DCT
2:25-cv-00991
Iridescence LLC v. Amazon.com Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Iridescence LLC (New Mexico)
- Defendant: Amazon.com, Inc. (Delaware)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 2:25-cv-00991, E.D. Tex., 10/01/2025
- 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 allegedly committed acts of patent infringement there.
- Core Dispute: Plaintiff alleges that unspecified products from Defendant infringe a patent related to a power control system for home automation networks.
- Technical Context: The technology concerns smart power controllers that can be remotely managed over the Internet to control and monitor home appliances, bridging different types of local networks (e.g., Wi-Fi, ZIGBEE®).
- Key Procedural History: The complaint does not reference any prior litigation, licensing history, or other procedural events involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2011-10-04 | ’560 Patent Priority Date |
| 2014-03-04 | ’560 Patent Issue Date |
| 2025-10-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,666,560 - "Power control system and method"
The Invention Explained
- Problem Addressed: The patent describes a market need for a home automation device that can be easily integrated into existing home networks without intrusive setup, controlled both locally and remotely via the Internet, and capable of bridging disparate network protocols like Wi-Fi and ZIGBEE®. Prior art systems are described as often being proprietary, difficult to integrate, and lacking direct, consumer-centric remote access. (’560 Patent, col. 4:20-38).
- The Patented Solution: The invention is a "Smart Gateway Power Controller" (SGPC), a device that acts as an intelligent bridge between a power outlet and an appliance. (’560 Patent, col. 5:24-38). As illustrated in Figure 1, the SGPC contains a power switch (0111) and an energy meter (0112) controlled by a microcontroller (0113) with wireless network modules (0115, 0116). This allows the SGPC to not only switch power to a device based on local or remote commands but also to function as a "sub-gateway," creating its own separate automation network that communicates with the main home network, thereby isolating it from network changes and enhancing security. (’560 Patent, col. 11:48-61).
- Technical Importance: The claimed invention aims to provide a versatile, non-intrusive home automation controller that solves interoperability and remote access problems common in the prior art. (’560 Patent, col. 2:35-39).
Key Claims at a Glance
- The complaint does not identify any specific claims of the ’560 Patent asserted against Defendant. It refers to "the exemplary claims" and "Exemplary '560 Patent Claims" that are allegedly detailed in an incorporated Exhibit 2, which was not filed with the complaint. (Compl. ¶¶11, 16).
III. The Accused Instrumentality
Product Identification
- The complaint does not identify any specific accused products, methods, or services by name.
Functionality and Market Context
- The complaint refers generally to "Exemplary Defendant Products" that are identified in the unprovided Exhibit 2. (Compl. ¶11). The complaint does not provide sufficient detail for analysis of the functionality of any accused instrumentality.
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint incorporates by reference claim charts from an unprovided "Exhibit 2" and does not contain specific infringement allegations in the body of the complaint itself. (Compl. ¶¶16-17). The narrative infringement theory alleges that the "Exemplary Defendant Products practice the technology claimed by the '560 Patent" and "satisfy all elements of the Exemplary '560 Patent Claims." (Compl. ¶16). Without the identification of asserted claims or accused products, a detailed analysis of the infringement allegations is not possible.
Identified Points of Contention
- The lack of specificity in the complaint raises fundamental questions that will likely be the immediate points of contention.
- Scope Questions: What specific claims of the ’560 Patent are being asserted? The complaint’s failure to identify claims leaves the scope of the dispute undefined.
- Technical Questions: What specific products made, used, or sold by Defendant are accused of infringement? Without this information, it is impossible to assess whether there is a plausible technical overlap between Defendant's technology and the patent's claims.
V. Key Claim Terms for Construction
The complaint does not provide sufficient detail for analysis of key claim terms, as no specific asserted claims are identified. (Compl. ¶11).
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 '560 Patent." (Compl. ¶14). These materials are allegedly referenced in the unprovided Exhibit 2. (Compl. ¶14).
Willful Infringement
- The complaint does not use the term "willful." However, it alleges that service of the complaint provides Defendant with "Actual Knowledge of Infringement" and that Defendant's allegedly infringing activities have continued despite this knowledge, which may form a basis for seeking enhanced damages for post-filing infringement. (Compl. ¶¶13-14).
VII. Analyst’s Conclusion: Key Questions for the Case
The complaint as filed is exceptionally sparse, deferring all substantive allegations to an external exhibit that was not provided. Consequently, the initial phase of this case will likely revolve around establishing the basic contours of the dispute. The key questions are:
- A question of identification: Which of Defendant’s products or services are accused of infringement, and which specific claims of the ’560 Patent are asserted against them? The resolution of this foundational question is a prerequisite for any substantive analysis.
- A question of factual basis: What specific features of the yet-to-be-identified accused products allegedly correspond to the elements of the yet-to-be-identified patent claims? The complaint's conclusory allegations will require factual support to proceed.
- A question of inducement: What specific instructions in Defendant's "product literature and website materials" are alleged to direct users to infringe the ’560 Patent, and how do those instructions map to the steps of any asserted method claims?