DCT
2:25-cv-00033
IoT Innovations LLC v. Fibar Group SA
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: IoT Innovations LLC (Texas)
- Defendant: BH Security, LLC d/b/a Brinks Home (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00333, E.D. Tex., 10/30/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Eastern District of Texas, employs individuals residing in the District, and has committed the alleged acts of infringement within the District.
- Core Dispute: Plaintiff alleges that Defendant’s home security platforms and systems infringe a portfolio of six U.S. patents related to various aspects of network communication, data management, and device functionality.
- Technical Context: The technologies at issue relate to the networking and management of connected devices, a foundational area for the modern Internet of Things (IoT) and smart home security markets.
- Key Procedural History: The complaint alleges Defendant had knowledge of the patents-in-suit due to two prior lawsuits filed by Plaintiff against "Monitronics International, Inc. d/b/a Brinks Home." The first, filed November 4, 2022, asserted two of the patents in the current suit, and the second, filed April 18, 2023, asserted the remaining four. These prior actions form the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2000-09-11 | U.S. Patent No. 7,526,762 Priority Date |
| 2001-04-16 | U.S. Patent No. 7,246,173 Priority Date |
| 2001-06-21 | U.S. Patent No. 7,274,761 Priority Date |
| 2002-11-27 | U.S. Patent No. 7,263,102 Priority Date |
| 2004-06-02 | U.S. Patent No. 7,280,830 Priority Date |
| 2004-10-13 | U.S. Patent No. 7,394,798 Priority Date |
| 2007-07-17 | U.S. Patent No. 7,246,173 Issued |
| 2007-08-28 | U.S. Patent No. 7,263,102 Issued |
| 2007-09-25 | U.S. Patent No. 7,274,761 Issued |
| 2007-10-09 | U.S. Patent No. 7,280,830 Issued |
| 2008-07-01 | U.S. Patent No. 7,394,798 Issued |
| 2009-04-28 | U.S. Patent No. 7,526,762 Issued |
| 2022-11-04 | Prior litigation filed, establishing alleged knowledge of '102 & '830 patents |
| 2023-04-18 | Prior litigation filed, establishing alleged knowledge of '173, '761, '798 & '762 patents |
| 2025-10-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,246,173 - "Method And Apparatus For Classifying IP Data," issued July 17, 2007
The Invention Explained
- Problem Addressed: In networks utilizing source routing (where the sender specifies intermediate routers for a packet to visit), the destination address in the main IP header may point to the next intermediate router, not the packet's final destination. This can cause incorrect behavior for protocols like RSVP (Resource Reservation Protocol) that rely on the final destination address to classify data flows and apply Quality of Service (QoS) rules (’173 Patent, col. 4:3-8; col. 4:38-44).
- The Patented Solution: The invention proposes classifying a data packet at a network node based on source routing information contained within the packet's header, rather than relying solely on the main destination address field. For IPv6, this involves examining the routing header (depicted in FIG. 5) to identify the final destination from a list of addresses. This allows a router to correctly identify the packet's session and apply the appropriate QoS, even when it is only an intermediate stop (’173 Patent, col. 5:10-14, col. 5:51-54).
- Technical Importance: This method enables more reliable implementation of QoS protocols in complex networks that use source routing, ensuring that reserved network resources are correctly allocated to data streams throughout their specified path (’173 Patent, col. 4:5-13).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶ 30).
- The essential elements of Claim 1 are:
- A method of classifying IP data in a packet switched network.
- Receiving the data at a first node, where the data includes a header with a list of at least one intermediate node to be visited.
- Classifying the data at the first node based on an entry in that header.
U.S. Patent No. 7,263,102 - "Multi-Path Gateway Communications Device," issued August 28, 2007
The Invention Explained
- Problem Addressed: In the early 2000s, users owned multiple electronic devices (e.g., PDAs, home PCs, wireless phones), each with different software and hardware. Managing and synchronizing personal data like contacts, calendars, and passwords across these disparate devices was cumbersome, often requiring duplicate manual entry and leading to data inconsistency (’102 Patent, col. 1:56-col. 2:16).
