Sensor360 LLC v. Applied Information Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: Applied Information, Inc. (Georgia)
  • Plaintiff’s Counsel: Advanced Technology Law; Rabicoff Law LLC
• Case Identification: 1:24-cv-02471, N.D. Ga., 06/05/2024
• Venue Allegations: Venue is alleged to be proper because Defendant has an established place of business in the district and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to self-organizing sensor networks for event monitoring.
• Technical Context: The technology concerns networks of distributed sensors that can autonomously determine their roles to monitor environments, a field relevant to military surveillance, disaster relief, and security applications.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2003-09-09	U.S. Patent No. 8,510,076 Priority Date
2013-08-13	U.S. Patent No. 8,510,076 Issues
2024-06-05	Complaint for Patent Infringement Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,510,076 - "Sensor apparatus and system," Issued August 13, 2013

The Invention Explained

• Problem Addressed: Traditional sensor networks for monitoring areas like battlefields often relied on two distinct types of modules: sensor modules to detect events and separate control modules to process and transmit data. This created a vulnerability, as disabling a single control module could render an entire section of the network useless (’076 Patent, col. 1:40-56). Furthermore, deploying such systems required careful placement, which is difficult in rapid-deployment scenarios (’076 Patent, col. 1:13-22).
• The Patented Solution: The invention is a single type of sensor module that contains a processor capable of deciding its own role within the network. Each module can communicate with others and autonomously determine whether it should act in a "sensing mode" (to detect events) or a "controlling mode" (to receive, process, and relay data) (’076 Patent, col. 1:28-34). This creates a "self organising adaptive network" where roles can be dynamically assigned based on factors like module location, density, or power levels, making the network more resilient and flexible (’076 Patent, Abstract; col. 2:1-25). Figure 4 illustrates this concept, showing multiple sensor modules (2a-2d) communicating with a module that has adopted a controlling role (2e) (’076 Patent, Fig. 4).
• Technical Importance: This approach provides a more robust and flexible sensor network by eliminating the single point of failure associated with dedicated control modules and allowing the network to adapt to random deployment patterns or changing conditions on the ground (’076 Patent, col. 3:26-44).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "exemplary claims" identified in an attached exhibit (Compl. ¶11). The patent contains two independent claims, Claim 1 (a sensor module) and Claim 22 (a sensor network).
• Independent Claim 1 (module): The essential elements are:
  • At least one sensor
  • A locator for determining the module's location
  • A transceiver for communication
  • A processor adapted to communicate with other modules and to determine whether the module should operate in a "sensing mode" or a "controlling mode" within the network.
• Independent Claim 22 (network): The essential elements are:
  • A plurality of sensor modules, each having a locator, a transceiver, and a processor
  • The network is adapted so that the modules communicate and determine whether each module should operate in a "sensing mode" or a "controlling mode" to identify and/or locate events.
• The complaint reserves the right to assert other claims, including by the doctrine of equivalents (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name the accused products in its main body, referring to them as "Exemplary Defendant Products" identified in charts within the unprovided Exhibit 2 (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context, as these details are deferred to the unprovided Exhibit 2 (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement but defers all specific comparisons of claim elements to accused product features to claim charts in an attached Exhibit 2 (Compl. ¶16-17). As Exhibit 2 was not provided with the complaint, a detailed claim chart summary cannot be constructed.

The complaint’s narrative theory of infringement is that the "Exemplary Defendant Products" practice the technology of the ’076 Patent and "satisfy all elements of the Exemplary ’076 Patent Claims" (Compl. ¶16). The infringement allegations cover acts of making, using, offering to sell, selling, and/or importing the accused products (Compl. ¶11).

• Identified Points of Contention:
  • Given the lack of specific allegations, the central dispute will likely revolve around whether the accused products’ architecture embodies the core concept of the ’076 patent.
  • Scope Questions: A primary question will be whether the accused products contain processors that perform the claimed function of actively "determin[ing] whether the sensor module should operate in a sensing mode or a controlling mode" (’076 Patent, col. 8:30-32). The nature and criteria for this "determination" will be a focal point.
  • Technical Questions: A key evidentiary question, once products are identified, will be whether the accused systems feature functionally distinct "sensing" and "controlling" modes, as opposed to a single mode of operation that includes both sensing and data relay. The complaint provides no evidence to address how the accused products perform this claimed dual-mode determination.

V. Key Claim Terms for Construction

• The Term: "determining whether the sensor module should operate in a sensing mode or a controlling mode"
• Context and Importance: This phrase from independent claims 1 and 22 captures the central inventive concept of a self-organizing network. The outcome of the case may depend on whether the accused products perform this specific "determination" process. Practitioners may focus on this term because the patent contrasts this dynamic, intelligent role-selection with prior art systems having fixed-function modules.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the "determination" can be based on a wide variety of factors, including "the location of the module," "the density of sensor modules," or even environmental factors like being in a valley (’076 Patent, col. 2:1-25). This could support an interpretation where any form of role differentiation based on network conditions meets the limitation.
  • Evidence for a Narrower Interpretation: The specification describes a more deliberate process, where a processor "may be adapted to review the situation either periodically or in response to certain occurrences," such as monitoring its own power level to decide whether to switch from sensing to control mode (’076 Patent, col. 3:5-14). This could support a narrower construction requiring a specific, ongoing, and responsive decision-making algorithm, rather than a static role assigned at startup.

VI. Other Allegations

• Indirect Infringement: Plaintiff alleges induced infringement, asserting that Defendant provides "product literature and website materials" that instruct and encourage end users to use the accused products in a manner that infringes the ’076 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges that service of the complaint itself provides "actual knowledge of infringement" (Compl. ¶13). The allegations of continued infringement after this notice form the basis for a claim of post-suit willful infringement (Compl. ¶14-15). The complaint does not allege any pre-suit knowledge by the Defendant.

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

The resolution of this dispute, based on the complaint, will likely depend on the answers to two fundamental questions:

1. A core issue will be one of functional operation: Do the accused products, which are not identified in the complaint, actually employ an architecture where individual modules autonomously "determine" whether to operate in distinct "sensing" or "controlling" modes, as required by the patent claims?
2. A second key question will be one of claim scope: How broadly will the court construe the term "determining"? Will it cover any system with differentiated node behavior, or will it be limited to a more explicit, dynamic, and ongoing process of self-assessment and role-switching as described in the patent’s preferred embodiments?