Sensor360 LLC v. Commsignia Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: Commsignia, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00294, D. Del., 03/11/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant, a Delaware corporation, has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to self-organizing, adaptive sensor networks.
• Technical Context: The technology concerns networks of deployable sensor modules that can autonomously determine whether to act as a data-gathering sensor or a data-processing controller, creating a resilient and flexible monitoring system.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,510,076 - "Sensor apparatus and system," Issued August 13, 2013

The Invention Explained

• Problem Addressed: The patent describes a need for rapidly deployable sensor systems for monitoring large areas, particularly in military applications, to detect events like vehicle movement or artillery fire (ʼ076 Patent, col. 1:10-18). Traditional sensor networks often relied on two distinct types of devices: simple "sensor modules" to detect events and more complex "control modules" to process and transmit data. This architecture created a vulnerability; if a control module was disabled, the nearby sensor modules would become useless (ʼ076 Patent, col. 2:38-54).
• The Patented Solution: The invention is a single, unified sensor module capable of operating in one of two modes: a "sensing mode" for detecting events or a "controlling mode" for receiving and processing data from other modules. Each module contains a processor that communicates with other modules in the network and determines which role it should play (ʼ076 Patent, Abstract; col. 2:28-34). This allows the network to be "self organising" and "adaptive," for example, by promoting a sensor-mode module to a control-mode module if the original controller fails or runs out of power (ʼ076 Patent, col. 3:10-18).
• Technical Importance: This design enhances the resilience and flexibility of a deployed sensor network by eliminating the single point of failure associated with dedicated control modules (ʼ076 Patent, col. 3:28-43).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, stating they are identified in an attached Exhibit 2, which was not publicly filed with the complaint (Compl. ¶11, ¶16). Independent claim 1 is the broadest apparatus claim.
• Independent Claim 1 requires:
  • A sensor module for use in a sensor network, comprising:
  • at least one sensor;
  • a locator for determining the location of the at least one sensor;
  • a transceiver for communicating with other sensor modules and/or a base station; and
  • a processor adapted to communicate with other sensor modules and to determine whether the sensor module should operate in a sensing mode or a controlling mode within the network.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to the "Exemplary Defendant Products" which are allegedly identified in claim charts provided in Exhibit 2, an exhibit not filed with the complaint (Compl. ¶11).

Functionality and Market Context

The complaint does not provide any specific details about the functionality or operation of the accused products. It alleges in a conclusory manner that the products "practice the technology claimed by the '076 Patent" (Compl. ¶16). No allegations are made regarding the products' commercial importance or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16-17). As this exhibit was not provided with the filed complaint, a detailed element-by-element analysis of the infringement allegations is not possible. The complaint’s narrative theory of infringement asserts that the "Exemplary Defendant Products" directly infringe by satisfying all elements of the "Exemplary '076 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent and the general nature of the allegations, the infringement analysis may raise several key questions:

• Technical Question: What evidence demonstrates that the accused products contain a processor that performs the active function of "determin[ing] whether the... module should operate in a sensing mode or a controlling mode"? This contrasts with a system where roles are pre-configured, static, or assigned by a central server external to the modules themselves.
• Scope Question: How does the architecture of the accused products map onto the patent's distinct "sensing mode" and "controlling mode"? The case may turn on whether the accused products’ operations can be fairly characterized as embodying this specific dual-mode functionality as claimed.

V. Key Claim Terms for Construction

• The Term: "determine whether the sensor module should operate in a sensing mode or a controlling mode" (from Claim 1)
• Context and Importance: This limitation appears to be the central innovative concept of the patent—the "self-organizing" capability. The outcome of the case could depend on whether the accused products perform this specific, autonomous decision-making process. Practitioners may focus on this term to distinguish the claimed invention from systems where nodes have fixed roles or are commanded by an external controller.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification lists several factors that the processor may consider, such as the module's location, the density of other nearby modules, and environmental conditions, suggesting a flexible and varied decision-making process (ʼ076 Patent, col. 2:2-25).
  • Evidence for a Narrower Interpretation: The patent repeatedly frames this determination as an active, independent decision by the module to adapt to changing network conditions, such as taking over for a failed control module or reorganizing based on newly detected events (ʼ076 Patent, col. 3:10-28). This language could support a construction requiring a specific, autonomous, and dynamic assessment rather than a passive receipt of instructions.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct customers and end users on how to use the accused products in a manner that directly infringes the ’076 Patent (Compl. ¶14).
• Willful Infringement: The willfulness allegation is based entirely on post-suit conduct. Plaintiff alleges that the service of the complaint provides Defendant with "actual knowledge" of infringement, and any continued infringing activity thereafter is willful (Compl. ¶13-14). The complaint does not allege any pre-suit knowledge.

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

• A core issue will be one of functional operation: Does the processor in an accused Commsignia module autonomously determine its own role (e.g., as a sensor or controller) by communicating with peer modules, as required by the patent's "self-organizing" concept? Or are roles assigned by a central controller or fixed at configuration, potentially placing the products outside the claim scope?
• A key evidentiary question will be what proof Plaintiff can marshal to show the internal decision-making logic of the accused products. The infringement analysis will likely require examination of technical documentation or source code to verify whether the accused processors perform the specific dynamic determination required by the claims, a fact not typically discernible from user-facing materials alone.