DCT
1:25-cv-01031
Sotat LLC v. Roku Inc
Key Events
Amended Complaint
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., 11/13/2025
- Venue Allegations: Venue is alleged as proper in the District of Delaware because Defendant is a Delaware corporation that resides in the state and has allegedly committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Roku-branded smart home security cameras, doorbells, and associated mobile application infringe two patents related to mobile surveillance systems that use motion detection to trigger data transfer to a user’s mobile device.
- Technical Context: The technology at issue falls within the consumer smart home and Internet of Things (IoT) sector, where network-connected devices provide users with remote monitoring and control capabilities via mobile applications.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the alleged infringement via a letter on July 30, 2025, approximately three and a half months prior to filing this First Amended Complaint.
Case Timeline
| Date | Event |
|---|---|
| 2009-07-31 | Priority Date for ’207 and ’809 Patents |
| 2017-12-26 | U.S. Patent No. 9,854,207 Issues |
| 2019-12-17 | U.S. Patent No. 10,511,809 Issues |
| 2025-07-30 | Plaintiff Sends Notice Letter to Defendant |
| 2025-11-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,854,207 - Mobile Surveillance System
The Invention Explained
- Problem Addressed: The patent describes conventional surveillance systems of the early 2000s as suffering from numerous drawbacks, including limited data storage, inefficient use of system resources, delays between an event and user notification, and a high incidence of false alarms (’207 Patent, col. 1:36-67; Compl. ¶15). These systems often required active, real-time monitoring or manual review of extensive footage, and lacked user-friendly remote configuration options (Compl. ¶¶12-13).
- The Patented Solution: The invention proposes a three-part system—a camera at a surveillance area, a server, and a mobile device—that shifts from continuous recording to event-based alerting (’207 Patent, Abstract). A motion detection mechanism at the camera triggers the system; when motion exceeds a set threshold, the server is signaled to transfer surveillance data (including metadata like audio, video, time, and location) to the user's mobile device, which in turn "activates" to alert the user (’207 Patent, col. 3:1-12, claim 10). The system is designed to give the user remote control over activation, recording, and data transfer via the mobile device (’207 Patent, col. 4:51-54).
- Technical Importance: The claimed approach sought to improve the efficiency and utility of surveillance by delivering targeted, actionable information to a user's mobile device in response to specific events, rather than requiring the storage and review of large volumes of irrelevant data (Compl. ¶20).
Key Claims at a Glance
- The complaint quotes independent claim 10 and alleges infringement of independent claim 19 (Compl. ¶¶19, 38). The analysis below focuses on claim 10 as it is detailed in the complaint's narrative.
- The essential elements of independent claim 10 include:
- A mobile device in communication with a server that receives surveillance data.
- At least one camera positioned at the surveillance area to capture the data.
- A motion detection mechanism operably engaged to the camera to detect motion variations.
- A server with a processor that signals the server to transfer surveillance data to the mobile device when motion exceeds a threshold.
- The processor also signals the server to retain stored data when motion reaches the threshold.
- The mobile device controls system activation and the start/stop of data capture.
- The mobile device controls the transfer of the surveillance data.
- The mobile device activates upon detection of motion at the surveillance area.
- The complaint reserves the right to assert additional claims, including dependent claims 23, 26, and 27 (Compl. ¶38, 48).
U.S. Patent No. 10,511,809 - Mobile Surveillance System
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’207 Patent, the ’809 Patent addresses the same shortcomings of prior art surveillance systems, focusing on the lack of efficient, interactive, and customizable user control (’809 Patent, col. 1:12-2:4; Compl. ¶¶12-15).
- The Patented Solution: This patent claims a method for conducting surveillance that incorporates the core motion-triggered data transfer system of the parent patent but adds an improved user interface component for scheduling (’809 Patent, Abstract, claim 1). The method includes steps for configuring the system, capturing data, and using the mobile device for control, but a central feature is that the mobile device "displays a datebook comprising days of the week and times of day" that a user can employ to schedule the transfer of surveillance data (’809 Patent, col. 6:12-22, claim 1).
