DCT
2:25-cv-00707
Smart Speaker LLC v. Amazon.com Services LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Smart Speaker LLC (Texas)
- Defendant: Amazon.com Services LLC (Delaware)
- Plaintiff’s Counsel: Fabricant LLP
- Case Identification: 2:25-cv-00707, E.D. Tex., 07/11/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business in the District, such as robotics fulfillment centers and delivery stations, and has committed the alleged acts of infringement within the District.
- Core Dispute: Plaintiff alleges that Defendant’s Amazon Echo smart speakers and associated Alexa cloud services infringe four patents related to the server-based control of devices using voice commands over a wireless network.
- Technical Context: The technology at issue is in the voice-activated smart home device sector, a significant and highly competitive consumer electronics market centered on integrating various in-home devices through a centralized, cloud-connected voice assistant.
- Key Procedural History: The complaint alleges that a prior owner of the patents-in-suit, May Patents Ltd., sent a letter to Amazon on July 23, 2024, providing notice of three of the four asserted patents and inviting licensing discussions. Plaintiff claims Amazon ignored this invitation, a fact which may be material to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2013-01-03 | Earliest Priority Date for '706, '174, '710, and '590 Patents |
| 2021-09-21 | U.S. Patent No. 11,128,710 Issues |
| 2021-11-30 | U.S. Patent No. 11,190,590 Issues |
| 2024-06-11 | U.S. Patent No. 12,010,174 Issues |
| 2024-07-23 | Prior Patent Owner Allegedly Sends Licensing Letter to Amazon |
| 2025-05-27 | U.S. Patent No. 12,316,706 Issues |
| 2025-07-11 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,316,706 - "System and Method for Server Based Control"
The Invention Explained
- Problem Addressed: The patent family addresses the technical challenge of implementing a centralized gateway or control system for various devices, such as sensors and actuators, operating within a building over diverse in-home networks ('710 Patent, col. 1:11-2:1).
- The Patented Solution: The invention describes a client device that acts as a hub within a building. This device captures distinct human voice commands, sends them via a wireless local area network (WLAN) to an external internet-connected server for processing, and receives back distinct messages. Based on these messages, the device is configured to operate its own internal actuator (e.g., a speaker) and also send a control message over the WLAN to a separate, second device (e.g., a smart light) to operate its actuator ('706 Patent, Claim 1). This architecture is depicted in the patent family, for example in Figure 2 of the related '710 Patent, which shows a router (21) mediating between internal "field units" (23a-c) and an external server (24) via the internet (16) ('710 Patent, FIG. 2).
- Technical Importance: This architecture centralizes complex processing logic on a remote server, allowing for a simplified, low-cost client device that can coordinate actions between itself and other disparate smart devices using a natural voice interface (Compl. ¶43).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶28).
- The essential elements of Claim 1 include:
- A client device for use with a WLAN in a building and a controlled device comprising a second actuator.
- A WLAN transceiver and a microphone for capturing first and second human voice data.
- At least one first actuator located within the client device.
- The client device being addressable on the WLAN with an IP address.
- The device is configured to send the captured voice data to an external server and receive first and second messages in response.
- The device is configured to operate its first actuator in response to the first message and send a control message to the controlled device in response to the second message.
- The complaint reserves the right to assert additional claims (Compl. ¶28).
U.S. Patent No. 12,010,174 - "System and Method for Server Based Control"
The Invention Explained
- Problem Addressed: As with the '706 Patent, the technology addresses the control of networked devices within an environment like a building ('710 Patent, col. 1:11-2:1).
- The Patented Solution: Unlike the device-focused '706 Patent, the ’174 Patent claims a complete system comprising three main components: an external server, a client device in the building, and a controlled device with a second actuator. The system is configured such that the client device captures voice data and sends it to the server; the server processes the data and generates responsive messages; and these messages are used to operate both a first actuator on the client device and the second actuator on the separate controlled device ('174 Patent, Claim 1). The process flow for this system is illustrated in Figure 19 of the related '710 Patent, which shows the path from receiving voice data (191) through processing (192) and logic (193) to sending an actuator command (175) ('710 Patent, FIG. 19).
