DCT
2:25-cv-00673
Applied Capital Inc v. Siemens Industry Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Applied Capital, Inc. (New Mexico)
- Defendant: Siemens Industry, Inc. (Delaware)
- Plaintiff’s Counsel: Offor Evans PLLC
- Case Identification: 2:25-cv-00673, E.D. Tex., 07/01/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a "regular and established place of business" in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s Siveillance security management software systems infringe a patent related to alarm monitoring systems that integrate alarm data with graphical information like floor plans.
- Technical Context: The technology addresses the need for emergency first responders to have enhanced situational awareness by automatically linking alarm signals to visual layouts of a premises.
- Key Procedural History: The asserted patent claims priority to provisional applications filed in 2009. The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2009-01-28 | Earliest Priority Date for ’082 Patent |
| 2017-08-08 | U.S. Patent No. 9,728,082 Issues |
| 2019-01-01 | Alleged First Infringement by Defendant (approx.) |
| 2025-07-01 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,728,082 - "Premises monitoring system"
- Issued: August 8, 2017
The Invention Explained
- Problem Addressed: The patent addresses a need recognized after the September 11, 2001 attacks for first responders to have better real-time information about an emergency situation, particularly a way to visualize alarm data from building sensors on a map or floor plan instead of relying on non-visual alarm panels (Compl. ¶5).
- The Patented Solution: The invention is a system that receives a signal from a remote alarm (e.g., a smoke detector), which contains a device identifier and its condition (e.g., "alarm"). Based on this signal, the system automatically retrieves and dispatches "enhanced information"—such as floor plans showing access paths, hazard areas, or contact information—to first responders' devices to provide immediate visual context (’082 Patent, Abstract; col. 2:50-65).
- Technical Importance: This approach sought to reduce emergency response times by providing critical, actionable visual intelligence directly to responders without manual intervention (Compl. ¶11).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 of the ’082 Patent (Compl. ¶24).
- The essential elements of claim 1, which is directed to a non-volatile computer-readable medium, include code for:
- Receiving one or more signals containing a device identifier and a device condition from a remote alarm monitoring system.
- Retrieving enhanced information based on the device identifier and condition.
- Determining communication methods and destinations based on the identifier and condition.
- Dispatching the enhanced information to a destination for graphical display.
- Crucially, the "retrieving enhanced information" step requires retrieving images that comprise "all of the members selected from the group consisting of superimposed visual indicators, hierarchically organized graphical images, and vector-based graphical images" (’082 Patent, cl. 1).
- The complaint does not explicitly reserve the right to assert other claims, though this is common practice.
III. The Accused Instrumentality
Product Identification
The accused products are security management software and systems sold under the names "Siveillance Control" and "Siveillance Control Pro" (Compl. ¶21).
Functionality and Market Context
- The accused products are described as client/server software that receives alarm signals and event messages from connected devices like cameras, detectors, and access control systems (Compl. ¶26). These signals allegedly include a "detector number" (the device identifier) and an "event message" (the device condition) (Compl. ¶26). The system allows administrators to configure rules for routing these alarm notifications to specific workstations or user groups (Compl. ¶28).
- A key alleged functionality is the ability for users to associate detectors with graphical images that appear as floor plans or layouts. The complaint alleges these graphics can be organized into hierarchies using "navigation points" to link different views (e.g., from a site level to a building level to a specific zone level), thereby enabling "hierarchical drill-down navigation" (Compl. ¶30, ¶32). The complaint includes a promotional graphic for the original "iLinkx" concept, showing a computer displaying a building layout over a larger floor plan marked "YOU ARE HERE," which illustrates the core idea of providing visual, map-based alarm context (Compl. p. 5).
- The complaint does not provide specific details on the products' market positioning beyond identifying customers as security integrators, facility managers, and industrial clients (Compl. ¶2).
