xMatrix LLC v. Nice Polska SP Z Oo

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: xMatrix LLC (New Mexico)
  • Defendant: Nice Polska Sp. z o.o. (Poland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00869, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a multi-services application gateway designed to manage various digital devices and services within a home or business.
• Technical Context: The technology addresses the management of increasingly complex home networks by centralizing control over disparate digital devices and services into a single gateway appliance.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term. The complaint does not specify any other relevant procedural history.

Case Timeline

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

U.S. Patent No. 12,300,366 - "Multi-services application gateway and system employing the same" (Issued May 13, 2025)

The Invention Explained

• Problem Addressed: The patent's background section describes the growing complexity of the "emerging digital home," which presents a "daunting and intimidating task" for technologically challenged users attempting to manage interconnected digital devices and home networks ( Compl. Ex. 1, ’366 Patent, col. 1:31-43). Existing solutions are described as "siloed" and not integrated with other aspects of a user's life ( Compl. Ex. 1, ’366 Patent, col. 1:62-64).
• The Patented Solution: The invention is an "intelligent gateway device" intended to be the central point of control for a home or business network ( Compl. Ex. 1, ’366 Patent, Abstract). As depicted in Figure 1A, the gateway (10) serves as an intermediary between a local IP network of "digital endpoint devices" (e.g., 30a, 32, 40) and an external "Networked Services Support Infrastructure" (50). The gateway contains a "services framework" that provides a storage and execution environment for service logic modules that manage, configure, and authenticate services for the connected endpoint devices ( Compl. Ex. 1, ’366 Patent, Abstract; Fig. 1A).
• Technical Importance: The technology aims to simplify the management of home networks by centralizing service delivery and control in a single, remotely manageable appliance, thereby abstracting technical complexity away from the end-user ( Compl. Ex. 1, ’366 Patent, col. 6:5-10).

Key Claims at a Glance

• The complaint does not identify any specific claims asserted against the Defendant. It refers generally to "one or more claims of the '366 Patent" and "Exemplary '366 Patent Claims" that are purportedly identified in an incorporated but unattached exhibit (Compl. ¶11, ¶16). Consequently, a breakdown of asserted claim elements is not possible based on the provided documents.

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any accused products or services (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that "Exemplary Defendant Products" practice the technology claimed by the '366 Patent but provides no specific details about their functionality, features, or market position (Compl. ¶16). This information is referenced as being contained in an unattached exhibit (Compl. ¶16, ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products" infringe the "'366 Patent Claims" both literally and under the doctrine of equivalents (Compl. ¶11). It states that claim charts comparing the asserted claims to the accused products are included in an Exhibit 2 (Compl. ¶16). As this exhibit was not provided with the complaint, a detailed claim chart summary cannot be constructed. The narrative infringement theory is conclusory, alleging that the accused products "satisfy all elements of the Exemplary '366 Patent Claims" without providing specific factual support in the body of the complaint (Compl. ¶16).

• Identified Points of Contention: The complaint's lack of specificity regarding the asserted claims and the accused products precludes a substantive analysis of potential technical or legal points of contention.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of Key Claim Terms for Construction. As the complaint fails to identify any specific asserted claims, no analysis of claim terms can be performed.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use its products in a manner that infringes the '366 Patent (Compl. ¶14, ¶15).
• Willful Infringement: The complaint alleges that the Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and its attached (but not publicly filed) claim charts (Compl. ¶13). It further alleges that Defendant continues its infringing conduct despite this knowledge, which may form the basis for a claim of post-suit willful infringement (Compl. ¶14).

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

The analysis of this case is currently constrained by the foundational information absent from the complaint. The central questions are therefore procedural and foundational rather than technical.

• A threshold issue will be one of pleading sufficiency: does the complaint, which identifies neither specific asserted claims nor specific accused products in its text and relies on unattached exhibits, provide the Defendant with sufficient notice of the infringement allegations to satisfy federal pleading standards?
• A key focus of early case development will be one of infringement theory clarification: Plaintiff will need to specify which claims of the '366 Patent it is asserting and map those claim limitations to the particular functionalities of Defendant's products, details that are presently absent from the public record.