3:25-cv-01232
SecureNet Solutions Group LLC v. Milestone Systems Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SecureNet Solutions Group, LLC (Florida)
- Defendant: Milestone Systems Inc. (Oregon)
- Plaintiff’s Counsel: ALLEN VELLONE WOLF HELFRICH & FACTOR P.C.
- Case Identification: 3:25-cv-01232, D. Or., 07/14/2025
- Venue Allegations: Venue is alleged to be proper as Defendant Milestone Systems Inc. resides in and has its principal place of business in Oregon.
- Core Dispute: Plaintiff alleges that Defendant’s XProtect video management software and associated hardware, alone or in combination with third-party analytics extensions, infringe nine patents related to computerized security systems that correlate data from various sensors to identify critical events.
- Technical Context: The technology addresses large-scale data analysis in security systems by ingesting data from disparate sources, normalizing it, and using a correlation engine with weighted attributes to reduce false positives and identify significant security events.
- Key Procedural History: The complaint alleges that Plaintiff provided actual notice of the parent patents to Defendant on or around March 14, 2013, forming a basis for willfulness allegations. The complaint also notes that during the prosecution of several asserted patents, the applicant addressed patent eligibility under the Supreme Court's Alice framework with the U.S. Patent and Trademark Office.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-04 | Earliest Patent Priority Date |
| 2012-03-06 | U.S. Patent No. 8,130,098 Issues |
| 2013-01-15 | U.S. Patent No. 8,354,926 Issues |
| 2013-03-14 | Plaintiff allegedly gave actual notice of '098 and '926 patents to Defendant |
| 2015-11-04 | Applicant interview with USPTO Examiner regarding Alice for '616 patent |
| 2016-05-17 | U.S. Patent No. 9,344,616 Issues |
| 2017-04-11 | U.S. Patent No. 9,619,984 Issues |
| 2018-07-10 | U.S. Patent No. 10,020,987 Issues |
| 2020-03-03 | U.S. Patent No. 10,587,460 Issues |
| 2020-05-03 | U.S. Patent No. 11,323,314 Issues |
| 2020-12-08 | U.S. Patent No. 10,862,744 Issues |
| 2024-03-12 | U.S. Patent No. 11,929,870 Issues |
| 2025-07-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,130,098 - Systems and methods for safety and business productivity
Issued March 6, 2012
The Invention Explained
- Problem Addressed: As smart surveillance systems began replacing traditional security systems, they created challenges for large-scale data analysis, including a high rate of errors and false positives (Compl. ¶¶7, 8).
- The Patented Solution: The invention describes a computerized system that collects security-related data, or "primitive events," from disparate sources like cameras, card access systems, and personnel databases (Compl. ¶9; '616 Patent, Fig. 1). A "normalization engine" converts these events into a standardized format, which are then processed by a "correlation engine" (Compl. ¶¶10, 11). This engine correlates multiple events, weighted by the "attribute data" of the data sources (e.g., reliability of a camera), to identify compound or critical events and reduce false alarms (Compl. ¶¶8, 18; '616 Patent, 35:65-36:14).
- Technical Importance: The patented approach provides a framework for integrating heterogeneous security data streams into a single analytical system that can apply business and privacy rules to automatically identify significant events that a human guard force might miss (Compl. ¶¶8, 12, 13, 37-44).
Key Claims at a Glance
- The complaint asserts independent claim 13 (Compl. ¶152).
- The essential elements of Claim 13 are:
- capturing sensory data from one or more sensors;
- storing the sensory data from the one or more sensors in a data storage device;
- processing the sensory data from the sensors, weighted by attribute data representing information about the sensors used to capture the sensory data, to detect primitive events in the sensory data 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 performed in the correlating step.
- 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
The Invention Explained
- The technology of the ’926 Patent is substantially similar to that described for the ’098 Patent, focusing on the same system architecture for correlating data from disparate security sensors (Compl. ¶¶6-29, ¶158).
Key Claims at a Glance
- The complaint asserts independent claim 34 (Compl. ¶158).
- The essential elements of Claim 34 are substantively identical to those of claim 13 of the '098 Patent, comprising the steps of capturing sensory data, storing the data, processing the data weighted by attribute data to detect primitive events, correlating primitive events, and performing actions based on the correlation (Compl. ¶158).
