SecureNet Solutions Group LLC v. Signify NV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SecureNet Solutions Group, LLC (Florida)
  • Defendant: Signify N.V. and Signify Netherlands B.V. (Netherlands)
  • Plaintiff’s Counsel: Michael Best & Friedrich LLP
• Case Identification: 2:25-cv-01229, E.D. Tex., 12/18/2025
• Venue Allegations: Plaintiff alleges venue is proper in any judicial district, including the Eastern District of Texas, because Defendants are not residents of the United States. Plaintiff further alleges a substantial part of the infringing acts occurred in the district, citing sales to Texas customers and, until 2024, the operation of a design, testing, and manufacturing facility in San Marcos, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Hue Secure Ecosystem infringes three patents related to computerized security systems for correlating sensory events, weighting event data based on sensor attributes, and managing data in a hierarchical storage system.
• Technical Context: The technology at issue falls within the domain of smart surveillance and video analytics, a field focused on automatically processing data from sensors like video cameras to identify and respond to security events, which is a significant component of the consumer and commercial smart-building markets.
• Key Procedural History: The complaint notes that the asserted patents belong to the same family and proactively addresses patent eligibility under 35 U.S.C. §101. It references the prosecution history of a related patent where the applicant allegedly discussed "inventive concepts" with the patent examiner in the context of the Supreme Court's Alice decision, suggesting an anticipation of an eligibility challenge from the Defendant.

Case Timeline

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

U.S. Patent No. 11,323,314 - "Hierarchical Data Storage and Correlation System for Correlating and Storing Sensory Events in a Security and Safety System"

The Invention Explained

• Problem Addressed: The patent background describes limitations in prior art security systems, which were unable to effectively correlate data from sensors in different locations and at different times, or to account for the disparate quality of data from various sensors (e.g., an old analog camera versus a new digital one) (Compl. ¶¶55-56). This could lead to a failure to detect threats or an increase in false alarms (’314 Patent, col. 2:6-10).
• The Patented Solution: The invention is a computerized system that collects "primitive events" from various sensors, such as video cameras and card access systems (Compl. ¶33). A "correlation engine" then processes these events, correlating them across time and geographical space to identify compound or critical events (Compl. ¶¶35, 39). Crucially, the system weights the incoming data based on the "attribute data" of the sensors—such as their reliability, age, or maintenance history—to improve accuracy (Compl. ¶55; '314 Patent, col. 6:1-10). The system also employs a "Hierarchical Storage Manager" to intelligently store large volumes of data, cascading less important data to slower, lower-cost storage tiers (Compl. ¶¶49-50; '314 Patent, col. 12:43-49). Figure 1 of the patent illustrates this architecture, showing data from various sensors being normalized, processed by a correlation engine, and stored in a tiered system (’314 Patent, Fig. 1).
• Technical Importance: The described technical approach of weighting input data from disparate systems was intended to lower false alarm rates and filter out irrelevant or spurious information in complex surveillance environments (Compl. ¶56; ’314 Patent, col. 2:6-10).

Key Claims at a Glance

• The complaint asserts independent claim 13 (’314 Patent, col. 47:16-48:11; Compl. p. 1).
• Essential elements of Claim 13 include:
  • Receiving one or more sensory events from a sensory event analytics module, where the sensors include at least one IP video camera.
  • The sensory events are selected from a group including a face detected, a vehicle detected, a license plate detected, a size of an object, and a speed of an object.
  • A hierarchical storage manager having access to a hierarchy of two or more data storage devices, adapted to store and cascade data through the hierarchy based at least on the sensory events.
  • An event queue having access to an event database to store the sensory events for later retrieval.
  • A correlation module to evaluate one or more historical correlations among stored sensory events across at least one of time and space.
  • The correlation module is adapted to monitor received sensory events to identify critical events based on the historical correlations.
  • An alerting module to send alerts based on the critical events, where communication between modules occurs over an IP network.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,929,870 - "Correlation Engine for Correlating Sensory Events"

