DCT

2:25-cv-00239

IoT Innovations LLC v. Resideo Tech Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00239, E.D. Tex., 02/25/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Resideo has committed acts of infringement in the district and maintains a regular and established place of business at 2601 Petty Place, Fort Worth, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home products and related software infringe eight patents related to network data classification, routing, and processing.
  • Technical Context: The asserted patents concern methods for managing and transmitting data in packet-switched networks, technologies foundational to modern smart home and Internet of Things (IoT) device ecosystems.
  • Key Procedural History: The complaint notes that Certificates of Correction were issued for U.S. Patent Nos. 7,974,266 and 7,474,667 after their initial issuance. No other procedural events, such as prior litigation or administrative challenges, are mentioned.

Case Timeline

Date Event
2001-04-16 ’173 Patent Priority Date
2001-07-09 ’872 Patent Priority Date
2001-11-13 ’876 Patent Priority Date
2004-10-13 ’798 Patent Priority Date
2007-01-09 ’428 Patent Priority Date
2007-04-18 ’580 Patent Priority Date
2007-04-24 U.S. Patent No. 7,209,876 Issued
2007-07-17 U.S. Patent No. 7,246,173 Issued
2007-07-17 ’266 Patent Priority Date
2007-07-18 ’667 Patent Priority Date
2008-07-01 U.S. Patent No. 7,394,798 Issued
2008-08-05 U.S. Patent No. 7,408,872 Issued
2009-01-06 U.S. Patent No. 7,474,667 Issued
2009-07-28 U.S. Patent No. 7,567,580 Issued
2009-09-22 U.S. Patent No. 7,593,428 Issued
2011-07-05 U.S. Patent No. 7,974,266 Issued
2011-11-22 ’266 Patent Certificate of Correction Issued
2013-01-01 ’667 Patent Certificate of Correction Issued
2025-02-25 Complaint Filed

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

U.S. Patent No. 7,974,266 - "Method and Apparatus for Classifying IP Data", Issued July 5, 2011

The Invention Explained

  • Problem Addressed: The patent describes that in computer networks utilizing "source routing"—where the sender of a data packet specifies the path it should take—a router may misinterpret the packet's final destination. This occurs because the destination address field in the main IP header may point to the next router in the path, not the ultimate recipient, which can cause incorrect application of Quality of Service (QoS) rules (Compl. ¶38; ’266 Patent, col. 4:5-27).
  • The Patented Solution: The invention proposes a method for a network node (like a router) to classify a data packet based on the last destination address listed in a series of addresses within the packet's routing header, rather than relying solely on the immediate destination in the main header. This ensures that classification decisions are made with respect to the packet's true final destination, even while it is en route (Compl. ¶38; ’266 Patent, Abstract; col. 5:6-14).
  • Technical Importance: This approach enables the correct application of resource reservation protocols and QoS policies in networks where senders dictate the data path, preventing the misclassification that could otherwise lead to degraded network performance for services like VoIP or video streaming (’266 Patent, col. 4:40-57).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶37).
  • The essential elements of claim 1 are:
    • receiving Internet Protocol (IP) data at a first node;
    • classifying the IP data received at the first node based on a last destination address entry of a plurality of destination address entries in a header of the IP data;
    • forwarding the IP data from the first node to a second node, where the IP data is classified at the second node based on the same last destination address entry.
  • The complaint does not specify any dependent claims for assertion.

U.S. Patent No. 7,246,173 - "Method and Apparatus for Classifying IP Data", Issued July 17, 2007

The Invention Explained

  • Problem Addressed: Similar to the ’266 Patent, this patent addresses the challenge of correctly classifying data packets for QoS purposes when source routing is employed. A router might incorrectly classify a packet's session if it only looks at the immediate destination in the IP header, which may be an intermediate stop on a longer, sender-defined path (’173 Patent, col. 4:5-27).
  • The Patented Solution: The invention discloses a method where a network node receives a data packet containing a header with a list of "at least one intermediate node to be visited." The node then classifies the data based on "an entry in said header," allowing it to use the source routing information (e.g., an address from an IPv4 LSRR/SSRR list or an IPv6 routing header) to correctly identify the data stream's requirements (’173 Patent, Abstract; col. 4:28-57).
  • Technical Importance: This method ensures that network services like resource reservation can function correctly for source-routed traffic, which is critical for maintaining performance guarantees in complex network environments (’173 Patent, col. 4:40-57).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶47).
  • The essential elements of claim 1 are:
    • receiving data at a first node, where the data includes a header comprising a list of at least one intermediate node to be visited en route to the destination; and
    • classifying the data at that first node based on an entry in that header.
  • The complaint does not specify any dependent claims for assertion.

