DCT

2:25-cv-01248

Cloud Controls LLC v. T-Mobile USA Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01248, E.D. Tex., 12/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business, such as retail stores, within the Eastern District of Texas and has committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s sale and distribution of a wide range of smartphones, tablets, headphones, and smart speakers infringes six patents related to mobile device user interface, wireless connectivity, authentication, audio management, data serving, and messaging functionalities.
  • Technical Context: The patents-in-suit cover foundational features of modern mobile and connected devices, addressing user experience challenges that arose as portable electronics evolved to include multimedia, wireless networking, and enhanced security capabilities.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2001-09-25 ’703 Patent Priority Date
2002-10-15 ’699 Patent Priority Date
2003-03-28 ’446 Patent Priority Date
2004-06-21 ’003 Patent Priority Date
2007-01-08 ’552 Patent Priority Date
2007-01-08 ’087 Patent Priority Date
2007-01-23 U.S. Patent No. 7,167,703 Issues
2009-11-03 U.S. Patent No. 7,613,446 Issues
2012-06-05 U.S. Patent No. 8,195,087 Issues
2017-02-28 U.S. Patent No. 9,585,003 Issues
2017-04-11 U.S. Patent No. 9,621,699 Issues
2018-07-17 U.S. Patent No. 10,025,552 Issues
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 addresses the issue of conventional device locking mechanisms being overly restrictive, preventing users from making simple adjustments like changing volume without fully unlocking the device (Compl. ¶14; ’552 Patent, col. 1:40-42).
  • The Patented Solution: The invention is a system that allows for the selective locking of input controls. When a user places the device in a "locked state," certain pre-selected controls (e.g., volume buttons) can remain active while others (e.g., track-skipping or menu buttons) are disabled (’552 Patent, Abstract). The system also describes configuring different sets of enabled/disabled controls for various "operational modes," such as "walking" or "working out," to tailor the device's locked-state functionality to specific activities (’552 Patent, col. 4:25-29).
  • Technical Importance: This approach aimed to improve the user experience of portable media players by allowing access to essential controls without the cumbersome need to fully unlock and re-lock the device for minor adjustments (’552 Patent, col. 2:28-32).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶45).
  • Claim 1 recites an apparatus with:
    • A "selection input" for receiving user selections of which control components to keep enabled during a locked state for a specific "individual operational mode".
    • First and second "control components".
    • A "control selection component" (e.g., a lock switch) to switch between locked and unlocked states.
    • Wherein, in a locked state for a given operational mode, a selected first control component is allowed to act on input, while an unselected second control component is prevented from acting on input (’552 Patent, col. 7:6-44).

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 identifies that early portable devices lacked established wireless connectivity and that users found it difficult to manage wireless functions (Compl. ¶19; ’087 Patent, col. 1:32-35).
  • The Patented Solution: The invention describes a system centered on a single input control, or "actuator" (like a button), that serves as both a "connection initiator" and a "status indicator" for wireless communications (’087 Patent, col. 2:1-4). This actuator is associated with an "illumination component" that provides visual feedback on the connection status, using different colors or blinking modes to signify states like "searching," "connecting," or "downloading" (’087 Patent, col. 5:35-50).
  • Technical Importance: This invention simplified the user experience for managing wireless connections by consolidating control and status feedback into a single, intuitive hardware element (’087 Patent, Abstract).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶57).
  • Claim 1 recites a system for connecting a portable media player to a wireless network, comprising:
    • An "actuator" located on the portable media player.
    • A "wireless connection component" configured to search for available networks upon selection of the actuator.
    • An "illumination component associated with the actuator", which is configured to indicate the communications state of the wireless connection via a "mode of illumination" (’087 Patent, col. 7:51-67).

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

Technology Synopsis

This patent describes a method for enhancing mobile phone security by providing two modes of operation: an unauthenticated mode with limited functions and an authenticated mode with full functionality (Compl. ¶25; ’446 Patent, col. 3:1-5). Authentication is performed via a fingerprint reader, which the patent suggests can be integrated with the power-on button to create a seamless user experience (’446 Patent, Abstract; col. 3:52-56).

Asserted Claims

The complaint asserts independent claim 8 (Compl. ¶69).

Accused Features

The complaint targets fingerprint-based authentication systems used to unlock smartphones and access their full range of functions (Compl. ¶¶25, 78).

