Communication Interface Tech LLC v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Communication Interface Technologies, LLC (Delaware)
  • Defendant: Honeywell International Inc. (Delaware)
  • Plaintiff’s Counsel: Beaty Legal PLLC
• Case Identification: 4:23-cv-00497, E.D. Tex., 07/28/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Honeywell maintains multiple established places of business in the district, including a specific facility in Richardson, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Honeywell GX RemoteControl mobile application infringes three expired patents related to creating and efficiently re-establishing client-server communication sessions, referred to as "virtual sessions."
• Technical Context: The technology addresses methods for maintaining persistent logical connections between a client (e.g., a mobile device) and a server over intermittent physical network links, a foundational concept for modern mobile applications that must conserve resources while appearing continuously connected.
• Key Procedural History: The complaint states that the patents-in-suit have been subject to extensive prior litigation, including cases that settled before claim construction hearings were conducted. The patents are also noted as currently being asserted against other defendants. Plaintiff also alleges that there are more than 180 licensees to each of the patents-in-suit.

Case Timeline

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

U.S. Patent No. 6,574,239 - VIRTUAL CONNECTION OF A REMOTE UNIT TO A SERVER

• Issued: June 3, 2003

The Invention Explained

• Problem Addressed: The patent describes the inefficiency of client-server communications in an era of intermittent and costly connections, such as dial-up or early wireless networks. Prior systems either required a continuous, expensive physical connection to maintain a session or forced users to undergo slow, repetitive, and resource-intensive reconnection and re-authentication processes each time a connection was needed (Compl. ¶¶11-12; ’239 Patent, col. 2:15-44).
• The Patented Solution: The invention proposes a "virtual session" layer in the communication protocol. This layer allows an application session to be maintained in memory (in a "deactivated state") even after the physical network connection is dropped (’239 Patent, col. 3:41-50). When a connection is needed again, the session can be quickly "reactivated" using stored parameters (e.g., authentication keys), bypassing a full, time-consuming negotiation process (’239 Patent, Fig. 5; col. 4:56-65). The server can maintain this virtual session in proxy, preserving the user's logged-in state on the application server (’239 Patent, col. 10:45-56).
• Technical Importance: This approach aimed to provide users with a seamless, "always-on" experience without the high cost and resource drain of maintaining a continuous physical network connection (Compl. ¶16).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 7 (’239 Patent, col. 26:46-64).
• Essential Elements of Claim 7 (Method):
  • Establishing a virtual session with a remote unit to support an application layer program.
  • Placing the virtual session in an inactive state.
  • Sending a signal to the remote unit, which is indicative of an incoming communication request and includes an "application-program identifying packet."
  • Placing the virtual session back into the active state and transferring data in response to the step of sending.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,266,296 - APPLICATION-LAYER EVALUATION OF COMMUNICATIONS RECEIVED BY A MOBILE DEVICE

• Issued: September 11, 2012

The Invention Explained

• Problem Addressed: As a continuation of the technology in the ’239 Patent, the ’296 Patent addresses the same core problem of managing intermittent connections but focuses on the client-side logic for handling server-initiated communications (Compl. ¶¶11-12; ’296 Patent, col. 1:20-27).
• The Patented Solution: The patent describes a method where a mobile device, having a "virtual session" in an inactive state, receives an unsolicited communication from a remote server. The mobile device's control program evaluates information within that communication at the application layer to identify which specific application on the device should be launched or activated to handle the incoming data and reactivate the communication session (’296 Patent, Abstract; col. 2:50-59).
• Technical Importance: This invention provides a mechanism for what is now commonly understood as a push notification, where a server can "wake up" a specific, dormant application on a mobile device to deliver new information (Compl. ¶15).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (’296 Patent, col. 29:33-51).
• Essential Elements of Claim 1 (Method):
  • At a mobile handset, receiving a first communication initiated by a remote entity that was not in response to a request from the handset.
  • The communication includes a set of information identifying an application layer program installed on the handset.
  • The handset evaluates this set of information.
  • Based on the evaluation identifying the application, the handset launches the application program.
  • The handset reactivates a communication session between the mobile handset and the remote entity from an inactive state.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,291,010 - VIRTUAL CONNECTION OF A REMOTE UNIT TO A SERVER

• Issued: October 16, 2012

Technology Synopsis

This patent, part of the same family as the ’239 and ’296 patents, also describes the "virtual session" concept. It focuses on the server-side method where the server, needing to send information to a disconnected client, initiates a dial-out or sends a signal containing identifying information (akin to Caller ID) that causes the remote client to reactivate the session and receive the data (Compl. ¶22; ’010 Patent, Abstract).

Asserted Claims

Independent claims 1 and 17.

Accused Features

The complaint alleges that the Accused Instrumentalities infringe by using wireless push notification messages sent over TLS sessions to prompt the re-establishment of a separate TLS connection for client-server communications (Compl. ¶74).

III. The Accused Instrumentality

Product Identification

The Honeywell GX RemoteControl mobile application (the "Accused Instrumentalities") (Compl. ¶36).

