xMatrix LLC v. Koninklijke Philips NV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: xMatrix LLC (New Mexico)
  • Defendant: Koninklijke Philips N.V. (Netherlands)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00867, E.D. Tex., 08/25/2025
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a multi-services application gateway for managing digital devices in a home or business.
• Technical Context: The technology relates to intelligent gateway devices designed to unify and manage the increasingly complex ecosystem of connected digital devices and services in a "digital home."
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 12,300,366 (“Multi-services application gateway and system employing the same”), issued May 13, 2025 (the “’366 Patent”).

U.S. Patent No. 12,300,366 - "Multi-services application gateway and system employing the same"

The Invention Explained

• Problem Addressed: The patent’s background section describes the growing complexity of the "digital home," which contains a "myriad of new and emerging digital devices." It notes that for technologically challenged users, managing these interconnected devices can be a "daunting and intimidating task" (’366 Patent, col. 1:26-38). The patent also identifies a lack of "meaningful direction and 'coaching'" and states that existing solutions are often "'siloed', not integrated, with other aspects of the user's life" (’366 Patent, col. 1:50-61).
• The Patented Solution: The invention is an "intelligent gateway device" intended to serve as a central hub for managing services and devices within a home or business (’366 Patent, Abstract). The gateway provides a "services framework" that can execute "service logic modules" to manage and support various "digital endpoint devices" (’366 Patent, Abstract). The patent summary highlights the inclusion of a "causation and correlation engine" designed to "enable broader services for users," suggesting a system that can learn from user behavior to provide more relevant services (’366 Patent, col. 2:8-12). The system is depicted with a layered software architecture to manage hardware, system services, and applications (’366 Patent, Fig. 2A; col. 10:40-50).
• Technical Importance: The technology aims to provide a unified platform to simplify the setup, management, and interoperability of the diverse and often incompatible devices and services that constitute a modern connected home or business (’366 Patent, col. 6:5-11).

Key Claims at a Glance

• The complaint does not identify any specific asserted claims, instead incorporating by reference an unprovided exhibit containing claim charts (Compl. ¶16). The provided copy of the ’366 Patent also does not include the patent’s claims. Therefore, an analysis of specific claim elements is not possible based on the provided documents.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to "Exemplary Defendant Products" that are identified in charts incorporated by reference into the complaint (Compl. ¶11, ¶16). These charts, contained in Exhibit 2, were not provided.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, as this information is contained within the unprovided Exhibit 2 (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint's infringement allegations are presented entirely within an external claim chart exhibit, which was not provided (Compl. ¶16-17). The complaint itself offers no narrative description of the accused product's functionality or how it allegedly meets the limitations of any specific patent claim. Consequently, an analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

As the complaint does not identify any asserted claims and the patent’s claims were not provided, an analysis of key terms for construction cannot be performed.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating on information and belief that the defendant distributes "product literature and website materials" that instruct end users to use the accused products in an infringing manner (Compl. ¶14). The basis for knowledge is alleged to arise at least upon service of the complaint (Compl. ¶15).
• Willful Infringement: The complaint alleges that service of the complaint and its attached claim charts constitutes actual knowledge of infringement (Compl. ¶13). It further alleges that any continued infringing activity by the defendant after this point is willful (Compl. ¶14).

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

Due to the limited information provided in the complaint, the initial phase of this case will likely focus on fundamental pleading and discovery issues before reaching substantive technical disputes.

• A threshold issue may be one of pleading sufficiency: does a complaint that identifies neither the accused products by name nor the asserted claims in its body, relying entirely on incorporated exhibits, meet the plausibility pleading standards established by federal court precedent?
• A primary question for discovery will be one of product identification: which specific Philips products, systems, or services are being accused of infringement, and what is their precise technical architecture and functionality?
• Assuming the case proceeds, a central technical question will likely be one of architectural correspondence: to what extent do the accused Philips products, once identified, practice the specific "services framework" and "causation and correlation engine" architecture described in the ’366 Patent, as opposed to representing a distinct, non-infringing approach to device and service management?