Unwired Global Systems LLC v. Universal Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Unwired Global Systems LLC (Delaware)
  • Defendant: Universal Electronics Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00947, D. Del., 07/29/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant being a Delaware corporation with an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a middleware interface for translating data between different communication protocols in a network.
• Technical Context: The technology concerns middleware for home area networks (HANs), designed to enable interoperability between household devices that use varied and often incompatible communication protocols.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2009-09-23	Priority Date for U.S. Patent No. 8,488,624
2010-09-22	Application Filing 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 Filing Date

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., for "smart" energy, lights, security) into a single home network ('624 Patent, col. 1:21-29). Different devices often use different, low-power communication protocols (like ZigBee or Bluetooth) that are not natively compatible with standard TCP/IP networks, creating significant programming overhead and complexity for developers trying to make them interoperate ('624 Patent, col. 1:30-59).
• The Patented Solution: The invention proposes a middleware layer, or "frame engine," that acts as a universal translator ('624 Patent, col. 2:6-14). This engine receives a data packet in a first protocol, uses a "machine-readable set of protocol frame definitions" to decode the packet into a standardized, "platform independent data object," and can then re-encode that object into a second protocol for transmission to a different device ('624 Patent, col. 11:9-22). This process is designed to abstract away the protocol-specific details, allowing applications to interact with diverse devices in a uniform manner ('624 Patent, col. 3:39-44).
• Technical Importance: This approach seeks to reduce the development burden of creating integrated smart home systems by providing a single, adaptable interface rather than requiring custom drivers for every device and protocol combination ('624 Patent, col. 1:55-63).

Key Claims at a Glance

• The complaint asserts "one or more claims" without specifying them (Compl. ¶11). Independent claim 1 is representative of the asserted method.
• Independent Claim 1 (Method):
  • 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 to the "Exemplary '624 Patent Claims" identified in its attached charts (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify specific products by name. It refers generally to "Exemplary Defendant Products" that are identified in charts attached as Exhibit 2, which was not included with the filed complaint (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’624 Patent (Compl. ¶16). It further alleges that Defendant has made, used, sold, offered for sale, and/or imported these products in the United States (Compl. ¶11, ¶14). The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided as Exhibit 2 (Compl. ¶16, ¶17). As Exhibit 2 was not provided with the complaint, a detailed element-by-element analysis based on the complaint's direct allegations is not possible.

The complaint’s narrative alleges that Defendant’s "Exemplary Defendant Products" directly infringe the ’624 Patent by practicing the claimed technology (Compl. ¶11, ¶16). It also alleges that Defendant’s internal testing and use of these products constitutes direct infringement (Compl. ¶12). No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "a machine-readable set of protocol frame definitions" (from Claim 1)

• Context and Importance: This term is the core of the claimed invention, as it describes the set of rules used by the "frame engine" to perform the crucial decoding and encoding steps. The scope of this term will likely determine whether the accused products' methods for handling data packets fall within the claims. Practitioners may focus on whether this term is limited to the specific file-based structures described in the patent or can encompass any set of rules for data translation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is broad, not limiting the "definitions" to a particular format. The specification describes the definitions as containing "instructions for translating to or from the particular data formats" ('624 Patent, col. 7:7-10), which could support an interpretation covering various rule-based systems.
  • Evidence for a Narrower Interpretation: The specification provides specific examples where these definitions are stored in files, such as XML files, located in a "base configuration directory" ('624 Patent, col. 8:36-44, col. 9:27-34). An embodiment describes a mapping in a "fields.xml" configuration file between tags in the definition language and the classes that implement the fields ('624 Patent, col. 8:19-25). A defendant may argue these specific implementations limit the term's scope to such file-based or XML-based architectures.

• The Term: "decoding the data packets into a set of data objects" (from Claim 1)

• Context and Importance: This term defines the central transformation step. The dispute may turn on what constitutes a "data object" in the context of the patent and whether the accused products create an equivalent intermediate data structure.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes the data objects as "platform independent," suggesting the key quality is their neutrality from the underlying communication protocol, not their specific data structure ('624 Patent, col. 3:18-22). The specification notes the objects are "suitable for access and modification" and may consist of "complex data objects" ('624 Patent, col. 3:22-25).
  • Evidence for a Narrower Interpretation: The specification repeatedly ties the "platform independent data objects" to JAVA primitives and data types ('624 Patent, col. 3:25-27, col. 4:5-10). It states that in one embodiment, "JAVA is the 'native language', and the platform independence of the data representation is due to the platform independence of Java's data representation" ('624 Patent, col. 4:63-65). This could support an argument that the claimed "data objects" are limited to those with Java-like properties or structures.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '624 Patent" (Compl. ¶14). These materials are referenced as being part of Exhibit 2 (Compl. ¶14).
• Willful Infringement: The complaint alleges knowledge of infringement based on the service of the complaint itself (Compl. ¶13). It alleges that despite this knowledge, Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" infringing products, which may serve as a basis for a willfulness claim based on post-filing conduct (Compl. ¶14).

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

This case appears to be in its earliest stages, with the complaint providing a high-level notice of the dispute. The central questions for the court will likely include:

1. A core issue will be one of definitional scope: How broadly will the court construe the term "machine-readable set of protocol frame definitions"? Will it be limited to the specific XML-based file structures detailed in the specification, or can it encompass any set of rules or instructions used by the accused products to translate between data protocols?

2. A key evidentiary question will be one of technical operation: Assuming a claim construction is established, what evidence will show that Defendant’s products actually perform the claimed three-step method of (1) receiving data in a first protocol, (2) "decoding" it into an intermediate, protocol-neutral "data object" based on "frame definitions," and (3) "encoding" that object into a second protocol? The specifics of this transformation process will be critical to the infringement analysis.