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 9,344,616 - Correlation engine for security, safety, and business productivity
Issued May 17, 2016
Technology Synopsis
This patent describes a non-transitory storage medium containing code for a system that receives sensory and IP data, processes it to detect primitive events, normalizes and stores those events, and then evaluates historical correlations to monitor for critical events and network failures, upon which it sends alerts. The technology is substantially similar to that described for the lead patents (Compl. ¶¶6-29, 164).
Asserted Claims
Claim 48 (dependent on claim 39) is asserted (Compl. ¶164).
Accused Features
The complaint alleges infringement by the XProtect system's functions for receiving, processing, normalizing, storing, retrieving, evaluating, and monitoring sensory data and network status to generate and send alerts (Compl. ¶¶165-167).
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 is directed to a monitoring system stored on a non-transitory medium. The system receives sensory and IP data, processes it to detect primitive events (including at least a face detected), normalizes and stores the events, evaluates historical correlations, monitors network status, and sends alerts. The face detected is then correlated with other primitive events based on attribute data of the sensor that detected the face (Compl. ¶172).
Asserted Claims
Claim 22 (dependent on claim 21, which is dependent on claim 1) is asserted (Compl. ¶172).
Accused Features
The complaint accuses the XProtect system's ability to practice the claimed steps, including the specific capability of its analytics partners (e.g., Bosch) to perform face detection and correlate that event with other events, such as an access control event (Compl. ¶¶173, 174).
U.S. Patent No. 10,020,987 - Systems and methods for correlating sensory events and legacy system events utilizing a correlation engine for security, safety, and business productivity
Issued July 10, 2018
Technology Synopsis
This patent describes a monitoring method that involves receiving and processing sensory data, IP data, and legacy system data. The system normalizes and stores these events, evaluates historical correlations across time and space where events are weighted by attribute data, and monitors for critical events to send alerts (Compl. ¶180).
Asserted Claims
Claim 20 is asserted (Compl. ¶180).
Accused Features
The complaint alleges infringement by the XProtect system's ability to receive and process data from sensors (like cameras), IP networks, and legacy systems (like access control or point-of-sale devices) and use its rules engine to correlate these events (Compl. ¶¶118, 181).
U.S. Patent No. 10,862,744 - Correlation system for correlating sensory events and legacy system events
Issued December 8, 2020
Technology Synopsis
This patent describes a monitoring system with specific software modules: a sensory event analytics module, a legacy event analytics module, an event queue, a correlation module, and an alerting module. The system processes sensory events (e.g., person, face, vehicle detection) and legacy events (e.g., access control, personnel system) and weights the sensory events based on attribute data (Compl. ¶188).
Asserted Claims
Claim 16 (dependent on claim 1) is asserted (Compl. ¶188).
Accused Features
The complaint alleges that the XProtect system, in conjunction with its analytics partners, implements the claimed modular functions to process and correlate events from both modern sensors and legacy systems (Compl. ¶¶189, 190).
U.S. Patent No. 10,587,460 - Systems and methods for correlating sensory events and legacy system events utilizing a correlation engine for security, safety, and business productivity
Issued March 3, 2020
Technology Synopsis
This patent claims a system with distinct analytics modules for primitive, legacy, and network events. It includes a normalization engine, an event queue, a correlation engine to evaluate historical correlations, and an alerting engine, with weighting of primitive sensory events based on attribute data (Compl. ¶195).
Asserted Claims
Claim 11 (dependent on claim 1) is asserted (Compl. ¶195).
Accused Features
The complaint alleges that the modular architecture of the XProtect system and its various extensions for sensory, legacy, and network data meets the limitations of the claimed system (Compl. ¶¶196-198).
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, 2020
Technology Synopsis
This patent describes a system that combines a correlation module with a hierarchical storage manager. The system receives and processes sensory events, manages the storage and cascading of data across a hierarchy of storage devices based on the events, correlates stored events, and sends alerts over an IP network (Compl. ¶203).
Asserted Claims
Claim 13 (dependent on claim 1) is asserted (Compl. ¶203).
Accused Features
The complaint alleges infringement by XProtect's features for multistage archiving and scheduled data movement, which are alleged to constitute a hierarchical storage manager, in combination with its event correlation capabilities (Compl. ¶¶53, 64, 65, 115, 204).
U.S. Patent No. 11,929,870 - Correlation engine for correlating sensory events
Issued March 12, 2024
Technology Synopsis
This patent claims a system with a receiver module, an event queue, and a correlation module. The system receives sensory events (face, vehicle, license plate detected) from an IP camera, stores them, and evaluates historical correlations based on weighting of the stored events by sensor attribute data (Compl. ¶210).
