DCT
2:25-cv-00763
Secure Communication Tech LLC v. Apple Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Secure Communication Technologies, LLC (Texas)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Nelson Bumgardner Conroy P.C.
- Case Identification: 2:25-cv-00763, E.D. Tex., 08/04/2025
- 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, including physical "Apple Shops" within partner retail stores like Best Buy, and has committed acts of infringement in the district by selling the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and laptops, through features like AirDrop and Find My, infringe three patents related to methods for discovering and communicating between nearby wireless devices.
- Technical Context: The technology concerns hybrid communication systems that use short-range wireless protocols (like Bluetooth) for device discovery and long-range cellular networks to broker secure, server-managed interactions.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patent family because it disclosed a related family member (U.S. Patent No. 8,385,913) during the prosecution of its own U.S. Patent No. 9,853,719, which is also cited in the complaint as describing the accused AirDrop functionality.
Case Timeline
| Date | Event |
|---|---|
| 2008-09-08 | Priority Date for ’918, ’344, and ’971 Patents |
| 2022-05-17 | U.S. Patent No. 11,334,918 ('918 Patent) Issued |
| 2022-09-13 | U.S. Patent No. 11,443,344 ('344 Patent) Issued |
| 2023-06-27 | U.S. Patent No. 11,687,971 ('971 Patent) Issued |
| 2025-08-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,334,918 - “Exchanging identifiers between wireless communication to determine further information to be exchanged or further services to be provided”
- Patent Identification: U.S. Patent No. 11334918, “Exchanging identifiers between wireless communication to determine further information to be exchanged or further services to be provided,” issued May 17, 2022 (’918 Patent).
The Invention Explained
- Problem Addressed: The patent describes the challenge of enabling secure, anonymous, and convenient electronic transactions and interactions between mobile devices in close proximity, particularly indoors where GPS is unreliable and without requiring specialized hardware like RFID chips (’918 Patent, col. 2:6-24). Existing peer-to-peer approaches allegedly suffered from security flaws and an inability to maintain communication once devices were no longer in proximity (’918 Patent, col. 2:46-62).
- The Patented Solution: The invention proposes a hybrid system where a device uses a short-range radio (e.g., Bluetooth) to detect a simple identifier from a nearby device. Instead of communicating directly, the detecting device then uses a long-range radio (e.g., cellular) to contact a central server. This server brokers the information exchange, applying security policies and using stored account information to facilitate the interaction, which can continue even after the devices are no longer in physical proximity (’918 Patent, Abstract; col. 3:5-24).
- Technical Importance: This server-brokered architecture allows for proximity-based services with enhanced security and privacy, as the server can manage dynamically changing identifiers and control information disclosure based on pre-set policies (’918 Patent, col. 4:3-23).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a device) and 9 (a method) (Compl. ¶48).
- The essential elements of independent claim 1 include:
- A mobile wireless device with a first radio, a second radio, processors, and memory.
- Receiving, with the first radio, identifier-related information for a proximity beacon service from a server.
- Receiving, with the second radio, short-range proximity beacon transmissions, each including a MAC address, a unique identifier, and a Proximity Beacon Service Identifier (PBSI).
- Determining if a transmission includes a MAC address and a PBSI that indicates it is associated with the proximity beacon service.
- If the conditions are met, determining if an entity associated with the service is in proximity by using the server-provided information and the unique identifier from the beacon.
- The complaint states it asserts "one or more claims... including, for example, claims 1 and 9," reserving the right to assert others (Compl. ¶48).
U.S. Patent No. 11,443,344 - “Efficient and secure communication using wireless service identifiers”
- Patent Identification: U.S. Patent No. 11443344, “Efficient and secure communication using wireless service identifiers,” issued September 13, 2022 (’344 Patent).
The Invention Explained
- Problem Addressed: The patent addresses the same technical problem as the ’918 Patent: enabling efficient and secure communication between proximate wireless devices without the limitations of pure peer-to-peer systems (’344 Patent, col. 1:52-2:51).
- The Patented Solution: The invention claims a method where a wireless device receives short-range beacon transmissions, with each beacon comprising three specific fields: a MAC address, a unique identifier that does not reveal location, and a beacon service identifier. The device then filters the received beacons based on the service identifier. It subsequently uses a second, different wireless protocol (e.g., cellular) to receive stored information from a server related to the filtered unique identifiers and takes further action based on that stored information (’344 Patent, Abstract; col. 2:52-3:33).
- Technical Importance: This approach specifies a structured beacon format and a filtering mechanism, enabling a device to efficiently ignore irrelevant ambient wireless traffic and engage a secure back-end server only for services of interest.
Key Claims at a Glance
- The complaint asserts independent claims 1 (a method), 29 (a device), and 30 (a computer program product) (Compl. ¶78).
- The essential elements of independent claim 1 include:
- Receiving, via a short-range protocol, beacon transmissions comprising a MAC address, a unique identifier, and a beacon service identifier.
- Receiving, via a second, different protocol, stored information from a server related to a first unique identifier.
- Selecting one or more unique identifiers by filtering the beacon transmissions for a particular beacon service identifier.
