Unwired Global Systems LLC v. Ledvance LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Unwired Global Systems LLC (Delaware)
  • Defendant: Ledvance LLC (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00943, D. Del., 07/29/2025
• Venue Allegations: Venue is asserted on the basis that Defendant is incorporated in Delaware and has an established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products, which appear to relate to network-connected devices, infringe a patent concerning a middleware interface for translating between different communication protocols.
• Technical Context: The technology relates to middleware for managing communications in heterogeneous networks, such as home area networks (HANs) where devices from various manufacturers use different, often proprietary, protocols.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2009-09-23	Priority Date for U.S. Patent No. 8,488,624
2013-07-16	Issue Date for U.S. Patent No. 8,488,624
2025-07-29	Complaint Filed

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

U.S. Patent No. 8,488,624 - "Method and apparatus for providing an area network middleware interface"

• Patent Identification: U.S. Patent No. 8,488,624, "Method and apparatus for providing an area network middleware interface", issued July 16, 2013.

The Invention Explained

• Problem Addressed: The patent describes the difficulty of integrating various household devices (e.g., smart lights, thermostats) into a single home network ('624 Patent, col. 1:41-44). These devices often use diverse, low-power communication protocols (e.g., ZigBee, Bluetooth) that are incompatible with standard TCP/IP networks, creating significant programming overhead and complexity for any central control system ('624 Patent, col. 1:28-40, 1:52-59).
• The Patented Solution: The invention proposes a middleware system, or "frame engine," that acts as a universal translator. This system receives a data packet in a device's native protocol, uses a set of "protocol frame definitions" (essentially a metadata map) to decode the packet into a standardized, "platform independent data object," and can then re-encode that object for transmission using a different protocol ('624 Patent, Abstract; col. 3:11-20). As illustrated in Figure 1, this allows a central routing computer (102) to mediate between different client devices (104) and various home area network (HAN) devices (108) without requiring application-level software to understand each device's specific protocol.
• Technical Importance: This approach creates an abstraction layer that simplifies the development of applications for home automation and the "Internet of Things," as it allows a single program to control a wide array of devices by interacting with the standardized data objects rather than with multiple, disparate, low-level communication protocols ('624 Patent, col. 1:55-59).

Key Claims at a Glance

• The complaint asserts "one or more claims" of the '624 Patent without specifying particular claims (Compl. ¶11). Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • A method for implementing a network interface performed by a special-purpose computer programmed by a frame engine, comprising:
  • receiving one or more data packets encoded in a first communication protocol;
  • decoding the data packets into a set of data objects wherein the data packets are decoded in accordance with a machine-readable set of protocol frame definitions containing one or more sub-fields for parsing of the data packets; and
  • encoding the data objects into a second communication protocol wherein the data objects are encoded in accordance with the machine-readable set of protocol frame definitions.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "claims of the '624 Patent" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name or model number. It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim charts referenced as Exhibit 2 (Compl. ¶¶11, 16). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint provides no description of the technical functionality, operation, or market context of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '624 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references infringement claim charts in an exhibit (Exhibit 2) that was not provided with the public filing (Compl. ¶¶16, 17). Therefore, a detailed element-by-element analysis is not possible based on the available document. The complaint’s narrative theory is that the "Exemplary Defendant Products," through their normal operation, "satisfy all elements of the Exemplary '624 Patent Claims" (Compl. ¶16). The complaint alleges infringement by making, using, offering to sell, selling, and/or importing the accused products (Compl. ¶11). No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the lack of detail, the primary points of contention are fundamental and evidentiary.
  • Evidentiary Question: A threshold question for the court will be to identify the specific products accused of infringement and to establish their precise technical architecture and method of operation.
  • Technical Question: Does the accused system, once identified, actually perform the three-step process of receiving in a first protocol, decoding to an intermediate "platform independent" format using "protocol frame definitions," and re-encoding into a second protocol as required by claim 1? The existence and nature of the intermediate data object and the "frame definitions" will be a central technical dispute.
  • Scope Question: The case may raise the question of whether the functionality of the accused products falls within the scope of the claims, particularly if their method of protocol translation differs from the specific embodiments described in the '624 Patent.

V. Key Claim Terms for Construction

• The Term: "platform independent data object"

  • Context and Importance: This term is central to the invention, defining the standardized intermediate format that enables protocol translation. The scope of this term will be critical; if construed narrowly, it may not cover modern data serialization formats not contemplated by the patent. Practitioners may focus on this term because its construction will determine whether a wide range of data structures can meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent summary describes the invention broadly as decoding packets "into a set of platform independent data objects" without limiting the format ('624 Patent, col. 2:3-5). This suggests any intermediate data representation that abstracts the underlying protocol could suffice.
    • Evidence for a Narrower Interpretation: The detailed description repeatedly references JAVA as the "native language" and states "the platform independence of the data representation is due to the platform independence of Java's data representation" ('624 Patent, col. 3:61-64). This could support an argument that the term is limited to Java objects or similarly structured object-oriented representations.

• The Term: "machine-readable set of protocol frame definitions"

  • Context and Importance: This term describes the "rules" or "map" used for decoding and encoding, which is the core mechanism of the claimed middleware. The dispute will likely center on what constitutes such a "set."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims require only a "machine-readable set" containing "sub-fields for parsing," which could arguably cover a wide array of configuration data, lookup tables, or schemas ('624 Patent, col. 11:15-18).
    • Evidence for a Narrower Interpretation: The specification provides specific examples, stating the definitions are "usually configured from XML metadata" and exist in files within a specific directory structure ('624 Patent, col. 5:35-44; col. 8:27-29). This could be used to argue that the term requires a file-based system of explicit, structured definitions, rather than, for example, hard-coded logic.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end-users on how to use the products in an infringing manner (Compl. ¶14). The allegation is also based on selling the products to customers for infringing use (Compl. ¶15).

Willful Infringement

The willfulness allegation is based on post-suit conduct. The complaint asserts that the filing of the complaint and its attached (but un-filed) claim charts provides Defendant with "actual knowledge," and any continued infringing activity thereafter is willful (Compl. ¶¶13-14).

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

1. An Evidentiary Question of Identification: The primary issue is the complete absence of information identifying the accused products and their functionality in the complaint. The case cannot proceed substantively until Plaintiff clarifies what specific Ledvance products are at issue and provides evidence of their technical operation.
2. A Core Issue of Claim Scope: The case will likely turn on the construction of "platform independent data object" and "machine-readable set of protocol frame definitions." The central question for the court will be whether these terms, as described in a patent from the JAVA and XML era, can be interpreted broadly enough to read on the architecture of modern connected-device ecosystems.
3. A Functional Question of Equivalence: Once the accused products are identified, a key dispute will be whether their method of handling data across different network layers is functionally equivalent to the patent's specific "decode-to-object-then-encode" process. The analysis will focus on whether the accused systems create a distinct, intermediate, and protocol-agnostic data object, as required by the claims, or if they employ a more direct or integrated translation method.