DCT

2:25-cv-01009

IoT Innovations LLC v. D Link Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01009, E.D. Tex., 10/03/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the district because Defendant is a foreign corporation not resident in any U.S. judicial district. The complaint also notes that Defendant has not challenged venue or personal jurisdiction in prior litigation in the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s extensive portfolio of networking and smart home products infringes ten patents related to various aspects of network communication, data classification, device synchronization, and signal modulation.
  • Technical Context: The lawsuit covers a broad range of fundamental networking technologies, from IP data packet classification to wireless signal modulation, which are critical to the operation of modern digital communication systems.
  • Key Procedural History: The complaint references two prior patent infringement lawsuits filed against D-Link in the Eastern District of Texas in 2024 and 2025, noting that Defendant did not challenge the court's exercise of personal jurisdiction or the propriety of venue in those proceedings.

Case Timeline

Date Event
2001-04-16 Priority Date for U.S. Patent No. 7,246,173 and 7,974,266
2001-06-21 Priority Date for U.S. Patent No. 7,274,761
2001-07-09 Priority Date for U.S. Patent No. 7,408,872
2001-11-13 Priority Date for U.S. Patent No. 7,209,876
2002-11-19 Priority Date for U.S. Patent No. 7,539,212
2004-10-13 Priority Date for U.S. Patent No. 7,394,798
2006-08-21 Priority Date for U.S. Patent No. 7,643,423
2007-01-09 Priority Date for U.S. Patent No. 7,593,428
2007-04-24 Issue Date for U.S. Patent No. 7,209,876
2007-07-17 Issue Date for U.S. Patent No. 7,246,173
2007-09-25 Issue Date for U.S. Patent No. 7,274,761
2008-07-01 Issue Date for U.S. Patent No. 7,394,798
2008-08-05 Issue Date for U.S. Patent No. 7,408,872
2009-05-26 Issue Date for U.S. Patent No. 7,539,212
2009-09-22 Issue Date for U.S. Patent No. 7,593,428
2010-01-05 Issue Date for U.S. Patent No. 7,643,423
2011-07-05 Issue Date for U.S. Patent No. 7,974,266 and 7,974,260
2025-10-03 Complaint Filing Date

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

U.S. Patent No. 7,246,173 - "Method and Apparatus for Classifying IP Data" (issued July 17, 2007)

The Invention Explained

  • Problem Addressed: In packet-switched networks, classifying data packets is necessary to provide differentiated services, such as Quality of Service (QoS). The patent addresses the need to classify data based on the specific path it is intended to travel, as defined by the data's source, rather than just its final destination. (’173 Patent, col. 1:45-53).
  • The Patented Solution: The invention describes a method and apparatus (e.g., a router) that receives an Internet Protocol (IP) data packet and classifies it based on "source routing information" contained within the packet's header. (’173 Patent, Abstract). This source routing information includes a list of intermediate network nodes the packet is supposed to visit on its way to the final destination, as specified in protocols like IPv4's Loose Source and Record Route (LSRR) option or IPv6's routing headers. (’173 Patent, col. 2:45-52). By classifying based on this path information, network nodes can apply specific rules, such as resource reservation for QoS, that are consistent with the path dictated by the source. (’173 Patent, col. 3:5-13).
  • Technical Importance: This technique allows for more granular network traffic management, enabling policies to be applied based on a packet's intended journey rather than just its endpoint, which is relevant for implementing end-to-end service guarantees in complex networks. (’173 Patent, col. 3:5-13).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (method), 13 (means-plus-function router), and 25 (apparatus router), as well as dependent claims 2, 14, and 26. (Compl. ¶25).
  • Independent Claim 1 recites a method comprising the essential elements of:
    • Receiving data at a first node, where the data includes a header comprising a list of at least one intermediate node to be visited.
    • Classifying the data at that first node based on an entry in that header.

U.S. Patent No. 7,974,266 - "Method and Apparatus for Classifying IP Data" (issued July 5, 2011)

The Invention Explained

  • Problem Addressed: This patent, which shares a specification with the ’173 Patent, also addresses the classification of IP data in networks that use source routing. The specific problem is ensuring consistent classification of a packet throughout its path based on its ultimate destination, even when the packet header lists multiple intermediate stops. (’266 Patent, col. 1:45-53).
  • The Patented Solution: The invention proposes a method where a network node classifies a received IP packet based on the "last destination address entry" in the list of addresses contained in the packet's header. (’266 Patent, Abstract; col. 2:60-67). After classification, the packet is forwarded to the next node in its path, where it is again classified based on that same last destination address, ensuring consistent treatment based on the packet's final endpoint throughout its source-routed journey. (’266 Patent, col. 3:1-4).
  • Technical Importance: This approach ensures that end-to-end network policies, such as QoS, are applied consistently to a data flow, as all nodes along a source-defined path classify the traffic based on the same ultimate destination. (’266 Patent, col. 4:1-12).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (method) and 16 (router), as well as dependent claims 2, 5, 17, and 20. (Compl. ¶38).
  • Independent Claim 1 recites a method comprising the essential elements of:
    • Receiving IP data at a first node.
    • Classifying the IP data based on a last destination address entry of a plurality of destination address entries in the data's header.
    • Forwarding the IP data to a second node, where the data is classified based on the same last destination address entry.

