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., 01/02/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant is a resident of Illinois, has a regular and established place of business in the district, and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services infringe a patent related to methods for communicating emergency messages from emergency personnel to a target person's electronic device within a defined geographic area.
• Technical Context: The technology addresses the challenge of delivering urgent alerts to individuals, particularly those in vehicles, by bypassing environmental noise and inattentiveness to directly communicate with their personal or in-vehicle electronic devices.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that it and its predecessors have entered into settlement licenses with other entities in prior litigation, asserting that those licenses do not trigger marking obligations under 35 U.S.C. § 287.

Case Timeline

Date	Event
2019-02-22	’439 Patent Priority Date
2022-06-14	’439 Patent Issue Date
2026-01-02	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 11,363,439, "Method for Communicating Emergency Messages to An Electronic Devices Associated with A Target Person," issued June 14, 2022 (’439 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty emergency personnel face when trying to communicate with people in nearby motor vehicles. It notes that in-vehicle noise (e.g., music), conversations, and general inattentiveness can prevent drivers from hearing traditional alerts like sirens or loudspeaker broadcasts, potentially delaying emergency response or creating dangerous situations (’439 Patent, col. 2:51-64).
• The Patented Solution: The invention is a method and system where emergency personnel can use a transmitter to send a geographically targeted emergency message directly to an electronic device (such as a cell phone or car radio) associated with a person in the vicinity (’439 Patent, Abstract). The system is designed to limit the signal to a specific "signal radius" and uses transmitting and receiving "security codes" to establish a secure, one-way communication link, allowing personnel to deliver alerts that might otherwise be missed (’439 Patent, col. 7:25-45; Fig. 1).
• Technical Importance: This approach aims to create a more reliable and direct channel for emergency communications, overcoming the physical and attentional barriers that render conventional mass-alert systems ineffective in localized, high-stakes scenarios (’439 Patent, col. 3:11-18).

Key Claims at a Glance

• The complaint asserts claims 1-13, with Claim 1 being the first independent method claim (’439 Patent, col. 13:1-14:40; Compl. ¶9).
• The essential elements of independent Claim 1 include:
  • Providing an emergency vehicle associated with emergency personnel, a transmitter, and an electronic device associated with a target person.
  • The transmitter is configured to transmit an emergency signal carrying a message and "one or more transmitting security codes."
  • The transmitter's operation, the message content, and a "signal radius" are selected and controlled by the emergency personnel.
  • The electronic device is "cooperatively configured" to connect to the transmitter and receive the message.
  • The method includes steps of selecting message content and signal radius, positioning the target person in the radius, transmitting the message, receiving it on the device, and confirming the message is from emergency personnel using "receiving security codes" before establishing the electronic connection.
• The complaint states that infringement is alleged for "one or more of claims 1-13" (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It alleges at a high level that Defendant's services involve a "method for controlling an environment, comprising establishing communication between a server and a control client" (Compl. ¶11, ¶12). No details are provided regarding how this alleged functionality relates to emergency communications or the specific features described in the ’439 Patent.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an exhibit (Exhibit B) to support its infringement allegations but does not include the exhibit with the pleading (Compl. ¶10). In the absence of a claim chart or specific factual allegations mapping product features to claim limitations, the infringement theory is articulated only in general terms. The complaint alleges that Defendant "maintains, operates, and administers systems, products, and services" that practice the patented methods (Compl. ¶9). No probative visual evidence provided in complaint.

Identified Points of Contention

• Factual Basis: A primary question for the court will be whether the plaintiff can produce evidence demonstrating that any of Defendant's unspecified "systems, products, and services" actually perform the specific steps recited in the asserted claims. The complaint’s lack of detail suggests that establishing a factual basis for infringement will be a central point of contention.
• Scope Questions: The complaint's only technical description of the accused functionality is "establishing communication between a server and a control client" (Compl. ¶11). This raises the question of whether this generic client-server architecture can satisfy the patent's more specific requirements, such as the use of a "transmitter" controlled by "emergency personnel" to broadcast a signal within a defined "signal radius."
• Technical Questions: What evidence does the complaint provide that Defendant’s systems use "transmitting security codes" and "receiving security codes" to confirm a message's origin before establishing a connection, as required by Claim 1? The pleading does not address this technical requirement, suggesting it may be a key point of dispute.

V. Key Claim Terms for Construction

The Term: "signal radius"

• Context and Importance: This term, appearing in independent Claim 1, is critical for defining the geographic scope of the claimed method. The patent describes a system for localized alerts, distinguishing it from wide-area broadcasts. Practitioners may focus on this term because the complaint’s only technical allegation—communication between a "server and a control client" (Compl. ¶11)—does not inherently imply a geographically constrained "radius," raising a potential mismatch between the alleged conduct and the claim language.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to define a specific method for creating the radius, which could support an argument that any form of location-based targeting (e.g., geofencing) meets the limitation.
  • Evidence for a Narrower Interpretation: The specification consistently links the "signal radius" to the physical range of the "transmitter 24" associated with the emergency personnel or vehicle (’439 Patent, Fig. 1; col. 7:32-37). This context may support a narrower construction tied to the propagation range of a local radio-frequency signal, as opposed to a logically defined zone in a cellular or IP-based network.

The Term: "emergency personnel"

• Context and Importance: This term defines the entity that controls the transmission of the emergency message under Claim 1. The definition of this term will be important for determining whether the accused system, which the complaint describes in terms of a "server and a control client" (Compl. ¶11), has a comparable controlling entity.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent provides a broad list of examples, including "law enforcement personnel, firefighters, ambulance drivers, EMTs, members of the military or private/public security forces and the like" (’439 Patent, col. 12:21-25). This list could support an argument that the term covers a wide range of human operators or even automated systems acting on their behalf.
  • Evidence for a Narrower Interpretation: The context throughout the patent implies a human in or near an emergency vehicle making active decisions about the message content, duration, and signal range (’439 Patent, col. 10:11-15). This could support a narrower construction requiring direct, real-time control by a human responder, potentially excluding fully automated alert systems.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement. It claims Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its products and services in an infringing manner (Compl. ¶11, ¶12). Knowledge is alleged based on Defendant having known of the ’439 patent "from at least the issuance of the patent" (Compl. ¶11).

Willful Infringement

• The complaint alleges willfulness based on Defendant's alleged knowledge of the ’439 Patent since its issue date and seeks treble damages (Compl. ¶11; Prayer for Relief ¶e). This constitutes an allegation of post-issuance willfulness.

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

• A primary issue will be one of evidentiary sufficiency: The complaint does not identify an accused product or provide any specific technical facts to support its infringement allegations. A key question for the case is whether the plaintiff can, through discovery, uncover evidence that maps the functionality of a specific product or service from the defendant to the detailed limitations of the asserted claims.
• A central legal issue will be one of definitional scope: Can the generic client-server communication architecture alleged in the complaint be construed to meet the specific claim requirements of an "emergency personnel" controlling a "transmitter" to send a secure message within a defined "signal radius"? The resolution of this question will likely depend on claim construction and determine whether the patent can read on modern networked systems.