Arbor Systems LLC v. Accenture Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Arbor Systems LLC (New Mexico)
  • Defendant: Accenture Limited (Ireland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-00045, E.D. Tex., 01/22/2026
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation and has committed acts of patent infringement causing harm within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to Internet of Things (IoT) devices that utilize blockchain smart contracts for secure operation.
• Technical Context: The technology involves the use of blockchain for secure and autonomous operation of smart, connected devices, a domain with increasing importance for data integrity and automated transactions.
• Key Procedural History: The complaint does not allege any significant procedural history, such as prior litigation or administrative proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 10,195,513 - "Smart device"

• Patent Identification: U.S. Patent No. 10,195,513, titled "Smart device," issued on February 5, 2019.

The Invention Explained

• Problem Addressed: The patent background describes the technical challenges arising from the proliferation of Internet of Things (IoT) devices, including the overwhelming volume of data generated and the potential for "major disruptions" caused by "fraudulent and harmful activities arising from hacked IOT devices" (’513 Patent, col. 1:12-18).
• The Patented Solution: The invention is an IoT device comprising a processor, sensor(s), and a wireless transceiver that can utilize blockchain smart contracts for secure operations ’513 Patent, Abstract; col. 2:7-10 The detailed description explains that such a device can use smart contracts to negotiate and enforce agreements, manage supply chains, and conduct secure peer-to-peer transactions between devices ’513 Patent, col. 4:58-6:29 The general electronic architecture for such a device is illustrated in Figure 2A ’513 Patent, col. 5:29-31
• Technical Importance: The patented approach purports to address security and data integrity issues inherent to the expanding network of connected devices by leveraging the decentralized and secure nature of blockchain technology ’513 Patent, col. 1:12-18

Key Claims at a Glance

The complaint does not identify the specific claims of the ’513 Patent that are being asserted. It states that infringement allegations are detailed in "charts incorporated into this Count below" and in an "Exhibit 2," neither of which are present in the provided complaint document Compl. ¶11, ¶16 Consequently, an analysis of the asserted claims and their elements cannot be performed.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" Compl. ¶11 Specific product names are not provided in the body of the complaint, which instead refers to an unprovided Exhibit 2 for their identification Compl. ¶16

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '513 Patent" Compl. ¶16 The complaint also alleges that the Defendant distributes "product literature and website materials" that instruct end users on the use of these products in an infringing manner Compl. ¶14 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an attached "Exhibit 2" to detail its infringement allegations but does not include this exhibit in the filing Compl. ¶16-17 In the absence of the claim charts, the complaint's narrative infringement theory is presented in general terms. Plaintiff alleges that Defendant directly infringes the ’513 Patent by "making, using, offering to sell, selling and/or importing" the accused products, and by its employees' internal testing and use of those products Compl. ¶11-12 The complaint further alleges induced infringement, stating that Defendant knowingly encourages infringement by selling the accused products and distributing "product literature and website materials" that direct end users to use the products in a manner that infringes the ’513 Patent Compl. ¶14-15 The complaint asserts that these materials are referenced in the missing Exhibit 2 Compl. ¶14

Identified Points of Contention

The complaint's lack of specificity regarding the asserted claims and the accused products precludes a detailed analysis of potential points of contention. The central dispute will necessarily revolve around the specific functionality of the "Exemplary Defendant Products" and whether that functionality falls within the scope of the specific patent claims that Plaintiff will ultimately assert.

V. Key Claim Terms for Construction

The complaint does not identify the specific claims asserted, precluding an analysis of key claim terms for construction.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that Defendant knowingly and intentionally induces infringement by selling its products to customers and distributing "product literature and website materials" that allegedly direct end users to use the products in a manner that infringes the ’513 Patent Compl. ¶14-15

Willful Infringement

The complaint does not use the term "willful." However, it alleges that the filing of the complaint provides Defendant with "Actual Knowledge of Infringement" Compl. ¶13 This allegation may form the basis for a claim of post-suit willful infringement if infringement continues. The complaint does not allege any facts suggesting pre-suit knowledge.

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

Given the general nature of the complaint and the absence of its key evidentiary exhibit, the litigation will likely focus on establishing the fundamental elements of the claim before proceeding to more nuanced legal and technical arguments. The key open questions are:

1. A primary evidentiary question will be one of specification: which of Defendant's specific products are accused of infringement, and what technical evidence will Plaintiff, through discovery and the eventual production of its claim charts, offer to demonstrate that these products practice the claimed invention?
2. A core issue will be one of claim scope and construction: once the asserted claims are identified, the dispute will turn on the court's construction of key terms related to IoT devices and blockchain technology (e.g., "smart contract," "transceiver," "processor"). The viability of the infringement case will depend on whether the defined scope of these terms reads on the functionality of the accused products.
3. A key question for induced infringement will be one of intent: what evidence exists in Defendant's "product literature and website materials" to suggest that Defendant not only knew of the patent but also specifically intended for its customers to use its products in a manner that would directly infringe the asserted claims?