DCT
4:23-cv-00844
ThinkLogix LLC v. Crestron Electronics Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ThinkLogix, LLC (Texas)
- Defendant: Crestron Electronics, Inc. (New Jersey)
- Plaintiff’s Counsel: Daignault Iyer LLP
- Case Identification: 4:23-cv-00844, E.D. Tex., 09/22/2023
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business in Plano, Texas, and employs multiple individuals within the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s conference room, video conferencing, and smart home control products and services infringe six patents related to remote control configuration, autonomous sensor networks, network link verification, and media streaming protocols.
- Technical Context: The technologies at issue relate to integrated control and media streaming systems for enterprise and home automation, a market focused on unifying the command of disparate electronic devices and managing complex media flows.
- Key Procedural History: The complaint alleges that Defendant has previously litigated cases in the Eastern District of Texas in which it admitted that venue was proper.
Case Timeline
| Date | Event |
|---|---|
| 2000-10-05 | ’700 Patent Priority Date |
| 2002-01-02 | ’467 Patent Priority Date |
| 2002-09-25 | ’898 Patent Priority Date |
| 2002-12-30 | ’835, ’994, and ’573 Patent Priority Date |
| 2006-08-15 | U.S. Patent No. 7,091,898 Issues |
| 2007-12-04 | U.S. Patent No. 7,305,467 Issues |
| 2011-04-12 | U.S. Patent No. 7,924,700 Issues |
| 2013-12-03 | U.S. Patent No. 8,599,835 Issues |
| 2016-01-05 | U.S. Patent No. 9,231,994 Issues |
| 2018-02-27 | U.S. Patent No. 9,906,573 Issues |
| 2023-09-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,091,898 - “System And Method For Using Keystroke Data To Configure A Remote Control Device”
The Invention Explained
- Problem Addressed: The patent’s background section describes the increasing complexity of universal remote controls as the number of remotely controllable home appliances and their functions grows, leading to a cluttered and difficult-to-use interface (Compl. ¶29; ’898 Patent, col. 1:19-35).
- The Patented Solution: The invention proposes a remote control that monitors a user's sequence of key presses, identifies frequently used patterns, and then suggests these patterns be consolidated into a single "activity key" or macro. This allows a user to execute a multi-step task, such as turning on a TV, switching to the correct input, and powering on a DVD player, with a single button press ('898 Patent, Abstract; col. 2:48-55).
- Technical Importance: The technology sought to simplify the user experience for increasingly complex home entertainment systems by automating common, repetitive command sequences (Compl. ¶28).
Key Claims at a Glance
- The complaint asserts at least independent claim 25 (’898 Patent, col. 12:48-61).
- The essential elements of claim 25, a computer-readable media claim, include instructions for:
- storing a sequence of activations of keys of the remote control device;
- searching the stored sequence to select one or more sequence subsets;
- presenting the selected sequence subsets to a user; and
- allowing a user to assign one of the selected sequence subsets to an activity key whereby the remote control performs actions in accordance with the assigned subset.
- The complaint asserts infringement of "one or more claims" of the patent (Compl. ¶65).
U.S. Patent No. 7,305,467 - “Autonomous tracking wireless imaging sensor network including an articulating sensor and automatically organizing network nodes”
The Invention Explained
- Problem Addressed: The patent addresses the limitations of prior art sensor networks, noting that passive sensors like acoustic or seismic detectors can be inaccurate and susceptible to environmental factors, while active tracking systems like lasers can be power-intensive and require a direct line of sight (Compl. ¶37; ’467 Patent, col. 1:49-61).
- The Patented Solution: The invention describes a wireless network of sensor nodes that can self-organize to form a surveillance system. The system combines low-power passive sensors to detect a target's presence with articulating imaging sensors (e.g., cameras) on other nodes that can be triggered to provide precise tracking and visual data. The network is described as remotely controllable, allowing operators to query for sensory and image data and re-task the system (’467 Patent, Abstract; col. 2:48-67).
- Technical Importance: This approach creates a more efficient and robust surveillance system by leveraging the strengths of different sensor types—wide-area, low-power detection combined with high-precision, targeted tracking—within a self-configuring network (Compl. ¶37).
