DCT
1:25-cv-01466
Iridescence LLC v. Wyze Labs Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Iridescence LLC (New Mexico)
- Defendant: Wyze Labs, Inc. (Delaware)
- Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
- Case Identification: 1:25-cv-01466, D. Del., 12/03/2025
- Venue Allegations: Venue is asserted based on Defendant’s incorporation in the State of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s smart home products infringe a patent related to systems and methods for remotely controlling power to electrical devices over a computer network.
- Technical Context: The technology relates to smart plugs and power controllers that integrate with home WiFi networks to allow both local and remote (Internet-based) control and monitoring of connected appliances.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-10-04 | ’560 Patent Priority Date |
| 2013-04-29 | ’560 Patent Application Filing Date |
| 2014-03-04 | ’560 Patent Issue Date |
| 2025-12-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,666,560 - "Power control system and method"
The Invention Explained
- Problem Addressed: The patent addresses deficiencies in prior art home automation systems. It notes that non-Internet-based systems (e.g., ZIGBEE®) cannot be controlled from anywhere, while early Internet-based systems were often intrusive to existing home networks, required professional setup, and forced users to communicate indirectly through a service provider's servers, creating performance and privacy issues (’560 Patent, col. 2:56-col. 3:20). The central challenge identified is the integration of disparate home automation networks with Internet-based control systems (’560 Patent, col. 4:33-38).
- The Patented Solution: The patent discloses a "Smart Gateway Power Controller" (SGPC), a device that functions as a "sub-gateway" on a home network (’560 Patent, Abstract; col. 11:57-62). The SGPC is designed to operate simultaneously as a client (station) on the user's primary home WiFi network and as an independent access point for its own dedicated subnet of automation devices (’560 Patent, Fig. 3; col. 11:48-56). This dual-role architecture allows for direct, local communication with the device (e.g., from a smartphone) while also using the main home gateway to connect to the Internet for remote access, thereby isolating the automation network from the dynamic nature of the main home network (’560 Patent, col. 11:57-col. 12:4).
- Technical Importance: This sub-gateway approach provided a method for seamlessly adding smart control capabilities to an existing home network without requiring replacement of the user’s primary router or reliance on a proprietary, closed ecosystem (’560 Patent, col. 4:49-54).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims" but does not specify which claims are asserted, instead referencing an external exhibit not provided with the complaint (Compl. ¶11, ¶16). Independent claim 1 is analyzed here as a representative claim.
- Independent Claim 1:
- A Smart Gateway Power Control (SGPC) system comprising a power plug, load receptacle, power switch, power monitor, computing device, and wireless communication interface.
- The computing device is configured to communicate to a first computer network and modulate the power switch in response to commands received from a user interface communicating with a second computer network.
- The computing device is configured to send a periodic message to a proxy server containing the SGPC's ID, password, router IP address, port, and subnet vector.
- A communication device is configured to request a translation from the proxy server, validate the SGPC ID and password, and return the router IP address and other path information to the user interface.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The complaint does not identify any specific accused products by name. It refers to "Exemplary Defendant Products" that are purportedly identified in charts within an external Exhibit 2, which was not filed with the complaint (Compl. ¶11).
Functionality and Market Context
The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market positioning.
IV. Analysis of Infringement Allegations
The complaint provides only conclusory allegations that the unspecified "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary ’560 Patent Claims" (Compl. ¶16). It references claim charts in Exhibit 2, which is not available for analysis (Compl. ¶17). As such, the complaint does not provide a narrative infringement theory or sufficient detail to construct a claim chart summary or identify specific points of contention.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The complaint offers no basis for analysis of key claim terms. Without specific infringement allegations linking claim limitations to features of an accused product, it is not possible to identify which terms are likely to be central to a dispute over claim scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in a manner that infringes the ’560 Patent (Compl. ¶14, ¶15).
- Willful Infringement: The complaint does not use the term "willful," but it alleges that service of the complaint constitutes "Actual Knowledge of Infringement" (Compl. ¶13). It further alleges that Defendant's continued infringing activities after receiving this notice support an award of enhanced damages (Compl. ¶14; Prayer ¶ D). This forms a basis for a claim of post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
Given the limited information in the complaint, the case will initially turn on fundamental evidentiary and claim construction issues that will be developed during discovery.
- A primary question will be one of evidentiary proof: Can Plaintiff demonstrate that Wyze's smart plug products, which are known to rely on a cloud-based architecture, implement the specific "sub-gateway" and "proxy server" communication protocol detailed in Claim 1 of the ’560 Patent? The analysis will likely focus on the precise method by which Wyze devices establish and maintain connectivity for remote access.
- The case may also center on a question of definitional scope: How should the term "proxy server" as used in the claims be construed? The patent describes a specific "pull mode" method where the SGPC periodically pushes its location to a server that users then query for access (’560 Patent, col. 12:47-50; col. 13:5-24). The resolution of the case may depend on whether Wyze’s cloud communication architecture falls within the scope of this claimed proxy server functionality.