DCT
2:25-cv-01091
Hisense Visual Technology Co Ltd v. Nokia Of America Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hisense Visual Technology Co., Ltd. (People's Republic of China)
- Defendant: Nokia of America Corporation (Delaware) and Nokia Corporation (Finland)
- Plaintiff’s Counsel: Jones Day
- Case Identification: 2:25-cv-01091, E.D. Tex., 10/31/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Nokia of America Corporation maintains a regular and established place of business in Lewisville, Texas, and has committed acts of infringement within the district. Venue over the foreign parent, Nokia Corporation, is alleged as proper in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s industrial edge computing platform, including its device management and private network components, infringes seven patents related to device-to-device control, card-based user interfaces, and event-driven data monitoring.
- Technical Context: The technology at issue addresses the management, control, and interoperability of heterogeneous devices within private wireless networks, a domain central to the industrial internet of things (IIoT) and "Industry 4.0" initiatives.
- Key Procedural History: The complaint alleges that Defendant had knowledge of the asserted patents no later than October 13, 2025, which predates the filing of the complaint and may form a basis for an allegation of pre-suit willful infringement. No prior litigation or administrative proceedings involving these patents are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-27 | ’885 Patent Priority Date |
| 2014-09-30 | ’885 Patent Issue Date |
| 2015-02-06 | ’602, ’570, ’371, ’649, ’744 Patent Priority Date |
| 2016-10-12 | ’516 Patent Priority Date |
| 2018-08-07 | ’649 Patent Issue Date |
| 2018-10-30 | ’602 Patent Issue Date |
| 2018-11-06 | ’516 Patent Issue Date |
| 2019-08-13 | ’371 Patent Issue Date |
| 2020-01-28 | ’570 Patent Issue Date |
| 2020-03-24 | ’744 Patent Issue Date |
| 2025-10-13 | Alleged Date of Defendant's Knowledge of Patents |
| 2025-10-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,116,602 - System and methods for device to device control
The Invention Explained
- Problem Addressed: The complaint suggests the technology addresses limitations of prior systems that required "device-specific integrations or manual configurations for each protocol and feature set" to enable communication and control between different types of devices (Compl. ¶33).
- The Patented Solution: The invention describes a system where an application on a first device can discover and control a second device in a standardized way. The application identifies the second device, determines its capabilities by matching an application profile against capabilities data provided by the second device, and then controls an operation on the second device using a communication protocol established by the application (Compl. ¶¶31, 34; ’602 Patent, col. 3:5-14). This creates a framework for interoperability without requiring bespoke integrations for each device pair.
- Technical Importance: This approach is designed to improve interoperability and simplify device control across a heterogeneous ecosystem, a foundational challenge in IoT and connected device environments (Compl. ¶33).
Key Claims at a Glance
- The complaint asserts at least independent claim 11 (Compl. ¶36).
- The essential elements of Claim 11 are:
- A device comprising a controller configured to execute an application for providing device connection and interoperability.
- The controller is configured to establish a connection with a second device identified by the application.
- The controller is configured to determine one or more capabilities of the second device based on a capability matching of the application, which is based on an application profile and capabilities output by the second device.
- The controller is configured to control an operation based on matched capabilities, wherein a command is exchanged via communication protocols established by the application.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,547,570 - System and methods for card element application operation
The Invention Explained
- Problem Addressed: The complaint characterizes the problem as conventional systems being "limited by device and configuration incompatibilities, and lack of interoperability" when managing functions and content across diverse devices (Compl. ¶56).
- The Patented Solution: The invention discloses a common platform for managing and operating applications through "card elements." A device's user interface displays these card elements, and a controller detects user commands associated with them (e.g., selecting or assigning a card to another device). The platform then determines and controls the resulting device operation by interoperating with the user interface and accessing entity information and metadata associated with the card and device. (’570 Patent, col. 4:25-31; Compl. ¶¶55-56).
- Technical Importance: This architecture enables "flexible, automated management and interaction of card elements and devices across heterogeneous systems," abstracting away device-specific complexities (Compl. ¶56).
Key Claims at a Glance
- The complaint asserts at least independent claim 11 (Compl. ¶59).
- The essential elements of Claim 11 are:
- A device comprising a display and a controller configured to control presentation of a card element for a user interface.
- The controller presents a UI for an application that lists other devices and displays a "device row" with a plurality of "device card elements" for a selected device.
- The controller detects a command for assigning a card element to the selected other device, where the command is an "exchange of the card element for exchange of at least one of content and capabilities."
