DCT
2:25-cv-00022
IoT Innovations LLC v. Snap One LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: IoT Innovations LLC (Texas)
- Defendant: Snap One, LLC (North Carolina)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00022, E.D. Tex., 01/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business in the Eastern District of Texas and has committed acts of patent infringement in the District.
- Core Dispute: Plaintiff alleges that Defendant’s Control4 Smart Home platform and associated products infringe eight U.S. patents related to mobile device security, proactive data caching, data synchronization, and network communication technologies.
- Technical Context: The patents address foundational technologies for managing security, data, and user experience across multiple connected devices, a core function of modern smart home and Internet of Things (IoT) ecosystems.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents. The complaint does note that Certificates of Correction have been issued for U.S. Patent Nos. 7,304,570; 7,263,102; 7,983,282; and 7,974,260.
Case Timeline
| Date | Event |
|---|---|
| 2000-08-23 | ’933 Patent Priority Date |
| 2000-09-11 | ’762 Patent Priority Date |
| 2000-09-11 | ’260 Patent Priority Date |
| 2002-05-20 | ’486 Patent Priority Date |
| 2002-11-27 | ’102 Patent Priority Date |
| 2002-11-27 | ’282 Patent Priority Date |
| 2003-04-17 | ’191 Patent Priority Date |
| 2004-10-05 | ’933 Patent Issued |
| 2005-07-19 | ’486 Patent Issued |
| 2005-08-10 | ’570 Patent Priority Date |
| 2007-08-28 | ’102 Patent Issued |
| 2007-12-04 | ’570 Patent Issued |
| 2008-11-04 | ’570 Patent Certificate of Correction Issued |
| 2009-04-28 | ’762 Patent Issued |
| 2011-07-05 | ’260 Patent Issued |
| 2011-07-19 | ’282 Patent Issued |
| 2011-11-29 | ’260 Patent Certificate of Correction Issued |
| 2013-01-01 | ’102 Patent Certificate of Correction Issued |
| 2013-04-30 | ’191 Patent Issued |
| 2013-07-16 | ’282 Patent Certificate of Correction Issued |
| 2025-01-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,304,570 - "Methods, Systems, And Computer Program Products For Providing Context-Based, Hierarchical Security For A Mobile Device," issued December 4, 2007
The Invention Explained
- Problem Addressed: The patent describes conventional mobile device security as inflexible, often relying on a single, severe action (e.g., deleting all data) regardless of whether a device is temporarily misplaced or stolen. Such services also typically require a network connection to function (’570 Patent, col. 2:3-23).
- The Patented Solution: The invention proposes a multi-level, hierarchical security system. It allows a user to define different security levels, each with specific security actions triggered by a corresponding "context." This enables an escalating response, such as first activating a ringer for a misplaced device (Level 1), and later deleting sensitive data if the device is determined to be stolen (Level 4) (’570 Patent, col. 2:36-46; Fig. 3).
- Technical Importance: This approach provides a more nuanced and adaptive security model for mobile devices, better aligning the response with the perceived threat level.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶29).
- Claim 1 is a method claim with the following essential elements:
- storing a hierarchy of security actions for protecting data or preventing unauthorized use of a mobile device, the hierarchy including a plurality of security levels, each level including at least one context-based security action;
- performing at least one security action associated with a first security level in response to the existence of a first context associated with the first security level; and
- performing at least one security action associated with a second security level in response to the existence of a second context associated with the second security level.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 6,801,933 - "System And Method For Proactive Caching Employing Graphical Usage Description," issued October 5, 2004
The Invention Explained
- Problem Addressed: The patent notes that servers supporting web applications are often slow to respond to user requests because they must retrieve data reactively. The server cannot anticipate a user's next action and pre-load the necessary information (’933 Patent, col. 1:21-26).
- The Patented Solution: The invention uses a "graphical usage description," which is a diagram representing the functional flow of an application (e.g., a state diagram). By tracking a user's "current state" within this diagram, the system can determine a likely "next state" and proactively cache, or pre-load, the data required for that next state. This is intended to improve system responsiveness (’933 Patent, col. 2:55-67; Fig. 2).