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

Technology Synopsis

The patent addresses the problem of audio alerts (e.g., for an incoming call) interfering with media playback (e.g., music) (’699 Patent, col. 1:52-60). The invention provides a "context sensitive" system where a second audio signal (the alert) is initially presented at a non-intrusive volume level lower than the first audio signal (the music), and then incrementally increases in volume until the user responds or an upper limit is reached (Compl. ¶29; ’699 Patent, col. 4:45-51, col. 6:38-44).

Asserted Claims

The complaint asserts independent claim 10 (Compl. ¶81).

Accused Features

The complaint targets audio management systems in the Accused Products that adjust alert volumes based on ongoing media playback (Compl. ¶¶29, 90).

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

Technology Synopsis

This patent describes a system that enables a wireless mobile phone, which may lack a persistent internet connection or a static IP address, to act as a server for data and applications accessible by other computing devices like laptops (’003 Patent, col. 3:20-28; Compl. ¶33). It outlines a protocol involving a proxy server and domain name server to bridge the connection between a client computer and the mobile phone, allowing the phone to serve content over a data network like GPRS (’003 Patent, col. 4:15-28).

Asserted Claims

The complaint asserts independent claim 1 (Compl. ¶93).

Accused Features

The complaint targets functionalities analogous to mobile hotspot or data tethering features in the Accused Products (Compl. ¶¶33, 102).

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

Technology Synopsis

This patent addresses the limitations of early mobile device input capabilities for non-verbal communication (Compl. ¶37; ’703 Patent, col. 1:51-57). The invention is a method for users to graphically convey information by selecting images from pre-defined categories (e.g., location, mood, activity) on their mobile device and transmitting those images, or identifiers for them, to another user's device (’703 Patent, col. 2:3-11, Abstract).

Asserted Claims

The complaint asserts independent claim 1 (Compl. ¶105).

Accused Features

The complaint targets image messaging functionalities in the Accused Products, such as sending emojis, stickers, or photos in messages (Compl. ¶¶37, 114).

III. The Accused Instrumentality

Product Identification

The complaint identifies four broad categories of accused instrumentalities: "Smartphones," "Tablets," "Earbuds / Headphone," and "Speakers / Smart-Speakers" (Compl. ¶40). The list of exemplary products is extensive, including numerous models of Apple iPhone and iPad, Google Pixel, Motorola, Nokia, and OnePlus devices, as well as peripherals like Apple AirPods, Beats headphones, and Bose speakers (Compl. ¶¶40-41).

Functionality and Market Context

The complaint alleges that these products incorporate a range of features that infringe the patents-in-suit. These functionalities include user interface controls for device locking (’552 Patent), wireless network management and status indication (’087 Patent), biometric security (’446 Patent), context-aware audio management (’699 Patent), data serving/tethering (’003 Patent), and graphical messaging (’703 Patent) (Compl. ¶¶14, 19, 25, 29, 33, 37). By targeting flagship products from major manufacturers sold by a national carrier, the complaint positions the accused functionalities as being of significant commercial importance (Compl. ¶¶4, 40-41).
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as Exhibits G-L but does not include them in the filing; therefore, the infringement theories are summarized below in prose.

’552 Patent Infringement Allegations Summary

The complaint alleges that the Accused Products, such as smartphones, practice the claimed invention by providing a selective locking feature (Compl. ¶¶14, 45). The theory suggests that when a user locks their device, the system prevents input from certain controls (e.g., the main touchscreen) while allowing input from others (e.g., physical volume or power buttons), which corresponds to the claimed concept of having selected controls remain enabled in a locked state based on an "operational mode" (Compl. ¶14, 54).

Identified Points of Contention

  • Scope Questions: A central question may be whether the standard "lock screen" on a modern smartphone constitutes an "individual operational mode" as contemplated by the patent, which describes distinct, configurable modes like "walking" and "working out." Does the term require user-selectable profiles beyond a single, default locked state?
  • Technical Questions: What evidence does the complaint provide that the Accused Products include a "selection input" specifically for "control component configuration for an individual operational mode", as required by claim 1? Does a general settings menu for lock screen behavior meet this limitation?

