Touchpoint Projection Innovations LLC v. Iboss Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:

  • Plaintiff: Touchpoint Projection Innovations, LLC (Wyoming)
  • Defendant: iboss, Inc. (Delaware)
  • Plaintiff’s Counsel: Lambert Shortell & Connaughton

• Case Identification: 1:25-cv-12054, D. Mass., 07/22/2025

• Venue Allegations: Venue is based on allegations that Defendant maintains a regular and established business presence in the District of Massachusetts, including a physical corporate headquarters in Boston, retains employees, and generates substantial revenue in the district.

• Core Dispute: Plaintiff alleges that Defendant’s Remote Browser Isolation platform infringes a patent related to securing network communications by isolating and rendering web content in a remote environment before delivering it to the user.

• Technical Context: The technology operates in the field of cybersecurity, specifically remote browser isolation (RBI), which aims to protect end-user devices from web-based malware by executing browser sessions in a remote, contained environment.

• Key Procedural History: The patent-in-suit was assigned from the original assignee, Everis, Inc., to Plaintiff Touchpoint Projection Innovations, LLC. The complaint notes that during prosecution, the U.S. Patent and Trademark Office considered three U.S. patents and twenty-nine published applications as relevant prior art before allowing the claims.

Case Timeline

Date	Event
2010-12-30	Earliest Priority Date for ’712 Patent
2015-08-25	U.S. Patent No. 9,118,712 Issues
2025-07-22	Complaint Filed

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

U.S. Patent No. 9,118,712 - "NETWORK COMMUNICATION SYSTEM WITH IMPROVED SECURITY" (Issued Aug. 25, 2015)

The Invention Explained

• Problem Addressed: The patent addresses the risk of malware being delivered to a user's computer through normal internet browsing, noting that conventional anti-virus software may be insufficient to protect against sophisticated hacks (’712 Patent, col. 1:24-36; col. 4:1-8).

• The Patented Solution: The invention proposes a remote security module that is "interposed in the data communication path" between a user's browser and internet data sources (’712 Patent, Abstract). This module intercepts requests, retrieves the web content (e.g., an HTML page), and "renders" it into a safe format, such as a "pixilated image" (’712 Patent, col. 5:29-31). This "safe" version, which may include interactive elements like links or video overlaid as separate layers, is then sent to the user's browser, preventing the original, potentially malicious code from ever reaching the user's machine (’712 Patent, col. 16:23-40). The system is designed to provide protection without requiring modification to the end-user's browser software (’712 Patent, col. 7:22-26).

• Technical Importance: This architecture supports a "trusted thin client" model, moving the vulnerable point of entry for malware from the end-user's device to a remote, manageable environment, thereby reducing the user's direct exposure to web-based threats (’712 Patent, col. 4:16-39).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶35).

• The essential elements of independent claim 1 include:

  • Providing a remote software rendering application.
  • Intercepting a user's browser command intended for an internet data source.
  • Receiving responsive data (containing "original user functionality") from the internet source.
  • Automatically rendering "all received responsive data into an interactive pixilated image as a layer defined by pixilated image data" so that no original browser executable code is executed by the user.
  • "Overlaying" the pixilated image data with a "secure browser readable code set layer" comprising interactive elements (e.g., a link, video) that includes the "original user functionality."
  • Sending the combined browser readable code set to the user's browser.

• The complaint reserves the right to assert other claims (Compl. ¶34).

III. The Accused Instrumentality

Product Identification

The accused product is the "iboss Zero Trust SASE Platform," which includes a "Remote Browser Isolation ('RBI')" functionality (Compl. ¶29).

Functionality and Market Context

The complaint alleges that the iboss RBI "protects users from web-based threats, such as malware, by establishing a remote, isolated environment to process and render web content" (Compl. ¶29). When a user initiates a browsing session, the RBI functionality "retrieves and interacts with the requested web content within an isolated environment," thereby ensuring that "any potentially harmful code or malware is contained and not delivered to the user's device" (Compl. ¶29). The complaint includes a screenshot from the Defendant's website, which lists a corporate headquarters in Boston, from which it markets its services (Compl. p. 3, Figure 1). The screenshot shows Defendant's North American locations, including its corporate headquarters in Boston, MA (Compl. p. 3, Figure 1).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentality practices the technology claimed in the ’712 Patent, satisfying all elements of at least claim 1 (Compl. ¶36). The complaint states that a claim chart in "Exhibit B" identifies specifically how each element of claim 1 is practiced (Compl. ¶34, 37). However, Exhibit B was not filed with the complaint.

