Survmatic LLC v. Hinovision Solutions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SurvMatic LLC (New Mexico)
  • Defendant: Hinovision Solutions, LLC (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00725, E.D. Tex., 07/17/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified surveillance products infringe a patent related to systems for remotely monitoring video cameras over a wireless network.
• Technical Context: The technology concerns remote video surveillance systems that leverage high-bandwidth cellular networks to allow users to view live and recorded video from cameras on a mobile device.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,688,203 - "Surveillance device by use of digital cameras linked to a cellular or wireless telephone"

• Patent Identification: U.S. Patent No. 7,688,203, "Surveillance device by use of digital cameras linked to a cellular or wireless telephone," issued March 30, 2010.

The Invention Explained

• Problem Addressed: The patent describes a need for improved remote surveillance capabilities, noting that prior art systems were often limited to sending compressed or stepped video frames over lower-bandwidth 2G and 3G networks and were typically inactive until a specific event, like an alarm, occurred (U.S. Patent No. 7,688,203, col. 1:58-68, col. 2:1-5).
• The Patented Solution: The invention is a surveillance system that uses one or more digital cameras to continuously record video to a "recirculating non volatile storage memory," which overwrites the oldest data once full. Upon a triggering event, such as an alarm or a remote user command over a 4G network, the system can transmit streaming video to a user's mobile terminal. Crucially, the system is designed to preserve and transmit video from the period immediately prior to the trigger, allowing a user to see the events leading up to it (’203 Patent, col. 3:22-28, col. 4:51-56; Fig. 1).
• Technical Importance: The system’s design leverages emerging "4G network technology" to provide sufficient bandwidth for streaming video, a capability the patent asserts was not practical on older cellular networks (’203 Patent, col. 2:25-30).

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring only to "Exemplary '203 Patent Claims" (Compl. ¶11). The patent contains two independent claims, Claim 1 and Claim 6.

• Independent Claim 1: A portable surveillance device comprising:
  • a controller, alarm sensors, and digital video cameras
  • a "recirculating non volatile storage memory"
  • a "non volatile event memory"
  • a "4G (802.16) wireless network subscriber interface" and a remote 4G terminal
  • wherein video from prior to an alarm trigger is transferred from the recirculating memory to the event memory to "show the sequence of events prior to and following the triggering of the alarm"
• Independent Claim 6: A portable surveillance device comprising similar hardware elements, but wherein:
  • the triggering of an alarm causes the controller to send a text message to a remote user
  • the remote user responds by initiating a call to the device to view video
• The complaint does not explicitly reserve the right to assert dependent claims, but its general language suggests this possibility (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It makes only conclusory allegations that the products "practice the technology claimed by the '203 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint states that "Exhibit 2 includes charts comparing the Exemplary '203 Patent Claims to the Exemplary Defendant Products" (Compl. ¶16). However, Exhibit 2 was not filed with the complaint. The infringement theory, as described in the body of the complaint, alleges that Defendant's products incorporate all elements of the asserted claims. For example, the complaint alleges that Defendant makes, uses, and sells products that "satisfy all elements of the Exemplary '203 Patent Claims" (Compl. ¶11, 16). The allegations cover both direct and indirect infringement.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The claims explicitly recite "a 4G (802.16) wireless network." This raises a critical question of scope: can this term, which refers to a specific standard (WiMAX) prominent during the patent’s prosecution, be construed to cover modern wireless technologies such as LTE and 5G that may be used in Defendant's products?
  • Technical Questions: A key technical question will be whether the accused products implement the specific memory architecture of Claim 1. The claim requires both a "recirculating non volatile storage memory" and a separate "non volatile event memory," with a specific function of transferring pre-trigger video between them. The infringement analysis will depend on evidence of whether the accused products perform this specific two-part memory operation or utilize a different method for preserving pre-event footage.

V. Key Claim Terms for Construction

• The Term: "a 4G (802.16) wireless network subscriber interface" (from Claims 1 and 6).

• Context and Importance: This term appears central to the scope of both independent claims. The patent was filed when "4G" was an emerging concept and "802.16" (the standard for WiMAX) was a leading candidate technology. Practitioners may focus on this term because its definition could determine whether the patent reads on products using current-generation wireless standards like LTE and 5G, which are distinct from the 802.16 standard.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that the parenthetical "(802.16)" is merely an example of the broader term "4G," and that the patent's focus on high-bandwidth streaming video captures the essence of the invention, regardless of the specific protocol used (’203 Patent, col. 2:25-30).
  • Evidence for a Narrower Interpretation: The specification repeatedly and specifically references the IEEE 802.16 standard as the foundation for the "new interconnected fixed and mobile network" that enables the invention (’203 Patent, col. 3:4-7). This repeated, specific linkage could support an interpretation that limits the claims to devices using the 802.16 protocol.

• The Term: "recirculating non volatile storage memory" (from Claims 1 and 6).

• Context and Importance: This term, in conjunction with the "non volatile event memory" in Claim 1, defines the core pre-event recording functionality. The dispute may turn on whether the accused products use this specific two-memory architecture or a functionally different single-memory system.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes this memory as capturing video for an extended period and "overwriting the old data" when full (’203 Patent, col. 3:25-28). This could be argued to broadly cover any system implementing a continuous loop recording buffer.
  • Evidence for a Narrower Interpretation: Claim 1 requires the "transfer of video from the recirculating memory to the event memory" (’203 Patent, col. 4:51-53). This language suggests a distinct operational step between two separate memories (or logically separate partitions), potentially narrowing the term to exclude systems that simply flag a portion of a single buffer for preservation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the ’203 Patent (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful infringement." However, it alleges that service of the complaint provides Defendant with "actual knowledge" of infringement and that Defendant's continued infringing activities are therefore knowing and intentional (Compl. ¶13-15). Plaintiff also requests that the case be declared "exceptional" under 35 U.S.C. § 285, which can be a predicate for enhanced damages and attorney's fees (Compl. ¶E.i.).

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

1. A core issue will be one of technological scope: can the claim term "4G (802.16)", which specifies a technical standard from the 2007-2010 era, be construed broadly enough to cover the distinct and more modern wireless protocols (e.g., LTE, 5G) likely used in contemporary surveillance products?
2. A key evidentiary question will be one of architectural equivalence: does the accused product's memory system perform the specific two-part function of transferring pre-trigger video from a "recirculating" memory to a separate "event" memory as required by Claim 1, or does it achieve a similar result through a technically distinct architecture?
3. An initial procedural question will be one of pleading sufficiency: given that the complaint fails to identify any specific accused products and relies on an unattached exhibit for its infringement contentions, a court may have to determine if the allegations meet the plausibility standard required to proceed to discovery.