DCT

2:25-cv-01246

Cloud Controls LLC v. AT&T Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01246, E.D. Tex., 12/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants have regular and established places of business in the district, including multiple retail stores, and have committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendants' sale and service of a wide range of smartphones, tablets, headphones, and smart speakers from various manufacturers infringes six patents related to mobile device user interface, wireless connectivity, authentication, audio management, data serving, and messaging technologies.
  • Technical Context: The patents-in-suit relate to foundational user experience and hardware features for mobile electronic devices, a market segment characterized by intense competition and rapid technological evolution.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2001-09-25 Earliest Priority Date for ’703 Patent
2002-10-15 Earliest Priority Date for ’699 Patent
2003-03-28 Earliest Priority Date for ’446 Patent
2004-06-21 Earliest Priority Date for ’003 Patent
2007-01-08 Earliest Priority Date for ’552 Patent
2007-01-08 Earliest Priority Date for ’087 Patent
2007-01-23 ’703 Patent Issued
2009-11-03 ’446 Patent Issued
2012-06-05 ’087 Patent Issued
2017-02-28 ’003 Patent Issued
2017-04-11 ’699 Patent Issued
2018-07-17 ’552 Patent Issued
2025-12-23 Complaint Filing Date

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

U.S. Patent No. 10,025,552 - *“Selective Locking of Input Controls of a Portable Media Player”*

The Invention Explained

  • Problem Addressed: The patent asserts that conventional locking mechanisms for portable media players were overly restrictive, preventing users from performing simple, desired actions like adjusting volume without fully unlocking the device, which could lead to other inadvertent inputs (Compl. ¶19; ’552 Patent, col. 1:36-41).
  • The Patented Solution: The invention is a system that allows for the selective locking of input controls. A user can configure the device for a specific "operational mode" (e.g., "walking," "working out"), and in that mode, certain pre-selected controls (like volume) remain active even when the device is in a locked state, while other controls are disabled to prevent accidental activation (’552 Patent, col. 2:1-17, col. 4:20-29).
  • Technical Importance: This approach improves the user experience by allowing access to essential functions while the device is safely locked, balancing convenience with the need to prevent unwanted commands (Compl. ¶19; ’552 Patent, col. 2:18-21).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶50).
  • Claim 1 of the ’552 Patent recites:
    • An apparatus, comprising:
    • A selection input to receive individual selections of one or more control components during a configuration for an individual operational mode.
    • The selected components are to remain enabled when the apparatus is in a locked state during that operational mode.
    • The same components are not enabled when the apparatus is in the locked state during a different operational mode.
    • A first control component and a second control component.
    • A control selection component to switch the apparatus between a locked and an unlocked state.
    • The apparatus is prevented from acting on input from the unselected second control component but is allowed to act on input from the selected first control component when in the locked state for that operational mode.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,195,087 - *“Controlling of Wireless Connection of a Portable Device Including an Illuminating Component or Switch”*

The Invention Explained

  • Problem Addressed: The patent describes a challenge for users of early portable media players who found it "difficult to manage or properly utilize the wireless capabilities" of their devices, as wireless connectivity was not a primary, well-integrated feature (Compl. ¶24; ’087 Patent, col. 1:30-34).
  • The Patented Solution: The invention provides a dedicated input control, such as an external button, that acts as a connection initiator and a status indicator for wireless communications. This button can include an "illumination component" that provides a visual indication of the network connection status, such as through different colors or blinking patterns, to the user (’087 Patent, Abstract; col. 2:1-14).
  • Technical Importance: The invention aims to simplify wireless network management on portable devices by providing a clear, dedicated physical interface for initiating connections and understanding the current connectivity status (Compl. ¶24; ’087 Patent, col. 2:1-14).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶62).
  • Claim 1 of the ’087 Patent recites:
    • A system for connecting a portable media player with a wireless communications network, comprising:
    • An actuator located on the portable media player.
    • A wireless connection component configured to search for and display available wireless networks upon selection of the actuator when not connected.
    • An illumination component associated with the actuator, configured to indicate a communications state of the wireless connection via a mode of illumination.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,613,446 - *“Wireless Mobile Phone with Authenticated Mode of Operation Including Finger Print Based Authentication”*

  • Patent Identification: U.S. Patent No. 7,613,446, “Wireless Mobile Phone with Authenticated Mode of Operation Including Finger Print Based Authentication,” issued November 3, 2009.
  • Technology Synopsis: The patent describes a method for authenticating a user on a mobile device via a fingerprint sensor, which can be integrated with a power-on button. Based on whether authentication is successful, the device makes different sets of functions available, thereby preventing unauthorized access to sensitive data or features (’446 Patent, Abstract; Compl. ¶30).
  • Asserted Claims: At least claim 8 is asserted (Compl. ¶74).
  • Accused Features: The complaint accuses products that use an "input mechanism... to make functions of the device available based on authentication performed via the mechanism" (Compl. ¶83).

