Sensor360 LLC v. Kuka Se & Co KGaA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: KUKA SE & Co. KGaA (Germany)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-00005, E.D. Tex., 01/06/2026
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation, and further alleges that Defendant has committed acts of infringement and caused harm within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to self-organizing sensor networks where individual sensor modules can dynamically determine their own operational mode.
• Technical Context: The technology at issue involves networks of deployable sensors that can autonomously organize to monitor an area, a field 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

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

U.S. Patent No. 8,510,076 - "Sensor apparatus and system"

The Invention Explained

• Problem Addressed: The patent describes a need for rapidly deployable sensor systems for area monitoring, particularly in military applications, without the risks of human reconnaissance (Compl. ¶9; ’076 Patent, col. 1:9-18). It notes that traditional sensor networks often rely on two distinct types of devices: simple "sensor modules" to detect events and more complex "control modules" to process and transmit data. This architecture creates a vulnerability, as disabling a single control module can render an entire section of the network useless (’076 Patent, col. 1:40-54).
• The Patented Solution: The invention proposes a "self organising adaptive network" composed of a single type of sensor module capable of performing either sensing or control functions (’076 Patent, Abstract). Each module contains a processor that communicates with other nearby modules and determines whether it should operate in a "sensing mode" (monitoring sensor outputs) or a "controlling mode" (receiving and processing data from other modules) based on factors like its location, the density of other modules, and the operational needs of the network (’076 Patent, col. 1:60-65, col. 2:26-28, col. 2:60-64). This allows the network to adapt dynamically to its deployment environment and remain resilient even if some modules fail (’076 Patent, col. 3:13-18, col. 3:20-27).
• Technical Importance: This approach provides a more flexible and robust sensor network by eliminating the single point of failure associated with dedicated control modules, allowing for rapid, non-precise deployment (e.g., air-dropped) where the network can configure itself post-deployment (’076 Patent, col. 3:28-43).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" without specifying them (Compl. ¶11). Independent claim 1 is foundational and representative.
• 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 but references "Exemplary '076 Patent Claims" in its incorporated charts (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2, which was not provided with the filed complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges in general terms that Defendant makes, uses, sells, and imports products that "practice the technology claimed by the '076 Patent" (Compl. ¶11, ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe the ’076 Patent and incorporates by reference the allegations contained in claim charts (Exhibit 2), which are not publicly available (Compl. ¶16-17). Without the claim charts or a specific identification of the accused products, a detailed element-by-element analysis is not possible. The infringement theory appears to be that Defendant's products are sensor modules that contain the structural elements of the claims (sensor, locator, transceiver, processor) and that the processor performs the claimed function of determining whether to operate in a sensing or controlling mode (Compl. ¶11, ¶16).

• Identified Points of Contention: The core of the infringement dispute will likely center on the functional limitation of the processor.
  • Scope Questions: A central question will be whether the accused products' processors perform the specific function of "determin[ing] whether the sensor module should operate in a sensing mode or a controlling mode" as understood within the context of the patent. This raises the question of whether the accused systems feature the distinct, dynamically-assigned operational modes described in the specification.
  • Technical Questions: A key technical question will be what evidence demonstrates that the accused products' software or firmware architecture includes logic for dynamically selecting between two distinct operational states corresponding to the claimed "sensing mode" and "controlling mode." The analysis will depend on whether the accused products simply perform sensing and control-type functions simultaneously or if they make an active, situational determination to operate primarily in one mode over the other, as the patent suggests is done to optimize network efficiency and power (’076 Patent, col. 3:1-3).

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 from independent claim 1 captures the core inventive concept of a self-organizing network where modules are not pre-assigned a static role. The outcome of the case may depend on whether the accused products' operations meet this specific functional requirement. Practitioners may focus on this term because it is the primary active limitation distinguishing the invention from prior art systems with fixed-function components.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the determination in functional terms, suggesting the modes are defined by primary activity. A "sensing mode" involves monitoring sensor outputs to detect events, while a "controlling mode" involves receiving information from other modules for processing or relaying (’076 Patent, col. 2:26-28, col. 2:60-64). This could support an argument that any system where modules shift their primary function between data gathering and data processing/relaying meets the limitation.
  • Evidence for a Narrower Interpretation: The specification provides specific examples that could be used to argue for a narrower construction. These include a module switching from sensing to control to take over for a failing module, or one module deactivating while a nearby redundant module operates in sensor mode to conserve power (’076 Patent, col. 2:13-19, col. 3:8-13). This language may support an interpretation that requires a distinct, binary choice between two mutually exclusive operational states for a specific purpose like power management or redundancy, rather than a more fluid or simultaneous performance of both functions.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that direct end users to use the accused products in an infringing manner (Compl. ¶14). The complaint references Exhibit 2 for further details on these materials (Compl. ¶14).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of its infringement at least since being served with the complaint and corresponding claim charts (Compl. ¶13, ¶15). This allegation appears to form the basis for a claim of post-filing willfulness.

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

1. A core issue will be one of definitional scope: How will the court construe the functional requirement that the processor "determine[s]" whether to operate in a "sensing mode" versus a "controlling mode"? The case may turn on whether this requires a discrete, binary selection between two mutually exclusive states, or if it can be read more broadly to cover systems with more fluid or distributed architectures.
2. A key evidentiary question will be one of technical operation: Assuming a construction is reached, what are the unidentified "Exemplary Defendant Products," and what evidence will show that their processors actually execute the specific decision-making process required by the claims? The current complaint lacks the factual specificity to assess the merits of this central infringement allegation.