Asserted Claims
Claim 6 (dependent on claim 5, which is dependent on claim 1) is asserted (Compl. ¶210).
Accused Features
The complaint alleges infringement by the XProtect system's core architecture for receiving, queuing, and correlating weighted sensory events to monitor for critical events (Compl. ¶¶211-213).
III. The Accused Instrumentality
Product Identification
The accused products are Milestone’s XProtect video management software (VMS), XProtect software in combination with analytics extensions (e.g., from Briefcam, Bosch, viisights), and XProtect software installed on Milestone Husky VMS hardware appliances (Compl. p. 2, ¶¶46-48).
Functionality and Market Context
The XProtect VMS is a software platform designed to manage IP surveillance cameras and other security devices (Compl. ¶55). Its core components include a recording server that retrieves and stores video streams in a media database, and an event server that handles tasks related to events, alarms, and third-party integrations (Compl. ¶¶52-54). The system allows users to create rules that specify actions (e.g., start recording) to be carried out under particular conditions (e.g., when motion is detected) (Compl. ¶66). The complaint alleges the platform is designed to integrate with a wide array of third-party analytics providers to incorporate functionalities like facial recognition, object tracking, and behavioral analysis (Compl. ¶¶48, 101-105, 147). The system's storage and archiving features allow for recorded data to be moved to different storage tiers based on user-defined schedules (Compl. ¶¶52, 64). An image from the XProtect Administrator Manual shows a user interface for managing recording and archiving configurations across different storage devices (Compl. p. 32).
IV. Analysis of Infringement Allegations
’098 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| capturing sensory data from one or more sensors | The XProtect system connects to and receives data streams from IP cameras, microphones, and external input sensors that detect events like doors opening. | ¶50, 61, 63, 101 | '616 Patent, col. 7:5-8 |
| storing the sensory data from the one or more sensors in a data storage device | The XProtect recording server stores retrieved audio and video data in a high-performance media database, and can archive recordings to network storage. | ¶52, 53, 64, 115 | '616 Patent, col. 10:63-65 |
| processing the sensory data from the sensors, weighted by attribute data representing information about the sensors used to capture the sensory data, to detect primitive events in the sensory data using a computer processor | The system uses thresholds for motion detection sensitivity and allows users to define image areas to be disregarded, which the complaint alleges constitutes a weighting scheme to increase reliability and reduce false positives. | ¶71-73, 145 | '616 Patent, col. 35:65-67 |
| correlating two or more primitive events to determine one or more correlated events using the computer processor | The XProtect system's Rules engine allows users to combine multiple events, time conditions, and devices to trigger actions, such as starting recording on two cameras when motion is detected on one. A screenshot from the Administrator Manual shows a rule being configured to perform an action on "Motion Start" from a specific camera (Compl. p. 35). | ¶68, 69, 132 | '616 Patent, col. 11:10-13 |
| performing one or more actions to ensure safety procedures are followed based on the correlation | When a rule's conditions are met, the system can perform actions such as starting/stopping recording, sending email notifications, or activating alarms. | ¶66, 67, 68, 146 | '616 Patent, col. 13:4-6 |
Identified Points of Contention
- Scope Question: A central issue may be whether XProtect's use of user-configurable parameters like motion detection sensitivity thresholds, exclusion zones, and event priorities (Compl. ¶¶72, 73, 145) meets the "weighted by attribute data" limitation. The patent specification discloses more complex attributes, such as sensor age, maintenance history, and reliability (Compl. ¶18; '616 Patent, col. 36:7-14), raising the question of whether the accused functionality falls within the claim's scope.
- Technical Question: The complaint alleges that the XProtect "Rules" engine performs the claimed "correlating" step (Compl. ¶¶68, 132). A key question for the court will be whether this user-defined, logic-based triggering system (e.g., IF motion on Camera 1 AND time is 8:30 PM, THEN start recording) performs the same function as the patent's "correlation engine," which is described as analyzing events across time and space to identify historical patterns and compound events like tailgating (Compl. ¶¶11, 14, 15).