- Technical Importance: By claiming the end-to-end system, the invention covers the integrated operation of local hardware and remote cloud processing to achieve synchronized, voice-activated control over a distributed smart home environment (Compl. ¶68).
Key Claims at a Glance
- The complaint asserts independent system Claim 1 (Compl. ¶48).
- The essential elements of Claim 1 include:
- A system for operating multiple actuators in response to captured human voice data.
- An internet-connected server device external to the building, configured for processing first and second human voice data and producing first and second messages.
- A client device in the building comprising a microphone and a first actuator.
- A controlled device in the building comprising a second actuator.
- The system is configured to send the voice data from the client to the server and receive the messages back, which in turn operate the first and second actuators.
- The complaint reserves the right to assert additional claims (Compl. ¶48).
Multi-Patent Capsules
U.S. Patent No. 11,128,710 - "System and Method for Server-Based Control"
- Technology Synopsis: This patent claims a method for operating multiple actuators through a client-server architecture. The claimed steps include capturing first and second voice data with a microphone on a client device, sending the data to an external server for processing, receiving first and second messages back from the server, operating a first actuator on the client device based on the first message, and operating a second actuator on a separate controlled device based on the second message (Compl. ¶74-83; ’710 Patent, Claim 1).
- Asserted Claims: Method Claim 1 (Compl. ¶73).
- Accused Features: The complaint alleges that the operation of the Amazon Echo System, wherein a user issues voice commands to an Echo device to control both the device itself and other smart home products like lights, performs the steps of the claimed method (Compl. ¶74).
U.S. Patent No. 11,190,590 - "System and Method for Server Based Control"
- Technology Synopsis: This patent claims an AC-powered appliance with an integrated wireless networking capability. The claimed appliance comprises, within a single enclosure, a connector for AC power, a current sensor to measure AC current consumed by the appliance, a first sensor for a physical phenomenon (e.g., sound, motion), an antenna, and a wireless transceiver. The appliance is configured to transmit digital data from the sensors over a wireless network and is controlled or activated in response to digital data received from that network (Compl. ¶96, 99-105; ’590 Patent, Claim 1).
- Asserted Claims: Claim 1 (Compl. ¶95).
- Accused Features: The Amazon Echo products are alleged to be AC-powered appliances that contain, in a single enclosure, a power connector, a power management IC acting as a current sensor, various physical sensors (microphones, motion/temperature sensors), and Wi-Fi/Bluetooth transceivers and antennas (Compl. ¶96-103).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the “Amazon Echo System,” which collectively refers to Amazon’s Alexa-enabled Echo hardware products (e.g., Amazon Echo, Echo Dot, Echo Show) and the associated “Amazon Cloud” server infrastructure that provides the Alexa voice service (Compl. ¶23).
Functionality and Market Context
The complaint alleges that the Amazon Echo products function as voice-controlled smart home hubs. They connect to a user's in-home WLAN and contain an array of microphones to capture spoken commands, which are initiated by a "wake word" like "Alexa" (Compl. ¶30-31, 51). The captured audio is allegedly transmitted over the internet to the Amazon Cloud for processing, which interprets the command and generates responsive messages (Compl. ¶34, 50). The Amazon Cloud then sends these messages back to the Echo device, instructing it to perform actions such as playing audio through its speaker or changing the color of its LED light ring (both identified as "first actuators") (Compl. ¶36, 57-58). The Echo device can also transmit control messages over the WLAN to separate "controlled devices," such as an Amazon Basics smart light bulb, instructing it to perform an action like turning on (Compl. ¶37, 55). An Amazon marketing graphic illustrates this complete system, showing an Echo device and a smart bulb responding to the voice command, "Alexa, turn on living room lights" (Compl. p. 10, image 10). The complaint positions these products as central to Amazon's smart home ecosystem (Compl. ¶23).
