Sensor360 LLC v. COHDA Wireless Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: COHDA Wireless Limited (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00295, D. Del., 03/11/2025
• Venue Allegations: Venue is asserted on the basis that Defendant has an established place of business in the District of Delaware.
• 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 distributed sensors where individual sensor modules can dynamically alternate between sensing and controlling roles to enhance network robustness and efficiency.
• 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 problem in conventional deployed sensor networks where there are two distinct types of devices: "sensor modules" that only detect events and "control modules" that only receive and process data (ʼ076 Patent, col. 1:39-44). This fixed-role architecture creates a vulnerability; if a critical control module is disabled or its power is exhausted, the sensor modules it serves "become useless" (ʼ076 Patent, col. 1:51-54).
• The Patented Solution: The invention proposes a single, homogenous type of sensor module that is capable of operating in either a "sensing mode" or a "controlling mode" ('076 Patent, col. 2:27-34). Each module includes a processor that communicates with other modules in the network and determines which role it should adopt based on factors like its location, the location of other modules, or its remaining power ('076 Patent, col. 2:1-19, 60-64). This creates a "self organising adaptive network" where roles can be re-assigned dynamically, for example, to have another module take over the "controlling mode" if the original controller fails or runs out of power ('076 Patent, col. 3:7-17; Fig. 4).
• Technical Importance: This approach is designed to increase the flexibility and survivability of rapidly deployed sensor networks, particularly in military or disaster-relief scenarios where ideal placement is not feasible and network nodes may be damaged or destroyed ('076 Patent, col. 3:26-43).

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying claim numbers (Compl. ¶11). The patent contains one independent claim, Claim 1.
• Independent Claim 1 recites:
  • 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,
  • wherein the processor is adapted, in use, 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 to infringement of "one or more claims" (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products or services. It refers to them generally as the "Exemplary Defendant Products" identified in an attached exhibit (Compl. ¶11).

Functionality and Market Context

• The complaint provides no description of the functionality or operation of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '076 Patent" (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges infringement through claim charts provided in an external "Exhibit 2" (Compl. ¶16), which was not attached to the publicly filed complaint. The complaint's narrative infringement theory is that the unspecified "Exemplary Defendant Products" practice the claimed technology and satisfy all elements of the asserted claims (Compl. ¶11, 16). Without the claim charts or identification of the accused products, a detailed element-by-element analysis is not possible based on the complaint alone. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Technical Question: A central question will be whether the accused products contain a processor that performs the active step of "determin[ing] whether the sensor module should operate in a sensing mode or a controlling mode," as required by Claim 1. The dispute may focus on whether the accused products feature this dynamic, in-field, self-organizing capability, or if their roles are pre-set or assigned by a central controller, which may not meet the claim limitation.
  • Scope Question: The case may turn on the definitions of "sensing mode" and "controlling mode." The patent describes the "controlling mode" as involving receiving information from other sensor modules for potential analysis and transmission ('076 Patent, col. 1:40-44). A dispute could arise over whether an accused product that merely relays data without performing analysis or exercising network control falls within the scope of a "controlling mode" as contemplated by the patent.

V. Key Claim Terms for Construction

The Term: "determine whether the sensor module should operate in a sensing mode or a controlling mode"

• Context and Importance: This phrase recites the core functional capability of the claimed processor and is the central point of novelty described in the patent. Practitioners may focus on this term because its construction will likely decide whether the accused products, once identified, perform the specific, dynamic role-selection process required by the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any system where a module's processor selects one of two operational states based on some input satisfies this limitation.
  • Evidence for a Narrower Interpretation: The specification suggests an active, ongoing determination based on network conditions. The patent states the processor may "compare the location of the module with the location of other modules" ('076 Patent, col. 2:2-4), consider the "density of sensor modules" ('076 Patent, col. 2:6-7), or "monitor the power level" to switch roles when a controlling module fails ('076 Patent, col. 3:11-17). This language may support an interpretation requiring a dynamic, adaptive decision-making process rather than a one-time role assignment.

The Term: "controlling mode"

• Context and Importance: The distinction between a "sensing mode" and a "controlling mode" is fundamental to the claim. The definition of "controlling mode" is critical for establishing whether an accused device performs a function distinct from merely sensing or relaying data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any module which aggregates data from other modules and transmits it onward is operating in a "controlling mode."
  • Evidence for a Narrower Interpretation: The specification describes control modules as those which "receive data from the sensor modules for possible analysis and transmission to a base station" ('076 Patent, col. 1:41-44). When acting in a "controlling mode," the module "receives information relating to events from the sensor modules, possibly processes the information, and passes anything of interest back to a base station" ('076 Patent, col. 2:60-64). This may support a narrower construction requiring data processing or analysis, not just simple data relaying.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users to operate the accused products in a manner that infringes the '076 Patent (Compl. ¶14-15).
• Willful Infringement: The willfulness allegation is based on post-suit conduct. The complaint asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement," and that any continued infringing activity thereafter is willful (Compl. ¶13-14). No facts alleging pre-suit knowledge are presented.

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

• A primary evidentiary question will be one of operational function: once the accused products are identified in discovery, what evidence will show that their processors perform the specific, dynamic determination of switching between functionally distinct "sensing" and "controlling" modes based on network conditions, as opposed to operating in static or pre-assigned roles?
• The case will also present a core issue of definitional scope: can the term "controlling mode," as described in the patent specification, be construed to cover a device that simply relays or aggregates data, or does it require a higher level of functionality, such as active data processing, analysis, or network management?