Unwired Global Systems LLC v. Tartbit

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Unwired Global Systems LLC (Delaware)
  • Defendant: Tartabit, LLC (Florida)
  • Plaintiff’s Counsel: Beusse Sanks, PLLC; Rabicoff Law LLC
• Case Identification: 9:25-cv-81398, S.D. Fla., 11/11/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products infringe a patent related to a middleware interface for translating data between different communication protocols in an area network.
• Technical Context: The technology at issue addresses the challenge of interoperability between various smart home or Internet of Things (IoT) devices that use different, often low-power, communication protocols (e.g., ZigBee, Bluetooth) and standard computer networks (e.g., TCP/IP).
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or inter partes review proceedings related to the patent-in-suit.

Case Timeline

Date	Event
2009-09-23	’624 Patent Priority Date
2013-07-16	’624 Patent Issue Date
2025-11-11	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

Issued July 16, 2013

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of integrating household devices that use various low-power communication protocols (such as ZigBee or Bluetooth) with traditional TCP/IP-based home networks. It notes that creating driver programs to translate between these protocols involves "significant programming overhead and a need for substantial computing capability" ( ’624 Patent, col. 1:41-56).
• The Patented Solution: The invention proposes a "protocol-neutral middleware interface" that acts as a universal translator for network communications ( ’624 Patent, Abstract). A central component called a "frame engine" receives a data packet in a first protocol. Using a "metadata map" contained in "field classes," the engine decodes the packet into a "platform independent data object." This standardized object can then be accessed by applications or re-encoded by the frame engine into a second, different communication protocol for transmission to another device ( ’624 Patent, col. 2:1-13; Fig. 1).
• Technical Importance: This approach aims to simplify the development of home automation systems by allowing software to communicate with a wide array of devices in a standardized way, without needing to implement a separate, complex protocol stack for each type of device ( ’624 Patent, col. 1:56-60).

Key Claims at a Glance

The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶11). The foundational independent claims of the patent are Claims 1 (method), 8 (apparatus), and 12 (network system).

• 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, where the decoding is done in accordance with a machine-readable set of protocol frame definitions containing sub-fields for parsing; and
  • encoding the data objects into a second communication protocol, also in accordance with the machine-readable set of protocol frame definitions.

• Independent Claim 8 (Apparatus):

  • At least one processor, support circuit, and storage device;
  • A frame engine to receive and decode a data packet from a first protocol into data objects;
  • A machine-readable set of protocol frame definitions with sub-fields for decoding the packet; and
  • A second machine-readable set of protocol frame definitions for encoding the data objects into a second protocol.

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 generally to "Exemplary Defendant Products" (Compl. ¶11) and incorporates by reference an unattached "Exhibit 2" that purportedly contains this information (Compl. ¶¶16-17).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the ’624 Patent" (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided with the filing (Compl. ¶¶16-17). The complaint’s narrative infringement theory is conclusory, stating that the accused products "satisfy all elements of the Exemplary ’624 Patent Claims" (Compl. ¶16). Without the claim charts or a more detailed factual narrative, a substantive analysis of the infringement allegations is not possible based on the complaint alone.

Identified Points of Contention

Given the abstract nature of the allegations, any infringement dispute will likely center on fundamental factual questions.

• Factual Questions: A primary question will be whether Defendant's products perform the core functions of the claims at all: specifically, do they receive data in a first protocol, decode it into a protocol-neutral format using predefined definitions, and then re-encode it into a second protocol? The complaint provides no facts to support this allegation.
• Scope Questions: A potential dispute may arise over the meaning of "decoding... in accordance with a machine-readable set of protocol frame definitions" (’624 Patent, col. 11:15-18). The question will be what level of structured, metadata-driven translation, as described in the patent's specification, is required to meet this limitation, versus more conventional protocol conversion techniques.

V. Key Claim Terms for Construction

The Term: "machine-readable set of protocol frame definitions"

• Context and Importance: This term is the core of the claimed invention, defining how the "frame engine" translates between protocols. The scope of this term will likely determine whether the patent covers a broad range of protocol translation systems or is limited to the specific architecture disclosed. Practitioners may focus on whether this term requires the use of external, configurable files (like the XML examples in the specification) or can read on hard-coded translation logic.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify the format of the "definitions," only that they are "machine-readable" and contain "sub-fields for parsing" (’624 Patent, col. 11:17-18). This could arguably encompass various forms of stored protocol structures.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes these definitions as being configured from "XML metadata" ( ’624 Patent, col. 7:30-31) and existing in files located through a specific directory-based algorithm ( ’624 Patent, col. 6:30-43). A defendant may argue that these embodiments limit the term to a system that uses such configurable, file-based metadata maps.

The Term: "frame engine"

• Context and Importance: This is the primary apparatus component responsible for executing the claimed method. Its construction will determine whether any software module that performs protocol translation infringes, or if the module must possess the specific operational characteristics described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims define the frame engine functionally, as a component that "receive[s] and decode[s] a data packet" and "encodes the data objects" (’624 Patent, col. 11:46-47; col. 12:20-22). This suggests a broad functional definition.
  • Evidence for a Narrower Interpretation: The detailed description portrays the frame engine (124) as a distinct component that works in concert with "field classes" (122) and "decoder classes" (128) to parse data packets based on metadata ( ’624 Patent, col. 4:30-32; col. 5:1-7). A defendant could argue that a true "frame engine" must operate using this specific modular architecture.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendant distributing "product literature and website materials" that instruct end users on an infringing use of the products (Compl. ¶14). The complaint references an unattached Exhibit 2 for support of this allegation (Compl. ¶14).
• Willful Infringement: The complaint bases its allegation of willfulness on Defendant's continued infringement after gaining "actual knowledge" of the patent via service of the complaint and its associated (but unattached) claim charts (Compl. ¶¶13-15). This constitutes an allegation of post-suit willfulness.

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

Based on the complaint, the litigation will likely turn on the resolution of two fundamental, open questions.

• Evidentiary Sufficiency: The primary hurdle for the plaintiff will be one of factual demonstration. Can the plaintiff produce evidence that the defendant’s unspecified products actually employ a system that decodes data from a first protocol into a standardized object and re-encodes it into a second protocol using a mechanism equivalent to the patent’s "machine-readable... frame definitions"? The complaint itself offers no such evidence.
• Definitional Scope: A core legal issue will be the construction of the term "machine-readable set of protocol frame definitions." Will this term be interpreted broadly to cover any form of automated protocol translation, or will it be limited by the specification's detailed examples of a system that relies on configurable XML files and metadata maps to achieve protocol neutrality?