U.S. Patent No. 7,209,876 - "System and Method for Automated Answering of Natural Language Questions and Queries" (issued April 24, 2007)

  • Technology Synopsis: This patent describes a method for processing a natural language question by transforming it into a generic query form and then into an "expected answer form." (’876 Patent, Abstract). This syntactic template is then used to search an information repository and retrieve answer phrases that match the expected structure. (’876 Patent, col. 2:54-65).
  • Asserted Claims: The complaint asserts claims 13, 14, 15, and 16. (Compl. ¶49). Independent claim 13 is a method claim.
  • Accused Features: The complaint alleges that D-Link's websites, including its Shop and Support sites, infringe by performing a method for producing answers to user queries. (Compl. ¶¶ 43, 50).

U.S. Patent No. 7,274,761 - "Device Synchronization Over a Network" (issued September 25, 2007)

  • Technology Synopsis: The patent discloses a method for synchronizing the real-time clocks of separate devices over a network. A transmitting device reads its real-time clock at a specific instance of a common time reference and sends the clock value and an identifier for that instance to a receiving device, which can then determine its own current, synchronized real-time clock value. (’761 Patent, Abstract).
  • Asserted Claims: The complaint asserts claims 1, 3, and 5. (Compl. ¶59). Independent claim 1 is an apparatus claim.
  • Accused Features: The infringement allegations target D-Link's Connected Home Hubs, Gateways, Smart Home Security Kits, and related sensors and cameras. (Compl. ¶¶ 53, 60).

U.S. Patent No. 7,394,798 - "Push-to-Talk Over Ad-Hoc Networks" (issued July 1, 2008)

  • Technology Synopsis: This patent describes a network system for push-to-talk (PTT) communication over a temporary, ad-hoc network. The system comprises network nodes that can temporarily form groups and communicate directly via a radio connection without relying on a central controller for the PTT service itself. (’798 Patent, Abstract).
  • Asserted Claims: The complaint asserts claims 1, 5, 13, 16, 17, 19, and 27. (Compl. ¶69). Independent claims 1 (system) and 16 (method) are asserted.
  • Accused Features: The accused products include D-Link's Connected Home Hubs, Gateways, and various smart home sensors and cameras. (Compl. ¶¶ 63, 70-71).

U.S. Patent No. 7,408,872 - "Modulation of Signals for Transmission in Packets via an Air Interface" (issued August 5, 2008)

  • Technology Synopsis: The invention relates to a method for modulating signals for wireless packet transmission, allowing for different data rates within the same packet. It proposes using a more complex modulation scheme (with a first set of values) for one part of a packet (e.g., the payload) to achieve a higher data rate, while using a simpler scheme (with a second, smaller set of values) for another part (e.g., the header), ensuring backward compatibility. (’872 Patent, Abstract).
  • Asserted Claims: The complaint asserts claims 1, 3, 12, 21, and 22. (Compl. ¶87). Independent claims 1 (method), 12 (modulator), 21 (device), and 22 (system) are asserted.
  • Accused Features: The allegations target D-Link devices such as Wi-Fi PCIe adapters, Wi-Fi cameras, and smart routers. (Compl. ¶¶ 81, 88).

U.S. Patent No. 7,539,212 - "Method and Apparatus for MAC Layer Inverse Multiplexing in a Third Generation Radio Access Network" (issued May 26, 2009)

  • Technology Synopsis: The patent describes a method for handling a high-rate data flow in a radio access network by splitting it into multiple lower-rate data flows at the Media Access Control (MAC) sublayer. This "inverse multiplexing" allows a network to transmit data to a user device at an aggregate rate higher than what a single channel can support, with information included to allow the user device to recombine the flows. (’212 Patent, Abstract; col. 4:49-60).
  • Asserted Claims: The complaint asserts claim 14. (Compl. ¶100). Claim 14 is a method claim.
  • Accused Features: The accused products are identified as Connected Home Hubs, Gateways, and Wi-Fi cameras using Z-Wave technology. (Compl. ¶¶ 94, 101).