U.S. Patent No. 7,474,667 - "Multi-Path Gateway Communications Device", Issued January 6, 2009

  • Technology Synopsis: The patent describes a personal digital gateway that manages communications for a user across multiple devices. The technology addresses the problem of synchronizing and formatting personalized data for different devices by using rule-based profiles to access, integrate, and configure the data appropriately for a selected communications device (Compl. ¶58; ’667 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶57).
  • Accused Features: The complaint accuses Defendants' systems of infringement for providing functionalities where users manage various smart home devices through a central application, which receives data and applies rule-based profiles to configure the communications (Compl. ¶58).

U.S. Patent No. 7,567,580 - "Edge Side Assembler", Issued July 28, 2009

  • Technology Synopsis: The technology relates to an "edge side assembler" that facilitates data exchange for a user's personal digital gateway. It addresses the challenge of accessing disparate information by identifying data associated with a user, locating and retrieving remote data from a selected device, integrating the local and remote data, and formatting it for communication (’580 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶67).
  • Accused Features: The infringement allegation targets Defendants' smart home platforms that retrieve data from various sensors and devices (e.g., thermostats, cameras), integrate it, and present it to the user in a unified format via an application (Compl. ¶68).

U.S. Patent No. 7,593,428 - "Apparatus, and Associated Method, for Forming, and Operating Upon, Multiple-Checksum-Protected Data Packet", Issued September 22, 2009

  • Technology Synopsis: This patent discloses a method for enhancing data integrity in packet communications. To address potential data corruption, the invention describes formatting a single data packet with multiple, distinct checksums, where each checksum protects a different portion of the data, allowing for more granular error detection (’428 Patent, Abstract).
  • Asserted Claims: At least independent claim 14 (Compl. ¶77).
  • Accused Features: The complaint alleges that the Accused Products utilize methods of data transmission that involve formatting data packets with at least two separate checksum calculations performed upon different portions of the data (Compl. ¶78).

U.S. Patent No. 7,209,876 - "System and Method for Automated Answering of Natural Language Questions and Queries", Issued April 24, 2007

  • Technology Synopsis: The patent addresses the problem of retrieving direct answers from electronic databases using conversational language. The solution involves a method that transforms a natural language question into a generic query form, then into an "expected answer form," and searches a data repository for text that syntactically matches this expected answer structure (’876 Patent, Abstract).
  • Asserted Claims: At least independent claim 13 (Compl. ¶86).
  • Accused Features: The complaint targets functionalities within the Accused Products that receive search queries from users, process them against an information repository, and provide structured answers (Compl. ¶87).

U.S. Patent No. 7,408,872 - "Modulation of Signals for Transmission in Packets Via an Air Interface", Issued August 5, 2008

  • Technology Synopsis: The technology relates to signal modulation for wireless packet transmission, aiming to balance higher data rates with backward compatibility. The invention proposes modulating different parts of a data packet (e.g., header versus payload) using different sets of values from a single underlying modulation scheme, thereby achieving variable data rates within the same packet (’872 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶95).
  • Accused Features: The accused functionality is the performance of signal modulation methods where different pluralities of bits within a data packet are mapped to values according to a selected modulation scheme (Compl. ¶96).

U.S. Patent No. 7,394,798 - "Push-to Talk Over Ad-Hoc Networks", Issued July 1, 2008

  • Technology Synopsis: The patent describes a method for controlling communication within a temporary, ad-hoc network. To enable direct device-to-device communication without a central controller, the invention involves network nodes temporarily forming a group and sending and receiving information via a direct radio connection between at least two nodes (’798 Patent, Abstract).
  • Asserted Claims: At least independent claim 16 (Compl. ¶104).
  • Accused Features: The complaint alleges infringement by Resideo products that use ad-hoc or mesh networking protocols (such as Z-Wave or the proprietary RedLINK® 3.0) to form local networks where devices communicate directly with each other (Compl. ¶¶27, 105).

III. The Accused Instrumentality

Product Identification

The "Accused Products" are a broad range of Resideo and Honeywell Home branded smart home devices, components, software, and services (Compl. ¶27). This includes, but is not limited to, smart thermostats (e.g., T6 Pro, T9, T10), security panels (e.g., ProSeries), internet gateways (e.g., RedLINK™ Internet Gateway), cameras, sensors, and associated mobile applications like the "Resideo App," "Total Connect Comfort app," and "First Alert App" (Compl. ¶¶11, 13-15, 27).

