DCT

2:25-cv-01051

AGIS Software Development LLC v. Sand Studio Pte Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01051, E.D. Tex., 10/17/2025
  • Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district. The complaint further alleges that Defendant conducts business and directs infringing activities within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s AirDroid Parental Control software and related services infringe four U.S. patents concerning methods for providing ad hoc, password-protected digital networks for location sharing and group communication.
  • Technical Context: The technology enables mobile device users to rapidly form temporary, secure networks to view each other's locations on a map and coordinate activities, a field with applications in emergency response, military coordination, and consumer location-sharing services.
  • Key Procedural History: The complaint notes that all four Patents-in-Suit successfully underwent Ex Parte Reexamination proceedings at the U.S. Patent and Trademark Office between 2021 and 2022, with all asserted claims confirmed as valid and patentable. This history may be raised by the Plaintiff to counter potential invalidity defenses regarding the prior art considered during reexamination.

Case Timeline

Date Event
2004-09-21 Earliest Priority Date for all Patents-in-Suit
2016-09-13 U.S. Patent No. 9,445,251 Issues
2016-10-11 U.S. Patent No. 9,467,838 Issues
2017-08-29 U.S. Patent No. 9,749,829 Issues
2017-11-14 U.S. Patent No. 9,820,123 Issues
2021-05-27 Ex Parte Reexamination Certificate Issued for '838 Patent
2021-06-08 Ex Parte Reexamination Certificate Issued for '251 Patent
2021-08-16 Ex Parte Reexamination Certificate Issued for '829 Patent
2021-09-24 Ex Parte Reexamination Certificate Issued for '123 Patent
2022-07-29 Accused Product "AirDroid Parental Control" Released
2025-10-17 Complaint Filed

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

U.S. Patent No. 9,445,251 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks,” issued September 13, 2016

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a need for military, first responder, and other emergency groups to establish temporary digital and voice networks "easily and rapidly" without pre-entering user data like names or phone numbers ('251 Patent, col. 2:7-20). This is particularly challenging when coordinating different organizations, such as police and fire departments, at a disaster scene ('251 Patent, col. 2:21-36).
  • The Patented Solution: The invention proposes a system where users join a network by providing a server IP address, an "ad hoc event name," and a password ('251 Patent, col. 3:46-55). A remote server acts as a central hub, receiving GPS location and status data from each participant's device and forwarding it to all other members of the group ('251 Patent, col. 3:15-24). This allows all participants to view each other's locations as symbols on a map and communicate without needing to know each other's IP addresses or phone numbers beforehand, as depicted in the server-centric architecture of Figure 5 ('251 Patent, Fig. 5; col. 4:1-14).
  • Technical Importance: This server-mediated approach simplifies the creation of temporary, secure communication groups for real-time situational awareness among users who may not have previously interacted ('251 Patent, col. 2:36-49).

Key Claims at a Glance

  • The complaint asserts independent Claim 24 ('251 Patent, Compl. ¶22).
  • The essential elements of Claim 24, a system claim directed to a "first device," include:
    • Receiving a message from a second device related to joining a group.
    • Participating in the group by sending its own location information to a server and receiving location information of other devices from the server.
    • Presenting a first interactive, georeferenced map with user-selectable symbols representing the other devices.
    • Sending a request to the server for a second, different georeferenced map.
    • Receiving and presenting the second georeferenced map with the symbols repositioned.
    • Identifying user interaction that selects one or more symbols and specifies an action, and based on that, using an Internet Protocol to send data to the selected devices via the server.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,467,838 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks,” issued October 11, 2016

The Invention Explained

  • Problem Addressed: As with the related ’251 Patent, this patent addresses the difficulty emergency response teams face in establishing rapid, cross-organizational communication networks for coordinating activities during a disaster ('838 Patent, col. 2:16-34).
  • The Patented Solution: The invention describes a method for devices to join a communication network corresponding to a group by transmitting a message with a group identifier ('838 Patent, col. 14:55-58). The system relies on a "first server" to manage the exchange of location information among group members for display on a georeferenced map, and a "second server" to field requests for different map data ('838 Patent, claim 54). This architecture enables users to maintain situational awareness and communicate with group members through the server infrastructure ('838 Patent, col. 3:50-col. 4:10).
  • Technical Importance: The system is designed to facilitate interoperability between different groups and devices by using a common, server-based communication protocol that does not require pre-configuration of user details ('838 Patent, col. 2:8-16).