Functionality and Market Context

• The complaint alleges that the Accused Instrumentalities are mobile device applications that use modern communication protocols to interact with remote servers (Compl. ¶¶36, 54, 72).
• The core accused functionality involves the use of wireless push notification messages sent over Transport Layer Security (TLS) sessions. The complaint alleges that upon receiving such a notification, the remote server and the client-side application establish a separate TLS connection for traditional client-server communications (Compl. ¶¶38, 56, 74). This process is alleged to allow the application to receive updates from the server even when it is not actively in use by the user.
• The complaint alleges that earlier versions of the app, operating in a materially similar manner, were published in and before 2018, during the pendency of the asserted patents (Compl. ¶¶38, 56, 74).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 4, 5, 6, and 7) that are not provided in the document. The narrative infringement theory is summarized below in prose.

No probative visual evidence provided in complaint.

The complaint’s infringement theory appears to map the patented "virtual session" technology onto the architecture of modern mobile applications. The core allegation is that when the Honeywell GX RemoteControl App is not in active use, its connection to the Honeywell server is analogous to the patented "inactive state" (Compl. ¶15). When the Honeywell server needs to send data to the app (e.g., an alert or update), it sends a "push notification" through services like Google's or Apple's. The complaint appears to allege that this push notification functions as the "unsolicited communication" or "signal" required by the asserted claims (Compl. ¶¶38, 74). Upon receipt of this notification, the app is allegedly prompted to launch or wake up and re-establish a direct TLS connection with the Honeywell server, which corresponds to "reactivating" the "communication session" to transfer data (Compl. ¶¶38, 56). This sequence of operations—a server-initiated, information-bearing message that causes a dormant client application to re-establish a connection for data transfer—is what Plaintiff alleges infringes claims of the ’239, ’296, and ’010 patents.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "communication session," as described in the 1998-priority patents in the context of stateful, persistent connections, can be construed to read on the potentially stateless, ephemeral TLS connections used by modern mobile apps. Further, does a modern push notification, often routed through third-party infrastructure (e.g., Apple/Google), constitute the claimed "signal" or "packet" sent from the server to the "remote unit"?
  • Technical Questions: What evidence does the complaint provide that the Accused Instrumentalities' background state is technically equivalent to the patents' "inactive state" where session parameters are explicitly maintained by a "virtual session server"? The analysis may focus on whether the accused system performs the specific function of reactivating a previously established session, as opposed to simply establishing a new, independent session in response to a notification.

V. Key Claim Terms for Construction

"communication session" (’296 Patent, Claim 1)

• Context and Importance: This term is the foundation of the patented invention. Its construction will be critical to determining whether the methods used by the accused modern mobile app, which may involve establishing new, independent TLS connections, fall within the scope of a "session" that is "reactivated" from an "inactive state." Practitioners may focus on this term because the patents were filed in an era of dial-up modems and persistent connections, whereas the accused technology operates in the context of modern, often stateless, mobile networking.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines a communication session as being "between nodes or communication endpoints" (’239 Patent, col. 10:61-63), a general definition that could encompass any logical link between the app and the server.
  • Evidence for a Narrower Interpretation: The specification describes the session in detail as being managed by a "virtual session server" that maintains a table of parameters (e.g., user ID, encryption keys) to preserve the session while the physical link is down (’239 Patent, col. 8:56-62, col. 11:12-22). This suggests a stateful, persistent entity, which may be narrower than a standard TLS connection established on demand.

"application-program identifying packet" (’239 Patent, Claim 7)

• Context and Importance: This term is crucial for the server-initiated reactivation method. The infringement allegation appears to equate a modern push notification with this "packet." The dispute will likely center on whether the data payload of a push notification serves the same identifying function described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the packet's function as enabling the remote unit to "properly and immediately respond" and to "select/activate [the correct] application" (’239 Patent, col. 23:30-32, col. 24:60-62). This functional language could arguably cover any data within a notification that allows a mobile OS to route it to the correct app.
  • Evidence for a Narrower Interpretation: The patent provides specific examples, such as using a "caller identification packet" with different extensions to identify whether an incoming communication is a voice call or an email (’239 Patent, col. 23:20-28). This could support an argument that the term requires a specific, pre-defined data structure for identification, rather than just the inherent routing information in a modern notification.

VI. Other Allegations

The complaint does not contain specific counts or detailed factual allegations for indirect infringement or willful infringement.

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

The resolution of this dispute may turn on the following central questions:

1. A core issue will be one of definitional scope: Can the term "communication session," rooted in the patent's disclosure of a stateful connection maintained in proxy by a server, be construed to cover the potentially stateless, on-demand TLS connections used in the accused mobile application's architecture?
2. A key evidentiary question will be one of technological equivalence: Does a modern push notification, delivered via third-party infrastructure, perform the same role and function as the claimed "application-program identifying packet" sent from a server to a remote unit, as contemplated by the 1998-priority patents?
3. The case also raises a fundamental question of temporal translation: How should claim terms drafted to solve problems of a specific technological era (e.g., slow dial-up modems, costly airtime) be applied to a subsequent technological paradigm (e.g., ubiquitous broadband, efficient mobile OS background processes) that solves similar user-experience goals through entirely different technical means?