U.S. Patent No. 7,593,428 - "Apparatus, and Associated Method, for Forming, and Operating Upon, Multiple-Checksum-Protected Data Packet" (issued September 22, 2009)

  • Technology Synopsis: The patent details a method for creating a data packet with multiple, distinct checksum-protected parts. A formatter can dynamically select different contiguous parts of the packet's payload and protect each with a different type of checksum, providing flexible and granular error detection. (’428 Patent, Abstract).
  • Asserted Claims: The complaint asserts claims 14, 15, and 16. (Compl. ¶112). Independent claim 14 is a method claim.
  • Accused Features: The complaint targets a wide array of D-Link products, including EAGLE PRO AI Mesh Systems, various Wi-Fi routers, extenders, adapters, and cameras. (Compl. ¶¶ 105, 113).

U.S. Patent No. 7,643,423 - "Dynamic Channel Allocation in Multiple-Access Communication Systems" (issued January 5, 2010)

  • Technology Synopsis: The invention describes a system for dynamic channel allocation where a "reservation set" of channels is used to reserve resources, and a corresponding "allocation set" is used for receiving the allocated channels. The reservation set information is broadcast on a downlink channel to multiple users, indicating which uplink channels are reserved for specific users. (’423 Patent, Abstract).
  • Asserted Claims: The complaint asserts claims 1, 2, 9, and 10. (Compl. ¶122). Independent claim 1 is a method claim.
  • Accused Features: The accused products include various Wi-Fi 6 PCIe adapters, outdoor Wi-Fi cameras, and smart routers. (Compl. ¶¶ 116, 123).

U.S. Patent No. 7,974,260 - "Method of Transmitting Time-Critical Scheduling Information Between Single Network Devices in a Wireless Network using Slotted Point-to-Point Links" (issued July 5, 2011)

  • Technology Synopsis: This patent discloses a method for transmitting time-critical scheduling information between wireless devices. The information is placed in a data sequence with a header and payload, where the payload contains only the timing control data, and transmitted in a defined contact slot, potentially on a dedicated channel independent of normal data traffic. (’260 Patent, Abstract; col. 3:11-30).
  • Asserted Claims: The complaint asserts claims 1, 5, and 14. (Compl. ¶133). Independent claims 1 (device), 5 (method), and 14 (computer-readable medium) are asserted.
  • Accused Features: The accused products include a range of Wi-Fi 6 adapters, smart plugs, cameras, and routers. (Compl. ¶¶ 127, 134-136).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses an exceptionally broad range of D-Link products, including but not limited to D-Link Switches, Routers, Modem/Gateways, Wi-Fi Extenders, Access Points, Network Cameras, Connected Home Hubs, and various other networking and smart home devices. (Compl. ¶¶ 18, 31, 43, 53, 63, 81, 94, 105, 116, 127). The lists of accused products span several pages for each of the first two counts alone.

Functionality and Market Context

  • The accused products are networking hardware that form the basis of local area networks in both consumer and business settings. Their core functionality involves receiving, processing, and forwarding IP data packets to enable communication between devices and with the internet. (Compl. ¶¶ 26, 39). The complaint alleges that in performing these functions, the products implement the patented methods of data classification, synchronization, and transmission. The complaint's targeting of entire product families (e.g., "DGS-1210 Series," "COVR" mesh systems) suggests an allegation that the purportedly infringing technology is fundamental to a significant portion of D-Link's product portfolio. (Compl. ¶¶ 18, 31).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’173 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of classifying Internet Protocol (IP) data to be sent from a source apparatus to a destination apparatus in a packet switched network, said method comprising: receiving said data at a first node, the data comprising a header comprising a list of at least one intermediate node to be visited on a way to the destination apparatus; The accused products are network devices (nodes) that receive IP data packets containing header information as part of their standard operation. ¶26 col. 2:45-47
and classifying said data at said first node based on an entry in said header. The accused products allegedly classify the received data based on an entry in the packet header to determine how the data should be handled or routed. ¶26 col. 3:5-13

’266 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of classifying data comprising: receiving Internet Protocol (IP) data at a first node; The accused products, as network nodes, receive IP data packets during operation. ¶39 col. 1:45-46
classifying the IP data received at the first node based on a last destination address entry of a plurality of destination address entries in a header of the IP data; The accused products allegedly classify the received IP data based on the final destination address specified in the header. ¶39 col. 2:60-67
and forwarding the IP data from the first node to a second node, wherein the IP data is classified at the second node based on the last destination address entry of the plurality of destination address entries in the header of the IP data. The accused products allegedly forward the data to subsequent nodes, where the data is again classified based on the same final destination address. ¶39 col. 3:1-4