- The operation is based on a platform for operation with card elements and one or more entities.
- The controller determines at least one capability of the selected other device based on the command and the platform, which includes accessing entity information based on a device profile.
- The controller controls the device operation, including controlling the exchange of a card element.
- The controller updates a card profile for the card element, including updating metadata to recognize the assignment.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,382,371 - System and methods for card interaction and assigning cards to devices
- Technology Synopsis: The patent relates to assigning "card elements" to devices within a user interface that organizes graphical elements into user and device rows (Compl. ¶¶77-78). The invention addresses the problem of interoperability and configuration burdens in connecting diverse devices by allowing for dynamic assignment and transfer of these card elements, including time-limited assignments, without requiring manual configuration (Compl. ¶¶79-80).
- Asserted Claims: At least independent claim 11 is asserted (Compl. ¶82).
- Accused Features: The complaint alleges that the application catalogs in Nokia's MXIE, IDM, and DAC Manager, which allow for assigning applications ("cards") to devices organized by location ("spaces") via graphical actions, infringe the ’371 Patent (Compl. ¶¶83, 85, 87).
U.S. Patent No. 10,044,649 - Systems and methods for connect to control
- Technology Synopsis: The patent describes a standardized sequence for device connection and control: an application uses a discovery engine to find a device, a pairing engine to request its profile, and a capabilities engine to obtain its capabilities (Compl. ¶¶101-102). This standardized flow is intended to overcome the complexity of pre-configuring heterogeneous devices by allowing an application to dynamically learn about a device and format control commands using plugin information (Compl. ¶103).
- Asserted Claims: At least independent claim 11 is asserted (Compl. ¶106).
- Accused Features: The discovery, onboarding, and control workflows in Nokia's MXIE (via its Integrated Operations Center), IDM, and DAC Manager are accused of infringing the ’649 Patent’s multi-step discovery, pairing, and capabilities-exchange process (Compl. ¶¶107, 109, 111).
U.S. Patent No. 10,601,744 - System and methods for presentation of a user interface and card elements
- Technology Synopsis: The invention addresses performance and interoperability issues in user interfaces that use modular "cards" (Compl. ¶127). It discloses an architecture where a device can preload a cross-platform framework file and then dynamically import or inject card content into that framework upon user selection, reducing latency and avoiding a full reload of the user interface (Compl. ¶¶125-126).
- Asserted Claims: At least independent claim 18 is asserted (Compl. ¶129).
- Accused Features: The complaint alleges that Nokia's MXIE platform, with its "click-to-deploy" application catalog, functions as a runtime framework that loads application modules ("cards") and their UI content, thereby infringing the '744 Patent's claims related to loading framework files and dynamically importing content (Compl. ¶¶129-130).
U.S. Patent No. 8,848,885 - Device Information Communication Method, Video Display Device, And Video Display System
- Technology Synopsis: The patent addresses the difficulty for a user on a call to determine if the other party's environment is suitable for confidential communication (Compl. ¶144). The invention provides a system where a video display device obtains information about connected devices (e.g., online status, geo-location, device ID) and sends that information to the communication partner, allowing the partner to assess the call environment (Compl. ¶¶143, 146).
- Asserted Claims: At least claim 7 is asserted (Compl. ¶148).
- Accused Features: Nokia's Team Comms application, which includes a "Dispatch Console," is accused of infringement. The complaint alleges the console functions as a video display device that obtains and sends device information (online status, geo-location) to communication partners to coordinate activity, thereby infringing the ’885 Patent (Compl. ¶149).
U.S. Patent No. 10,121,516 - Data Monitoring and Management Device and Event Data Monitoring Method
- Technology Synopsis: The invention discloses an event-driven data monitoring device that automatically controls sensors to capture data when an event is detected, records the event data along with associated metadata, and presents filtered, event-specific information (e.g., thumbnails, video snippets) to a user (Compl. ¶¶163-164). This is intended to improve upon systems that require manually sifting through continuous data feeds (Compl. ¶163).
- Asserted Claims: At least independent claim 1 is asserted (Compl. ¶168).
- Accused Features: Nokia's MXIE platform, when running applications like Scene Analytics and Visual Position and Object Detection (VPOD), is accused of infringement. The complaint alleges these applications monitor video feeds, detect events (e.g., anomalies, "fallen worker"), automatically record event-related data, and present filtered information (alerts, snippets) to operators, thus practicing the claimed invention (Compl. ¶¶168a-e).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are components of Nokia's industrial edge platform: Nokia MX Industrial Edge (MXIE), Nokia Industrial Device Management (IDM), Nokia DAC Manager, and Nokia Team Comms (Compl. ¶23).
