('082 Patent, col. 5:14-18). A party could argue the term requires the indicator itself to convey such specific instructive content, not just serve as a generic placemarker or link.
The Term: "hierarchically organized graphical images"
- Context and Importance: Plaintiff alleges that e-maps linked to child e-maps via "hot regions" meet this limitation (Compl. ¶29). Practitioners may focus on this term because the outcome will depend on whether a system of hyperlinked static images constitutes a "hierarchy" in the claimed sense.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent defines this broadly as "any group of graphical images arranged relative to one another and/or accessible through one another" ('082 Patent, col. 5:50-53). This could be read to cover a simple parent-child link between two images.
- Evidence for a Narrower Interpretation: The specific example provided is "a camera feed from a room of a device accessible from a floor plan accessible from a site plan accessible from a map" ('082 Patent, col. 5:53-56). This suggests a nested, drill-down structure with increasing levels of detail, which a party might argue is a requirement that is not met by simply linking two peer-level maps.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead a formal count for either induced or contributory infringement.
- Willful Infringement: The complaint does not allege facts to support a claim for willful infringement, such as pre-suit knowledge of the patent or egregious conduct. The prayer for relief includes a standard request for enhanced damages "upon proof," but the body of the complaint does not lay a foundation for such a claim (Compl. p.14, ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim terms "superimposed visual indicators" and "hierarchically organized graphical images", which are described in the patent with specific instructive examples, be construed broadly enough to read on the accused product’s functionality of placing "hot spots" and linking between "e-maps"?
- A key question of functional mapping will be whether the accused system's routing of alarm notifications to users based on pre-configured roles and permissions satisfies the claim requirement that communication destinations be determined "based on the device identifier and the device condition," or if this represents a fundamental difference in technical operation.