- Technical Importance: This method aims to improve the performance and user experience of server-based applications by predicting user navigation to reduce data retrieval latency.
Key Claims at a Glance
- The complaint asserts independent claim 7 (Compl. ¶46).
- Claim 7 is a method claim with the following essential elements:
- receiving a request for data;
- producing a current state based on the request;
- determining a next state based on the current state;
- caching data based on the current state and the next state; and
- associating the request with a user of an application having a plurality of states, wherein the user is located in one of the plurality of states.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 6,920,486 - "Method And Apparatus For Enabling Synchronizing Data In Different Devices Having Different Capabilities And Unmatched Data Fields," issued July 19, 2005
- Technology Synopsis: The patent addresses the problem of synchronizing data between two devices when one device's data store contains fields (data components) that the other does not. The invention proposes a method where a server forms "structure information" about the unmatched fields and, upon detecting the first use of such a field on one device, prompts for or sets a "correspondence" to determine how that data should be handled by the other device (Compl. ¶57; ’486 Patent, col. 5:48-50).
- Asserted Claims: At least Claim 1 (Compl. ¶56).
- Accused Features: The Control4 system is accused of performing a method to synchronize data stores between different client devices connected to a server, specifically by forming structure information for unmatched data fields and setting a correspondence for their use (Compl. ¶57).
U.S. Patent No. 7,263,102 - "Multi-Path Gateway Communications Device," issued August 28, 2007
- Technology Synopsis: The patent describes a "personal digital gateway" that uses rule-based profiles to manage and communicate data to a plurality of different communications devices. The profiles categorize data as being associated with different functional agents, such as access, configuration, security, and management agents, allowing the gateway to customize data presentation and access for each connected device (’102 Patent, col. 3:53-64).
- Asserted Claims: At least Claim 1 (Compl. ¶66).
- Accused Features: The Accused Products are alleged to provide a personal digital gateway containing a database of rule-based profiles that categorize and manage data communication to various connected devices (Compl. ¶67).
U.S. Patent No. RE44,191 - "Electric Device, Computer, Program, System And Method Of Setting Up User Applications," issued April 30, 2013
- Technology Synopsis: This patent relates to simplifying the setup of applications that share data between two electric devices over a wireless proximity interface. The invention involves one device receiving instructions to execute a command from another device, where the command replaces a series of user actions and enables interactive operation between the applications on both devices (’191 Patent, Abstract).
- Asserted Claims: At least Claim 19 (Compl. ¶82).
- Accused Features: The Control4 system is accused of providing a computer program on a storage medium that executes commands received from another device over a wireless interface, where the command replaces a series of user actions to enable interactive operation (Compl. ¶83).
U.S. Patent No. 7,983,282 - "Edge Side Assembler," issued July 19, 2011
- Technology Synopsis: The technology appears related to the '102 Patent, describing a method for personalizing a user experience across multiple devices via a personal digital gateway. The method involves identifying data associated with a common user, selecting a device, retrieving data from that device, and forwarding it to another device in the user's network (’282 Patent, Abstract).
- Asserted Claims: At least Claim 1 (Compl. ¶91).
- Accused Features: The Accused Products are alleged to perform a method of identifying a common user's data, receiving a device selection, and retrieving and forwarding remote data between the user's devices (Compl. ¶92).
U.S. Patent No. 7,526,762 - "Network With Mobile Terminals As Browsers Having Wireless Access To The Internet And Method For Using Same," issued April 28, 2009
- Technology Synopsis: The patent describes a system for managing software updates delivered to terminal devices. A central configuration server receives an upgrade, identifies which users require it, provides the upgrade to their respective terminal servers, and tracks which terminal servers have not yet received the update, delivering it upon activation (’762 Patent, Abstract).
- Asserted Claims: At least Claim 7 (Compl. ¶100).
- Accused Features: The Accused Products are alleged to provide a system with a configuration server that manages and distributes software upgrades to terminal servers for users identified as requiring the upgrade (Compl. ¶101).