U.S. Patent No. 9,621,699 - *“Mobile Digital Communication/Computing Device Having a Context Sensitive Audio System”*

  • Patent Identification: U.S. Patent No. 9,621,699, “Mobile Digital Communication/Computing Device Having a Context Sensitive Audio System,” issued April 11, 2017.
  • Technology Synopsis: The patent addresses the problem of audio alerts (e.g., a call notification) interfering with media playback (e.g., music). The invention provides a "context sensitive" system where an alert starts at a non-intrusive volume level relative to the ongoing media audio and then increases until the user responds (’699 Patent, Abstract; Compl. ¶34).
  • Asserted Claims: At least claim 10 is asserted (Compl. ¶86).
  • Accused Features: The complaint accuses products that provide "audio signals at different volume levels" where an alert's volume level is initially low but increases until the user responds (Compl. ¶95).

U.S. Patent No. 9,585,003 - *“Serving Data/Applications from a Wireless Mobile Phone”*

  • Patent Identification: U.S. Patent No. 9,585,003, “Serving Data/Applications from a Wireless Mobile Phone,” issued February 28, 2017.
  • Technology Synopsis: The patent describes a method enabling a wireless mobile phone to serve data or applications to other computing devices, such as client computers. The system is designed to overcome the technical hurdle that mobile phones typically lack a persistent internet connection or a stable IP address (’003 Patent, Abstract; Compl. ¶38).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶98).
  • Accused Features: The complaint accuses products with features for "serving data or applications from mobile devices" (Compl. ¶107).

U.S. Patent No. 7,167,703 - *“Wireless Mobile Image Messaging”*

  • Patent Identification: U.S. Patent No. 7,167,703, “Wireless Mobile Image Messaging,” issued January 23, 2007.
  • Technology Synopsis: The patent addresses the "limited input capabilities" of early mobile devices by creating a method for non-verbal communication using images. A user can select images from predefined categories to graphically convey information (e.g., mood, location) in a message to another user (’703 Patent, Abstract; Compl. ¶42).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶110).
  • Accused Features: The complaint accuses products with features for "sending image messages from one mobile device to another" (Compl. ¶119).

III. The Accused Instrumentality

Product Identification

The complaint identifies a broad and extensive range of "Accused Products," including "Smartphones," "Tablets," "Earbuds / Headphones," and "Speakers / Smart-Speakers" (Compl. ¶45). The list includes dozens of specific product lines from numerous manufacturers such as Apple, Motorola, Google, LG, Sonim, AT&T, Alcatel, Kyocera, Blackberry, Microsoft, Razer, Lenovo, TCL, Bose, JLab, Beats, Skullcandy, Plantronics, Speck, Ultimate Ears, TYLT, Altec Lansing, and ION (Compl. ¶45).

Functionality and Market Context

The complaint alleges that these products incorporate functionalities that map to the technologies of the patents-in-suit. These functionalities include, but are not limited to, user-configurable lock screens, management of wireless connections with status indicators, fingerprint-based authentication, context-aware audio management for notifications, the ability to serve data to other devices (e.g., tethering or hotspots), and image-based messaging systems (e.g., emojis or stickers) (Compl. ¶¶ 59, 71, 83, 95, 107, 119). The accused products represent a significant portion of the consumer electronics market in the United States. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits G-L, but these exhibits were not filed with the public complaint. The infringement theories are summarized below in prose based on the complaint's narrative allegations.

’552 Patent Infringement Allegations Summary

The complaint alleges that the Accused Products directly and indirectly infringe at least claim 1 of the ’552 Patent. The narrative theory is that the Accused Products incorporate a "selective locking system" that constitutes a material part of the invention (Compl. ¶¶ 50, 59). This functionality allegedly allows a user to prevent input on certain controls while the device is locked, which maps to the elements of claim 1. This likely refers to features in modern operating systems that permit access to certain functions like music controls, camera, or system settings from the lock screen.

’087 Patent Infringement Allegations Summary

The complaint alleges that the Accused Products infringe at least claim 1 of the ’087 Patent. The theory centers on the claim's requirement for an "illumination component" that "indicates a communication state of the wireless connection" (Compl. ¶¶ 24, 71). The accused "special features" allegedly perform this function. This could refer to on-screen software icons (e.g., Wi-Fi, Bluetooth, cellular data symbols) that change appearance to reflect connectivity status, or to physical indicator lights on peripheral devices like earbuds and their charging cases.

