DCT

1:25-cv-00944

Unwired Global Systems LLC v. Litetrace Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00944, D. Del., 07/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant has an established place of business in the district and has allegedly committed acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a middleware interface for translating data between different network communication protocols.
  • Technical Context: The technology addresses the challenge of enabling communication between low-power devices on specialized networks (e.g., ZigBee in home automation) and applications running on conventional TCP/IP-based computer networks.
  • Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No other procedural history, such as prior litigation or administrative proceedings, is mentioned.

Case Timeline

Date Event
2009-09-23 ’624 Patent Priority Date (Provisional App. 61/277,288)
2013-07-16 ’624 Patent Issued
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

  • Issued: July 16, 2013

The Invention Explained

  • Problem Addressed: The patent identifies the difficulty and "significant programming overhead" associated with integrating household smart devices, which often use low-power, non-TCP/IP protocols (like ZigBee or Bluetooth), with applications running on standard computer networks (’624 Patent, col. 1:30-59). Creating custom drivers for each device type to communicate over a TCP/IP network is complex and computationally expensive for the devices involved (id. at col. 1:49-59).
  • The Patented Solution: The invention proposes a "protocol-neutral middleware interface" that acts as a universal translator (’624 Patent, Abstract). This interface, implemented on a routing computer, receives a data packet in a device's native protocol (the "first communication protocol") and uses a set of "protocol frame definitions" to decode it into a "platform independent data object" (id. at col. 2:1-6). This allows a host computer application to interact with the data in a standardized format, after which the interface can re-encode the object into a "second communication protocol" for transmission elsewhere (id. at col. 11:18-22). This process is managed by a "frame engine" that uses metadata to parse and create the data packets, as illustrated in the system architecture of Figure 1 (’624 Patent, Fig. 1; col. 4:40-43).
  • Technical Importance: This middleware approach sought to abstract the complexities of various proprietary or specialized communication protocols, enabling software developers to create applications for home automation and other "Internet of Things" (IoT) environments without needing deep expertise in each underlying hardware protocol (’624 Patent, col. 1:55-63).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims," including "exemplary claims" identified in an unprovided exhibit (Compl. ¶11). Independent claim 1 is representative of the core method.
  • Independent Claim 1 recites a method with the following essential elements:
    • Performing a method on a special-purpose computer programmed by a "frame engine."
    • Receiving one or more data packets encoded in a "first communication protocol."
    • Decoding the data packets into a set of data objects, where the decoding is performed "in accordance with a machine-readable set of protocol frame definitions containing one or more sub-fields for parsing of the data packets."
    • Encoding the data objects into a "second communication protocol" using "the machine-readable set of protocol frame definitions."
  • The complaint, through its general allegations, reserves the right to assert other independent and dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses "Exemplary Defendant Products" which it states are identified in charts incorporated into the complaint and attached as Exhibit 2 (Compl. ¶11, ¶16). These exhibits were not filed with the public version of the complaint.

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused products' specific features, functionality, or market context. It alleges that the products "practice the technology claimed by the ’624 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe the ’624 Patent but incorporates the specific infringement allegations by reference to an unprovided exhibit (Exhibit 2) containing claim charts (Compl. ¶16, ¶17). Without this exhibit, a direct comparison of accused functionality to claim elements is not possible based on the complaint alone. The complaint’s narrative theory is that the accused products satisfy all elements of the asserted claims (Compl. ¶16).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the technology and the claim language, the dispute may center on several technical and legal questions:
    • Scope Questions: The case may raise the question of what constitutes a "platform independent data object" as understood by the patent. The analysis will likely focus on whether the defendant's internal data representations are truly independent of its hardware and software platform or are merely an intermediate format within a proprietary system.
    • Technical Questions: A central evidentiary question may be whether the accused products perform the claimed "decoding" and "encoding" using a "machine-readable set of protocol frame definitions" as required by claim 1. The alternative could be that the products use hard-coded software logic for protocol translation, which may not meet the "frame definitions" limitation. Further, it may be disputed whether the accused system uses a single set of definitions for both decoding and encoding, as suggested by the claim language.

V. Key Claim Terms for Construction

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

    • Context and Importance: This term is the mechanism by which the claimed invention achieves its protocol-neutral translation. The definition will be critical to determine whether the accused products, which presumably perform some form of protocol translation, do so in the manner required by the patent. Practitioners may focus on whether this term requires a specific format (e.g., external configuration files) or can read on compiled code or other integrated logic.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that definitions "are usually configured from XML metadata" but "can also be configured via API," suggesting the format is not strictly limited to static files (’624 Patent, col. 7:28-31). This could support an argument that any structured, machine-parsable set of rules meets the limitation.
      • Evidence for a Narrower Interpretation: The specification repeatedly uses the example of definition files stored in a directory structure, such as C:\glue-1.0.0\frames\zcl\header.xml (’624 Patent, col. 6:35-44). This implementation detail could be argued to limit the scope of "definitions" to discrete, file-based metadata maps that are separate from the core executable code of the frame engine.

  • The Term: "platform independent data objects"

    • Context and Importance: This term describes the result of the "decoding" step and is the core of the invention's abstraction layer. Whether the data objects created by the accused system are "platform independent" will be a key infringement question.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term itself suggests a functional definition: an object whose representation is not dependent on a specific processor architecture or operating system. The purpose is to allow a driver program to "communicate with the household devices in a platform independent manner" (’624 Patent, col. 1:59-61).
      • Evidence for a Narrower Interpretation: The specification explicitly links the concept to the Java language: "the platform independence of the data representation is due to the platform independence of Java's data representation" (’624 Patent, col. 4:63-65). A defendant may argue this ties the claim term's scope to the specific object model and virtual machine environment of Java or functionally similar languages.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end users to operate the accused products in an infringing manner (Compl. ¶14). The knowledge element for inducement is alleged to exist "at least since being served by this Complaint" (Compl. ¶15).
  • Willful Infringement: The complaint does not contain a separate count for willful infringement. However, it alleges that Defendant has "Actual Knowledge of Infringement" from the date of service of the complaint and has continued its allegedly infringing activities despite this knowledge (Compl. ¶13, ¶14). The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is often associated with findings of willful infringement or other litigation misconduct (Compl. p. 5).

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

This case will likely depend on the resolution of fundamental questions regarding claim scope and the specific operation of the accused technology, which is not detailed in the complaint.

  • A core issue will be one of definitional scope: can the term "machine-readable set of protocol frame definitions" be construed to cover the internal logic of the accused products, or does it require a system of discrete, separable metadata files as exemplified in the patent’s specification?
  • A key evidentiary question will be one of technical implementation: what evidence will be adduced to demonstrate that the accused system generates "platform independent data objects"? The dispute will likely focus on whether the internal data structures are merely transient, proprietary formats or if they provide a stable, platform-agnostic interface as envisioned by the patent.
  • Finally, the inducement claim raises a legal and factual question: can infringement be induced solely by providing standard product documentation for post-suit conduct, and does that documentation in fact direct users to perform every step of the asserted method claim?