SecureNet Solutions Group LLC v. Siemens Industry Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SecureNet Solutions Group, LLC (Florida)
  • Defendant: Siemens Industry, Inc. (Delaware, with principal place of business in Illinois)
  • Plaintiff’s Counsel: Michael Best & Friedrich LLP
• Case Identification: 1:26-cv-01149, N.D. Ill., 02/02/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Siemens resides there, has its principal place of business there, and conducts business, including the allegedly infringing activity, in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Siveillance Suite of video analytics and security management products infringes seven U.S. patents related to systems for correlating sensory data from disparate sources to identify critical events.
• Technical Context: The technology addresses the field of computerized security and surveillance, aiming to overcome the challenges of analyzing large volumes of data from siloed sensor systems by intelligently correlating events to reduce false positives and enhance situational awareness.
• Key Procedural History: The complaint alleges that during the prosecution of several of the asserted patents, the applicant addressed patent eligibility issues under Alice v. CLS Bank, distinguishing the inventions as specific computerized improvements, not abstract ideas. The complaint also alleges that Siemens had pre-suit knowledge of several patents-in-suit or members of their patent family as early as March 2010, and also through a partnership with Milestone Systems, Inc., which allegedly had notice of other asserted patents in 2013; these allegations form the basis of a willfulness claim.

Case Timeline

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

U.S. Patent No. 7,737,837 - Hierarchical Data Storage Manager, Anonymous Tip Processing Engine, and a Vehicle Information Processing Engine for Security and Safety Applications

• Issued: June 15, 2010

The Invention Explained

• Problem Addressed: Traditional computerized security systems generate massive volumes of data from disparate sources (e.g., cameras, sensors, 911 calls) but lack the ability to effectively analyze and connect crime-related events, resulting in errors and false positives (Compl. ¶¶6-7; ’314 Patent, col. 1:33-52). The sheer volume of data makes storage and retrieval difficult and costly Compl. ¶30 ’314 Patent, col. 11:21-35
• The Patented Solution: The invention is a system that ingests "primitive events" from various sensors, normalizes them into a standard format, and processes them through a "correlation engine" Compl. ¶¶7, 10-11 This engine can weigh events based on the "attribute data" (e.g., reliability, age, maintenance history) of the sensors that captured them, correlate events across space and time to identify more complex "compound events," and issue alerts based on predefined rules Compl. ¶¶11-16 ’314 Patent, col. 7:15-28 It also specifies a hierarchical storage manager to intelligently cascade data to different storage tiers based on importance, optimizing performance and cost Compl. ¶¶30-34 ’314 Patent, Fig. 4
• Technical Importance: This approach provided a framework for transforming siloed, raw sensor data into a coherent, weighted, and correlated picture of events, aiming to reduce false alarms and allow security personnel to focus on critical threats Compl. ¶¶48-49

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶122
• Essential Elements of Claim 1:
  • An alerting system, comprising: one or more sensors for capturing sensory data;
  • a hierarchy of two or more data storage devices, connected to the sensors via network, for storing the sensory data;
  • one or more processors connected to the sensors via the network; and
  • one or more memories with program code to:
    • capture sensory data from the sensors;
    • capture attribute data representing information about the sensors;
    • process the sensory data to detect primitive events;
    • correlate two or more primitive events, where the primitive events are weighted by the attribute data; and
    • perform one or more actions based on the correlation.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,130,098 - Systems and methods for safety and business productivity

• Issued: March 6, 2012

The Invention Explained

This patent shares a common specification with the ’837 Patent and is directed to the same core technology of correlating weighted sensor data, as described above. The asserted claim is a method claim that mirrors the functionality of the system claim of the ’837 Patent.

Key Claims at a Glance

• The complaint asserts independent claim 13 Compl. ¶128
• Essential Elements of Claim 13:
  • A safety method, comprising the steps of: capturing sensory data from one or more sensors;
  • storing the sensory data from the sensors in a data storage device;
  • processing the sensory data, weighted by attribute data, to detect primitive events using a computer processor;
  • correlating two or more primitive events to determine one or more correlated events using the computer processor; and
  • performing one or more actions to ensure safety procedures are followed based on the correlation.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,354,926 - Systems and methods for business process monitoring