’926 Patent Infringement Allegations
| Claim Element (from Independent Claim 34) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| capturing sensory data from one or more sensors | The XProtect system receives data from cameras and other connected sensors. | ¶50, 61, 63, 101 | '616 Patent, col. 7:5-8 |
| storing the sensory data from the one or more sensors in a data storage device | The system's recording server stores sensory data in a media database. | ¶52, 53, 115 | '616 Patent, col. 10:63-65 |
| processing the sensory data from the sensors, weighted by attribute data representing information about the sensors used to capture the sensory data, to detect primitive events... | The complaint alleges that XProtect's motion detection configuration, which allows users to set sensitivity thresholds and exclude regions of an image, constitutes weighting by attribute data. A screenshot illustrates the user interface for setting these sensitivity parameters (Compl. p. 37). | ¶71-73, 145 | '616 Patent, col. 35:65-67 |
| correlating two or more primitive events to determine one or more correlated events... | The system's Rules engine is alleged to perform correlation by combining time, events, and devices as conditions for triggering an action. | ¶68, 132, 159 | '616 Patent, col. 11:10-13 |
| performing one or more actions to ensure safety procedures are followed based on the correlation... | When a rule is satisfied, the system can trigger actions such as activating alarms or sending notifications to security staff. | ¶66, 67, 146 | '616 Patent, col. 13:4-6 |
Identified Points of Contention
- The points of contention for the ’926 Patent are substantially similar to those identified for the ’098 Patent, as the asserted claims and infringement theories are nearly identical. The dispute will likely focus on the definition and scope of "weighted by attribute data" and "correlating."
V. Key Claim Terms for Construction
"attribute data"
Context and Importance
This term is critical because the infringement theory relies on equating XProtect’s motion detection sensitivity settings and event priorities with the patent's concept of weighting events by sensor attributes. The definition of this term will determine whether simple, user-set parameters meet a limitation that the specification describes in more complex, objective terms.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claims broadly recite "attribute data representing information about the sensors" without specifying the type of information. This language may support an argument that any information about a sensor, including a user-defined sensitivity level for its motion detection algorithm, qualifies as "attribute data."
- Evidence for a Narrower Interpretation: The specification provides specific examples of "attribute data," such as the quality of data produced by the sensor, its age, time since last maintenance, and reliability (Compl. ¶18; '616 Patent, col. 8:1-8). These examples may support a narrower construction limited to objective, inherent characteristics of the sensor itself, rather than user-configured software parameters.
"correlating"
Context and Importance
The definition of "correlating" is central to whether the XProtect "Rules" engine infringes. Plaintiff alleges that combining conditions in a rule constitutes correlation, while Defendant may argue its system performs simple Boolean logic, distinct from the more advanced temporal and spatial analysis described in the patent.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent states the basic function of the correlation engine is to "correlate[] two or more primitive events" (Compl. ¶11; '616 Patent, col. 11:10-13). This general language could be argued to encompass any logical combination of events.
- Evidence for a Narrower Interpretation: The specification describes "correlating" in terms of complex functions, such as identifying "historical event correlations between events detected now, and events that occurred historically" and correlating events "across multiple sensors of varying types located across space" (Compl. ¶11; '616 Patent, col. 12:17-23). An alarm system diagram provided in the complaint further illustrates the flow of data through various clients and servers for alarm configuration and distribution (Compl. p. 47). This context may support a narrower construction that requires more than simple IF-THEN rule execution.
VI. Other Allegations
Indirect Infringement
The complaint alleges that Defendant induces infringement by providing the Accused Products to its customers and enabling them to practice the patented methods (Compl. ¶¶153, 154, 159, 160).
Willful Infringement
The willfulness allegations are based on alleged pre-suit knowledge. The complaint asserts that Plaintiff gave Defendant actual notice of the '098 and '926 patents (and others in the same family) on or around March 14, 2013 (Compl. ¶¶154, 160, 168, 176, 184, 191, 199, 206, 214).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "weighted by attribute data," which the patent specification illustrates with objective sensor characteristics like age and maintenance history, be construed to cover user-configured software settings such as motion-detection sensitivity thresholds and event priorities in the accused system?
- A key technical question will be one of functional operation: does the accused product’s rules-based engine, which executes user-defined logical commands (e.g., IF event A AND condition B, THEN action C), perform the function of "correlating" as described by the patents, which teach a system that analyzes events across time and space to identify historical patterns and emergent compound events?
- An evidentiary question will concern patent eligibility: although the Plaintiff notes that patent eligibility under Alice was addressed during prosecution for several of the patents-in-suit, this issue may be re-examined by the court, focusing on whether the claims are directed to an abstract idea of data correlation and, if so, whether they contain a sufficient "inventive concept" tied to a specific technological improvement.