- Taking a first further action related to the stored information if the first unique identifier is present among the selected identifiers.
- The complaint asserts claims 1, 29, and 30 (Compl. ¶78).
U.S. Patent No. 11,687,971 - “Efficient and secure communication using wireless service identifiers”
- Patent Identification: U.S. Patent No. 11687971, “Efficient and secure communication using wireless service identifiers,” issued June 27, 2023 (’971 Patent).
- Technology Synopsis: Belonging to the same patent family, this invention covers a method where a wireless device receives short-range beacons containing a MAC address, a unique identifier, and a beacon service identifier. The key aspect is that the beacon service identifier "identifies that the unique identifier is relevant to stored information associated with a wireless beacon service, wherein the stored information is not otherwise accessible" via the short-range protocol, thereby necessitating communication with a server using a different protocol (’971 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claims 1 (a method), 37 (a device), and 50 (a computer program product) (Compl. ¶102).
- Accused Features: The complaint alleges that Apple's AirDrop and Find My features, including Offline Finding and AirTags, infringe this patent (Compl. ¶105).
III. The Accused Instrumentality
Product Identification
- The complaint identifies a range of Apple-branded devices, including iPhones (14, 15, and 16 series), iPads (Pro, Air, mini), and MacBooks (Air, Pro), collectively termed the "Accused Products" (Compl. ¶42).
Functionality and Market Context
- The infringement allegations center on the "AirDrop" and "Find My" functionalities, which include "Offline Finding" and "AirTags" (Compl. ¶43).
- AirDrop: This feature is alleged to use Bluetooth Low Energy (BLE) to broadcast and detect nearby devices. For authentication, it uses iCloud services to create an "AirDrop short identity hash" based on a user's Apple Account information, which is then transmitted in a BLE signal. Once a user is identified and selected, a peer-to-peer Wi-Fi connection is used for file transfer (Compl. ¶59; Compl. p. 26).
- Find My / Offline Finding: This functionality creates a crowdsourced location network. A lost Apple device broadcasts encrypted, rotating BLE signals. Nearby Apple devices in the network can detect these signals, record the location, and securely upload it to Apple's servers. The owner of the lost device can then access this location information via the Find My application, which communicates with Apple's servers using a long-range protocol (e.g., Wi-Fi or cellular) (Compl. ¶60, ¶86; Compl. pp. 32-35). A screenshot in the complaint depicts the Find My app displaying a map with a notification stating, "AirTag Detected Near You" (Compl. p. 22).
IV. Analysis of Infringement Allegations
’918 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, using the first radio, identifier related information associated with a proximity beacon service, from one or more servers | The accused devices receive information from Apple’s servers (e.g., iCloud) via Wi-Fi or cellular radio; for AirDrop, this is an identity hash, and for Find My, this includes beacon keys and location reports. | ¶55 | col. 3:15-24 |
| receiving, using the second radio, a plurality of short range transmissions, including a plurality of proximity beacon transmissions...each...including a respective MAC address, a respective unique identifier, and a Proximity Beacon Service Identifier (PBSI) | The accused devices receive BLE transmissions from other Apple devices. These transmissions are alleged to contain a MAC address, a unique identifier (e.g., an AirDrop identity hash or a Find My public key), and a service identifier indicating the specific Apple service. | ¶58 | col. 3:5-14 |
| determining if a particular short range transmission... a) includes a MAC address, and b) includes the proximity beacon service identifier (PBSI) and if c) the PBSI indicates the particular short range transmission is a proximity beacon transmission... | The accused devices' operating systems allegedly parse incoming BLE packets to determine if they are associated with a specific service like AirDrop or Find My, based on a service identifier within the packet payload. | ¶61 | col. 5:29-45 |
| then: determining if an entity or object associated with the proximity beacon service is in proximity to the mobile wireless device, by utilizing the identifier related information and the unique identifier | Upon identifying a relevant beacon, AirDrop displays the nearby user for selection, and Find My displays the location of the lost item on a map, thereby determining the proximity of the entity or object. A visual in the complaint shows the Find My interface alerting a user that an "AirTag [is] Detected Near You" (Compl. p. 22). | ¶66 | col. 7:5-15 |
- Identified Points of Contention:
- Scope Questions: A potential issue is whether the claimed "Proximity Beacon Service Identifier (PBSI)" reads on the data structures used by Apple. The complaint alleges that a service code within an "Apple Manufacturer Specific Data" field of a BLE advertisement constitutes a PBSI (Compl. pp. 28, 30). The defense may argue that a PBSI must be a distinct, standardized field rather than a proprietary value within a general-purpose data field.
- Technical Questions: The complaint alleges a specific, multi-step process of receiving server information first, then detecting a beacon, then determining proximity. A factual question will be whether the accused AirDrop and Find My systems perform these steps in the claimed sequence and manner, or if their operational logic differs in a material way.
