xMatrix LLC v. Reolink Digital Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: xMatrix LLC (New Mexico)
  • Defendant: Reolink Digital Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-870, E.D. Tex., 08/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district, causing harm.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to a multi-services application gateway for managing digital devices and services within a user's premises.
• Technical Context: The technology addresses the management of increasingly complex "digital home" environments by centralizing control, communication, and service delivery in a single gateway appliance.
• Key Procedural History: The patent-in-suit is a continuation of a lengthy chain of prior applications and is subject to a terminal disclaimer. The complaint does not reference any prior litigation or administrative proceedings involving the patent.

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"

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

The Invention Explained

• Problem Addressed: The patent’s background section describes the growing complexity of the "digital home," which contains a myriad of interconnected digital devices for communication, entertainment, and security. It notes that managing these devices can be a "daunting and intimidating task" for technologically challenged users, and that existing solutions are often "siloed" and not integrated with other aspects of a user's life. (’366 Patent, col. 1:31-67).
• The Patented Solution: The invention proposes an "intelligent gateway device" located at a user's premise (e.g., home or business) to serve as a central point for managing application services for various digital endpoint devices. This gateway includes a "services framework" and a communications infrastructure that enables service management, configuration, and user authentication, thereby providing a "network-based services point of presence" within the premises. (’366 Patent, Abstract; Fig. 1A).
• Technical Importance: This technical approach aims to simplify the user experience by centralizing the management of disparate digital devices and services, moving intelligence and control functions that are often network-based directly into an appliance at the user's location. (’366 Patent, col. 6:3-10).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims of the '366 Patent" but does not identify any specific claims asserted. It refers to "Exemplary '366 Patent Claims" that are allegedly detailed in an Exhibit 2, which was not attached to the publicly filed complaint. (Compl. ¶11, 16).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in charts within an unattached Exhibit 2. (Compl. ¶11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '366 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided. The narrative infringement theory is limited to the assertion that the "Exemplary Defendant Products" satisfy all elements of the "Exemplary '366 Patent Claims." (Compl. ¶16). Without the asserted claims or any description of the accused products' operation, a substantive analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not identify specific asserted claims or provide any basis for an analysis of claim construction.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced 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 '366 Patent." (Compl. ¶14). The complaint also alleges that Defendant sells its products to customers for use in a manner that infringes. (Compl. ¶15). These allegations incorporate by reference the unprovided Exhibit 2. (Compl. ¶14).
• Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that the service of the complaint constitutes "Actual Knowledge of Infringement" and that Defendant continues its allegedly infringing activities "[d]espite such actual knowledge," which may form the basis for a future claim of post-suit willfulness. (Compl. ¶13-14).

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

• A threshold issue will be one of pleading sufficiency: does the complaint, which relies entirely on an unattached exhibit to identify the accused products and asserted claims, provide sufficient factual detail to state a plausible claim for relief under the Twombly/Iqbal standard as it applies to patent infringement?
• A central technical question will be one of architectural mapping: once the specific products and claims are known, the dispute will likely focus on whether the architecture of Defendant’s system—which may be distributed across cloud services and end-user devices—constitutes the localized, premises-based "intelligent gateway device" with an integrated "services framework" as described and claimed in the ’366 Patent.