IV. Analysis of Infringement Allegations
12,316,706 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A client device for use with a Wireless Local Area Network...in a building and with a controlled device that comprises a second actuator in the building | The Amazon Echo Dot is a client device used in a home (building) with a WLAN (Wi-Fi) and controls a separate controlled device such as an Amazon Basics smart light, which contains a lighting element (second actuator). | ¶29 | col. 171:20-24 |
| a WLAN transceiver | The Echo Dot includes a Wi-Fi transceiver for communicating over the WLAN. A teardown image in the complaint identifies Wi-Fi/Bluetooth antennas. | ¶30, p. 11 visual 12 | col. 171:25 |
| a microphone configured to capture first human voice data and second human voice data | The Echo Dot includes microphones that capture distinct user commands, such as "Alexa, play today's hits" (first voice data) and "Alexa, turn on the living room lights" (second voice data). | ¶31 | col. 171:26-28 |
| at least one first actuator in the client device | The Echo Dot includes a speaker for audio output and an LED light ring for visual feedback, both of which are alleged to be first actuators. | ¶32-33 | col. 171:39 |
| the client device being addressable in the WLAN and using an Internet Protocol ("IP") address | The Echo Dot is addressable on a WLAN using an IP address, which can be located via the user's router settings. | ¶38 | col. 171:10-12 |
| configured to...send the captured first and second human voice data over the Internet to an Internet-connected server device external to the building | The Echo Dot is configured to send the captured voice commands to the Amazon Cloud (an external server) for processing. | ¶34 | col. 171:29-33 |
| configured to...receive from the server device...a first message and a second message, in response | The Echo Dot receives messages from the Amazon Cloud in response to the user's voice commands, such as a message to play audio and a separate message to control a smart light. | ¶35 | col. 171:36-39 |
| configured to operate the first actuator in response to receiving the first message | The Echo Dot operates its speaker (e.g., to play music) in response to receiving a first message from the Amazon Cloud. | ¶36 | col. 171:39-41 |
| configured to send to the controlled device over the WLAN a control message in response to the received second message | The Echo Dot sends a control message (e.g., "turn on") over the WLAN to a controlled device like a smart light bulb in response to receiving a second message from the Amazon Cloud. | ¶37 | col. 171:44-48 |
12,010,174 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for operating multiple actuators in response to captured human voice data... | The Amazon Echo System, comprising Echo devices and the Amazon Cloud, operates actuators like speakers and lights in response to voice commands. | ¶49 | col. 171:19-24 |
| an internet-connected server device external to the building configured for processing first and second human voice data and producing first and second messages... | The Amazon Cloud is an external server that processes voice data (e.g., "play music," "turn on lights") and produces corresponding messages to control devices. | ¶50, 52-54 | col. 171:25-28 |
| a client device in the building comprising a microphone for capturing the first and second human voice data and at least a first actuator | The Amazon Echo device is a client device in a user's home (building) with microphones to capture voice and at least one actuator (speaker, LED light). | ¶55-58 | col. 171:29-32 |
| a controlled device that comprises a second actuator in the building | A compatible smart light is a controlled device with a lighting element (second actuator) located in the user's home. | ¶49 | col. 171:22-24 |
| wherein the system is configured for sending to the server by the client device...the captured first and second human voice data | The system is configured for the Echo device to send captured voice commands to the Amazon Cloud for processing. | ¶60 | col. 171:33-36 |
| wherein the system is further configured for receiving from the server at least the first and second messages... | The system receives messages from the Amazon Cloud at the Echo device in response to the sent voice data. | ¶61 | col. 171:37-39 |
| to operate the first actuator...in response to the received first message | The system operates the Echo device's speaker in response to a message from the Amazon Cloud. | ¶61 | col. 171:39-41 |
| to operate the second actuator in the controlled device in response to the received second message | The system operates the smart light in response to a second message from the Amazon Cloud, relayed by the Echo device. | ¶61 | col. 171:42-45 |
Identified Points of Contention
- Scope Questions: A central question for the system and method claims ('174 and '710 Patents) may be one of divided infringement. The court will need to determine whether Amazon "directs or controls" the actions of its customers to such an extent that Amazon can be held liable for infringement of claim steps performed by end-users (e.g., speaking the voice command). The complaint's allegation that Amazon conditions the product's benefits upon performance of specific steps may be aimed at satisfying this legal standard (Compl. ¶84).
