DCT
2:25-cv-01177
Knossos Global Systems LLC v. BlackBerry Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Knossos Global Systems LLC (Texas)
- Defendant: BlackBerry Limited (Canada)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-01177, E.D. Tex., 11/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that does not reside in any U.S. judicial district. The complaint further supports venue by citing Defendant's business activities within the district and its history of litigating in the E.D. Tex.
- Core Dispute: Plaintiff alleges that Defendant’s secure enterprise communication products infringe a patent related to methods for private electronic information exchange using a server-managed "private domain" and hybrid encryption.
- Technical Context: The technology at issue involves creating secure communication channels within public networks by verifying participants and using a specific two-layer encryption process to protect both message content and user address information.
- Key Procedural History: The complaint notes that BlackBerry has been a party to multiple prior lawsuits in the Eastern District of Texas, which Plaintiff presents as evidence that the court is a foreseeable forum for disputes involving BlackBerry's products.
Case Timeline
| Date | Event |
|---|---|
| 2004-04-22 | U.S. Patent No. 8,819,410 Priority Date |
| 2014-08-26 | U.S. Patent No. 8,819,410 Issued |
| 2025-11-26 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,819,410 - “Private Electronic Information Exchange”
- Patent Identification: U.S. Patent No. 8,819,410 (“Private Electronic Information Exchange”), issued August 26, 2014 (the “’410 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section identifies the public and open nature of the Internet as a vulnerability for electronic communication, noting that standard email addresses are public and can be exploited by fraudsters for spam and spoofing, even when message content is encrypted (’410 Patent, col. 1:45-51, col. 2:26-40).
- The Patented Solution: The invention proposes a "private domain" for information exchange, which acts as a secure subset of a public network like the Internet (’410 Patent, col. 2:41-50). In this system, a central server authenticates senders and verifies whether recipients are members of the private domain. To send a message, the server provides the recipient's public key to the sender. The sender then encrypts the message with a newly created, unique symmetric key and separately encrypts that symmetric key using the recipient's public key, bundling them together for transmission (’410 Patent, Abstract; Fig. 6). This hybrid approach aims to secure both the message and the means of its decryption within a closed community.
- Technical Importance: The described method seeks to protect communication metadata (i.e., the sender and recipient identities) in addition to the message content, addressing a weakness in conventional email systems where addresses remain exposed (’410 Patent, col. 2:26-34).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 of the ’410 Patent (Compl. ¶27).
- The essential elements of independent claim 1 include:
- Registering a sender to access services of a private domain.
- Receiving data at a server indicating the sender is initiating a transmission to a recipient.
- Determining at the server whether the recipient is a member of the private domain.
- Providing the sender with a public cryptographic key associated with the recipient if the recipient is a member.
- Receiving, at the server, electronic information from the sender, where the information is encrypted by a symmetric key unique for the transmission.
- The electronic information further comprises a security package containing an encrypted version of the unique symmetric key, which itself was encrypted by the sender using the recipient's public key.
- Transmitting the electronic information and the security package over an electronic network to the recipient.
III. The Accused Instrumentality
Product Identification
- BlackBerry BBM Enterprise and BlackBerry Work (the “Accused Products”) (Compl. ¶18).