Identified Points of Contention

  • Scope Questions: A central question for both patents may be whether the term "portable media player," as used in the specifications from the mid-2000s, can be construed to cover the diverse range of modern accused instrumentalities, including smartphones, tablets, and smart speakers. For the ’087 Patent, a further question is whether a software-based, on-screen graphical user interface element can be considered an "illumination component" that is "associated with an actuator" in the manner claimed.
  • Technical Questions: For the ’552 Patent, a key technical question is what evidence exists that the accused devices perform the claimed "selection input" step, which requires receiving "individual selections" from a user to configure which controls remain active during a specific "operational mode." The analysis may focus on whether default operating system settings meet this limitation or if it requires an explicit, granular user-customization process. For the ’087 Patent, a question may be whether the accused on-screen icons or indicator lights display different "mode[s] of illumination" corresponding to different communication states as required by the claims.

V. Key Claim Terms for Construction

For the ’552 Patent

  • The Term: "selection input to receive individual selections of one or more control components ... during a control component configuration for an individual operational mode" (from claim 1).
  • Context and Importance: This term is critical because infringement may depend on whether the Accused Products allow for the specific, user-driven configuration process recited in the claim. Practitioners may focus on whether a device's default lock-screen behavior satisfies this element, or if it requires a distinct setup phase where a user actively selects which controls to enable for different modes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses user-selectable "modes" such as "'walking,' 'working out,' 'traveling'," which could suggest the selection is mode-based rather than requiring a granular, control-by-control checkbox interface (’552 Patent, col. 4:26-29).
    • Evidence for a Narrower Interpretation: The claim's use of "individual selections" and the specification's mention of a user making selections "during an initial set up of his/her player" could support a narrower reading that requires a specific, explicit configuration action by the user for each control component (’552 Patent, col. 4:20-22).

For the ’087 Patent

  • The Term: "illumination component" (from claim 1).
  • Context and Importance: The infringement case may turn on whether this term is limited to a physical, hardware-based light source or can encompass a software icon on a display. Practitioners may focus on this term to determine if the patent's scope can reach modern graphical user interfaces.
  • Evidence for a Broader Interpretation: The patent's stated purpose is to provide a "visual indication of the network connection status," a function that an on-screen icon arguably performs (’087 Patent, col. 2:11-14). The term itself is not explicitly limited to hardware in its plain meaning.
  • Evidence for a Narrower Interpretation: The patent abstract describes a "button that includes an indicator light," and the patent's title in the complaint is "Controlling of Wireless Connection of a Portable Device Including an Illuminating Component or Switch," suggesting the "component" is a physical object integrated with a switch (Compl. ¶23; ’087 Patent, Abstract).

VI. Other Allegations

Indirect Infringement

For each asserted patent, the complaint alleges induced infringement, stating on information and belief that Defendants provide customers with "extensive customer support and instructions that instructed and encouraged their customers to infringe" (e.g., Compl. ¶54, ¶66). It also alleges contributory infringement, asserting that the Accused Products contain "special features" that are material to the inventions and are not staple articles of commerce suitable for substantial non-infringing use (e.g., Compl. ¶59, ¶71).

Willful Infringement

The complaint alleges that Defendants' infringement was and continues to be willful. It asserts that Defendants have had knowledge of the patents-in-suit and their infringement at least from the date of service of the complaint (e.g., Compl. ¶52, ¶60). The complaint states that further discovery may reveal evidence of pre-suit knowledge (Compl. ¶47).

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

  • A core issue will be one of claim construction and technological scope: Can claim terms drafted for early-generation "portable media players" and "mobile phones" (e.g., "selection input," "illumination component") be construed to read on the highly integrated, software-driven features of modern smartphones, tablets, and related peripherals? The outcome of claim construction for these terms will be pivotal.
  • A second central question will be evidentiary and factual: Can the plaintiff demonstrate that the accused functionalities in a vast and technologically diverse range of products, spanning over a decade of development, actually operate in the specific manner required by each claim limitation? This may require detailed, product-by-product technical evidence.
  • A third key question will be case manageability and specificity: Given the assertion of six distinct patents against hundreds of products from over a dozen manufacturers, a significant challenge will be whether the plaintiff's broad allegations can be narrowed and substantiated with the specificity required as the case proceeds, or if the breadth of the accusation itself becomes a central point of contention.