Ryrusch IP LLC v. Haas Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ryrusch IP LLC (Texas)
  • Defendant: Haas, Inc. (Illinois)
  • Plaintiff’s Counsel: Ramey, LLP; Carden & Tracy, LLC; CHOKEN WELLING LLP
• Case Identification: 1:25-cv-12615, N.D. Ill., 10/15/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a resident of Illinois, has a regular and established place of business in the district, and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services for controlling an environment infringe a patent related to methods for communicating emergency messages to electronic devices associated with a target person.
• Technical Context: The technology at issue involves systems for targeted, localized, and secure communication of emergency alerts from personnel to individuals, often in vehicles, to direct them to take appropriate action.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that its predecessors have entered into prior settlement licenses. It preemptively argues that these licenses did not require patent marking under 35 U.S.C. § 287(a) because they did not grant rights to produce a patented article and contained no admission of infringement.

Case Timeline

Date	Event
2019-02-22	U.S. Patent No. 11,363,439 Priority Date
2022-06-14	U.S. Patent No. 11,363,439 Issues
2025-10-15	Complaint Filed

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

U.S. Patent No. 11,363,439 - Method For Communicating Emergency Messages To An Electronic Devices Associated With A Target Person

• Patent Identification: U.S. Patent No. 11,363,439 (the "'439 Patent"), issued June 14, 2022.

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty emergency personnel face when trying to communicate with the public, particularly with individuals in motor vehicles. It identifies challenges such as ambient noise from traffic, in-vehicle distractions like music, general inattentiveness, and the spatial distance between the emergency vehicle and the target person, all of which can render traditional sirens and loudspeakers ineffective. (’439 Patent, col. 2:51-68). This communication failure can lead to traffic congestion that delays emergency responders. (’439 Patent, col. 3:17-23).
• The Patented Solution: The invention is a method for directly and securely transmitting an emergency message from a transmitter controlled by emergency personnel to a specific electronic device (e.g., a car radio, cell phone) associated with a "target person" within a defined signal radius. (’439 Patent, Abstract). The system establishes a one-way, temporary communication link using security codes, allowing personnel to bypass ambient noise and communicate specific instructions, such as to move a vehicle out of the way. (’439 Patent, col. 4:30-39; col. 7:27-44).
• Technical Importance: The described method sought to improve the reliability and specificity of emergency communications compared to broad, non-specific alerts like sirens or public address systems. (’439 Patent, col. 4:21-29).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-13. (Compl. ¶9). Independent claim 1 is a method claim.
• The essential elements of independent claim 1 include:
  • Providing an emergency vehicle, a transmitter, and an electronic device associated with a target person.
  • The transmitter is configured to send an emergency signal carrying a message and security codes within a signal radius, with its operation controlled by emergency personnel.
  • The electronic device is "cooperatively configured" to connect to and receive the message from said transmitter.
  • Confirming the message's origin using the security codes to establish an electronic connection.
  • "Beneficially controlling" an audio or visual function of the electronic device to improve the target person's ability to receive the message.
• The complaint reserves the right to assert dependent claims. (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific product, system, or service by name. It accuses "systems, products, and services for enabling a method for controlling an environment." (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that the accused instrumentality involves "establishing communication between a server and a control client." (Compl. ¶¶11-12). No further technical details on the functionality of this client-server communication are provided.
• The complaint does not provide sufficient detail for analysis of the accused instrumentality's market context or commercial importance.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "exhibit B" but this exhibit was not included with the provided filing. (Compl. ¶10). The body of the complaint offers only general and conclusory allegations of infringement without mapping specific features of an accused product to the elements of the asserted claims. (Compl. ¶9). For example, it states that Defendant "maintains, operates, and administers systems... that infringe" but does not describe how those systems operate. (Compl. ¶9). The complaint does not provide sufficient detail for a claim chart analysis.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the accused client-server communication architecture falls within the scope of the patent's claims, which describe a direct transmitter-to-device link controlled by "emergency personnel" within a "signal radius." The applicability of claim terms rooted in localized, direct-broadcast technology to a potentially broader, network-based server architecture may be a point of dispute.
  • Technical Questions: The complaint's lack of specificity raises the fundamental question of what technical evidence supports the allegation that Defendant's systems perform the steps of the claimed method. For instance, what evidence demonstrates that an accused system "confirms" a message's origin using "security codes" in the manner required by claim 1, or that it "beneficially controls" a device's audio/visual functions as claimed.

V. Key Claim Terms for Construction

• The Term: "cooperatively configured to be electronically connected to said transmitter and to receive said emergency message from said transmitter" (from claim 1).
• Context and Importance: The definition of this term is critical for determining the required relationship between the message-sending and message-receiving components. Practitioners may focus on this term because its construction will dictate whether the claim covers general-purpose devices that are temporarily enabled (e.g., via an application) to receive certain alerts, or if it is limited to systems where the transmitter and receiver are specifically designed with a pre-existing, dedicated communication protocol.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification mentions common electronic devices like "a radio 16a," "a cellular telephone 16b," and "a loudspeaker 16c," which could suggest the invention is intended to work with widely available, multi-purpose hardware. (’439 Patent, col. 6:28-32).
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes the use of "pre-existing code key systems" and matched "transmitting security codes" and "receiving security codes" to establish a "closed electronic communication network." (’439 Patent, col. 7:27-33; col. 11:55-61). This language may support a narrower construction requiring a specific, secure handshake protocol rather than a general-purpose connection.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its products in an infringing manner. (Compl. ¶11). It alleges contributory infringement on a similar basis. (Compl. ¶12). Both allegations are based on Defendant having known of the patent "from at least the issuance of the patent." (Compl. ¶11).
• Willful Infringement: The complaint alleges that Defendant's infringement is willful and seeks treble damages, based on the same allegation of knowledge since the patent's issuance date. (Compl. ¶¶11-12; Prayer for Relief ¶e).

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

This case appears to present several fundamental questions for the court:

1. Pleading Sufficiency: A threshold issue will be one of procedural compliance: do the complaint's generalized allegations against unspecified "systems, products, and services," absent the referenced claim chart exhibit, provide sufficient notice of infringement to satisfy federal pleading standards?
2. Architectural Mismatch: A key technical question will be one of system equivalence: does the accused "server and a control client" architecture, as described, perform the specific, localized, and secure transmission method recited in the claims? The dispute may center on whether a network-based system can be considered equivalent to the direct transmitter-to-receiver link described in the patent.
3. Definitional Scope: The outcome will likely depend on a core issue of claim construction: does the term "cooperatively configured" require a dedicated, pre-established communication protocol between the transmitter and receiver, or can it be construed more broadly to encompass general-purpose devices that are temporarily instructed by software to receive a message?