Iridescence LLC v. Shelly Group Se

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Iridescence LLC (New Mexico)
  • Defendant: Shelly Group SE (Bulgaria)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00992, E.D. Tex., 10/01/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to systems and methods for remotely controlling power to electrical devices via a network.
• Technical Context: The technology at issue involves smart home automation, specifically devices that act as gateways to control and monitor power consumption for appliances over local networks and the Internet.
• 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

U.S. Patent No. 8,666,560 - "Power control system and method"

The Invention Explained

• Problem Addressed: The patent describes a market demand for a "wirelessly and remotely controlled AC power switch" that can also measure energy consumption (’560 Patent, col. 1:41-46). It notes that prior art systems were often "intrusive" to existing home networks, required proprietary controllers, and did not easily integrate with the Internet for remote access from devices like smartphones (’560 Patent, col. 3:5-18, col. 1:65-col. 2:4).
• The Patented Solution: The invention is a "Smart Gateway Power Controller" (SGPC), a device that plugs into a standard power outlet and acts as a bridge between an electrical appliance and the power source (’560 Patent, col. 5:25-30). The SGPC contains a power switch, an energy meter, and a microcontroller with wireless (e.g., WiFi) capabilities (’560 Patent, Fig. 1). This allows it to function as a "sub-gateway," creating a separate, secondary network for home automation devices that communicates with the main home network, enabling both local and remote control via the Internet without requiring changes to the user's primary home router (’560 Patent, col. 11:48-54).
• Technical Importance: The described approach aims to provide a non-intrusive method for adding smart control capabilities to an existing home network, allowing for both direct local communication and remote Internet-based access to control and monitor home appliances (’560 Patent, col. 4:46-52).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and "Exemplary '’560 Patent Claims" without specifying them (Compl. ¶11, ¶16). Independent claim 1 is representative:
• A Smart Gateway Power Control (SGPC) system comprising:
  • (a) power source plug;
  • (b) power load receptacle;
  • (c) power switch;
  • (d) power monitor;
  • (e) computing device; and
  • (f) wireless communication interface;
  • wherein said computing device is configured to send a periodic message from said SGPC to a proxy server containing the ID, password, router IP ADR, port, and subnet vector or path of said SGPC;
  • ...and wherein said communication device is configured to request a SGPC ID translation by said proxy server from said user interface.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" but does not name any specific products, instead incorporating them by reference to an attached Exhibit 2 (Compl. ¶11). This exhibit was not included with the publicly filed complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality of the accused products. It alleges in general terms that the products are made, used, sold, and imported by Defendant and that they "practice the technology claimed by the '’560 Patent" (Compl. ¶11, ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's products infringe "at least the exemplary claims of the '’560 Patent" (Compl. ¶11). It incorporates by reference "charts comparing the Exemplary '’560 Patent Claims to the Exemplary Defendant Products" in an Exhibit 2, stating these charts demonstrate that the products "satisfy all elements" of the asserted claims (Compl. ¶16). However, this Exhibit 2 was not provided with the complaint, precluding a detailed, element-by-element analysis of the infringement allegations.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific claim terms that may be in dispute. However, based on the technology described in the '’560 Patent, the following terms may become central to the case.

Term: "Smart Gateway Power Controller (SGPC)"

• Context and Importance: This term, introduced by the patentee, defines the core inventive device. The scope of infringement will depend on whether the accused products can be characterized as an "SGPC" as that term is defined and used throughout the patent. Practitioners may focus on whether this term requires the device to perform both as a network client (station) and a network access point simultaneously, a key feature described in the specification (’560 Patent, col. 11:48-54, col. 18:28-35).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the SGPC "acts as a bridge between a power source... and power load" and contains a switch, meter, and microcontroller (’560 Patent, col. 5:26-34). This functional description could be argued to cover a wide range of smart plug devices.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the SGPC's dual role as a "sub-gateway that 'separates' the home automation network from the existing home network" (’560 Patent, col. 11:59-62). This suggests the term may be limited to devices that create their own distinct subnet, rather than simply joining an existing WiFi network as a client.

Term: "proxy server"

• Context and Importance: Independent claim 1 requires the SGPC to send periodic messages to, and receive translations from, a "proxy server" to enable remote access (’560 Patent, col. 29:51-62). The infringement analysis for this claim will depend on whether the accused system's architecture for remote communication uses a component that meets the definition of a "proxy server" as understood in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the proxy server functionally as "a server on the Internet that keeps track of the IP address and port number of a SGPC at home" (’560 Patent, col. 12:49-51). This could be interpreted to cover any cloud-based service that facilitates a connection between a remote user and a local smart device.
  • Evidence for a Narrower Interpretation: The detailed description of the "Proxy Server Mode (Pull Mode)" outlines a specific method where the SGPC periodically sends messages to the server, which then populates an "ID/IP translation database" (’560 Patent, col. 13:7-25, Fig. 17). An accused system that uses a different architecture for establishing remote connections (e.g., a persistent connection or a different "push" model) may be argued to fall outside this definition.

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 the products in an infringing manner (Compl. ¶14).
• Willful Infringement: Willfulness is not explicitly pleaded. However, the complaint alleges that service of the complaint and its attached (but missing) claim charts provides Defendant with "Actual Knowledge of Infringement," which could form the basis for a future claim of post-filing willful infringement (Compl. ¶13-¶14).

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

1. Architectural Equivalence: A central technical question will be whether the architecture of the accused products matches the specific "sub-gateway" and "proxy server" models claimed in the patent. The case may turn on whether the accused devices simply act as clients on a home WiFi network communicating with a generic cloud service, or if they implement the claimed two-network system that communicates with a specialized proxy server for remote access.
2. Evidentiary Basis: With the claim charts missing from the initial pleading, a primary question is what specific features of the accused products are alleged to meet each claim limitation. The initial stages of the case will likely focus on compelling Plaintiff to produce these charts and provide a more detailed factual basis for its infringement contentions.