Key Claims at a Glance

  • The complaint asserts independent Claim 54 ('838 Patent, Compl. ¶31).
  • The essential elements of Claim 54, a system claim directed to a "first device," include:
    • Joining a communication network for a group by transmitting a message with a group identifier.
    • Participating in the group by sending its location to a "first server" and receiving locations of other devices from that server.
    • Presenting a first interactive, georeferenced map with a first set of symbols representing group members.
    • Sending a request for different map data to a "second server."
    • Receiving the second map data from the second server and presenting a second map with a second set of symbols.
    • Identifying user interaction selecting symbols on the second map and specifying an action, and based on this, sending data to the selected devices "via the first server."
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,820,123 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks,” issued November 14, 2017

  • Technology Synopsis: The patent discloses a system for creating ad hoc communication groups where a first device, upon receiving a message to join a group from a second device, participates by sending its location to a server and receiving the locations of other group members. The system presents these locations as selectable symbols on a georeferenced map, and user selection of a symbol is identified by searching for the symbol nearest to the coordinates of the user's touch on the display (Compl. ¶43).
  • Asserted Claims: The complaint asserts at least independent Claim 23 (Compl. ¶40).
  • Accused Features: The accused features include the AirDroid Parental Control system's functionalities for forming and joining groups, exchanging location information with a server, presenting member locations on an interactive map, and allowing users to interact with symbols on the map to initiate communications (Compl. ¶44).

U.S. Patent No. 9,749,829 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks,” issued August 29, 2017

  • Technology Synopsis: The patent describes a system focused on the interaction between a first device and a second device within a group. A second device receives a request to join a group from a first device, accepts, and then receives updated location information from the first device via a server. The second device displays the first device's location as a symbol on a map and can send messages to the first server to remotely control the first device (Compl. ¶52).
  • Asserted Claims: The complaint asserts at least independent Claim 34 (Compl. ¶49).
  • Accused Features: The complaint targets the AirDroid Parental Control features where a parent's device (second device) can add a child's device (first device) to a group, track the child's location in real-time on a map, and use features like "Remote Camera" or "One-Way Audio" to remotely control the child's device (Compl. ¶¶ 52-53). A screenshot in the complaint shows the interface for the "One-Way Audio" remote control feature (Compl. p. 17).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "AirDroid Parental Control" mobile applications, desktop/laptop software applications, web applications, and related servers and services (collectively, "Accused Products") (Compl. ¶17).

Functionality and Market Context

  • The complaint describes the Accused Products as being designed for child safety, allowing a parent to monitor a child's device and location (Compl. p. 7). The functionality allegedly includes forming or joining groups called "family members" by sending email invitations (Compl. p. 15). A screenshot depicts the interface for inviting a new family member via email (Compl. p. 15).
  • Key technical functions alleged in the complaint include a "Real-time Family Location Tracker" that displays a child's current location and past movements on a map, and a geofencing feature that sends alerts when a child enters or exits a predefined zone (Compl. pp. 12-13). A marketing screenshot from Defendant's website illustrates this real-time location tracking capability (Compl. p. 12).
  • The product is also alleged to enable communication within the group via "Family Chatting" and remote control features such as "One-Way Audio" that allow a parent to listen to the microphone on a child's device (Compl. ¶11, p. 17).
  • The complaint alleges the product has significant market reach, citing over 10 million downloads from the Google Play store (Compl. p. 7).

IV. Analysis of Infringement Allegations

'251 Patent Infringement Allegations

Claim Element (from Independent Claim 24) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving a message from a second device, wherein the message relates to joining a group The Accused Products allow a user to send an email invitation to a desired family member to join a group (network). ¶26; p. 15 col. 9:1-10
based on receiving the message... participating in the group, wherein participating in the group includes sending first location information to a server and receiving second location information from the server Once a user joins a group, the Accused Products facilitate participation by communicating with a server to send and receive location information for display. ¶26 col. 7:51-67
presenting, via an interactive display of the first device, a first interactive, georeferenced map and a plurality of user-selectable symbols corresponding to the plurality of second devices The Accused Products display an interactive map showing the locations of other group members (e.g., a child) as selectable symbols. ¶26; pp. 11-12 col. 7:45-50
sending...a request for a second georeferenced map different from the first georeferenced map, wherein the request specifies a map location The Accused Products permit users to request and display additional maps, for example by moving the map screen or selecting different map types. ¶26 col. 8:10-20
presenting...the second georeferenced map and the plurality of user-selectable symbols...wherein the symbols are positioned on the second georeferenced map The Accused Products display the new map view with the symbols for other devices repositioned according to their geographic locations. ¶26 col. 8:21-29
identifying user interaction with the interactive display selecting one or more of the user-selectable symbols...and user interaction with the display specifying an action and, based thereon, using an Internet Protocol to send data to the one or more second devices via the server The system permits user interaction with the symbols on the map to select a user and send data (e.g., a chat message) to that user's device via a server. ¶26 col. 7:8-21