Functionality and Market Context
- The complaint describes the accused products as an integrated "Industry 4.0 stack" for deploying and managing applications and devices on private 4G/5G wireless networks (Compl. ¶23).
- MXIE is identified as the core on-premises edge computing platform that hosts and orchestrates industrial applications, providing low-latency control and data processing close to machines (Compl. ¶24). An architectural diagram in the complaint shows MXIE situated between the cloud and industrial devices, running applications and managing integration (Compl. p. 9).
- IDM is presented as the centralized console for managing the lifecycle of devices within the ecosystem, including onboarding, monitoring health, enforcing policies, and deploying software (Compl. ¶25).
- DAC Manager is a web-based console that operates the private wireless network itself, provisions subscribers, and provides access to the Industrial Application Catalog for deploying applications onto the MXIE platform (Compl. ¶26). A network diagram illustrates how DAC Manager provides cloud-based management for on-site MXIE and 4G/5G radios (Compl. p. 15).
- Team Comms is an example of an application that runs on the MXIE platform, providing push-to-talk, video, and messaging services for workers on a campus network (Compl. ¶27).
- The complaint alleges these products are marketed for industrial digitalization across various sectors, including manufacturing, logistics, and mining (Compl. p. 9).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,116,602 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a device comprising: a controller configured to execute an application configured to provide the device connection and interoperability with at least one other device associated with the application | MXIE is described as an on-premises edge platform that runs industrial applications from a catalog to connect and provide interoperability between various operational technology (OT) systems and devices. | ¶36a | col. 2:59-65 |
| wherein the controller is configured to establish a connection with a second device, wherein the second device is identified to the device by the application | MXIE-hosted services, such as Device Management, are used to onboard, provision, and connect specific industrial endpoints and devices that are targeted by an application. | ¶36b | col. 3:5-8 |
| wherein the controller is configured to determine one or more capabilities of the second device based on a capability matching of the application, wherein determining is based on an application profile for the second device and capabilities output by the second device | Nokia’s Integrated Operations Center (IOC), running on MXIE, uses integration microservices to collect and normalize device attributes, which are then used by application logic and a rule engine for capability matching. | ¶36c | col. 3:8-12 |
| wherein the controller is configured to control an operation based on one or more matched capabilities, wherein a command is exchanged relative to the device and second device by way of communication protocols established by the application | The IOC's rule engine on MXIE automates workflows and orchestrates applications and industrial connectors, enabling application-driven control actions over connected devices using integrated protocols. | ¶36d | col. 3:12-14 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Nokia's software architecture, which includes distinct components like "MXIE," "IOC," "microservices," and a "rule engine," collectively performs the functions of the claimed "controller" executing a single "application." The defense may argue these are separate, uncombined systems, while the plaintiff will likely contend they form an integrated infringing device.
- Technical Questions: The complaint's allegation relies on mapping Nokia's "rule engine" to the claim's "capability matching" based on an "application profile." A key factual dispute may be whether the logic executed by the IOC's rule engine technically constitutes "matching" based on a "profile" as those terms are understood in the context of the ’602 Patent’s specification.
U.S. Patent No. 10,547,570 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...a controller configured to present a user interface for an application including a listing of other devices...the user interface presents a device row for a selected other device, the device row displaying a plurality of device card elements associated with the selected other device... | MXIE's Industrial Application Catalog and device management interface are alleged to present application "card" elements and device listings, visually identifying and listing applications and digital entities associated with each device. | ¶59b | col. 3:62-67 |
| ...detect a command for the user interface...wherein the command is associated with assigning a card element displayed by the user interface to the selected other device, wherein the command is an exchange of the card element for exchange of at least one of content and capabilities... | MXIE's provisioning flows are alleged to detect administrative commands that assign applications ("card elements") to connected assets, which constitutes an exchange of content and capabilities. | ¶59c | col. 4:2-8 |
| ...determine at least one capability of the selected other device based on the command and the platform...wherein determining includes accessing entity information for the selected device based on a profile generated for the device... | MXIE's IDM module allegedly onboards and profiles device capability data to determine compatibility for specific device/application pairings, accessing device profiles that include "self-description" attributes. | ¶59d | col. 4:9-19 |
| ...control operation of the device based on said determining, where control includes controlling exchange of a card element relative to the first device and the selected other device. | MXIE is alleged to orchestrate card/app deployments to and between devices, pushing configuration and application deployment events that reflect the assignment and exchange of the card element. | ¶59e | col. 4:32-36 |
| ...updating a card profile for the card element including updating card metadata stored by the platform...to recognize assignment of the card element to the selected other device. | MXIE's device management platform allegedly maintains assignment and status metadata for each application (card) and device, resulting in an up-to-date "card" profile that recognizes the assignment. | ¶59f | col. 4:51-54 |
- Identified Points of Contention:
- Scope Questions: The infringement theory equates a software "application" in Nokia's catalog with the patent's "card element." A key legal question will be whether the term "card element", as defined and used in the patent, is broad enough to read on a deployable software application, or if it implies a more specific data structure or graphical object.