Functionality and Market Context
- The complaint alleges the Accused Products are "private electronic information exchange services" that Defendant provides to its customers (Compl. ¶18). A screenshot from BlackBerry's website, included as Exhibit 3, promotes a "Secure Digital Workplace" featuring "BBMe" (BlackBerry Messenger Enterprise) and "BlackBerry Work" as solutions for secure communication and access to work data (Compl., Ex. 3, p. 4). The complaint alleges these products create a "personal digital gateway" for transmissions between members of a private domain (Compl. ¶28).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,819,410 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| registering a sender to enable the sender to access services of a private domain... | The Accused Products register a sender to enable access to services of a private domain for electronic information transmissions between members. | ¶28 | col. 15:35-43 |
| receiving, at a server associated with the private domain, data from the sender indicating that the sender is initiating the transmission of electronic information... | A server associated with the private domain receives data from the sender indicating the initiation of a transmission to a recipient. | ¶28 | col. 16:26-34 |
| determining, at the server associated with the private domain, whether the recipient is a member of the private domain by examining a record of members... | The server determines if the recipient is a member of the private domain by examining a record of members. | ¶28 | col. 16:62-65 |
| providing to the sender, from the server associated with the private domain, a public cryptographic key associated with the recipient... | The server provides the sender a public cryptographic key associated with the recipient when the recipient is determined to be a member. | ¶28 | col. 17:10-14 |
| receiving, at the server...electronic information...encrypted by a symmetric cryptographic key that is unique for the transmission... | The server receives electronic information encrypted by a unique symmetric cryptographic key for that transmission. | ¶28 | col. 17:15-21 |
| ...wherein the electronic information further comprises a security package that contains an encrypted version of the symmetric cryptographic key, the encrypted version...encrypted by the sender using the public cryptographic key... | The electronic information includes a security package containing the symmetric key, which is itself encrypted using the recipient's public key. | ¶28 | col. 8:43-54 |
| transmitting the electronic information, with the security package, over an electronic network to the recipient. | The electronic information and security package are transmitted over a network to the recipient. | ¶28 | col. 18:61-65 |
Identified Points of Contention
- Scope Questions: A central question may be whether the architecture of BlackBerry’s enterprise services, which provide secure communication environments for corporate users, constitutes a "private domain" as contemplated by the patent. The analysis may explore whether the patent’s teachings require a specific addressing or routing scheme not present in the Accused Products.
- Technical Questions: The complaint alleges the use of a "symmetric cryptographic key that is unique for the transmission" (Compl. ¶28). A potential point of dispute is what technical evidence exists to demonstrate that the Accused Products generate a new, distinct symmetric key for each individual message transmission, as opposed to using a different key management protocol, such as session-based keys.
V. Key Claim Terms for Construction
The Term: "private domain"
- Context and Importance: This term is foundational to the patent's claims, defining the secure environment in which the invention operates. The outcome of the case may depend on whether BlackBerry's secure enterprise messaging systems are found to be "private domains."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a "private domain" as a "private network community" that is a "subset of the electronic network" and analogizes it to a "gated community" that "creates privacy in a physical world" (’410 Patent, col. 4:31-47). This language could support construing the term to cover any logically segregated, access-controlled communication system.
- Evidence for a Narrower Interpretation: The patent also describes embodiments using specific technical features, such as private routing addresses with a "private top level domain (PTLD)" that are not routable on the open internet (’410 Patent, col. 10:1-20). A defendant may argue that a "private domain" is limited to systems that incorporate such non-standard addressing schemes.
The Term: "a symmetric cryptographic key that is unique for the transmission"
- Context and Importance: This limitation defines a specific and potentially demanding requirement for key generation. Infringement may turn on whether the Accused Products practice this per-message key uniqueness.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "unique for the transmission" does not require a cryptographically new key for every single message but could refer to a key that is unique to a particular communication session or context.
- Evidence for a Narrower Interpretation: The specification provides strong support for a narrow, per-message interpretation, stating that "a symmetric key may be created every time a sender is transmitting an electronic message" and that "each message sent has a different and unique symmetric key" (’410 Patent, col. 11:15-21; col. 12:18-21).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, asserting that BlackBerry provides materials that instruct its customers on how to use the Accused Products in an infringing manner for private information exchanges (Compl. ¶¶14, 19).
- Willful Infringement: The complaint does not contain an allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "private domain," which is described in the patent with specific examples of proprietary, non-routable addresses, be construed to cover the secure, access-controlled environments of BlackBerry's enterprise communication products, which operate over the standard Internet protocol suite?
- A key evidentiary question will be one of technical implementation: what evidence will demonstrate that the Accused Products employ the specific two-step hybrid encryption method required by Claim 1, particularly the generation of a "unique" symmetric key for each individual message transmission, as distinguished from other secure key-management techniques common in enterprise software?