DCT
1:25-cv-13141
Touchpoint Projection Innovations LLC v. Cato Networks Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Touchpoint Projection Innovations, LLC (Wyoming)
- Defendant: Cato Networks, Inc. (Delaware)
- Plaintiff’s Counsel: Lambert Shortell & Connaughton; DNL Zito
- Case Identification: 1:25-cv-13141, D. Mass., 10/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendant maintains a regular and established place of business in the district, including a physical office location.
- Core Dispute: Plaintiff alleges that Defendant’s Remote Browser Isolation service infringes a patent related to securing network communications by remotely rendering web content and transmitting a safe version to the end-user.
- Technical Context: The technology, known generally as remote browser isolation, is a cybersecurity method designed to protect users from web-based threats like malware by executing browsing sessions in a remote, isolated environment.
- Key Procedural History: The complaint notes that during the patent's prosecution, the U.S. Patent and Trademark Office considered three U.S. patents and twenty-nine published U.S. patent applications as prior art before allowing the claims to issue. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-30 | ’712 Patent Priority Date |
| 2015-08-25 | ’712 Patent Issue Date |
| 2025-10-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,118,712 - NETWORK COMMUNICATION SYSTEM WITH IMPROVED SECURITY
- Patent Identification: U.S. Patent No. 9,118,712, titled “NETWORK COMMUNICATION SYSTEM WITH IMPROVED SECURITY,” issued August 25, 2015 (the “’712 Patent”). (Compl. ¶10).
The Invention Explained
- Problem Addressed: The patent identifies the risk of users receiving malware through internet browsing, even from legitimate websites that have been compromised, noting that conventional anti-virus software is not always sufficient to prevent harm. (Compl. ¶19; ’712 Patent, col. 1:24-39).
- The Patented Solution: The invention describes interposing a remote "software rendering application" between a user's browser and the internet. This remote application receives the requested web content, processes it, and renders it into a new, safe "browser readable code set" to be sent to the user. This process is intended to strip out malicious code while preserving the user's ability to interact with the content. (Compl. ¶16-17; ’712 Patent, Abstract; col. 5:14-34). The system is architected with a security module (110) that is remote from both the user computers (112, 114, 116) and the server computers (102, 104, 106). (’712 Patent, Fig. 1).
- Technical Importance: This remote isolation architecture aims to provide a higher level of security by ensuring that potentially malicious code from the internet is never executed on the end-user's local machine, thereby neutralizing a primary vector for cyberattacks. (Compl. ¶24).
Key Claims at a Glance
- The complaint asserts infringement of one or more claims, including at least independent claim 1. (Compl. ¶35).
- The essential elements of independent claim 1 of the ’712 Patent include:
- Providing a remote software rendering application.
- Issuing a command from a user browser, which is then intercepted and proxied by the remote application.
- Receiving responsive data with original user functionality from the target internet source.
- Automatically rendering all responsive data into an "interactive pixilated image as a layer" such that no original executable code will run on the user's computer.
- "Overlaying" the pixilated image layer with a "secure browser readable code set layer" containing interactive elements (e.g., links, forms, video, audio) that includes the original user functionality.
- Sending the resulting browser readable code set to the user's browser. (’712 Patent, col. 16:4-46).
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims." (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
- The Cato Networks Remote Browser Isolation service (“Cato Networks RBI”). (Compl. ¶29).
Functionality and Market Context
- The Cato Networks RBI is described as a cloud-delivered security service that executes a user's web session in a remote, isolated browser instance on Cato Networks' cloud platform. (Compl. ¶29). When a user requests web content, the service intercepts the request, retrieves the responsive code (e.g., JavaScript, HTML, CSS) from the internet, renders it, and "converts this code into safe pixel streams" which are then sent to the user's local browser for display. (Compl. ¶29). The complaint includes a screenshot from Defendant's website showing its Boston office, from which it allegedly conducts business related to the accused service. (Compl. Fig. 1).
IV. Analysis of Infringement Allegations
The complaint alleges that the Cato Networks RBI service practices the method of claim 1 of the ’712 Patent. (Compl. ¶34-36). Although the complaint references a claim chart in an exhibit that was not provided, the narrative allegations in the complaint map the functionality of the accused service to the elements of claim 1.
