Sensor360 LLC v. Alps Electric Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: Alps Electric Co., Ltd. (Japan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00424, E.D. Tex., 06/05/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified sensor products infringe a patent related to self-organizing, adaptive sensor networks.
• Technical Context: The technology concerns networks of deployable sensors that can autonomously determine their roles, such as actively sensing events or controlling other sensors, to optimize network performance and power usage.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,510,076 - Sensor apparatus and system

• Issued: August 13, 2013

The Invention Explained

• Problem Addressed: The patent describes the need for a rapidly deployable sensor system for monitoring large areas, particularly in military applications, without the risks associated with human reconnaissance teams. A key challenge with conventional sensor networks is their vulnerability; if a designated "control module" is disabled, a portion of the network fails. (’076 Patent, col. 1:10-22, col. 1:48-54).
• The Patented Solution: The invention proposes a network of identical sensor modules, each capable of operating in either a "sensing mode" (to detect events) or a "controlling mode" (to receive and process data from other modules). A processor within each module communicates with others in the network to determine which role it should adopt based on factors like location, module density, or power levels, creating a "self organising adaptive network." (’076 Patent, Abstract; col. 2:60-64). This adaptability is intended to make the network more resilient and efficient.
• Technical Importance: The claimed invention addresses a key limitation of static sensor networks by introducing dynamic role allocation, which can improve network longevity, robustness, and efficiency in unpredictable environments. (Compl. ¶9; ’076 Patent, col. 3:25-33).

Key Claims at a Glance

• The complaint does not identify any specific claims asserted, referring only to "the Exemplary '076 Patent Claims" detailed in an unprovided exhibit (Compl. ¶11, ¶16).
• For analytical purposes, independent claim 1 is presented below as a representative claim:
  • A sensor module for use in a sensor network, the sensor module comprising at least one sensor,
  • a locator for determining the location of the at least one sensor,
  • a transceiver for communicating with other sensor modules and/or a base station,
  • and a processor wherein the processor is adapted, in use, to communicate with other sensor modules and to determine whether the sensor module should operate in a sensing mode or a controlling mode within the network.
• The complaint makes no explicit reservation of rights to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers to them generally as "Exemplary Defendant Products" that are identified in charts contained in Exhibit 2, which was not filed with the complaint. (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint provides no narrative infringement theory, stating only that the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '076 Patent Claims" as detailed in the claim charts of the unprovided Exhibit 2 (Compl. ¶16-17). Without access to Exhibit 2 or any specific factual allegations in the complaint body, a detailed analysis of the infringement allegations is not possible.

V. Key Claim Terms for Construction

Because the complaint does not specify which claims are asserted, the following analysis is based on representative independent claim 1.

• The Term: "determine whether the sensor module should operate in a sensing mode or a controlling mode"
• Context and Importance: This phrase appears to recite the central inventive concept of the patent: a module's autonomous ability to switch roles within the network. The outcome of the case may hinge on whether the accused products perform this specific dynamic determination, as opposed to operating in a single, pre-assigned mode. Practitioners may focus on whether this determination must be an active, ongoing process or if a one-time assignment upon network initialization meets the limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the determination can be based on a wide variety of factors, including "the location of the module," "the density of sensor modules," or "power level." (’076 Patent, col. 2:1-17, col. 3:11-13). This could support an interpretation where the "determination" covers a range of decision-making triggers.
  • Evidence for a Narrower Interpretation: The patent repeatedly describes the determination as a way to facilitate network "reorganisation" in response to changing conditions, such as a controlling module running out of power or the detection of an event in a new area. (’076 Patent, col. 3:7-25). This context could support a narrower construction requiring an adaptive, ongoing re-evaluation of the module's role rather than a static, initial assignment.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that since being served with the complaint, Defendant has knowingly induced infringement by selling the accused products and distributing "product literature and website materials" that instruct end users on their infringing use (Compl. ¶14-15).
• Willful Infringement: The basis for willfulness is entirely post-suit knowledge. The complaint alleges that "service of this Complaint...constitutes actual knowledge" and that Defendant's continued infringement thereafter is willful (Compl. ¶13-14).

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

1. A Procedural Question of Specificity: A threshold issue may be whether the complaint, which omits the names of any accused products and contains no substantive infringement allegations apart from incorporating an unfiled exhibit, meets federal pleading standards that require plausible factual allegations.
2. A Core Technical Question of Functionality: Assuming the case proceeds, a central dispute will likely be whether the accused products perform the dynamic role-switching recited in the claims. The key question will be one of functional operation: does the processor in the accused products "determine whether the sensor module should operate in a sensing mode or a controlling mode," or do the products operate in fixed, predetermined roles that fall outside the patent's claims?
3. A Definitional Question of Scope: The construction of the term "determine" will be critical. The case may turn on whether a one-time role assignment at network startup is sufficient to meet this limitation, or if the patent requires an ongoing, adaptive capability to re-evaluate and change roles in response to new network conditions.