- The Patented Solution: The patent describes a "personal digital gateway" (PDG) that serves as a central interface for a user's various devices. The PDG uses a database of "rule-based profiles" to manage communications, automatically categorizing data into types such as access, configuration, security, and management. This allows the gateway to intelligently format and route information to different devices based on their specific capabilities, creating a "virtual personalized network" for the user (’102 Patent, col. 3:4-15; col. 3:54-col. 4:11). The overall system architecture is illustrated in the patent's FIG. 2.
- Technical Importance: This technology provides a framework for unifying a user's digital life across a growing number of personal electronic devices, automating the process of data sharing and synchronization that was previously a significant manual burden (’102 Patent, col. 2:30-34).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶ 44).
- The essential elements of Claim 1 are:
- A personal digital gateway comprising a database of rule-based profiles for communicating data to a selected communications device.
- The rule-based profile categorizes data as associated with at least one of an access agent, a configuration agent, a security agent, and a management agent.
- A processor that associates a profile with the selected device.
- A communications interface enabling data communication with a plurality of devices.
- A memory device that is removable from the gateway.
Multi-Patent Capsule: U.S. Patent No. 7,274,761 - "Device Synchronisation Over A Network," issued September 25, 2007
- Technology Synopsis: The patent addresses the problem of synchronizing real-time clocks across separate devices in a network (’761 Patent, col. 1:5-16). The solution involves a device reading its own clock at a specific instance of a common time reference and transmitting both the clock value and an identifier for that instance to another device, allowing the receiving device to synchronize its own clock (’761 Patent, col. 1:31-41).
- Asserted Claims: At least independent claim 1 (Compl. ¶ 61).
- Accused Features: The complaint alleges that the Brinks Home Hubs, Brinks Home IQ 2.0 Control Panels, and Brinks Home App infringe by providing a device that synchronizes to a common time reference and transmits real time clock values between devices in the network (Compl. ¶ 62).
Multi-Patent Capsule: U.S. Patent No. 7,280,830 - "Automatic Registration Services Provided Through A Home Relationship Established Between A Device And A Local Area Network," issued October 9, 2007
- Technology Synopsis: The patent describes a method to simplify the registration of new electronic devices. The process involves first establishing a "home" relationship between the new device and a network server, which recognizes the device as "owned" (’830 Patent, col. 1:44-49). The server then automatically obtains registration information for the device and sends it to a registration server, automating what is typically a cumbersome manual process for the user (’830 Patent, col. 1:49-55).
- Asserted Claims: At least independent claim 1 (Compl. ¶ 75).
- Accused Features: The complaint alleges the Accused Products perform a method of automatic registration for a new wireless device by establishing a home relationship with a network server, determining the device is an "owned device," and automatically obtaining and sending registration information to a registration server (Compl. ¶ 76).
Multi-Patent Capsule: U.S. Patent No. 7,394,798 - "Push-To Talk Over Ad-Hoc Networks," issued July 1, 2008
- Technology Synopsis: The invention describes a network system where nodes can temporarily form groups to enable push-to-talk communication. The system allows for information to be sent and received within the group via a direct radio connection between at least two network nodes, creating an ad-hoc network for communication (’798 Patent, col. 1:43-52).
- Asserted Claims: At least independent claim 16 (Compl. ¶ 92).
- Accused Features: The complaint alleges the Brinks Home Hubs and IQ 2.0 Control Panels perform a method of controlling a network system by temporarily forming groups of network nodes and sending/receiving information between the groups using a direct radio connection (Compl. ¶ 93).
Multi-Patent Capsule: 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 upgrades on a network of terminals. A central configuration server receives an upgrade message, identifies which users and associated terminal servers require the upgrade, and provides the upgrade to those terminal servers for subsequent distribution. The system also tracks which servers have not yet transferred the upgrade and can provide it upon activation of an associated terminal (’762 Patent, Abstract).
- Asserted Claims: At least independent claim 7 (Compl. ¶ 109).