’712 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a software rendering application that is: (i) remote from the user computer... | The Cato Networks RBI is a "cloud-delivered security service" where the web session is executed in a "remote, isolated browser instance." | ¶29 | col. 16:11-14 |
| issuing at least one command from the user browser software... intercepting... the at least one command... proxying... the at least one command... | A user sends a command, which is "intercepted by the Cato Networks RBI, which sends a data request to the internet." | ¶29 | col. 16:15-25 |
| receiving... responsive data comprising original user functionality... from the target internet data source | The Cato Networks RBI "receives... a responsive code, such as JavaScript, HTML, and CSS, received from the internet." | ¶29 | col. 16:26-29 |
| automatically rendering... all received responsive data into an interactive pixilated image as a layer... such that no original browser executable code will be executed at the user computer | The RBI service "renders a responsive code" and "converts this code into safe pixel streams." | ¶29 | col. 16:30-35 |
| overlaying... the pixilated image data with a secure browser readable code set layer comprising at least one of a link, a fillable user input data field... | The complaint does not provide sufficient detail for analysis of this element. | col. 16:36-43 | |
| sending the browser readable code set from the software rendering application to the user browser software | The service sends the resulting "safe pixel streams... to the local browser running on the user's computer." | ¶29 | col. 16:44-46 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over whether the accused "safe pixel streams" constitute the specific two-part structure required by claim 1: an "interactive pixilated image as a layer" that is then separately "overlaid" with a "secure browser readable code set layer." The claim language suggests a distinct creation of a rendered image followed by the addition of a separate interactive layer, which may differ from the single-stream output described in the complaint.
- Technical Questions: The complaint does not specify how the accused "safe pixel streams" preserve the "original user functionality" (e.g., clickable links, fillable forms) after the original code is converted. This raises the evidentiary question of whether the accused product actually performs the "overlaying" step as claimed, or if it uses a different technical method to maintain interactivity that falls outside the scope of the claim.
V. Key Claim Terms for Construction
The Term: "rendering... into an interactive pixilated image as a layer"
Context and Importance
- This term defines the core transformation of potentially malicious web content into a safe format. The defendant may argue its "pixel streams" are merely a video-like feed, not the specific "interactive pixilated image as a layer" required by the claim. The plaintiff's infringement case depends on demonstrating that the accused product's output meets this structural limitation.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification discusses creating "good quality and functional facsimiles" of web content and rendering responsive data into a "pixilated image defined by pixilated image data," which could support an argument that any pixel-based representation preserving functionality is covered. (’712 Patent, col. 5:28-31; col. 7:8-10).
- Evidence for a Narrower Interpretation: The claim’s use of the word "layer" suggests a specific structural characteristic. This is reinforced by the specification’s discussion of adding "additional layers as standard CSS layers," implying a distinct, layered architecture rather than a monolithic stream. (’712 Patent, col. 8:53-56).
The Term: "overlaying... with a secure browser readable code set layer"
Context and Importance
- This term is critical because it defines how interactivity is restored after the base content is rendered into a safe image. Infringement requires proof that the accused product performs this specific additive "overlaying" step. If the accused product's "pixel streams" embed interactivity in a different manner, it may not infringe.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent’s overall objective is to provide a safe but functional browsing experience. Plaintiff may argue that any technical method that adds back interactivity on top of a rendered visual should be considered "overlaying" in the context of the invention.
- Evidence for a Narrower Interpretation: The claim recites "overlaying" as a distinct step that follows "rendering." This sequential language, combined with the specification's mention of using "CSS layers" for elements like links and video, suggests a specific technical implementation where a base image layer and an interactive data layer are combined, not generated as a single, undifferentiated stream. (’712 Patent, col. 8:53-61).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by encouraging and providing instructions to its end-users to use the Cato Networks RBI service in its normal, infringing manner. (Compl. ¶47).
- Willful Infringement: While the complaint does not explicitly use the word "willful," it alleges Defendant has knowledge of its infringement "at least as of the service of the present complaint" and alleges that "Defendant has made no effort to alter its services or otherwise attempt to design around the claims" after becoming aware of its infringement. (Compl. ¶33, 51). These allegations establish a basis for a claim of post-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and structure: can the phrase "rendering... into an interactive pixilated image as a layer" and then "overlaying... with a secure... layer" be construed to cover the accused service's generation of "safe pixel streams"? The case may turn on whether the accused method performs two distinct steps to create a multi-layered output, or if it uses a fundamentally different, single-stream process.
- A key evidentiary question will be one of technical implementation: what is the precise data structure of the "safe pixel streams" sent to the end-user's browser by the accused service? Discovery will likely focus on whether this data stream contains the distinct rendered image "layer" and interactive "overlay" required by the asserted claim, or if it represents a different technological approach to remote browser isolation.