The Invention Explained

• Problem Addressed: As a member of the same patent family, the ’870 Patent addresses the same technical problems as the ’314 Patent: the inability of prior art systems to effectively correlate disparate sensor data across time and space and to account for varying data quality (Compl. ¶¶55-56).
• The Patented Solution: The ’870 Patent describes a similar solution centered on a "correlation engine" that processes sensory events from sources like IP cameras (’870 Patent, Abstract). The system evaluates historical correlations and weights the sensory events based on "attribute data" of the sensors used to capture the data, aiming to provide more accurate and intelligent security analysis (Compl. ¶¶32, 55; ’870 Patent, col. 1:15-2:10). The overall architecture of data ingestion, correlation, and alerting is consistent with that described for the ’314 Patent.
• Technical Importance: The technical approach is aimed at improving computerized security systems by making them more discerning and less prone to false alarms through computerized weighting and correlation (Compl. ¶56).

Key Claims at a Glance

• The complaint asserts independent claim 20 (’870 Patent, col. 49:21-50:20; Compl. p. 1).
• Essential elements of Claim 20 include:
  • A non-transitory storage medium with code for a hardware processor to implement a system.
  • A receiver module to receive sensory events from an analytics module, where sensors include at least one IP video camera.
  • The sensory events are selected from a group including a face detected, a vehicle detected, and a license plate detected.
  • An event queue with access to an event database for storing sensory events.
  • A correlation module to evaluate historical correlations among the stored sensory events across time and space, based on at least weighting of the stored sensory events.
  • An alerting module to send alerts based on critical events identified by the correlation module.
  • A hierarchical storage manager to store and cascade data through a hierarchy of data storage devices based at least on the sensory events.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,375,342 - "Correlation Engine for Correlating Sensory Events"

Multi-Patent Capsule

• Technology Synopsis: Belonging to the same patent family, this patent also describes a computerized security system. The invention centers on a "correlation engine" that receives sensory data from IP video cameras, evaluates historical correlations across time and space, and weights events based on sensor attribute data to improve the accuracy of event detection and alerting (Compl. ¶¶32, 55-56; '342 Patent, Abstract).
• Asserted Claims: Independent claim 17 is asserted (Compl. p. 1).
• Accused Features: The complaint alleges that the Hue Secure Ecosystem's use of IP video cameras, its cloud-based processing for event detection (e.g., face detected), its hierarchical data storage, and its correlation and alerting functions infringe this patent (Compl. ¶¶78-79, 83-84, 87-88, 91-92, 97-98).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the "Philips Hue Ecosystem," which is alleged to include the Signify Secure Camera, Signify Bridge Pro, Signify Hue Application, and Signify Cloud (Compl. ¶¶1, 75).

Functionality and Market Context

• The Hue Secure Ecosystem is a smart home security system that uses IP video cameras ("Secure Cameras") to capture video upon motion detection (Compl. ¶80). The complaint alleges that the "Hue Cloud" component performs additional processing on the video data to detect and identify persons, faces, and objects such as packages (Compl. ¶80).
• The system offers subscription-based "Home security plans" that provide features including "AI-powered person, animal, vehicle, and package detection" and "Instant motion notifications" (Compl. ¶22).
• The complaint alleges a hierarchical storage structure where data is first buffered on the Secure Cameras, then recorded video is stored in the Hue Cloud, and finally an event timeline is cached and made available to the user's smartphone via the Hue Application (Compl. ¶84). A screenshot of the subscription plans shows options for 24-hour, 30-day, or 60-day video history, which the complaint uses as evidence of this storage structure (Compl. p. 40).
• The system is sold to U.S. customers, including those in Texas, through the Philips Hue website and U.S. retailers such as Home Depot (Compl. ¶¶18, 21). Screenshots from the Home Depot website show various "Hue Secured" products for sale, including wired and battery-operated cameras (Compl. p. 9).

IV. Analysis of Infringement Allegations

’314 Patent Infringement Allegations

’870 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether the term "hierarchical storage manager" that "cascades" data, as described in the patent specification, reads on the accused product's time-based cloud storage and retention model (e.g., 30-day or 60-day history). The patent describes cascading as a mechanism to move data between faster and slower storage tiers based on a calculated "importance" score to manage space (’314 Patent, col. 13:61-17:13), whereas the accused system appears to use time-based deletion.
• Technical Questions: The analysis may turn on whether the accused product's user-configurable "Activity Zones" and "sensitivity" settings (Compl. ¶92) perform the function of "weighting" based on "attribute data of the...sensors" as required by the claims. The patents describe "attribute data" as intrinsic sensor characteristics like age, reliability, and maintenance history (’314 Patent, col. 3:42-55). It is an open question whether a user-defined spatial filter is equivalent to a system-applied weight based on inherent sensor quality.