- Technical Importance: The introduction of a "datebook" feature aimed to provide users with a more functional and customizable level of control over system operations than was available in earlier systems (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 10, among others (Compl. ¶39, 50). The analysis focuses on claim 1, which is quoted in the complaint.
- The essential elements of independent claim 1 include:
- Configuring a mobile device to communicate with a server.
- Positioning at least one camera at a surveillance area to capture data.
- Using the mobile device to control the start and stop of data capture.
- Providing a motion detection device to detect motion variations.
- Transferring surveillance data from the server to the mobile device when motion exceeds a predetermined threshold.
- Wherein the mobile device displays a datebook with days and times to schedule the transferring of surveillance data.
- The complaint reserves the right to assert additional claims, including dependent claim 17 (Compl. ¶50).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the "Exemplary Roku Products," which include Roku's line of network-connected security cameras (e.g., Floodlight Camera, Indoor Camera 360°), video doorbells, and the corresponding "Roku Smart Home App" mobile application (Compl. ¶¶30, 32).
Functionality and Market Context
- The accused products are described as surveillance systems comprising hardware (a camera, motion detector, microphone, speaker, wireless transmitter) that communicates wirelessly with the Roku Smart Home App installed on an end user's mobile device (Compl. ¶¶29, 37). The complaint alleges that users can configure these devices to transmit surveillance data to the mobile app upon the detection of motion (Compl. ¶30). The complaint includes an annotated image of the Roku Floodlight Camera identifying its key hardware components (Compl. ¶31, p. 11). The system allegedly allows users to control the devices and schedule the recording and transfer of data via a datebook-like interface within the mobile app (Compl. ¶¶42, 44).
IV. Analysis of Infringement Allegations
’207 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile device in communication with a server, wherein the server receives surveillance data | A user's mobile device with the Roku app communicates with Roku's servers, which receive data from the camera. | ¶41, 42 | col. 4:32-38 |
| at least one camera positioned at the surveillance area | End users position a Roku camera product at a location to be monitored. | ¶30, 40 | col. 4:46-48 |
| a motion detection mechanism operably engaged to the camera | Roku camera products include an integrated motion detector. | ¶31, 37 | col. 3:1-5 |
| the server comprises a processor that signals the server to transfer surveillance data to the mobile device when the motion detection mechanism obtains a motion detection measurement that exceeds a determined threshold | Surveillance data is communicated from the Roku product to the user's mobile device via a server upon detection of motion exceeding a threshold. | ¶43 | col. 3:5-12 |
| the processor signals the server to retain the stored surveillance data when the motion detection mechanism obtains a motion detection measurement that reaches the determined threshold | The complaint alleges that all elements of the claims are met by end users' use of the system. | ¶38 | col. 3:12-18 |
| the mobile device controls activation of the mobile surveillance system and control of start and stop of the capture of the surveillance data | The Roku app is used to activate, configure, and control the start and stop of data capture by the camera. | ¶42 | col. 4:51-54 |
| the mobile device controls the transfer of the surveillance data | The Roku app is used to schedule the transfer of surveillance data. | ¶44 | col. 4:51-54 |
| the mobile device activates upon detection of motion at the surveillance area | The user's mobile device activates upon receiving surveillance data by displaying a notification. Screenshot B depicts such a notification (Compl. ¶32, p. 12). | ¶43 | col. 10:43-44 |
’809 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| configuring a mobile device to communicate with a server | End users install and configure the Roku Smart Home App on their mobile devices to communicate with Roku's servers. | ¶42 | col. 9:18-22 |
| positioning at least one camera at said surveillance area | End users position a Roku camera product at a location to be monitored. | ¶40 | col. 9:23-28 |
| using the mobile device to control start and stop of the capture of the surveillance data | The Roku app is used to control the start and stop of data capture. | ¶42 | col. 4:49-52 |
| providing a motion detection device to detect variations in motion measurements | Roku products include an integrated motion detector. | ¶31, 37 | col. 3:2-11 |
| transferring surveillance data from the server to the mobile device when the motion detection device obtains a motion detection measurement that exceeds a predetermined threshold | Data is transmitted via a server to the mobile app when motion is detected. | ¶43 | col. 3:3-11 |
| wherein the mobile device displays a datebook comprising days of the week and times of day that can be synchronized... to schedule the transferring of surveillance data | The Roku app displays an interface for scheduling surveillance events, as depicted in Screenshot C (Compl. ¶32, p. 12). | ¶35, 44 | col. 6:12-22 |
- Identified Points of Contention:
- Scope Questions: The infringement theory depends on mapping the patent's general terms onto Roku's specific cloud-based architecture. A potential question for the court is whether Roku’s distributed cloud infrastructure constitutes the claimed "server" and "server processor" performing the recited signaling functions.