- Technical Questions: For the '590 Patent, a key technical dispute may arise over whether the "MediaTek MT6323 Power Management IC" (Compl. ¶99, p. 48 visual 70) qualifies as a "current sensor coupled to the AC connector for measuring an AC current consumed by the appliance," as claimed. The analysis may turn on whether the primary function of this multifaceted IC is current sensing in the manner described by the patent, or if its actual operation differs materially from the claim language.
V. Key Claim Terms for Construction
The Term: "client device"
- Context and Importance: The asserted claims in the '706 and '174 Patents require a "client device" that is distinct from a "controlled device." The definition of "client device" is critical because it establishes the architecture of the infringing system. Practitioners may focus on this term because the defense could argue that certain Amazon products, such as an Echo Show which can display video content, function as both the "client device" and the "controlled device," potentially avoiding the two-device structure required by the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification of the related '710 Patent describes a "field unit" as potentially being a sensor, an actuator, or a combination, and states it can be integrated into a home appliance or be a small device ('710 Patent, col. 15:1-12). This flexible definition may support a broad interpretation of what can constitute a client device.
- Evidence for a Narrower Interpretation: Figure 2 of the '710 Patent depicts a clear architectural separation between the central "Router" (21) and the peripheral "Field Units" (23a-c), which may suggest the inventor envisioned the "client device" as the central communications hub, distinct from the end-point "controlled devices" ('710 Patent, FIG. 2).
The Term: "first human voice data" and "second human voice data"
- Context and Importance: The claims of the '706 and '174 Patents require the capture of two distinct sets of voice data, which lead to two distinct messages and two distinct actuations. The construction of these terms is vital to the infringement analysis. The complaint maps these terms to two separate user commands (e.g., one to play music, another to turn on a light) (Compl. ¶31, 34). The defense may argue for a narrower interpretation, perhaps requiring a specific temporal or logical relationship between the two voice data captures that is not met by sequential, unrelated commands to Alexa.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not specify any relationship between the first and second voice data, only that they are captured by the microphone and sent for processing ('174 Patent, Claim 1). This lack of an explicit limitation may support an interpretation that any two distinct voice commands captured by the device meet the limitation.
- Evidence for a Narrower Interpretation: The detailed description in the patent family often discusses a single sensory input leading to a coordinated response. The claims' recitation of two separate data inputs leading to two separate messages and actuations could be interpreted as requiring a single, more complex voice command that is parsed into two components (e.g., "Alexa, play music and turn on the lights"), a scenario different from the complaint's theory of two wholly separate commands.
VI. Other Allegations
Indirect Infringement
The complaint alleges that Amazon induces infringement by providing customers with products, user manuals, quick start guides, and website instructions that expressly direct them to set up and use the Echo System in an infringing manner. These instructions allegedly include connecting the Echo device to a WLAN and the Amazon Cloud, and using voice commands to control both the device and other smart home products (Compl. ¶39-41, 64-65, 85-87).
Willful Infringement
The willfulness allegations for the '174, '710, and '590 Patents are based on alleged pre-suit knowledge stemming from a July 23, 2024 licensing letter from the prior patent owner, which Amazon allegedly ignored (Compl. ¶24, 67, 87, 112). For the '706 Patent, which issued after this letter, willfulness is alleged based on knowledge as of the filing of the complaint (Compl. ¶42). Plaintiff further alleges that Amazon maintains a policy of not reviewing patents of others, which it characterizes as willful blindness (Compl. ¶66, 88, 113).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of divided infringement: For the system and method claims, can the plaintiff demonstrate that Amazon directs or controls the actions of its customers to the extent required to hold Amazon liable for all steps of the claimed invention, particularly those steps performed by the end-user within their home?
- A key question of claim scope will be the construction of "first human voice data" and "second human voice data." The case may turn on whether these terms can be construed broadly to cover any two unrelated voice commands issued over time, as alleged by the plaintiff, or if they require a more specific, unitary command structure that the accused system does not facilitate.
- An evidentiary question of technical function will be presented by the '590 Patent: does the accused product's general-purpose power management IC perform the specific role of a "current sensor coupled to the AC connector" as defined by the claim, or is there a fundamental mismatch in its technical operation and placement that precludes a finding of infringement?