U.S. Patent No. 7,974,260 - "Method Of Transmitting Time-Critical Scheduling Information Between Single Network Devices In A Wireless Network Using Slotted Point-To-Point Links," issued July 5, 2011
- Technology Synopsis: The patent discloses a method for transmitting timing control information between wireless devices. The method involves defining a data sequence with a header (containing the address of a second device) and a payload (containing the timing control information) and transmitting this sequence in a predefined time slot to control when the second device communicates (’260 Patent, Abstract).
- Asserted Claims: At least Claim 1 (Compl. ¶110).
- Accused Features: The Accused Products are alleged to include a device that defines and transmits data sequences containing header and payload portions, where the payload includes timing control information for communicating packets between devices in a network (Compl. ¶111).
III. The Accused Instrumentality
- Product Identification: The complaint identifies the accused instrumentalities as the "Control4 Smart Home" control and security platform and systems (Compl. ¶9, ¶21). This includes a broad range of hardware and software components, such as Touchscreen Controls, Automation Controllers, the Control4 App, Control4 OS 3 software, and associated server hardware (Compl. ¶21).
- Functionality and Market Context: The complaint alleges that the Accused Products form an integrated system for home security and control (Compl. ¶22). The complaint provides an excerpt from Defendant's website, which shows a user interface for navigating rooms, controlling integrated devices, and personalizing the system by adding favorites. The visual evidence shows an interface on a touchscreen device for controlling aspects of a smart home, such as media and background settings (Compl. ¶22, Fig. 1). The system is advertised through Defendant's website and sold through a network of dealers and showrooms, including several in the Eastern District of Texas (Compl. ¶15, ¶20).
IV. Analysis of Infringement Allegations
’570 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing a hierarchy of security actions...the hierarchy including a plurality of security levels, each security level including at least one context-based security action | The Accused Products allegedly perform a method that stores a hierarchy of security actions, which includes multiple security levels, with each level having at least one context-based security action. | ¶30 | col. 2:37-40 |
| performing at least one security action associated with a first security level in response to the existence of a first context associated with the first security level | The Accused Products allegedly perform at least one security action tied to a first security level when a first context associated with that level exists. | ¶30 | col. 2:40-43 |
| and performing at least one security action associated with a second security level in response to the existence of a second context associated with the second security level | The Accused Products allegedly perform at least one security action tied to a second security level when a second context associated with that level exists. | ¶30 | col. 2:43-46 |
- Identified Points of Contention:
- Scope Questions: A central question may be how the term "mobile device," central to the patent's disclosure, is applied to the accused smart home controllers and touchscreens, some of which may be stationary. The scope of "context-based security action" will also be critical—what specific events or conditions in the Control4 system does the plaintiff allege constitute a "context" that triggers a distinct security level?
- Technical Questions: What evidence does the complaint provide that the Control4 system implements a true "hierarchy" of security levels with escalating actions, as opposed to a flat set of user-configurable rules? The complaint's infringement theory is described at a high level, and factual discovery will be needed to determine if the accused software architecture maps onto the claimed hierarchical structure.
’933 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a request for data | The Accused Products are alleged to perform a method that includes receiving a request for data. | ¶47 | col. 2:48-49 |
| producing a current state based on the request | The Accused Products allegedly produce a current state based on the user's request. | ¶47 | col. 2:49-51 |
| determining a next state based on the current state | The Accused Products allegedly determine a next state based on the current state. | ¶47 | col. 2:51-53 |
| caching data based on the current state and the next state | The Accused Products allegedly cache data based on both the determined current and next states. | ¶47 | col. 2:53-54 |
| and associating the request with a user of an application having a plurality of states... | The Accused Products allegedly associate the request with a user who is located in one of a plurality of states within an application. | ¶47 | col. 3:7-9 |
- Identified Points of Contention:
- Scope Questions: The patent heavily relies on the concept of a "graphical usage description" to determine the "next state." A key question will be whether the Control4 system's method for predicting user actions and pre-loading data, if any, meets the definition of using such a description. Does the system's logic resemble the state diagrams described in the patent?