Functionality and Market Context

The Accused Products are designed to provide "home connectivity" by allowing users to remotely control and monitor home systems such as heating, cooling, and security (Compl. ¶7, ¶10). These devices typically connect to a user's home Wi-Fi network to communicate with cloud servers and can also form local networks using protocols like Z-Wave to communicate directly with one another (Compl. ¶¶10, 27). The system is comprised of hardware devices, cloud infrastructure, and software applications that provide users with "control, visibility, insights, and alerts" (Compl. ¶7). Defendants' revenue from the "Products & Solutions" segment, which includes these devices, was reported as $2.672 billion for 2023 (Compl. ¶26).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided. The narrative infringement theories are summarized below.

’266 Patent Infringement Allegations

The complaint alleges that the Accused Products perform a method of classifying Internet Protocol (IP) data. This method purportedly involves receiving IP data at a first node, classifying that data based on the "last destination address entry" found within a list in the packet's header, and then forwarding the data to a second node where the classification is repeated on the same basis (Compl. ¶38). The complaint does not offer specific facts explaining how or where within the accused ecosystem this specific classification method occurs, instead referencing the unattached Exhibit A.

’173 Patent Infringement Allegations

The complaint alleges that the Accused Products perform a method for classifying IP data that is being sent through a packet-switched network. The alleged method comprises receiving data at a first node where the packet header contains a list of intermediate nodes to be visited, and then "classifying said data at said first node based on an entry in said header" (Compl. ¶48). As with the ’266 patent, the complaint provides a conclusory statement of infringement without specific supporting facts, deferring to the unattached Exhibit B.

Identified Points of Contention

  • Evidentiary Questions: The central factual dispute for the ’266 and ’173 patents will be whether the Accused Products actually use source routing mechanisms (such as IPv4's LSRR/SSRR options or IPv6 routing headers) and, if so, whether they perform "classification" based on entries in those headers as claimed. The complaint's allegations are conclusory and lack factual support, suggesting this will be a primary focus of discovery.
  • Scope Questions: A likely point of contention is whether the networking environment of the accused smart home ecosystem—which may involve proprietary protocols, local mesh networks, and communication with cloud servers—falls within the scope of the "packet switched network" and "nodes" described in the patents, which appear to be directed at more general internet routing principles.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • For the ’266 Patent and ’173 Patent:
    • The Term: "classifying"
    • Context and Importance: This term is the active step of the asserted claims in both lead patents. The outcome of the case may depend on whether this term is construed broadly to cover any form of routing, filtering, or data handling, or more narrowly to cover only the specific Quality of Service (QoS) session identification functions described in the patents' specifications. Practitioners may focus on this term because the Defendants will likely argue their products' routing and data handling do not meet the specific type of "classification" disclosed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patents do not provide an explicit definition of "classifying." The term's plain and ordinary meaning could encompass any act of categorizing or sorting data for subsequent handling.
      • Evidence for a Narrower Interpretation: The specifications of both patents repeatedly frame the purpose of the invention in the context of solving a problem with the Resource Reservation Protocol (RSVP) and ensuring correct Quality of Service (QoS) delivery. For example, the specification states that incorrect classification "may cause the packet to not receive the requested QoS" (’173 Patent, col. 4:40-43). This context may support a narrower construction limited to classification for QoS purposes.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for the ’798 patent. Inducement is alleged based on Defendants' user guides for products like the T6 Pro Z-Wave Thermostat, which allegedly instruct customers on how to use the products in an infringing manner (Compl. ¶¶107, 113). Contributory infringement is alleged on the basis that the Accused Products have "special features that are specially designed to be used in an infringing way" and have no substantial non-infringing uses (Compl. ¶116).

Willful Infringement

Willfulness is alleged for infringement of the ’798 patent. The allegation is based on knowledge of the patent obtained "at least as of the date when it was notified of the filing of this action" (Compl. ¶106, ¶119). The complaint further alleges a "policy or practice of not reviewing the patents of others," which it characterizes as willful blindness (Compl. ¶120).

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

  • A core issue will be one of evidentiary sufficiency: Can the plaintiff produce technical evidence, likely through discovery, to substantiate its conclusory allegations that Resideo's products perform the specific source-routing-based data classification methods required by the ’266 and ’173 patents?
  • A key legal question will be one of claim scope: Will the term "classifying," central to the lead patents, be construed broadly to cover general data routing and filtering, or will it be limited by the specification's context to specific Quality of Service (QoS) session identification functions related to protocols like RSVP?
  • A fundamental technical question will be one of applicability: Do the networking methods disclosed in the asserted patents, which are described in the context of general Internet protocols like IPv4 and IPv6, read on the potentially proprietary and specialized network architecture of the accused smart home ecosystem, which includes local ad-hoc networks (e.g., Z-Wave) and cloud-based communication?