'838 Patent Infringement Allegations

Claim Element (from Independent Claim 54) Alleged Infringing Functionality Complaint Citation Patent Citation
joining a communication network corresponding to a group, wherein joining the communication network comprises transmitting a message including an identifier corresponding to the group The Accused Products allow users to establish and join groups by exchanging messages (e.g., invitations) via interaction with servers. ¶35; p. 15 col. 15:44-50
participating in the group, wherein participating in the group includes sending first location information to a first server and receiving second location information from the first server The system facilitates group participation by communicating with a server, sending the user's own location and receiving location information for other group members. ¶35 col. 17:59-67
presenting, via an interactive display of the first device, a first interactive, georeferenced map and a first set of one or more user-selectable symbols The Accused Products present location information on an interactive map display with selectable symbols corresponding to other devices/users. ¶35; p. 12 col. 15:1-12
sending, to a second server, a request for second georeferenced map data different from the first georeferenced map data The system allows users to retrieve map information from multiple sources, such as by moving the map screen or selecting satellite imagery. ¶35 col. 18:8-12
receiving, from the second server, the second georeferenced map data; [and] presenting...a second georeferenced map and a second set of...user-selectable symbols The Accused Products display the new map data received from the server, with symbols for group members shown at their respective locations. ¶35 col. 18:13-24
identifying user interaction...selecting one or more of the second set of user-selectable symbols...and user interaction...specifying an action and, based thereon, sending third data to the selected one or more second devices via the first server The system permits user interaction with the display to select one or more symbols and, based on that interaction, send data to the corresponding devices via a server. ¶35 col. 18:25-34
  • Identified Points of Contention:
    • Scope Questions: The patents' specifications repeatedly frame the invention in the context of "ad hoc" networks for "military, first responder, and other public and private emergency groups" ('251 Patent, col. 2:7-9). A potential point of contention is whether the accused product's persistent "family groups" for consumer use fall within the scope of the claimed "group" and the patents' described "ad hoc network."
    • Technical Questions: Claim 54 of the ’838 Patent recites a system architecture involving a "first server" for location information exchange and a "second server" for map data requests. The complaint alleges in general terms that the accused system uses "servers" (Compl. ¶35), but it does not provide specific facts showing that the accused architecture employs two distinct servers for these separate functions. This raises the question of whether the accused system’s server architecture technically corresponds to the specific two-server limitation recited in the claim.

V. Key Claim Terms for Construction

  • The Term: "group"

    • Context and Importance: The asserted claims in all four patents require the device to join or participate in a "group." The patents' specifications extensively describe these groups in the context of temporary, "ad hoc" networks for emergency responders ('251 Patent, col. 2:7-20). The construction of "group" will be critical to determining if the accused product's more permanent "family members" structure meets this limitation.
    • Intrinsic Evidence for a Broader Interpretation: The claims themselves simply use the word "group" without modifiers like "ad hoc" or "temporary" ('251 Patent, Claim 24). This may support an argument for the term's plain and ordinary meaning, which would not be limited to a specific use case like emergency response.
    • Intrinsic Evidence for a Narrower Interpretation: The "Background of the Invention" and "Summary of the Invention" sections consistently frame the problem and solution around the needs of "Military, first responder, and other public and private emergency groups" ('251 Patent, col. 2:7-9). A party could argue that this context limits the scope of "group" to the types of temporary, task-oriented networks described therein.

  • The Term: "first server" / "second server" (in the ’838 Patent)

    • Context and Importance: Claim 54 of the ’838 Patent requires operations involving two distinct entities: a "first server" that handles user location data and a "second server" that provides map data. Infringement of this claim hinges on whether the accused system has this specific two-server architecture.
    • Intrinsic Evidence for a Broader Interpretation: The patent does not explicitly define "server" or state that the two servers must be physically separate machines. This could support an interpretation where "first server" and "second server" refer to different logical functions, services, or software modules that could potentially run on the same physical hardware.
    • Intrinsic Evidence for a Narrower Interpretation: The plain language "a first server" and "a second server" suggests two distinct entities. The absence of any language in the specification suggesting they can be the same entity may support an argument that the claim requires two structurally separate servers or at least two independently addressable network endpoints.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides instructional materials such as user guides, training videos, and demonstrations through its website that "intentionally instructs its customers to infringe" (Compl. ¶¶ 19, 23, 32).
  • Willful Infringement: Willfulness is alleged based on the assertion that Defendant has had knowledge of the Patents-in-Suit and its infringement "since at least the issuance date of the Patents-in-Suit" (Compl. ¶16). The complaint seeks treble damages as a result of the alleged willful and deliberate infringement (Compl. p. 32, ¶ e).

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

This case presents several questions for the court that will be central to resolving the dispute.

  • A core issue will be one of definitional scope: Can the term "group," rooted in the patents' description of temporary "ad hoc" networks for emergency responders, be construed to cover the persistent "family groups" implemented in the accused consumer-focused parental control application?
  • A key evidentiary question will be one of architectural correspondence: Does the accused AirDroid system utilize a "first server" for user location data and a distinct "second server" for map data requests, as explicitly required by Claim 54 of the '838 patent, or is there a fundamental mismatch in the technical operation of the accused server infrastructure?
  • A third question will relate to remote control functionality: Does the accused product's ability for a parent device to remotely activate a child's camera or microphone meet the specific claim limitations of the '829 patent related to receiving, processing, and acting upon messages for "remotely controlling the first device to perform an action"?