SZ DJI Technology Co Ltd v. Irdeto BV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SZ DJI Technology Co., Ltd. (China)
  • Defendant: Irdeto B.V. and Irdeto Security B.V. (The Netherlands)
  • Plaintiff’s Counsel: McKool Smith, P.C.
• Case Identification: 2:25-cv-01066, E.D. Tex., 10/24/2025
• Venue Allegations: The complaint alleges that venue is proper in any judicial district because Defendants are foreign entities not resident in the United States. It further alleges specific contacts with Texas, including marketing the accused product at Texas-based conferences and placing products into the state's stream of commerce.
• Core Dispute: Plaintiff alleges that Defendant’s Keystone digital key and vehicle access management platform infringes four U.S. patents related to application development for movable objects, redundant control systems, and managing restricted regions.
• Technical Context: The technology at issue resides in the field of secure, remote access and control for vehicles, a critical component of modern fleet management, shared mobility services, and connected vehicle ecosystems.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date	Event
2015-03-31	Earliest Priority Date for U.S. Patent No. 11,482,121
2015-04-20	Earliest Priority Date for U.S. Patent Nos. 10,116,785 and 11,184,474
2016-08-12	Earliest Priority Date for U.S. Patent No. 11,119,474
2018-10-30	U.S. Patent No. 10,116,785 Issued
2021-09-14	U.S. Patent No. 11,119,474 Issued
2021-11-23	U.S. Patent No. 11,184,474 Issued
2022-10-25	U.S. Patent No. 11,482,121 Issued
2025-10-24	Complaint Filed

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

U.S. Patent No. 10,116,785 - "System and method for supporting movable object application development"

The Invention Explained

• Problem Addressed: The patent addresses the general challenge of developing software applications for controlling movable objects, such as unmanned vehicles (’785 Patent, col. 1:15-18).
• The Patented Solution: The invention describes a "movable object manager," which acts as a software intermediary (akin to a Software Development Kit or SDK) between a user's application and the movable object itself. This manager establishes a connection, handles the flow of data packets from the object's hardware modules (e.g., camera, battery) to the application, and sends commands from the application back to the object's modules, thereby simplifying the development process ('785 Patent, Abstract; col. 5:7-20; Fig. 4).
• Technical Importance: This architecture abstracts the underlying hardware complexity, creating a standardized layer that enables third-party developers to more easily create applications for sophisticated movable objects without needing to understand the low-level communication protocols ('785 Patent, col. 5:4-7).

Key Claims at a Glance

• The complaint asserts independent claim 35 ('785 Patent, col. 15:35-16:15; Compl. ¶31).
• Essential elements of Claim 35 include:
  • Establishing, via a movable object manager, a connection with a movable object configured to process commands for controlling at least one hardware module.
  • Receiving, via the manager, data packets from the movable object containing information corresponding to the hardware module.
  • Providing, via the manager, the information from the data packets to an application on a user terminal.
  • Providing, via the manager, commands from the application to the movable object to control the hardware module.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,119,474 - "Method, device, and system for redundancy control"

The Invention Explained

• Problem Addressed: The patent addresses the safety risk that arises when a remotely operated unmanned aerial vehicle (UAV) experiences an abnormal connection with its remote control device, which can lead to an "out-of-control state" ('9,474 Patent, col. 1:20-25).
• The Patented Solution: The invention proposes a system for redundancy by using multiple remote control paths. A device on the movable object is equipped with at least a first and a second receiver, each communicatively coupled to a separate remote control device. This device can then select one of the incoming control signals to control the movable object, providing a backup if the primary connection fails ('9,474 Patent, Abstract; col. 1:33-40).
• Technical Importance: This method enhances the operational safety and reliability of remotely controlled vehicles by creating a fail-safe mechanism that mitigates the risk of losing control due to a single point of communication failure ('9,474 Patent, col. 2:1-3).

