Unwired Global Systems LLC v. Xicato Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Unwired Global Systems LLC (Delaware)
  • Defendant: Xicato, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00948, D. Del., 07/29/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district, has committed acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to middleware for translating data between different communication protocols in a network environment.
• Technical Context: The technology concerns creating a protocol-neutral interface, allowing devices using disparate communication standards (e.g., ZigBee, Bluetooth) to communicate with a central computer system that typically uses a different protocol (e.g., TCP/IP).
• Key Procedural History: No prior litigation, licensing history, or other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2009-09-23	U.S. Patent No. 8,488,624 Priority Date
2010-09-22	Application for U.S. Patent No. 8,488,624 Filed
2013-07-16	U.S. Patent No. 8,488,624 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”

• Patent Identification: U.S. Patent No. 8,488,624, 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 home network ('924 Patent, col. 1:41-44). These devices often use low-power, specialized protocols (like ZigBee or Bluetooth), while central computers and internet-connected applications use standard protocols like TCP/IP, creating an incompatibility that requires significant programming overhead to bridge ('924 Patent, col. 1:30-40, 1:50-57).
• The Patented Solution: The invention proposes a middleware "frame engine" that acts as a universal translator. It receives a data packet in a device-specific "first communication protocol," uses a set of "protocol frame definitions" to decode it into a "platform independent data object," and can then re-encode that object for a "second communication protocol" ('924 Patent, Abstract; col. 2:1-14). This is accomplished by using "field classes" and metadata maps to parse the incoming data structure and transform it into a standardized, neutral format that other applications can easily access and manipulate ('924 Patent, col. 3:11-24; Fig. 1).
• Technical Importance: This approach aims to simplify the development of home automation and "Internet of Things" (IoT) applications by abstracting away the complexities of individual device protocols, allowing a single driver program to communicate with many different types of devices ('924 Patent, col. 1:55-63).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶11). Independent claims 1 (method) and 8 (apparatus) are the broadest claims in the patent.
• 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 alleges infringement of "one or more claims" generally (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Defendant Products" which it states are identified in charts incorporated as Exhibit 2 (Compl. ¶11, ¶16). The body of the complaint itself does not name any specific Xicato products, services, or methods.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context, as this information is allegedly contained within the unprovided Exhibit 2. It makes the conclusory allegation that the "Exemplary Defendant Products practice the technology claimed by the '624 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2 (Compl. ¶16-17). As Exhibit 2 was not included with the filed complaint document, a detailed element-by-element analysis is not possible.

The complaint’s narrative theory is that the Defendant’s "Exemplary Defendant Products" directly infringe the '624 Patent by performing the claimed method of protocol translation (Compl. ¶11). The complaint alleges that these products "satisfy all elements of the Exemplary '624 Patent Claims" (Compl. ¶16). It further alleges infringement by Defendant's employees who "internally test and use these Exemplary Products" (Compl. ¶12).

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent and the general nature of the allegations, the central dispute will likely revolve around how the accused products handle data from different network protocols.

• Scope Questions: A primary question will be whether the Defendant's products perform both the "decoding" and "encoding" steps as required by independent claim 1. The analysis will question if the accused system merely receives data in one format for internal use, or if it actively translates it into a second, distinct communication protocol for transmission to another device or network.
• Technical Questions: A key factual question will be whether the accused products utilize a "machine-readable set of protocol frame definitions" to perform protocol translation. The court may need to determine if the accused products use a flexible, metadata-driven system as described in the patent, or a more hard-coded, proprietary translation method that may not meet the claim's requirements.

V. Key Claim Terms for Construction

• The Term: "protocol frame definitions"

  • Context and Importance: This term is central to defining the mechanism of the invention. The patent describes these definitions as containing rules, metadata, and "sub-fields" for parsing data packets ('924 Patent, col. 11:16-18). The infringement analysis will depend on whether the accused products use a structure that can be characterized as "protocol frame definitions" or a different type of translation logic.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that these definitions can be configured from various sources, including XML metadata, and that they define how a frame is parsed ('924 Patent, col. 9:28-30, 9:66-68). This could support an interpretation covering any machine-readable rule set that dictates data translation.
    • Evidence for a Narrower Interpretation: The patent provides specific examples of these definitions, such as files in a "frames" directory that map to specific protocols like ZigBee, and which contain nested fields ('924 Patent, col. 8:36-44, 9:1-15). This could support a narrower construction requiring a hierarchical, file-based structure with explicit sub-fields, as opposed to a monolithic block of code.

• The Term: "platform independent data object"

  • Context and Importance: This term defines the result of the "decoding" step and the input to the "encoding" step. The core of the alleged invention is the creation of this intermediate, neutral data representation. Practitioners may focus on this term because the distinction between a protocol-specific "packet" and a "platform independent object" is critical to infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the objects are "suitable for access and modification" and can be accessed via an API as "JAVA primitives" ('924 Patent, col. 3:19-24). This may support a broad definition covering any internal data structure that has been abstracted from its original wire format.
    • Evidence for a Narrower Interpretation: The patent notes that the platform independence of the data object in one embodiment is "due to the platform independence of Java's data representation," and that "Not all languages provide a platform independent data representation" ('924 Patent, col. 4:63-col. 5:1). This could be used to argue that the term requires a specific type of neutrality, such as that provided by a managed runtime environment like Java, and not just any internal software object.

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 accused products in an infringing manner (Compl. ¶14). The claim is based on knowledge "at least since being served by this Complaint" (Compl. ¶15).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that the service of the complaint constitutes "actual knowledge" and that Defendant's infringement continues "despite such actual knowledge," which provides a basis for alleging post-filing willful infringement (Compl. ¶13-14). The prayer for relief requests damages for "continuing or future infringement," which aligns with this theory (Compl. Prayer ¶D).

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

1. A central issue will be one of technical mechanism: Do the accused products utilize a flexible, metadata-driven translation system that meets the "machine-readable set of protocol frame definitions" limitation, or do they employ a different, potentially non-infringing architecture for handling data from various network devices?
2. A key evidentiary question will be one of functional operation: Do the accused products perform the complete, three-step method of Claim 1—receiving in a first protocol, decoding to a platform-neutral object, and re-encoding into a second protocol—or does their functionality stop short of this full cycle, potentially avoiding infringement?
3. The case may also turn on a question of definitional scope: Can the term "platform independent data object," as described in the patent, be construed to read on the specific internal data representations used by Defendant’s software, or is there a fundamental mismatch in their technical character?