• Issued: January 15, 2013
• Technology Synopsis: This patent, from the same family, describes a method to ensure business processes are followed. It uses the same underlying technology of capturing, storing, and processing sensory data that is weighted by sensor attributes to correlate events and trigger actions Compl. ¶133
• Asserted Claims: Independent claim 34 Compl. ¶133
• Accused Features: The Siveillance Suite is alleged to enable customers to practice the claimed method of monitoring business processes Compl. ¶134

U.S. Patent No. 9,344,616 - Correlation engine for security, safety, and business productivity

• Issued: May 17, 2016
• Technology Synopsis: This patent claims a non-transitory storage medium with code for executing a multi-step process. The process involves receiving and processing sensory data to detect primitive events, normalizing them, storing them, and then evaluating historical correlations across time and space to identify critical events, with the events being weighted by sensor attribute data Compl. ¶138
• Asserted Claims: Independent claim 39 and dependent claim 48 Compl. ¶138
• Accused Features: The Siveillance Suite is alleged to perform the claimed steps, including normalizing data from various sensors and inputs Compl. ¶139

U.S. Patent No. 9,619,984 - Systems and methods for correlating data from IP sensor networks for security, safety, and business productivity applications

• Issued: April 11, 2017
• Technology Synopsis: This patent claims a monitoring system on a non-transitory storage medium. The system is configured to receive and process sensory and IP data, normalize events, evaluate historical correlations, and monitor for critical events and network failures. The claims specifically recite that a detected face can be a primitive sensory event and can be correlated with other events based on sensor attribute data Compl. ¶143
• Asserted Claims: Independent claim 1 and dependent claims 21 and 22 Compl. ¶143
• Accused Features: The Siveillance Suite is alleged to practice the claimed steps, including the ability to correlate a detected face with other events when integrated with third-party video analytics Compl. ¶¶144-145

U.S. Patent No. 11,323,314 - Heirarchical data storage and correlation system for correlating and storing sensory events in a security and safety system

• Issued: May 3, 2022
• Technology Synopsis: This patent claims a non-transitory storage medium with code for a system comprising several interconnected modules: a sensory event analytics module, a hierarchical storage manager, a correlation module, and an alerting module, all communicating over an IP network. The system processes events from IP video cameras (e.g., face, vehicle, license plate) and weights them based on sensor attribute data Compl. ¶149
• Asserted Claims: Independent claim 1 and dependent claim 13 Compl. ¶149
• Accused Features: The Siveillance Suite is alleged to practice the claimed system of interconnected modules Compl. ¶150

U.S. Patent No. 11,929,870 - Correlation engine for correlating sensory events

• Issued: March 12, 2024
• Technology Synopsis: This patent claims a non-transitory storage medium with code for implementing a system with a receiver module, an event queue, a correlation module, an alerting module, and a network analytics module. The system is designed to process specific sensory events (face, vehicle, license plate) from an IP video camera and weight them based on sensor attribute data and historical correlations Compl. ¶154
• Asserted Claims: Dependent claim 6 (dependent on claims 1-5) Compl. ¶154
• Accused Features: The Siveillance Suite is alleged to normalize, store, and correlate data based on the claimed steps Compl. ¶¶155-156

III. The Accused Instrumentality

Product Identification

• The accused products are the Siemens Siveillance Suite, which includes Siveillance Control, Siveillance Control Pro, Siveillance Video Advanced, and Siveillance Video Pro Compl. ¶1

Functionality and Market Context

• The Siveillance Suite is described as a Physical Security Information Management (PSIM) system designed to integrate and manage multiple disparate safety and security subsystems (e.g., access control, video surveillance, fire alarms) on a common platform Compl. ¶¶54, 59, 102 The complaint alleges the system is designed to handle thousands of events per day by using intelligent workflows, geo-referencing, and a rule engine to correlate events and group related alarms Compl. ¶¶57, 60, 63 An included diagram illustrates the Siveillance VMS architecture, which shows interconnected servers (Event, Management, Recording), databases, and clients communicating over an IP network Compl. ¶67 A further diagram shows how data from alarms, access control, and third-party integrations travel to an "Event Server" to be coordinated and identify critical events Compl. ¶106
• The functionality allegedly includes a secure multi-stage storage system that moves video data between a live database and secondary disk systems or network drives based on rules for cost-efficient, long-term storage Compl. ¶¶72, 93-94 The suite is also alleged to use sensor-attribute-dependent parameters, such as "Auto adjustable VMD sensitivity," to fine-tune detection and avoid unwanted events Compl. ¶115 The system is marketed for use in critical infrastructure like airports, ports, and industrial complexes Compl. ¶55