- Accused Features: The complaint alleges the Brinks Home Hubs, IQ 2.0 Control Panels, and Brinks Home App provide a system with a configuration server that receives upgrade messages, identifies users requiring the upgrade, provides the upgrade to terminal servers, and manages subsequent distribution to terminals (Compl. ¶ 110).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the Brinks Home security platform and systems, which include the Brinks Home Hubs, Brinks Home IQ 2.0 Control Panels (such as the Qolsys IQ Panel2), and the Brinks Home App (Compl. ¶ 21, ¶ 31, ¶ 62).
Functionality and Market Context
The complaint characterizes the Accused Products as a "home alarm and/or security platform and systems" (Compl. ¶ 21). Their alleged technical functionalities span a range of networking tasks, including classifying IP data packets, managing data across multiple devices, synchronizing device clocks, automatically registering new devices to the network, forming ad-hoc communication groups, and distributing software updates (Compl. ¶¶ 31, 45, 62, 76, 93, 110). The complaint includes a press release announcing a partnership, which suggests Defendant is actively marketing its "cutting-edge products and services" to expand its presence in the home security market (Compl. p. 4; ¶ 12).
IV. Analysis of Infringement Allegations
The complaint references Exhibits A-F containing detailed infringement evidence, but these exhibits were not provided. The following analysis is based on the narrative summaries in the complaint body.
7,246,173 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of classifying Internet Protocol (IP) data to be sent from a source apparatus to a destination apparatus in a packet switched network | The Accused Products perform a method of classifying IP data to be sent from a source to a destination in a packet switched network. | ¶31 | col. 2:42-45 |
| receiving said data at a first node, the data comprising a header comprising a list of at least one intermediate node to be visited on a way... | The installation and use of the Accused Products involves receiving data at a first node, with the data's header comprising a list of an intermediate node. | ¶31 | col. 3:55-60 |
| classifying said data at said first node based on an entry in said header. | The Accused Products classify the data at the first node based on an entry in the header. | ¶31 | col. 5:10-14 |
- Identified Points of Contention:
- Scope Question: A primary question may be whether the routing and data handling in the accused Brinks Home system constitutes "source routing" as contemplated by the patent, where a packet header contains a "list of at least one intermediate node." The infringement analysis may turn on how the accused devices direct traffic between hubs, panels, and external servers.
- Technical Question: The complaint alleges classification is "based on an entry in said header." A key factual question will be what specific data field in what specific header the accused products use for classification, and whether this corresponds to the patent's teaching of using an entry from a source routing list rather than the standard destination IP address field.
7,263,102 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A personal digital gateway, comprising: a database of personal digital gateway rule-based profiles for communicating data to a communications device..., the rule-based profile categorizing the data as at least one of (1) data...access agent, (2) data...configuration agent, (3) data...security agent, and (4) data...management agent; | The Accused Products provide a personal digital gateway with a database of rule-based profiles that categorize data for communication, including data associated with an access agent, configuration agent, security agent, and management agent. | ¶45 | col. 16:5-9 |
| a processor communicating with a memory device, the processor associating a personal digital gateway rule-based profile with the selected communications device; | The Accused Products use a processor communicating with a memory device to associate a rule-based profile with a selected communications device. | ¶45 | col. 3:7-10 |
| a communications interface between the personal digital gateway and, the selected communications device, wherein the personal digital gateway enables communication of the data with each communications device of the plurality of communications devices... | The Accused Products provide a communications interface that enables communication between the gateway and a plurality of devices (e.g., wireless devices, mobile phones, computers). | ¶45 | col. 3:10-12 |
| and wherein the memory device is removable from the personal digital gateway. | The memory device in the Accused Products is removable from the personal digital gateway. | ¶45 | col. 15:2-4 |
- Identified Points of Contention:
- Technical Question: The infringement allegation hinges on whether the accused system's architecture includes a "database of...rule-based profiles" that explicitly "categoriz[es] the data" according to the four specific "agent" types listed in the claim. The defense may argue its system uses a different data management logic that does not map onto this claimed structure.