- Technical Questions: Does the accused Control4 OS 3 software actually perform proactive caching based on predicting a user's next navigation step? The complaint alleges this functionality but does not specify which technical operations of the accused software constitute "determining a next state" and "caching data" in the manner claimed.
V. Key Claim Terms for Construction
For the ’570 Patent:
- The Term: "context-based security action"
- Context and Importance: This term is the core of the invention. The infringement analysis will depend on whether the security features in the Control4 system are triggered by a "context" as understood by the patent, or by more conventional triggers (e.g., a direct user command). Practitioners may focus on this term because it appears to be the primary point of novelty.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification lists a wide variety of security actions, from activating a ringer to deleting data, and suggests that the triggering "context" can be varied, including time-based triggers or external notifications (e.g., "device is missing") (’570 Patent, Table 1, col. 5-6). This may support a broad reading covering various automated security rules.
- Evidence for a Narrower Interpretation: The detailed examples in the patent's Table 1 all relate to the context of a device being "missing" for progressively longer periods of time. This may support an argument that the term is limited to contexts related to the physical loss or theft of the device, rather than general-purpose security rules.
For the ’933 Patent:
- The Term: "graphical usage description"
- Context and Importance: This term is critical because it defines the mechanism by which the "next state" is predicted for proactive caching. Infringement will turn on whether the accused system uses a functional equivalent of the state diagrams shown and described in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the term as a "flow diagram of the user's interaction" and a representation of the "functional flow of the application" (’933 Patent, col. 1:35-41, col. 2:60-62). This could be argued to cover any predefined map of application logic used for predictive purposes.
- Evidence for a Narrower Interpretation: The patent repeatedly illustrates the concept with explicit state diagrams (e.g., Fig. 3, Fig. 4) where user interface screens are nodes and control flows are links. This suggests the possibility that the term requires a structure that explicitly maps user interface states and transitions, which may not be present in all predictive caching schemes.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all asserted patents, stating that Defendant provides instructions, user manuals, and advertising that guide end-users to operate the Accused Products in an infringing manner (Compl. ¶31, ¶68, ¶112). Figure 1 is cited as an example of such instructional material (Compl. ¶31). Contributory infringement is also alleged for the ’570, ’102, and ’260 patents, based on the Accused Products allegedly having "special features" with no substantial non-infringing use (Compl. ¶32, ¶69, ¶113).
- Willful Infringement: The complaint alleges willful infringement for the ’570, ’102, and ’260 patents. The allegations are based on knowledge of the patents "at least as of the date when it was notified of the filing of this action" (Compl. ¶33, ¶70, ¶114) and, on information and belief, a "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (Compl. ¶34, ¶71, ¶115).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents a broad challenge to a smart home ecosystem, asserting infringement across eight distinct patents. The outcome will likely depend on the resolution of several key technical and legal questions for the court:
- A central issue will be one of definitional scope: Can terms rooted in the context of early-2000s mobile devices and web applications—such as the '570 patent's "mobile device" security and the '933 patent's "graphical usage description" for web navigation—be construed to cover the architecture and functionality of a modern, integrated smart home platform?
- A second core question will be one of technical implementation: The complaint makes high-level allegations that the Accused Products perform the functions claimed in the patents. A critical evidentiary battle will be to determine whether the actual software architecture and operational logic of the Control4 OS 3 system maps onto the specific, multi-step methods required by claims such as Claim 1 of the ’570 patent (hierarchical, context-based security) and Claim 7 of the ’933 patent (proactive caching based on state prediction).
- A third question concerns indirect infringement and willfulness: Given the breadth of the accused platform, Plaintiff’s claims for indirect infringement will require evidence that Defendant specifically intended for its customers to use the system in the precise manner claimed by each patent. The willfulness allegations, based primarily on post-suit knowledge and an alleged policy of willful blindness, will depend on evidence of Defendant's subjective intent and objective recklessness.