DCT
2:26-cv-00002
Sensor360 LLC v. Agilox Services GmbH
Key Events
Complaint
Table of Contents
complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sensor360 LLC (Delaware)
- Defendant: AGILOX Services GmbH (Austria)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 2:26-cv-00002, E.D. Tex., 01/06/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to a self-organizing, adaptive network of sensor modules.
- Technical Context: The technology concerns networks of deployable sensors that can autonomously determine their roles, a concept relevant to military surveillance, disaster relief, and industrial monitoring.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2003-09-09 | U.S. Patent No. 8,510,076 Priority Date |
| 2013-08-13 | U.S. Patent No. 8,510,076 Issued |
| 2026-01-06 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8,510,076, “Sensor apparatus and system,” issued August 13, 2013.
The Invention Explained
- Problem Addressed: The patent describes a need for rapidly deployable sensor systems for monitoring large areas, particularly for military applications like detecting vehicle movement or artillery fire ( ’076 Patent, col. 1:9-14). Traditional sensor networks relied on two distinct types of devices: simple "sensor modules" to detect events and more complex, power-intensive "control modules" to process and transmit data. This created a vulnerability, as the entire network in a given vicinity was dependent on the survival and operation of a single, identifiable control module ( ’076 Patent, col. 1:39-54).
- The Patented Solution: The invention proposes a single type of sensor module capable of performing either function. Each module contains a processor that communicates with other modules in the network and determines whether it should operate in a "sensing mode" (monitoring its sensors for events) or a "controlling mode" (receiving and processing data from other modules) ( ’076 Patent, col. 1:24-34; Abstract). This allows the network to be "self organising" and "adaptive," as modules can dynamically change roles based on factors like location, power levels, or damage to other modules, thereby eliminating the single point of failure associated with dedicated control modules ( ’076 Patent, col. 2:1-34; col. 3:5-25). Figure 4 illustrates a network where module 2e acts in a controlling mode for sensing modules 2a-2d ( ’076 Patent, col. 5:29-32; Fig. 4).
- Technical Importance: This approach provides a more resilient and flexible sensor network architecture that does not require careful pre-deployment planning of where specialized control units must be placed ( ’076 Patent, col. 3:26-33).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims" without specifying which are exemplary (Compl. ¶11). Independent claim 1 is the primary apparatus claim.
- Independent Claim 1:
- A sensor module for use in a sensor network, the sensor module comprising:
- at least one sensor,
- a locator for determining the location of the at least one sensor,
- a transceiver for communicating with other sensor modules and/or a base station, and
- a processor wherein the processor is adapted, in use, to communicate with other sensor modules and to determine whether the sensor module should operate in a sensing mode or a controlling mode within the network.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
- Product Identification: The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" (Compl. ¶11, ¶16).
- Functionality and Market Context: The complaint does not describe the functionality of the accused products. It alleges that Defendant makes, uses, sells, and imports these products in the United States (Compl. ¶11, ¶14). The complaint does not provide sufficient detail for analysis of the products' technical operation or market positioning.
IV. Analysis of Infringement Allegations
The complaint’s infringement allegations are contained within an "Exhibit 2," which is referenced but not provided with the complaint (Compl. ¶14, ¶16, ¶17). The complaint asserts that this unattached exhibit contains "charts comparing the Exemplary ’076 Patent Claims to the Exemplary Defendant Products" and that these charts show that the products "satisfy all elements of the Exemplary ’076 Patent Claims" (Compl. ¶16). Without this exhibit, a substantive analysis of the infringement theory is not possible based on the complaint alone. No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
- The Term: "determine whether the sensor module should operate in a sensing mode or a controlling mode"
- Context and Importance: This phrase appears in independent claim 1 and captures the core inventive concept of a self-organizing, adaptive network. The infringement analysis will likely hinge on whether the accused products perform this specific dynamic, decision-making function. Practitioners may focus on this term because the distinction between the two modes and the active "determination" process are central to distinguishing the invention from prior art networks with static roles.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the "determination" can be based on a wide variety of "circumstances," including the module's location relative to others, the density of modules in an area, environmental factors, or even remaining power levels ( ’076 Patent, col. 2:1-25; col. 3:10-14). This could support an interpretation covering any system where modules select from different operational states based on network conditions.
- Evidence for a Narrower Interpretation: The patent repeatedly frames the two modes as distinct functions: "sensing mode" involves monitoring the module's own sensors to "detect events," while "controlling mode" involves receiving information "from other sensor modules" for processing and potential relay to a base station ( ’076 Patent, col. 1:31-34; col. 2:26-28, col. 2:60-64). This could support a narrower construction requiring the accused device to be capable of performing both of these specific, distinct roles and actively choosing between them, rather than simply toggling between active and sleep states.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). These materials are referenced as being part of the unprovided Exhibit 2 (Compl. ¶14). The knowledge element for inducement is alleged to arise "at least since being served by this Complaint" (Compl. ¶15).
- Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that Defendant gained "Actual Knowledge of Infringement" upon service of the complaint and its attached claim charts, and continued its allegedly infringing activities despite this knowledge (Compl. ¶13-14). This allegation could form the basis for a future claim of post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional operation: Do the accused products, which are not identified in the complaint, actually feature an architecture where individual modules dynamically "determine" whether to act as event detectors ("sensing mode") or as data aggregators/processors for other modules ("controlling mode")? The case may depend on whether the defendant’s system architecture maps onto this claimed self-organizing, dual-mode capability.
- A second key question will be one of definitional scope: How will the court construe the term "controlling mode"? If construed narrowly to require receiving, processing, and relaying data from other peer modules, it may present a different infringement question than if construed more broadly to include any module that communicates status or commands within a network.
- An immediate procedural question will be the sufficiency of the pleadings: Given that the complaint's entire infringement theory is incorporated by reference from an unprovided exhibit, the initial phases of the case may focus on whether the complaint provides sufficient notice of the basis for its claims as required by federal pleading standards.
Analysis metadata