DCT

2:25-cv-01217

IoT Innovations LLC v. Resideo Technologies Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01217, E.D. Tex., 12/12/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants have committed acts of infringement in the District and maintain a regular and established place of business in the District, specifically a logistics and distribution facility in Fort Worth.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home products, including thermostats, security system communicators, and control panels, infringe four patents related to methods for secure network routing, dynamic wireless channel allocation, and Quality of Service (QoS) setup.
  • Technical Context: The patents-in-suit relate to foundational communication protocols for managing secure connectivity, data traffic, and resource allocation in mobile and wireless networks, technologies integral to the functioning of Internet of Things (IoT) devices.
  • Key Procedural History: The complaint notes that U.S. Patent No. 8,175,037 is a continuation of the application that resulted in U.S. Patent No. 7,756,073, with both patents sharing the same priority date. No other significant procedural history is mentioned in the complaint.

Case Timeline

Date Event
2000-01-07 ’423 Patent Priority Date
2001-11-05 ’270 Patent Priority Date
2002-09-20 ’073 & ’037 Patent Priority Date
2010-01-05 ’423 Patent Issued
2010-07-13 ’073 Patent Issued
2011-07-26 ’270 Patent Issued
2012-05-08 ’037 Patent Issued
2025-02-13 Ademco Inc. converts to Resideo LLC
2025-12-12 Complaint Filing Date

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

U.S. Patent No. 7,756,073 - "Method For Updating A Routing Entry"

Issued July 13, 2010

The Invention Explained

  • Problem Addressed: The patent addresses a security vulnerability in the Mobile IPv6 protocol, where a malicious node could send fraudulent "Binding Update" messages to redirect a mobile node's traffic. The standard security solution, the "Return Routability" test, relies on an encrypted channel that is often blocked by network firewalls, rendering it unusable in many real-world environments (’073 Patent, col. 2:40-52).
  • The Patented Solution: The invention proposes an alternative verification method that can operate through firewalls. A mobile node (MN) sends its Binding Update to a correspondent node (CN) while separately sending verification information (specifically, a cryptographic hash of the update) to its trusted home agent (HA). The CN, upon receiving the update, contacts the HA to retrieve the verification information. If the information matches what the CN calculates from the update it received, the update is authenticated. This three-party handshake avoids the need for a direct encrypted tunnel between the MN and its HA (’073 Patent, Abstract; Fig. 1).
  • Technical Importance: This method provides a mechanism to securely maintain mobile network sessions for devices operating in environments with common security features like firewalls, which could otherwise prevent secure roaming (’073 Patent, col. 4:9-16).

Key Claims at a Glance

  • The complaint asserts independent claim 15 and dependent claim 17 (Compl. ¶34).
  • Independent Claim 15 requires, at a first communication node (the CN), the essential elements of:
    • Receiving a request for a routing entry update from a second communication node (the MN).
    • Verifying the authenticity of the update request via communication with a routing node (the HA).
    • Updating the routing entry if authenticity is verified.
    • The verification step itself includes transmitting a "random challenge" to the routing node and receiving back the random challenge along with a "function of address information" of the second communication node (’073 Patent, col. 9:8-24).

U.S. Patent No. 8,175,037 - "Method For Updating A Routing Entry"

Issued May 8, 2012

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’073 patent, this patent addresses the same problem: enabling secure updates of routing information for mobile nodes in networks where firewalls may block standard security protocols (’037 Patent, col. 2:50-61).
  • The Patented Solution: The patent describes the same fundamental three-party verification protocol involving a mobile node (MN), a correspondent node (CN), and a home agent (HA). The claims in this patent are structured differently but cover the same core inventive concept of using the HA as a trusted intermediary to validate Binding Updates sent from the MN to the CN (’037 Patent, Abstract; Fig. 1).
  • Technical Importance: The technical importance is identical to that of the parent ’073 Patent, focusing on enabling secure mobile communications in firewalled network environments (’037 Patent, col. 4:10-15).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claim 4 (Compl. ¶43).
  • Independent Claim 1 requires, at a first communication node (the CN), the essential elements of:
    • Receiving a request for a routing entry update from a second communication node (the MN).
    • Verifying authenticity by transmitting a request for verification to a routing node (the HA).
    • Receiving from the routing node a verification response containing "information previously transmitted to the routing node by the second communication node."
    • Updating the routing entry if authenticity is verified (’037 Patent, col. 8:6-22).

U.S. Patent No. 7,643,423 - "Dynamic Channel Allocation In Multiple-Access Communication Systems"

Issued January 5, 2010

  • Technology Synopsis: This patent addresses inefficient channel allocation in wireless systems like GPRS/EDGE. The problem is that critical control information for multiple users is often embedded within data blocks optimized for a single user, making it difficult for other users on the shared channel to decode it. The patented solution designates a specific "reservation set" block within a multi-frame data structure to carry this shared allocation information in a robust "broadcast" mode that all users can receive, freeing the remaining blocks to be optimized for their individual recipients (’423 Patent, Abstract; col. 6:18-33).
  • Asserted Claims: Independent claim 1 and dependent claims 2, 9, and 10 (Compl. ¶52).
  • Accused Features: The complaint alleges infringement by Defendants' smart home products that use wireless protocols but does not specify which product features are accused of infringing this patent (Compl. ¶23).