’344 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving, at a wireless device, via a short range wireless protocol, a first plurality of beacon transmissions, each beacon transmission comprising three fields (a) a MAC address, (b) a unique identifier... and (c) a beacon service identifier | The accused devices receive BLE advertisements for AirDrop and Find My, which are alleged to be structured with a MAC address, a unique identifier (e.g., identity hash or public key), and a beacon service identifier that distinguishes the service. | ¶81 | col. 2:52-64 |
| receiving, at the wireless device via a second wireless protocol, stored information from one or more servers, the stored information relating to a particular entity or object associated with a first unique identifier... | The accused devices use a second protocol (Wi-Fi/cellular) to communicate with Apple servers to authenticate users for AirDrop or to download location reports and beacon keys for the Find My network. | ¶84 | col. 3:1-7 |
| causing selection of one or more of the unique identifiers...by filtering the beacon transmissions which include a particular beacon service identifier... | The operating system on the accused devices allegedly filters incoming BLE traffic, selecting only those beacons that contain a service identifier for AirDrop or Find My to act upon. The complaint presents a figure from another patent, annotated to show the "SVC ID" field used for this filtering (Compl. p. 83). | ¶87 | col. 3:8-15 |
| taking first further action relating to the stored information, if the first unique identifier is present among the selected one or more unique identifiers | Upon matching a filtered identifier, the device takes further action: for AirDrop, it displays the contact for file transfer; for Find My, it reports the location of a lost device or displays it on a map for the owner. | ¶90 | col. 3:16-20 |
- Identified Points of Contention:
- Scope Questions: A central dispute may be whether the data in Apple's BLE advertisements constitutes the specifically claimed "three fields." The defense may argue that the information is not organized into these distinct fields or that what the plaintiff calls a "beacon service identifier" is merely part of a larger, undifferentiated data payload.
- Technical Questions: The claim requires "taking first further action relating to the stored information." A factual question is what constitutes the "stored information" for each accused feature and whether the subsequent action is directly related to it as claimed, or if the action is triggered by other logic.
V. Key Claim Terms for Construction
The Term: "beacon service identifier"
Context and Importance: This term is critical because infringement hinges on whether Apple's devices filter BLE transmissions based on such an identifier. The plaintiff's theory requires this term to encompass a specific code within a general "manufacturer specific data" field in a BLE packet. Practitioners may focus on this term because its construction will determine if Apple's proprietary data structure falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a system where identifiers can correspond to various distinct services, such as social networking, e-commerce, or chat, suggesting the term is meant to be a functional descriptor for any data that distinguishes one service from another (’918 Patent, col. 3:42-52).
- Evidence for a Narrower Interpretation: Figures in a patent cited by the complaint itself (U.S. Patent No. 9,853,719) depict a "MFG ID" field and a separate "SVC ID" field (Compl. p. 83). A defendant may argue this shows that a "service identifier" is understood in the art to be distinct from a general manufacturer identifier, potentially narrowing the term to exclude Apple's implementation if its service code is not in a dedicated field.
The Term: "unique identifier"
Context and Importance: The claims require this identifier to be received in a short-range beacon and be distinct from a MAC address. Plaintiff alleges Apple's rotating public keys (Find My) and short identity hashes (AirDrop) meet this limitation. The construction will determine if these dynamic, cryptographic, or hashed values qualify as "identifiers" in the context of the patents.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests that for privacy and security, identifiers may be changed over time and coordinated by a central server (’918 Patent, col. 4:39-49). This supports interpreting the term to include dynamic values like rotating keys.
- Evidence for a Narrower Interpretation: The specification also provides examples of identifiers such as a "device name" or a "MAC address" (’918 Patent, col. 9:32-37). A defendant may argue that the term should be construed as a more persistent, human- or device-readable label, rather than a temporary cryptographic value that has no meaning outside its specific security function.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Apple induces infringement by providing extensive customer support materials, including user guides on its website, instructional videos on YouTube, and in-store support, that all instruct and encourage users to use the accused AirDrop and Find My features in an infringing manner (Compl. ¶71, ¶95, ¶119).
- Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. Post-suit knowledge is based on the filing of the complaint (Compl. ¶69). The allegation of pre-suit knowledge is based on the assertion that Apple disclosed a patent from the asserted patents' family (U.S. Patent No. 8,385,913) to the USPTO during its own prosecution of a patent related to AirDrop (U.S. Patent No. 9,853,719) (Compl. ¶69, ¶93, ¶117).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "beacon service identifier" be construed to cover a proprietary service code embedded within a general-purpose "manufacturer data" field in a BLE packet, as alleged by the plaintiff? The outcome of this claim construction battle may be determinative.
- A key evidentiary question will be one of technical mapping: does discovery into Apple's proprietary systems confirm the functional breakdown alleged in the complaint, which relies on third-party technical papers and analysis of other patents? The case will likely turn on whether the actual operation of AirDrop and Find My aligns with the specific, multi-step filtering and action sequences recited in the asserted claims.
- A central question for willfulness and damages will be pre-suit knowledge: did Apple's citation of a parent patent during the prosecution of its own related technology give it knowledge of the inventions claimed in the patents-in-suit, and did it subsequently engage in egregious conduct despite this knowledge?