’087 Patent Infringement Allegations Summary

The infringement theory posits that the Accused Products utilize an "actuator" (e.g., a software button or icon on a touchscreen) that is "associated with" an "illumination component" (e.g., the changing state or color of that icon or another status bar icon) to manage and indicate wireless network status (Compl. ¶¶19, 57). The complaint alleges that user interaction with this actuator initiates network functions, and the visual change in the illumination component informs the user of the "communications state", thereby meeting the elements of claim 1 (Compl. ¶¶19, 66).

Identified Points of Contention

  • Scope Questions: The primary dispute may focus on whether an on-screen software icon can be both the "actuator" and the "illumination component" or if they are sufficiently "associated." Does the patent’s focus on a physical, illuminating button limit the claim’s scope to hardware implementations?
  • Technical Questions: Does the complaint allege facts showing that a single, identifiable "actuator" in the Accused Products is used to both initiate a network search and is the component that illuminates to show status, or are these functions handled by separate UI elements?

V. Key Claim Terms for Construction

’552 Patent (Claim 1)

The Term

"individual operational mode"

Context and Importance

The infringement analysis may turn on whether the accused devices' single, default lock screen behavior qualifies as one of multiple, selectable "operational modes." If the term is construed to require distinct, user-configurable profiles (e.g., a "Car Mode" vs. a "Pocket Mode" with different active buttons), infringement may be more difficult to establish.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification provides examples such as ""walking," "working out," "traveling"" but does not explicitly limit the term to these examples, which could support a construction where any distinct state of the device (including simply "locked") is an "operational mode" (’552 Patent, col. 4:27-29).
  • Evidence for a Narrower Interpretation: Claim 1 requires a "selection input to receive individual selections... during a control component configuration for an individual operational mode," which suggests a specific setup process tied to a named mode, potentially narrowing the term to explicitly defined and configured profiles rather than a generic state (’552 Patent, col. 7:6-12).

’087 Patent (Claim 1)

The Term

"illumination component associated with the actuator"

Context and Importance

This term defines the required relationship between the user input element and the visual status indicator. The case may hinge on whether a software icon on a touchscreen is "associated with" itself or with another UI element in the manner claimed, or if the patent requires a closer, physical integration.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The term "associated with" is not explicitly defined, leaving room for a functional interpretation where one component acts in response to the other, regardless of physical separation on a screen.
  • Evidence for a Narrower Interpretation: The abstract and detailed description repeatedly refer to a "button" that "includes an indicator light," suggesting a physical integration. The patent states the system "includes an input control, such as a button placed externally on a portable media player," which may support a narrower construction limited to hardware components (’087 Patent, col. 2:1-3, Abstract).

VI. Other Allegations

Indirect Infringement

For each asserted patent, the complaint alleges induced infringement, stating that Defendant provides customer support, user manuals, and instructions that "instructed and encouraged" end-users to use the Accused Products in an infringing manner (e.g., Compl. ¶¶49, 61, 73). It also pleads contributory infringement, alleging the products contain "special features" integral to the inventions that are not staple articles of commerce and lack substantial non-infringing uses (e.g., Compl. ¶¶54, 66, 78).

Willful Infringement

Willfulness is alleged for all patents based on Defendant’s knowledge of the patents and the alleged infringement "at least through service of the Complaint" (e.g., Compl. ¶¶47, 59, 71). The complaint also reserves the right to prove pre-suit knowledge through discovery (Compl. ¶42).

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

  • A core issue will be one of technological translation: can claim terms rooted in the context of early-2000s hardware-centric devices (e.g., a physical, illuminating "actuator" for wireless status, or a fingerprint reader integrated into a "power on button") be construed to read on the modern, software-driven, touchscreen-based implementations of those same functions in the accused smartphones and tablets?
  • A key evidentiary question will be one of specificity and scale: does the complaint, which asserts six different patents against hundreds of products from over a dozen manufacturers, provide sufficient factual detail to plausibly allege that each distinct product family practices the granular, multi-element limitations of each asserted claim (e.g., the specific audio-ramping behavior of the ’699 patent or the configurable "operational modes" of the ’552 patent)?
  • A central dispute may concern the non-obviousness of combining known elements: given that the patents-in-suit often claim combinations of functionalities (e.g., locking plus selective control access, authentication plus power-on), a critical question will be whether the specific claimed arrangements represented an inventive step over the prior art at the time of filing, or whether they were predictable improvements to mobile device usability.