- Technical Questions: Claim 11 requires the command to be an "exchange of the card element for exchange of at least one of content and capabilities." The analysis may turn on whether assigning an application from a catalog to a device in the accused system technically constitutes this specific, double-layered "exchange" function, or if it is a simpler one-way deployment.
V. Key Claim Terms for Construction
For the ’602 Patent:
- The Term: "capability matching"
- Context and Importance: This term is the core of the asserted intelligence in the system. The infringement case hinges on whether the process Nokia's IOC uses to align device attributes with application logic qualifies as "capability matching." Practitioners may focus on this term because the complaint's allegations are described at a high level of abstraction, suggesting the technical details of the matching process will be a central point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification may describe the process in general terms, such as an application comparing its needs to a device's reported functions, which could support a broader definition not tied to a specific algorithm. For example, the patent states determining capabilities is based on an "application profile for the second device and capabilities output by the second device" (’602 Patent, claim 11), which suggests a comparison of two sets of data.
- Evidence for a Narrower Interpretation: The specification describes using structured data fields like "capability_uid," "capability_name," and "capability_api_uri" (Compl. ¶32). A defendant may argue that "capability matching" requires a direct comparison of these specific, enumerated data structures, rather than a more general evaluation of device properties by a rule engine.
For the ’570 Patent:
- The Term: "card element"
- Context and Importance: The entire claim revolves around the presentation, assignment, and exchange of "card elements." Plaintiff's theory equates this term with Nokia's deployable "applications." The viability of this theory depends entirely on the construed scope of "card element."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract describes a platform for "operation with card elements," and the patent discusses managing the "exchange of card elements" between devices (Compl. ¶¶55, 56). This could support a reading where a "card element" is any modular unit of functionality or content designed for exchange within the platform.
- Evidence for a Narrower Interpretation: The patent repeatedly refers to a "card element displayed by the user interface" and a "device row displaying a plurality of device card elements" (Compl. ¶55; ’570 Patent, claim 11). A defendant may argue that this language, combined with figures that may depict card-like graphical objects, limits the term to a specific visual and data construct, not a general software application.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement across all asserted patents, stating that Nokia provides "documentation, support services, and marketing materials" that instruct and encourage customers to use the accused products in an infringing manner (e.g., Compl. ¶¶43-44, 66-67). Contributory infringement is also alleged on the basis that the accused products are material components of the claimed inventions, are not staple articles of commerce, and are known by Nokia to be especially adapted for infringement (e.g., Compl. ¶¶47, 70).
- Willful Infringement: The complaint alleges willfulness on two potential grounds. First, it alleges pre-suit knowledge of the patents as of October 13, 2025 (e.g., Compl. ¶¶44, 67). Second, it asserts that infringement has been willful "at least since the filing of the complaint," establishing post-suit knowledge as an independent basis (e.g., Compl. ¶¶50, 73).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the terminology of the patents, which centers on concepts like "card elements" and "capability matching," read on the accused system's architecture of "applications," "device profiles," and "rule engines"? The outcome may depend on whether the court construes these patent terms broadly as functional descriptors or narrowly as specific technical implementations.
- A second central question will be one of system-level functionality: do Nokia's accused products, when used as intended, perform the specific, multi-step process sequences required by the claims? For instance, does the interaction between the DAC Manager, MXIE, and an end device execute the full discover-profile-capabilities-control sequence claimed in the ’649 patent, or is there a functional or architectural mismatch?
- A final key question will be one of infringing combination: the infringement allegations often span multiple Nokia products (e.g., MXIE, IDM, DAC Manager). A crucial point of contention will likely be whether these separate products combine to form a single infringing "device" or "system" as required by the claims, or if their functionalities are too distinct to be considered a single infringing instrumentality under the control of one party.