DCT
1:25-cv-01031
Sotat LLC v. Roku Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SOTAT, LLC (Florida)
- Defendant: Roku, Inc. (Delaware)
- Plaintiff’s Counsel: STAMOULIS & WEINBLATT LLC; CLAYTON, MCKAY & BAILEY, PC
- Case Identification: 1:25-cv-01031, D. Del., 08/15/2025
- Venue Allegations: Venue is asserted based on Defendant Roku, Inc. being a Delaware corporation and thus residing in the District of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s smart home security products and associated mobile application infringe patents related to mobile surveillance systems that use motion detection to trigger the transfer of data to a remote device.
- Technical Context: The technology at issue pertains to the integration of cameras, servers, and mobile devices for remote security monitoring, a central feature in the consumer-facing smart home and Internet of Things (IoT) market.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patents and its infringement allegations via a letter dated July 30, 2025, which forms the basis for the willfulness claims.
Case Timeline
| Date | Event |
|---|---|
| 2009-07-31 | '207 and '809 Patents Priority Date |
| 2017-12-26 | '207 Patent Issue Date |
| 2019-12-17 | '809 Patent Issue Date |
| 2025-07-30 | Plaintiff allegedly sent notice letter to Defendant |
| 2025-08-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,854,207 - "Mobile Surveillance System," issued December 26, 2017
The Invention Explained
- Problem Addressed: The patent describes prior art electronic surveillance systems as suffering from numerous shortcomings, including inefficient resource use, data storage limitations, an inability to parse different data types for selective transfer, and a lack of user-friendly interfaces for scheduling surveillance operations (Compl. ¶15; ’207 Patent, col. 1:36-67).
- The Patented Solution: The invention proposes a surveillance system architecture comprising a camera at a surveillance location, a server, and a mobile device (’207 Patent, Abstract). This system is designed to overcome prior art limitations by using a motion detection mechanism to trigger the transfer of surveillance data to the user's mobile device only when an event of interest occurs, thereby conserving storage and bandwidth, and allowing the user to control the system remotely (’207 Patent, col. 4:30-49).
- Technical Importance: This approach sought to provide a more efficient and responsive remote surveillance solution compared to systems that required continuous recording or manual review of footage (Compl. ¶19).
Key Claims at a Glance
- The complaint’s allegations focus on independent system claim 19 (Compl. ¶39).
- Essential elements of Claim 19 include:
- A mobile device configured to communicate with at least one camera at a surveillance area.
- The mobile device is configured to control activation, start/stop of capture, and transfer of surveillance data.
- The surveillance data is wirelessly communicated directly from a transmitter linked to the camera to the mobile device.
- The mobile device is configured to activate upon detection of motion that exceeds a determined threshold.
- The complaint reserves the right to assert additional claims.
U.S. Patent No. 10,511,809 - "Mobile Surveillance System," issued December 17, 2019
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the '207 Patent, the '809 Patent addresses the same technical problems in conventional surveillance systems, such as limited storage, inefficient data transmission, and poor user control over recording schedules (’809 Patent, col. 1:12-67).
- The Patented Solution: The '809 Patent claims a method for conducting surveillance where a user controls a camera system via a mobile device (’809 Patent, Abstract). A key feature is the mobile device displaying a "datebook" that can be synchronized with a software application to schedule the recording and transfer of surveillance data based on specific days and times, in addition to being triggered by motion detection (’809 Patent, col. 6:12-22).
- Technical Importance: The claimed method provided for a higher degree of user customization and functional control over when surveillance data is captured and transmitted, improving on less flexible systems (Compl. ¶22).
Key Claims at a Glance
- The complaint’s allegations focus on independent method claim 10 (Compl. ¶41).
- Essential elements of Claim 10 include:
- Receiving an instruction from a mobile device to control start and stop of data capture.
- Capturing surveillance data with a camera that is engaged with a motion detection mechanism.
- Transferring the data to the mobile device when a motion measurement exceeds a predetermined threshold.
- The mobile device displaying a "datebook" with days and times to schedule the data transfer.
- The complaint reserves the right to assert additional claims.
III. The Accused Instrumentality
Product Identification
The accused products are Defendant’s "Roku" branded surveillance devices, including its Indoor Camera, Indoor Camera 360°, Battery Camera, Battery Camera Plus, Outdoor Wired Camera, Floodlight Camera, Video Doorbell, and Wire-free Video Doorbell products (collectively, "Exemplary Roku Products") (Compl. ¶25). These devices are used in conjunction with Defendant’s Roku Smart Home App (the "mobile application") (Compl. ¶26).