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,737,837 Infringement Allegations

U.S. Patent No. 8,130,098 Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the court will be whether the accused products' use of "user defined prioritization of events or alarms" (Compl. ¶114) and "auto adjustable VMD sensitivity" Compl. ¶115 falls within the scope of the claim term "weighted by attribute data." The patents describe a specific mathematical framework for weighting, and it is an open question whether Siemens's more general-sounding prioritization and sensitivity adjustments meet this limitation.
• Technical Questions: The patents describe a correlation engine with specific, ordered modules for normalization, privacy filtering, business filtering, and spatio-temporal correlation (Compl. ¶¶12-16). The complaint alleges the accused product "correlates" events (Compl. ¶63) but does not provide sufficient detail for a direct comparison of the internal software architecture. The evidentiary burden will be on the Plaintiff to demonstrate that the accused software performs the same specific sequence of functions as claimed.

V. Key Claim Terms for Construction

• The Term: "attribute data"

• Context and Importance: This term is critical because the core of the infringement theory rests on the allegation that the accused products "weight" events using this data. The construction of "attribute data" will determine whether features like Siemens's adjustable sensitivity settings or alarm priority levels (Compl. ¶¶115, 117) satisfy the "weighting" limitation present in nearly all asserted patents.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of examples, including "quality of the data," "age of the sensory device," and "time since the sensory device was last maintained," suggesting the term could encompass a wide range of metadata about a sensor's state or history (’314 Patent, col. 5:6-9, col. 25:51-61).
  • Evidence for a Narrower Interpretation: The specification describes "attribute weight data" as "sets of vectors" used in specific formulae for calculating a weighted average or combined probability (’314 Patent, col. 11:1-26, col. 35:9-19). A party might argue that "attribute data" is limited to data structured and used in such a specific mathematical weighting scheme, not just any parameter used for configuration.

• The Term: "correlate two or more primitive events"

• Context and Importance: All asserted patents require a "correlation" step. Whether the accused product's function of "grouping of related alarms and messages into one event" or "correlating events based on geo-referencing" (Compl. ¶¶60, 63) infringes will depend on the scope of "correlate."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the "basic function of the correlation engine" is to "correlate[] two or more primitive events," which is broad, general language that could support a wide range of meanings (’314 Patent, col. 7:15-17).
  • Evidence for a Narrower Interpretation: The patent discloses a specific, multi-step process within the correlation engine, including "compound event detection," "event correlation... across geographical space," and "event correlation... across time" (’314 Patent, col. 7:40-56). A party could argue that "correlate" must be construed to require this specific sequence of spatial and temporal analysis, not just a simple grouping of alarms.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Siemens has induced infringement by providing technical support and repair services to its customers and by providing documentation that instructs users on how to operate the infringing systems (Compl. ¶¶4, 121, 127).
• Willful Infringement: The complaint dedicates a separate count to willful infringement, alleging Siemens had pre-suit knowledge of the asserted patents. The allegations are based on: (1) actual notice of the parent family of the ’837 patent provided to Siemens in March 2010; (2) Siemens's partnership with Milestone Systems, which allegedly received actual notice of the ’098 and ’926 patents in March 2013; and (3) Siemens's general awareness of the patent family due to its long-time involvement in the security industry Compl. ¶¶158-162

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

• A core issue will be one of definitional scope: does the accused product's system for setting alarm priorities and adjusting motion detection sensitivity constitute "weighting" events based on "attribute data" as those terms are used in the patents? The case may turn on whether this functionality can be mapped to the specific mathematical and vectorial framework for weighting described in the patent specification.
• A key evidentiary question will be one of architectural correspondence: can Plaintiff demonstrate that the Siveillance Suite's software architecture contains the specific, ordered modules of the claimed "correlation engine," including normalization, privacy/business filtering, and distinct spatial and temporal correlation steps? The complaint describes the accused product's high-level functions, but proof of infringement will likely require evidence of a direct structural and operational correspondence.
• A central legal question will concern willfulness: given the allegations of actual notice dating back to 2010 and notice imputed through a business partner in 2013, the court will have to determine whether Siemens's alleged infringement, if any, was willful, which could expose it to enhanced damages.