Key Claims at a Glance

• The complaint asserts independent claim 19 ('9,474 Patent, col. 21:10-22:12; Compl. ¶38).
• Essential elements of Claim 19 include:
  • A device comprising a memory and a processor.
  • The processor is configured to receive, through a first receiver, a first control signal from a first remote control device.
  • The processor is configured to receive, through a second receiver, a second control signal from a second remote control device.
  • The processor is configured to select one of the first control signal and the second control signal for controlling a movable object.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,184,474 - "System and method for supporting movable object application development"

Technology Synopsis

This patent describes a security framework for movable object applications. A user terminal with an application receives an "application key" from an authentication server. To control a movable object, the terminal generates an activation request including this key and sends it to the server. The server determines whether to grant the requested privilege based on the key, and only upon receiving a grant does the user terminal transmit control signals to the object ('4,474 Patent, Abstract; col. 1:39-49).

Asserted Claims

The complaint asserts independent claim 29 (Compl. ¶45).

Accused Features

The complaint alleges infringement by Irdeto's Keystone system, which uses a cloud-based backend server (the authentication server) to manage policy rules and issue credentials (the application key) to a mobile application (the user terminal) to control vehicle functions (the movable object) (Compl. ¶¶23-24, 56).

U.S. Patent No. 11,482,121 - "Open platform for vehicle restricted region"

Technology Synopsis

This patent discloses a system for managing user-defined "restriction regions" (i.e., geofences) for ground vehicles, particularly associated with private property. The system receives parameters defining a region from a user, authenticates the user's identity to ensure they are authorized to designate the region, stores the region in a database, and implements "response measures" (e.g., forcing the vehicle to stop, change direction, or providing an alert) when the vehicle approaches or enters the designated area (’121 Patent, Abstract; col. 1:31-45).

Asserted Claims

The complaint asserts independent claim 1 (Compl. ¶52).

Accused Features

The complaint alleges infringement by the Keystone system's use of "geofence parameter" policies to control vehicle access. These policies, managed by the Keystone backend, can grant or deny vehicle functions based on location, which the complaint maps to the patent's claimed system for managing and enforcing restriction regions (Compl. ¶¶24, 56).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Irdeto's Keystone digital-key and vehicle-access-management platform (Compl. ¶¶23, 56).

Functionality and Market Context

The complaint describes Keystone as a platform designed to replace physical vehicle keys with secure, policy-based digital credentials managed via a smartphone (Compl. ¶23). The system's architecture consists of three main components: (1) a cloud-based backend server for managing user credentials, access policies, and logs; (2) an in-vehicle module that receives and executes commands; and (3) a mobile application that communicates with the vehicle via short-range wireless protocols like Bluetooth Low Energy (BLE) (Compl. ¶23). When a user's phone is near an authorized vehicle, the app authenticates its digital credential against predefined policies (e.g., user identity, time of access, geofence parameters) stored on the backend, and if valid, can perform vehicle functions like unlocking doors or starting the engine (Compl. ¶24). The complaint states Keystone is marketed to commercial fleet operators, rental agencies, and shared-mobility providers and is advertised as "brand- and model-agnostic" (Compl. ¶¶23, 25). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; therefore, the infringement theories are summarized below in prose.

’785 Patent Infringement Allegations

The complaint's narrative suggests an infringement theory where the Keystone mobile application and/or its associated SDK functions as the claimed "movable object manager" (Compl. ¶¶23-24, 60). In this theory, the Keystone app/SDK establishes a connection with the in-vehicle module (the "movable object"). It allegedly receives "data packets," such as vehicle status information, from the hardware in the vehicle and provides this information to the user-facing application. Concurrently, it provides commands, such as "unlock door," from the application to the in-vehicle module for execution (Compl. ¶23).

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "movable object manager," described in the patent's context of an SDK for unmanned aerial vehicles, can be construed to read on a mobile application and SDK for a ground vehicle digital key system.
  • Technical Questions: The analysis may focus on whether the Keystone mobile app/SDK is a distinct "manager" that provides information to an "application," or if the app and manager are one and the same. The specific nature of the "data packets" received from the vehicle and how they correspond to "hardware modules" as claimed will also raise evidentiary questions.