IV. Analysis of Infringement Allegations
’082 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| code receiving one or more signals containing a device identifier and a device condition from one or more remote alarm monitoring systems | The Siveillance Control application receives alarm signals and event messages from connected devices; these messages allegedly contain a "detector number" (device identifier) and an event "message" (device condition). | ¶26 | col. 2:8-13 |
| code determining one or more communication methods and communication destinations based on the device identifier and the device condition | The system allows an administrative user to configure message control rules to associate particular alarm signals with specific workstations or user groups, thereby determining the communication destination. | ¶28 | col. 2:13-17 |
| code retrieving enhanced information... the images comprising all of the members selected from the group consisting of superimposed visual indicators, hierarchically organized graphical images, and vector-based graphical images | The system allegedly retrieves graphics for display, where: (1) detector icons placed on a floor plan are "superimposed visual indicators"; (2) linkages between graphics via navigation points create "hierarchically organized graphical images"; and (3) graphics in DWG, DXF, or GRX formats are "vector-based graphical images." | ¶29-¶30 | col. 5:1-19; col. 5:44-60; col. 6:1-10 |
| code dispatching the enhanced information to the one or more communication destinations using the one or more communication methods | The Siveillance application dispatches the retrieved graphics associated with an alarm to the appropriate workstation, enabling an operator to "drill down" to the alarm's location. | ¶32 | col. 2:17-20 |
Identified Points of Contention
- Scope Questions: The infringement case may turn on whether the accused product’s features meet the specific definitions of all three required image types in claim 1. A primary question is whether linking graphics with user-defined "navigation points," as alleged, constitutes "hierarchically organized graphical images" as contemplated by the patent. A second question is whether placing an icon on a floor plan is sufficient to meet the "superimposed visual indicators" limitation.
- Technical Questions: The complaint alleges that graphics provided in certain formats (DWG, DXF) embody "vector-based graphical images" (Compl. ¶13). A technical question for the court will be whether the Siveillance system exclusively uses such formats for the accused functionality or if the use of non-vector (raster) images could allow Defendant to operate outside the scope of this claim element.
V. Key Claim Terms for Construction
"hierarchically organized graphical images"
- Context and Importance: This term is critical because infringement depends on whether the accused product's method of linking floor plans together via "navigation points" meets this definition. Practitioners may focus on this term to determine if a simple "drill-down" capability is sufficient, or if a more structured, pre-defined parent-child data relationship is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a hierarchical image as including "any group of graphical images arranged relative to one another and/or accessible through one another," giving an example of a camera feed accessible from a floor plan, which is accessible from a site plan (’082 Patent, col. 5:53-60). This language could support a broad definition covering any linked set of graphics.
- Evidence for a Narrower Interpretation: A defendant could argue that the term implies a formal, structured hierarchy, not merely ad-hoc links. The patent's consistent reference to navigating between discrete levels (site, building, floor) may be used to argue for a more rigid structural requirement.
"superimposed visual indicators"
- Context and Importance: The complaint alleges that placing detector icons on a floor plan satisfies this limitation (Compl. ¶30). The viability of this infringement theory rests on the construction of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a visual indicator "may include one or more icons or one or more designators superimposed on a map, picture, floor plan, and/or site plan" (’082 Patent, col. 5:14-18). This language appears to directly support the plaintiff's theory.
- Evidence for a Narrower Interpretation: The same passage later states the indicator may be "customizable, blinkable, and/or color-codable" (’082 Patent, col. 5:23-25). A defendant might argue that to be a "superimposed visual indicator" in the context of the invention, the icon must do more than mark a location; it must be capable of dynamically conveying meaningful information about the device's condition.
VI. Other Allegations
Indirect Infringement
The complaint does not plead a formal count for indirect infringement. However, it alleges facts that could support such a claim, stating that Defendant "teaches its customers how to install and use the products it sells" and provides detailed operation and configuration manuals (Compl. ¶2, ¶22).
Willful Infringement
The complaint does not allege that Defendant had knowledge of the ’082 Patent before the lawsuit was filed. It does, however, request enhanced damages in the prayer for relief, which suggests an allegation that any continued infringement after the filing of the complaint is willful (Compl. p. 15, ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and construction: can the composite claim limitation requiring "superimposed visual indicators, hierarchically organized graphical images, and vector-based graphical images" be met by the accused system's alleged functionality? The case will likely involve a detailed, feature-by-feature comparison of how the Siveillance system manages graphical layers and navigation against how those concepts are defined and described in the ’082 patent.
- A key evidentiary question will be one of technical implementation: what is the precise nature of the graphical images and linking mechanisms used in the Siveillance products? Discovery will likely focus on whether the system's architecture requires the use of vector-based graphics and hierarchical organization in all infringing modes, or if there are non-infringing alternatives available within the same product.