Identified Points of Contention

  • ’173 Patent: A potential point of contention may be the scope of the term "classifying... based on an entry in said header." The complaint's allegations are general. (Compl. ¶26). The patent specification discusses this classification in the context of source routing options like LSRR/SSRR, which allow a source to specify a path of intermediate nodes. (’173 Patent, col. 2:45-67). The analysis may raise the question of whether the accused products' standard routing decisions constitute the specific "classifying" taught by the patent, or if the claim requires the processing of explicit source routing headers that may not be present in typical network traffic.
  • ’266 Patent: The infringement analysis for the ’266 patent will likely focus on the highly specific limitation "last destination address entry of a plurality of destination address entries." The complaint alleges the accused products perform this step. (Compl. ¶39). This claim language strongly suggests a source-routing context where a packet header contains an explicit list of sequential destinations. A key technical question will be what evidence the complaint or subsequent discovery provides that the accused products encounter and process such headers, and then perform classification specifically based on the last entry in that list, as opposed to simply processing packets with a single source and destination address.

V. Key Claim Terms for Construction

  • For the ’173 and ’266 Patents:

    • The Term: "classifying"
    • Context and Importance: The definition of "classifying" is central to the infringement analysis for both patents. Practitioners may focus on this term because its scope will determine whether routine packet forwarding decisions fall within the claims. If "classifying" is construed narrowly to mean only specific QoS actions (like resource reservation), infringement may be more difficult to establish than if it is construed broadly to include any routing or handling decision based on header information.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claims themselves do not limit "classifying" to a specific purpose. Claim 1 of the ’173 patent simply requires classifying "based on an entry in said header," which could arguably encompass any decision-making process. (’173 Patent, col. 5:21-23).
      • Evidence for a Narrower Interpretation: The specification repeatedly discusses classification in the context of enabling Quality of Service via protocols like RSVP. (’173 Patent, col. 3:5-13). This context may support an argument that "classifying" requires more than standard packet forwarding and implies a specific action related to service guarantees.

  • For the ’266 Patent:

    • The Term: "a last destination address entry of a plurality of destination address entries in a header"
    • Context and Importance: This phrase is the lynchpin of the asserted claims of the ’266 Patent. The entire infringement theory depends on whether the accused products process headers containing a "plurality" of such entries and act upon the "last" one. Practitioners may focus on this term because if the accused products only operate on packets with a single destination address, there can be no "plurality" and thus no literal infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint does not provide a basis for a broader interpretation; it simply recites the claim language. (Compl. ¶39).
      • Evidence for a Narrower Interpretation: The patent specification describes this concept in the context of source routing, where "the source apparatus may put the address of the first intermediate router... in a destination address field... and the addresses of the remaining routers... in the route data field." (’266 Patent, col. 2:53-58). This language strongly supports a narrow construction requiring an explicit list of addresses, such as that found in an IPv4 LSRR option or an IPv6 routing header.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for the ’798 patent, stating that Defendant has taken "active steps" to cause infringement by distributors and end-users. (Compl. ¶73). These alleged steps include "advising or directing personnel," "advertising and promoting the use of the Accused Products," and "distributing instructions that guide users to use the Accused Products in an infringing manner." (Compl. ¶73). The complaint also makes a general allegation that Defendant provides assistance to customers to enable infringing use across all asserted patents. (Compl. ¶15).
  • Willful Infringement: Willful infringement is alleged only for the ’798 patent. (Compl. ¶75). The allegation is based on knowledge of the patent "at least as of the date when it was notified of the filing of this action." (Compl. ¶72). The complaint further alleges on "information and belief" that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness. (Compl. ¶76).

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

  • A central issue for several of the asserted networking patents, particularly the ’173 and ’266 patents, will be one of technical applicability: can the specific, and in some cases legacy, source-routing functionalities described in the patents (e.g., classifying based on a "list" of intermediate nodes or the "last" address in such a list) be shown to map onto the actual, day-to-day packet processing performed by the accused D-Link products? The complaint's general allegations will need to be substantiated with evidence that the accused products perform these very specific claimed functions.
  • Given the assertion of ten patents against a vast and diverse product portfolio, a key procedural question will be one of case manageability. The complexity of construing claims and analyzing infringement across ten distinct technologies and hundreds of accused product models may require the parties and the court to focus the litigation on a small number of representative patents and products to make the case tractable.
  • For the ’798 patent, the willfulness claim appears to be based primarily on post-suit knowledge. A key evidentiary question will be one of pre-suit conduct: can Plaintiff develop factual evidence to support its allegation of a "policy or practice" of willful blindness, which would be necessary to establish pre-suit willfulness, or will the claim be limited to potential enhanced damages for post-filing infringement?