’9,474 Patent Infringement Allegations

The complaint does not provide sufficient detail for a clear analysis of the infringement theory for the ’9,474 Patent. The asserted claim requires a device on the movable object that receives signals from two distinct "remote control devices" via two distinct receivers and selects one signal for control (Compl. ¶38). However, the complaint's description of the Keystone system centers on a single mobile application communicating with an in-vehicle module, with no mention of a redundant, secondary remote control device or a second receiver on the vehicle (Compl. ¶¶23-26).

• Identified Points of Contention:
  • Scope Questions: A primary question of scope will be how the plaintiff defines two separate "remote control devices" and two corresponding "receivers" within the Keystone architecture. The defense may argue that the term "remote control device" in the context of the patent implies a user-operated device for active vehicle control, which may not map onto every component of the accused system.
  • Technical Questions: A key factual dispute will likely be the identification of the accused components that allegedly meet the "first remote control device," "second remote control device," "first receiver," and "second receiver" limitations of the claim.

V. Key Claim Terms for Construction

’785 Patent: "movable object manager" (Claim 35)

• Context and Importance: This term is the central component of the claimed invention. Its construction will determine whether the claim is applicable to the software architecture of the accused Keystone system. Practitioners may focus on this term because its definition will likely dictate whether a system designed for ground vehicle access falls within the scope of a claim originating from a patent focused on UAV application development.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the manager's function in general terms as being "used for supporting the development of software applications in the movable object environment" and to "manage[] the communication between the application... and the movable object" ('785 Patent, col. 5:4-11). This language may support an interpretation covering any software layer that serves as an intermediary between an application and a movable object.
  • Evidence for a Narrower Interpretation: The detailed description repeatedly uses "unmanned aircraft" as the primary example of a "movable object" ('785 Patent, col. 2:59-63) and includes figures explicitly depicting an "Unmanned Aircraft Interface" and a "Drone" ('785 Patent, Figs. 10-11). This context may support a narrower construction limited to software development kits for UAVs or similar autonomous craft.

’9,474 Patent: "remote control device" (Claim 19)

• Context and Importance: The claim requires two distinct "remote control devices." The viability of the infringement allegation depends on identifying two such components within the Keystone system. Practitioners may focus on this term because the complaint's description of the accused product does not facially disclose two separate user-operated controllers, suggesting a non-obvious mapping that will be central to the dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide a specific definition that limits the term. A party could argue that any component that remotely transmits a "control signal" qualifies, which might allow for an unconventional mapping where, for example, a mobile phone is one "device" and a cloud server that pushes policy updates is another.
  • Evidence for a Narrower Interpretation: The patent's background discusses safety issues when a "remote control device experiences abnormal connection" in the context of UAVs ('9,474 Patent, col. 1:22-24). The figures and flowcharts illustrate scenarios that imply active, real-time user operation consistent with a traditional handheld controller for a vehicle ('9,474 Patent, Figs. 1, 3). This may support a narrower construction limited to devices actively manipulated by a user for vehicle operation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The factual basis cited is Defendant's marketing of the Keystone system for use in the U.S. and providing "online tutorials that instruct users to perform the claimed limitations" (Compl. ¶¶61, 67, 73, 79).
• Willful Infringement: The complaint alleges that Defendants have knowledge of the asserted patents and their infringement "at least as of the filing of this Complaint" (Compl. ¶¶59, 65, 71, 77). This forms the basis for a claim of post-suit willful infringement, for which enhanced damages are sought in the prayer for relief (Compl. p. 19, ¶b).

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

• A core issue will be one of definitional scope: can claim terms rooted in patents that heavily describe technology in the context of unmanned aerial vehicles (e.g., "movable object manager," "redundancy control") be construed broadly enough to encompass a digital key and access management system for commercial ground vehicles?
• A second key question will be one of technical mapping: for the '9,474 patent, does the architecture of the accused Keystone system—described as a mobile app, in-vehicle module, and cloud backend—contain two distinct "remote control devices" and two corresponding "receivers" as required by the claim, or is there a fundamental mismatch in technical operation?
• A third key question will be one of functional equivalence: for the '121 patent on restricted regions, does the accused Keystone system's "geofence parameter" feature, which is described as controlling access, perform the specific "response measures" claimed—such as actively "forcing the ground vehicle to stop" or "move away"—or does it perform a different, non-infringing function?