v. xMatrix LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: xMatrix LLC (NM)
  • Defendant: Synology Inc. (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00077, E.D. Tex., 01/26/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place 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 unspecified products infringe patents related to remotely managed network gateway infrastructure and managed file backup services.
• Technical Context: The technology concerns network-attached storage (NAS) and gateway devices that provide application services (such as file backup) locally at a user's premises while being managed by a remote service provider.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit. Both asserted patents claim priority to the same 2006 provisional applications, indicating they stem from a common inventive effort.

Case Timeline

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

U.S. Patent No. 10,630,501 - System and method for providing network support services and premises gateway support infrastructure

• Patent Identification: U.S. Patent No. 10,630,501, “System and method for providing network support services and premises gateway support infrastructure,” issued April 21, 2020 (’501 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the growing complexity of the "digital home," which can be a "daunting and intimidating task" for technologically challenged users to manage across numerous interconnected devices and services (’501 Patent, col. 1:36-44). The conventional model of hosting service logic on remote network servers is presented as inadequate for this environment (’501 Patent, col. 2:37-44).
• The Patented Solution: The invention proposes moving application service logic from distant network servers into a gateway device located at the user's premises (’501 Patent, col. 9:10-14). This local gateway executes services directly but is remotely managed by a "service management system," which can selectively activate or deactivate "service logic modules" within the gateway to provision, update, and control services like media delivery or home automation (’501 Patent, Abstract; FIG. 1).
• Technical Importance: This architecture sought to simplify the digital home experience by centralizing service delivery in a local, managed appliance, potentially improving performance and simplifying upgrades for the end-user while retaining centralized control for the service provider (’501 Patent, col. 2:57-65).

Key Claims at a Glance

• The complaint does not identify the specific claims asserted from the ’501 Patent, instead referring to an external exhibit not provided with the complaint (Compl. ¶12, 17).

U.S. Patent No. 8,180,735 - Managed file backup and restore at remote storage locations through multi-services gateway at user premises

• Patent Identification: U.S. Patent No. 8,180,735, “Managed file backup and restore at remote storage locations through multi-services gateway at user premises,” issued May 15, 2012 (’735 Patent).

The Invention Explained

• Problem Addressed: The patent identifies the need for file backup services and notes the disadvantages of relying on local storage, which carries the "potential loss of the original files and the backup files in the event of a catastrophic event, such as a fire in the premises" (’735 Patent, col. 5:11-20).
• The Patented Solution: The invention describes a system where a gateway device at the user’s premises manages the backup and restore of data from endpoint devices (e.g., PCs) to a remote storage area. A separate, external "service management center" communicates with the gateway via a wide area network to control the gateway's access to the remote storage area, thus creating a managed, off-site backup system orchestrated locally (’735 Patent, Abstract).
• Technical Importance: The technology aimed to provide a more robust backup solution by combining the convenience of a local network appliance for managing the process with the security of off-site storage, all under the control of a managing service provider (’735 Patent, col. 5:21-34).

Key Claims at a Glance

• The complaint does not identify the specific claims asserted from the ’735 Patent, instead referring to an external exhibit not provided with the complaint (Compl. ¶21, 26).

III. The Accused Instrumentality

Product Identification

• The complaint does not name or describe any specific accused products, methods, or services from Defendant Synology Inc. (Compl. ¶12, 21). It refers generally to "Exemplary Defendant Products" identified in external exhibits that were not provided with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It makes only the conclusory allegation that the unspecified products "practice the technology claimed" by the patents-in-suit (Compl. ¶17, 26).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe the ’501 Patent and ’735 Patent, incorporating by reference external claim chart exhibits (Exhibits 3 and 4) that were not provided (Compl. ¶18, 27). The complaint’s narrative theory of infringement is that Defendant's unspecified "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements" of certain "Exemplary" claims from the patents-in-suit (Compl. ¶17, 26). Without the asserted claims or a description of the accused products, a detailed analysis or claim chart summary is not possible.

• Identified Points of Contention: The complaint’s lack of detail regarding the asserted claims and the functionality of the accused products precludes an analysis of potential technical or legal points of contention regarding infringement.

V. Key Claim Terms for Construction

As the complaint does not identify the specific claims being asserted from either the ’501 Patent or the ’735 Patent, an analysis of key claim terms for construction is not possible.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. The allegations are based on Defendant selling the accused products to customers and distributing "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents (Compl. ¶15, 24).
• Willful Infringement: The complaint does not use the term "willful infringement." However, it alleges that service of the complaint constitutes "Actual Knowledge of Infringement" for both patents (Compl. ¶14, 23). It further alleges that "Despite such actual knowledge, Defendant continues to make, use, test, sell, offer for sale, market, and/or import" the accused products (Compl. ¶15, 24). These allegations may form the basis for a claim of post-suit willful infringement.

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

The complaint's sparse factual content frames the initial phase of the litigation around foundational legal and technical questions rather than specific claim disputes.

• A primary threshold question will be one of "pleading sufficiency": does the complaint, which makes conclusory infringement allegations and relies entirely on external, unprovided exhibits to identify the accused products, asserted claims, and infringing functionality, provide plausible grounds for relief as required by federal pleading standards?
• Assuming the case proceeds, a central technical question will concern "architectural mapping": how do the specific software and hardware components of Defendant's products, once identified, map onto the patents' claimed architecture of a locally-executing, remotely-managed gateway system?
• A critical issue for claim construction will be the "scope of the 'gateway device'": how will the court construe the role and capabilities of the claimed "gateway device," particularly the interaction between its local "service logic modules" (in the ’501 Patent) or backup management functions (in the ’735 Patent) and the remote "service management system," and does the accused system operate in a corresponding manner?