V. Key Claim Terms for Construction

• The Term: "hierarchical storage manager...adapted to manage storage and cascade of data" (’314 Patent, cl. 13)

• Context and Importance: This term's construction is fundamental to the infringement case. The dispute will likely focus on whether the accused system's storage model (local buffer, cloud storage with fixed retention, app cache) qualifies as the "cascading" hierarchy described in the patents. Practitioners may focus on this term because the patent specification provides a detailed, formula-driven definition of "cascading" based on an "importance ('Y')" value, which may be narrower than the functionality of the accused product (’314 Patent, col. 13:1-14).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself requires a "hierarchy of two or more data storage devices" and cascading "based at least on the sensory events." Plaintiff may argue that the local camera buffer, cloud storage, and app cache constitute at least two tiers, and that time-based retention (e.g., deleting events older than 60 days) is a form of cascading based on the event's age.
  • Evidence for a Narrower Interpretation: The detailed description explains that cascading moves "unused data...to lower level storage devices" to "free[] up higher level (faster) storage devices" (’314 Patent, col. 12:43-49). It provides a specific formula for calculating an "importance ('Y')" value to govern this process (’314 Patent, eq. A). A defendant may argue this detailed embodiment limits the claim term to a system that actively manages data movement between tiers to optimize storage, not one that simply deletes old data.

• The Term: "sensory events are weighted based at least on one or more attribute data of the one or more sensors" (’870 Patent, cl. 20)

• Context and Importance: This term is critical for determining infringement of the weighting limitation. The complaint alleges that user-defined "Activity Zones" and "sensitivity" adjustments constitute weighting (Compl. ¶92). Practitioners may focus on this term because there appears to be a potential mismatch between the patent's definition of "attribute data" and the accused functionality.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Plaintiff could argue that by creating an Activity Zone, a user is instructing the system to apply a higher weight to events inside the zone and a lower (or zero) weight to events outside it, and that this constitutes "weighting based at least on" data from the sensor (i.e., the spatial location of the event).
  • Evidence for a Narrower Interpretation: The specification defines "attribute data" as data about the sensor itself, such as "quality of the data produced by the sensory device, the age of the sensory device, time since the sensory device was last maintained," and its reliability (’314 Patent, col. 6:1-10). A defendant could argue this limits the term to weighting based on intrinsic hardware characteristics, not user-drawn software filters applied after the data is captured.

VI. Other Allegations

• Indirect Infringement: The complaint alleges Defendants induced infringement by directing and controlling subsidiaries that sell the accused products in the U.S. and by placing the products into the stream of commerce with the knowledge that they would be used in an infringing manner (Compl. ¶¶11, 24a, 102). The factual basis provided is general and does not cite specific instructional materials or manuals.
• Willful Infringement: The complaint does not allege any pre-suit knowledge of the asserted patents. The prayer for relief seeks a finding of an exceptional case and enhanced damages, which suggests that willfulness allegations are based on knowledge gained from the filing and service of the complaint itself (Compl. p. 47, ¶e).

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

• A core issue will be one of definitional scope: can the patent term "hierarchical storage manager" that "cascades" data based on a calculated "importance" value be construed to cover the accused product's time-based cloud video retention and deletion system?
• A key evidentiary question will be one of technical and functional equivalence: does the accused system's use of user-defined "Activity Zones" and "sensitivity" settings perform the function of "weighting" based on the intrinsic "attribute data of the...sensors" (e.g., camera age, quality, reliability) as required by the claims, or is there a fundamental mismatch in technical operation?
• A third question will concern patent eligibility: given the complaint's pre-emptive discussion of the Alice framework, the patentability of the claims under 35 U.S.C. §101, which addresses abstract ideas implemented on a computer, will likely be a central point of early motion practice in the case.