Functionality and Market Context
The complaint alleges that the accused system consists of network-connected surveillance devices (which include a camera and motion detector) that wirelessly communicate with a user's mobile device via a server (Compl. ¶¶ 24, 32). Users allegedly employ the mobile application to configure and control the cameras, including starting and stopping data capture (Compl. ¶33). When the camera's motion detector senses movement exceeding a threshold, surveillance data is transmitted to the user's mobile device, which in turn activates and displays a notification (Compl. ¶34). The complaint also alleges the mobile application provides a "datebook" for scheduling recording and data transfer (Compl. ¶35).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'207 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile device configured to communicate with at least one camera positioned at a surveillance area... | The Roku Smart Home App, installed on a mobile device, communicates with the Roku cameras. | ¶33 | col. 2:14-18 |
| the mobile device is configured to control activation of the mobile surveillance system, and control start and stop of the capture of the surveillance data, and transfer of the surveillance data... | End users allegedly use the mobile application to activate the system and to start and stop the capture and transfer of surveillance data. | ¶33 | col. 4:49-52 |
| the surveillance data is wirelessly communicated directly from a transmitter linked to the camera to the mobile device... | The Roku camera contains a transmitter that wirelessly communicates surveillance data to the user's mobile device, via a server. | ¶¶32, 34 | col. 4:30-40 |
| the mobile device is further configured to activate upon detection of motion at the surveillance area... | The user's mobile device activates upon receiving surveillance data and displays a notification when motion is detected by the camera. | ¶34 | col. 9:43-45 |
| wherein mobile device activates when the motion measurements exceeds a determined threshold. | The transfer of data and activation of the mobile device occurs upon the motion detection mechanism detecting a measurement that exceeds a threshold. | ¶34 | col. 3:5-11 |
'809 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving an instruction from a mobile device to control start and stop of capture of surveillance data at a surveillance area; | End users allegedly use the mobile application to control the starting and stopping of data capture by the Roku cameras. | ¶33 | col. 4:58-62 |
| capturing the surveillance data by a camera at the surveillance area, wherein the camera is operably engaged to a motion detection mechanism... | The accused Roku cameras capture surveillance data and are operably engaged to a motion detection mechanism. | ¶28 | col. 3:2-7 |
| transferring said surveillance data to the mobile device when the motion detection mechanism obtains a motion detection measurement that exceeds a predetermined threshold... | Surveillance data is communicated from the Roku camera to the user's mobile device upon the detection of motion exceeding a threshold. | ¶34 | col. 3:5-11 |
| wherein the mobile device displays a datebook comprising days of the week and times of day that can be synchronized with an application of the user device to schedule the transferring of surveillance data. | The mobile application is alleged to provide a scheduling feature, or "datebook," which includes days of the week and times of day to schedule recording and data transfer. | ¶35 | col. 6:12-22 |
Identified Points of Contention
- Scope Questions:
- A central question for the ’207 Patent may be the interpretation of "wirelessly communicated directly from a transmitter... to the mobile device." The complaint alleges the accused system operates "via a server" (Compl. ¶32), which raises the question of whether communication that passes through an intermediary server can be considered "direct" under the patent's claims.
- For the '809 Patent, a key dispute may arise over the meaning of "datebook." The infringement allegation will depend on whether the accused application's scheduling interface meets the definition of this term as used in the patent.
- Technical Questions: The complaint alleges that the mobile device "activates" upon receiving data (Compl. ¶34). The case may require evidence establishing what constitutes "activation" of the mobile device and whether the accused system's push notifications or other alerts perform this claimed function.
V. Key Claim Terms for Construction
The Term: "wirelessly communicated directly from a transmitter linked to the camera to the mobile device" (’207 Patent, Claim 19)
- Context and Importance: This term's construction is critical because the complaint alleges the accused system communicates "via a server" (Compl. ¶32). A narrow construction requiring a direct peer-to-peer connection could support a non-infringement argument, while a broader construction that allows for data routing through standard network infrastructure like servers would be necessary for the plaintiff's theory to succeed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes embodiments where communication occurs through a "network" and "base station," which inherently involve intermediary components between the camera and mobile device (’207 Patent, Fig. 4; col. 8:50-67).
- Evidence for a Narrower Interpretation: The claim drafter’s choice of the word "directly" in this specific claim, which is absent from other descriptions in the patent, may suggest an intentional limitation to distinguish it from system architectures that explicitly rely on servers or base stations.
The Term: "datebook" (’809 Patent, Claim 10)
- Context and Importance: Infringement of claim 10 hinges on whether the scheduling feature in the Roku Smart Home App constitutes a "datebook." Practitioners may focus on this term as it appears to be a specific feature described in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the functional purpose as allowing a user to "program the camera... to start and stop recording at designated times of day" (’809 Patent, col. 4:58-60). This language could support construing any graphical user interface that allows for time-based scheduling as a "datebook."
- Evidence for a Narrower Interpretation: The specification provides a more specific description, stating the "datebook depicts a month of dates associated with a time of day and/or event" (’809 Patent, col. 6:13-15). This could support a narrower construction requiring a calendar-style interface, which the accused product may or may not possess.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement. It asserts that Defendant induces infringement by providing instructional materials, such as user manuals and videos, that direct end users to set up and operate the accused products in an infringing manner (Compl. ¶¶ 38, 64, 75). Contributory infringement is alleged on the basis that Defendant's products are a material part of the patented invention and are not suitable for substantial non-infringing use (Compl. ¶¶ 44, 65, 76).
Willful Infringement
The complaint alleges willful infringement based on Defendant's purported knowledge of the patents-in-suit since at least July 30, 2025, the date Plaintiff's counsel allegedly sent a notice letter to Defendant (Compl. ¶¶ 53-54). The complaint further alleges that Defendant continued its infringing conduct despite an objectively high likelihood of infringement (Compl. ¶¶ 56-57).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute will likely center on several key technical and legal questions for the court's determination:
- A core issue will be one of definitional scope: Can the claim term "wirelessly communicated directly," in the context of the '207 Patent, be construed to cover a system architecture where data is routed "via a server," as alleged in the complaint? The resolution of this question may determine infringement for a primary asserted claim.
- Another key issue will be one of claim construction: Does the scheduling interface within the accused Roku application constitute a "datebook" as required by claim 10 of the '809 Patent, particularly given the patent's specific description of a "month of dates" display?
- A third issue will be one of evidentiary proof: What evidence will be presented to demonstrate that the accused system's components—from the motion detection thresholds to the "activation" of the mobile device—perform the specific functions recited in the asserted claims in the manner they require?