- Technical Questions: For the ’207 Patent, the complaint’s narrative focuses on the transfer of data upon motion detection. A point of contention may arise regarding the separate claim element that "the processor signals the server to retain the stored surveillance data," as the complaint does not provide specific factual allegations detailing how the accused system performs this distinct step.
V. Key Claim Terms for Construction
The Term: "the mobile device activates upon detection of motion" (’207 Patent, claim 10)
Context and Importance: The meaning of "activates" is central to determining infringement of this element. The accused functionality is the display of a push notification on a mobile device (Compl. ¶43, Screenshot B). Whether this constitutes "activation" of the device itself, as opposed to merely an action by an application on the device, will likely be a key dispute.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a specific definition for "activates," which may support an argument that the term should be given its plain and ordinary meaning, which could encompass any action that makes the user aware of the motion event, such as a notification.
- Evidence for a Narrower Interpretation: The patent’s objective is to provide "real time surveillance" (’207 Patent, col. 2:9-10). A party could argue that "activates" should be construed to mean a more involved process, such as automatically launching the mobile application or a live video feed, rather than simply displaying a passive notification.
The Term: "datebook" (’809 Patent, claim 1)
Context and Importance: Infringement of the ’809 Patent’s method claims hinges on whether the scheduling feature in the Roku Smart Home App is a "datebook." The complaint provides a screenshot of a "Create schedule" screen with options for start/end times and days of the week (Compl. ¶32, Screenshot C).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself provides functional language, describing the datebook as "comprising days of the week and times of day that can be synchronized...to schedule the transferring of surveillance data" (’809 Patent, claim 1). Plaintiff may argue that any graphical user interface that performs this function meets the claim limitation, regardless of its name or appearance.
- Evidence for a Narrower Interpretation: The specification describes the datebook as depicting a "month of dates associated with a time of day and/or event" (’809 Patent, col. 6:14-16). A party could argue this language requires a calendar-style interface (displaying a "month of dates") and that a simpler weekly scheduling tool, as potentially depicted in the complaint, does not meet this more specific description.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Roku instructs end users on how to use the accused products in an infringing manner through its website, user manuals, and videos (Compl. ¶¶47, 73, 84). Contributory infringement is based on the allegation that the accused Roku products are material components of the invention, are especially made for an infringing use, and are not suitable for a substantial non-infringing use (Compl. ¶¶53, 74, 85).
- Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint states that Plaintiff sent a notice letter to Roku on July 30, 2025, and that Roku continued its allegedly infringing conduct despite awareness of an "objectively high likelihood" of infringement (Compl. ¶¶62-63, 65).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: The case may turn on the construction of common words used in a specific technical context. Can the term "activates," as applied to a mobile device, be construed to cover the display of a software-based push notification? Similarly, does the accused app's weekly scheduling interface meet the patent's more descriptive language of a "datebook" that depicts a "month of dates"?
- A second central question will relate to system architecture: The dispute will likely involve whether Plaintiff can successfully map the elements of the patented three-part system (camera, server, mobile device) onto Roku’s integrated product ecosystem, which consists of a hardware device, a cloud-based service platform, and a mobile application. The analysis may focus on whether Roku’s cloud services perform the specific signaling and processing functions required of the claimed "server."
- A key evidentiary question will be one of functional specificity: For the ’207 Patent, the case may require evidence that the accused system performs the specific, claimed function of a processor signaling the server to retain stored data upon a motion event, a step that is distinct from the more heavily emphasized allegation of signaling the server to transfer data.