U.S. Patent No. 7,987,270 - "Apparatus, And Associated Method, For Facilitating QoS And Bearer Setup In An IP-Based Communication System"

Issued July 26, 2011

  • Technology Synopsis: This patent addresses the challenge of initiating a Quality of Service (QoS) or "bearer" setup for a mobile device in an IP-based network. The problem is that prior methods required a direct, and therefore unscalable, interface between an application server and the network's bearer manager. The invention proposes using the existing AAA (Authentication, Authorization, Accounting) infrastructure as an intermediary; an application-level request is sent to a transport-level AAA entity, which then securely routes the request to the appropriate bearer manager, eliminating the need for a direct interface (’270 Patent, Abstract; col. 3:17-34).
  • Asserted Claims: Independent claim 10 (Compl. ¶61).
  • Accused Features: The complaint accuses Defendants' smart home products generally but does not link specific product features to this patent's claims (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

  • The accused products are a wide range of Resideo and Honeywell Home branded smart home devices, components, software, and services (Compl. ¶¶13-14). This includes, among others, the Resideo Smart Home App, the Total Connect 2.0 App, various 4G LTE communicators for VISTA and LYNX security systems, and PROLTE series cellular communication modules (Compl. ¶¶24, 11).

Functionality and Market Context

  • The complaint describes the accused products as smart home devices that "connect to other devices in a network or other networks using a wireless protocol, such as Wi-Fi" (Compl. ¶23). These devices include programmable thermostats, security panels, and cellular/internet communicators that enable remote monitoring and control of home systems (Compl. ¶¶23-24). The complaint alleges that the business segments responsible for these products reported combined external revenues exceeding $6 billion in 2023, indicating significant market presence (Compl. ¶22).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain narrative infringement allegations or claim charts mapping elements of the asserted claims to the accused products. Instead, it references Exhibits A, B, C, and D, which were not filed with the complaint, as providing "Evidence of Use" for each of the four asserted patents (Compl. ¶¶34, 43, 52, 61). As such, the specific infringement theory is not detailed in the provided document.

  • Identified Points of Contention:
    • Architectural Mapping: A primary question for the ’073 and ’037 patents will be factual: does the Resideo ecosystem—comprising smart devices, user apps, and backend servers—implement the specific three-party architecture of a mobile node, correspondent node, and home agent as required by the claims? The complaint does not provide facts to support such a mapping.
    • Protocol Equivalence: For all asserted patents, a central issue may be whether the communication protocols used by the accused products (e.g., standard Wi-Fi, LTE) perform the specific functions claimed in patents that describe solutions in the context of different or older protocols (e.g., Mobile IPv6 for the ’073/’037 patents; GPRS/EDGE for the ’423 patent). The complaint does not allege that the accused products practice these specific protocols.
    • Functional Mismatch: For the ’270 patent, a key technical question will be whether the Resideo system initiates QoS or bearer setup using an application-level request that is routed through a transport-level AAA infrastructure to a bearer manager, as the claim requires.

V. Key Claim Terms for Construction

’073 Patent (Asserted Claim 15)

  • The Term: "routing entry"
  • Context and Importance: This term defines the data that is being updated. The patent's specification frames this in the context of a Mobile IPv6 "binding cache." The dispute will likely focus on whether session data or connection tables within the Resideo server architecture constitute a "routing entry" as contemplated by the patent, which is critical for determining infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself is general and could be argued to encompass any data structure used to direct network traffic associated with a specific node.
    • Evidence for a Narrower Interpretation: The specification consistently describes the invention in the context of Mobile IPv6, stating the goal is to update a "binding cache at the correspondent node CN" (’073 Patent, col. 1:46-49). This context may support an interpretation limiting the term to data structures that perform the specific function of a Mobile IP binding cache entry.

’037 Patent (Asserted Claim 1)

  • The Term: "routing node"
  • Context and Importance: This term identifies the trusted third-party entity used for verification. Its construction is central to determining what type of server in the accused infrastructure could satisfy this claim element. Practitioners may focus on this term because the patent's examples define it narrowly, while infringement may depend on a broader reading.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning could encompass any network node that participates in routing or verification processes, not limited to a specific protocol-defined entity.
    • Evidence for a Narrower Interpretation: The specification explicitly equates the "routing node" with a "home agent HA (of the mobile node MN)" (’037 Patent, col. 1:43-45). This could be used to argue that the term is limited to an entity that performs the specific role of a Home Agent in a Mobile IP framework.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement (Compl. ¶12) and states that "Defendants each instruct their customers, agents, employees, and affiliates regarding how to use the Accused Products," which may form the basis for a claim of induced infringement (Compl. ¶25). No specific facts, such as citations to user manuals or instructional materials, are provided to support this allegation.

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

The disposition of this case may turn on the resolution of several fundamental, open questions for the court.

  • A core issue will be one of architectural applicability: can the Plaintiff demonstrate that the architecture of the accused Resideo smart home ecosystem—consisting of end-user devices, applications, and backend cloud servers—maps onto the specific multi-party network structures (e.g., the mobile node, correspondent node, and home agent triad) recited in the claims of the ’073 and ’037 patents?
  • A second key question will be one of protocol translation: will the scope of claim terms rooted in the context of specific, and potentially dated, communication standards (such as Mobile IPv6 and GPRS/EDGE) be construed broadly enough to read on the functionality of the more modern, mainstream wireless protocols presumably used by the accused products?
  • Finally, the case presents a significant evidentiary question: given the absence of technical detail in the complaint, what evidence will be presented to show that the accused products actually perform the highly specific methods of secure handshake, channel reservation, and bearer setup as claimed in the patents-in-suit?