In lieu of a claim chart, the complaint’s narrative theory of infringement is that the iboss RBI performs the patented method by "connecting the user's browser to the internet via a remote container for the purposes of data communication with internet data sources" (Compl. ¶29). This remote container allegedly creates an "isolated environment to process and render web content," which prevents malware from being delivered to the user's device (Compl. ¶29). This functionality is alleged to directly infringe one or more claims of the ’712 Patent (Compl. ¶35).

• Identified Points of Contention:
  • Technical Questions: A primary technical question will be whether the accused iboss RBI "renders" content in a manner that meets the claim limitation of "automatically rendering... all received responsive data into an interactive pixilated image as a layer." The complaint's description of "process and render web content" is general. The specific mechanism used by iboss—whether it creates a literal pixel-based image or uses a different data streaming technique—will be a central factual issue.
  • Scope Questions: The infringement analysis may turn on the construction of key claim terms. For example, does the accused product's method of preserving interactivity meet the specific "overlaying... with a secure browser readable code set layer" limitation, or does it use a different architecture? The case will likely require a detailed comparison between the two-layer (image + overlay) structure described in the patent and the potentially more integrated data stream of a modern RBI service.

V. Key Claim Terms for Construction

• The Term: "interactive pixilated image as a layer"

  • Context and Importance: This term is at the heart of the patented method for neutralizing malware. Its construction will determine whether the claim is limited to a specific type of static image format (like a bitmap or JPG) or if it can be interpreted more broadly to cover other forms of pixel-based data streams generated by the accused RBI service.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent defines rendering as processing data "to the point where the data could be directly presented to as an auditory and/or visual presentation" and then re-encapsulating it, which may suggest a focus on the functional outcome rather than a specific format (’712 Patent, col. 15:63-col. 16:1).
    • Evidence for a Narrower Interpretation: The specification provides examples such as a "pixelated bitmap of a picture of the text" and compressing the image as a "jpg image file," which could be used to argue that the term is limited to these more conventional static image file types (’712 Patent, col. 8:5-13).

• The Term: "overlaying... with a secure browser readable code set layer"

  • Context and Importance: This term defines how the system restores interactivity (the "original user functionality") to the "safe" image sent to the user. The dispute will likely focus on whether the accused product employs a distinct "overlay" on a base image, as the claim language suggests, or uses a more integrated method.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses adding layers, such as an "HTML5 video format" layer, to a "rendered base layer," suggesting a flexible, multi-layered approach to composing the final output (’712 Patent, col. 8:51-57).
    • Evidence for a Narrower Interpretation: The description of creating "a new html page containing pretty much only the rendered base image" could support an interpretation where the "overlay" is a minimal set of code added to a fundamentally image-based page, rather than a more complex or integrated structure (’712 Patent, col. 8:9-12).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant aids and abets its customers' direct infringement by "supplying components and providing instructions to consumer end-users for using those components in practicing the method claimed in claim 1" (Compl. ¶47). The complaint alleges Defendant acts with knowledge and specific intent (Compl. ¶48).

• Willful Infringement: The complaint alleges Defendant has had knowledge of its infringement at least since the date the complaint was served (Compl. ¶33). It further alleges that "Defendant has made no effort to alter its services or otherwise attempt to design around the claims," which may form the basis for a claim of post-filing willfulness (Compl. ¶51).

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

• A central issue will be one of technical implementation: Does the accused iboss RBI service operate using the specific two-step architecture required by Claim 1—first, rendering "all" web data into a "pixilated image," and second, "overlaying" that image with a separate interactive layer? Or does it use a different, more integrated technology to stream content that falls outside the claim's scope? The lack of a claim chart exhibit in the complaint leaves this question entirely open pending discovery.

• The case will also turn on a question of definitional scope: Can the term "interactive pixilated image," which the patent illustrates with examples like JPGs and bitmaps, be construed broadly enough to read on the modern, dynamic data streams likely used by the accused RBI service? The court's interpretation of this core term will likely be dispositive for the infringement analysis.