- Scope Question: The requirement that "the memory device is removable" presents a specific, potentially dispositive technical question. The analysis will depend on the physical hardware construction of the accused Brinks Home hubs and control panels.
V. Key Claim Terms for Construction
For the ’173 Patent
- The Term: "classifying said data... based on an entry in said header"
- Context and Importance: This term is the central inventive step of the asserted claim. The case may depend on whether the accused product's method of data classification falls within the scope of this language. Practitioners may focus on this term because it distinguishes the patented method from conventional IP routing, which typically classifies packets based only on the destination address field in the main IP header.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language "an entry in said header" is not explicitly limited to a specific type of header or a specific entry within it, which could support a construction covering any classification method that uses any information from any header beyond the main destination address.
- Evidence for a Narrower Interpretation: The specification consistently frames the invention as a solution to problems arising from source routing in the context of QoS protocols like RSVP (’173 Patent, col. 4:3-44). The described embodiments classify data based on the last address in a source route list to identify the true final destination (’173 Patent, col. 5:10-14, col. 5:51-54). This context suggests the term could be narrowed to classification based on an entry within a source routing header specifically.
For the ’102 Patent
- The Term: "removable"
- Context and Importance: This term defines a physical characteristic of the claimed "memory device." It is a simple, binary limitation that could be dispositive for infringement. Practitioners may focus on this term because its construction is not a matter of technical debate but of direct physical evidence regarding the accused products' hardware.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide a special definition of "removable." A party might argue for its plain and ordinary meaning, which could encompass any memory that can be detached without destroying the gateway, such as a flash memory card, an external hard drive, or other peripheral storage.
- Evidence for a Narrower Interpretation: The specification mentions "flash memory 14" and "peripheral storage device 40" in the context of system components (’102 Patent, col. 6:10-12). A party might argue that the context of early-2000s hardware implies a user-accessible and easily swappable medium like a Compact Flash card or memory stick, potentially excluding internal memory modules that require disassembly to access.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement for the ’102, ’830, and ’798 patents. Inducement is based on allegations that Defendant provides instructions, advertising, and user guides that direct customers to use the products in an infringing manner (Compl. ¶¶ 46, 77, 94). Contributory infringement is based on allegations that the products contain "special features" designed for infringement with no substantial non-infringing uses (Compl. ¶¶ 47, 78, 95).
Willful Infringement
Willfulness is alleged for all six asserted patents. The claims are based on pre-suit knowledge allegedly established by the filing of two prior lawsuits against a related entity, "Monitronics International, Inc. d/b/a Brinks Home." Knowledge of the ’102 and ’830 patents is alleged since November 4, 2022, and knowledge of the ’173, ’761, ’798, and ’762 patents is alleged since April 18, 2023 (Compl. ¶ 32, ¶ 48, ¶ 63, ¶ 79, ¶ 96, ¶ 111). The complaint further alleges willful blindness based on a purported policy of not reviewing third-party patents (Compl. ¶ 33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technological applicability: Can patent claims drafted for networking technologies and device architectures of the early 2000s be construed to cover the integrated functionalities of a modern IoT home security platform? This question will be central to claim construction, particularly for terms describing specific protocols (like the source routing context of the '173 patent) or hardware features (like the "removable" memory of the '102 patent).
- A second central question will be evidentiary sufficiency: The complaint makes infringement allegations that closely track the claim language but relies on un-provided exhibits for technical proof. The case will likely turn on whether discovery produces specific evidence showing that the accused system's software architecture and data management logic performs the precise, multi-step functions required by the asserted claims, such as categorizing data into the four "agent" types of the '102 patent.
- A final key question relates to willfulness and damages: Given that the willfulness allegations are based on knowledge derived from prior lawsuits, the corporate relationship between the defendant in this case (BH Security, LLC) and the defendant in the prior cases (Monitronics International, Inc.) may become a significant factual issue in determining the extent of pre-suit knowledge and potential for enhanced damages.