Key Claims at a Glance
- The complaint asserts at least independent claim 11 (’467 Patent, col. 9:43-57).
- The essential elements of claim 11, a sensor network claim, include:
- a plurality of nodes coupled to communicate with a remote system via a wide area network;
- wherein the nodes automatically organize to form the sensor network in response to information communicated among them;
- wherein the automatic organizing includes automatically coupling, configuring, and controlling data transfer, processing, and storage within the network; and
- wherein the nodes' functions are remotely controllable and programmable.
- The complaint asserts infringement of "one or more claims" of the patent (Compl. ¶75).
U.S. Patent No. 7,924,700 - “Private network link verification procedure in free space optical communication network”
- Technology Synopsis: The patent addresses methods for verifying the integrity and stability of a communication link. The invention provides a system where a first network device monitors a communication link at both a physical level and a second, content-based level, allowing for more robust error detection and ensuring link reliability before enabling data transmission (Compl. ¶¶42-44).
- Asserted Claims: At least claim 1 (Compl. ¶81).
- Accused Features: The complaint accuses Defendant's MyCrestron Services, which are cloud services used to remotely monitor the status and health of Crestron Home systems and their network connections (Compl. ¶¶82-84).
U.S. Patent No. 8,599,835 - “Streaming media”
- Technology Synopsis: The patent relates to a method for multimedia streaming using the Session Initiation Protocol (SIP). The invention describes a method where a SIP session is established between entities, allowing for the transmission and control (e.g., storage, playback) of media streams (Compl. ¶¶49-50).
- Asserted Claims: At least claim 1 (Compl. ¶88).
- Accused Features: The complaint accuses Crestron's mobile applications, such as Crestron-Go, which allegedly use SIP for functionalities like video intercom and streaming from IP-based cameras (Compl. ¶¶89, 35-36).
U.S. Patent No. 9,231,994 - “Streaming media”
- Technology Synopsis: The complaint states that the specification is the same as that of the ’835 Patent and addresses similar problems in SIP-based multimedia streaming (Compl. ¶57). The technology concerns a system configured to send a first SIP message from a first device to a second device, with the message containing specific header fields and parameters to request that a media stream be sent to the first device (Compl. ¶96).
- Asserted Claims: At least claim 19 (Compl. ¶95).
- Accused Features: The complaint accuses Crestron systems, including its mobile apps, that send SIP INVITE messages to initiate media streams from sources like IP cameras or servers (Compl. ¶96).
U.S. Patent No. 9,906,573 - “Streaming media”
- Technology Synopsis: The complaint states that the specification is the same as that of the ’835 Patent (Compl. ¶63). The technology relates to a system with processors configured to send a SIP message to a media source device, where the message's header includes a uniform resource identifier (URI) and a parameter indicating that streaming is requested (Compl. ¶104).
- Asserted Claims: At least claim 18 (Compl. ¶103).
- Accused Features: The complaint accuses Crestron systems that use processors to send SIP messages to media sources to initiate streaming for functions like viewing live or recorded video (Compl. ¶¶104-107).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as the “Crestron Products and Services,” which collectively include Crestron Conference Room Solutions, All-in-One Solutions, Intelligent Video Systems, MyCrestron Services, Crestron Mobile Apps (such as Crestron Home App and Crestron-Go), and Crestron IP Cameras (Compl. ¶11).
Functionality and Market Context
- The accused products provide integrated control over audio, video, lighting, security, and other systems in enterprise and residential environments. The Crestron Home App, for example, allows users to create "Quick Actions," which are programmed sequences of commands that control multiple devices simultaneously, such as setting lights and starting a movie with a single tap (Compl. ¶¶18, 67-68). This functionality is supported by screenshots from Crestron's documentation showing the user interface for configuring these actions (Compl. p. 19).
- The Intelligent Video Systems are described as multi-camera networks capable of automatically switching between cameras to focus on an active speaker, a feature intended for conference rooms and meeting spaces (Compl. ¶77; Compl. p. 30). MyCrestron Services provide cloud-based remote monitoring and management of these systems (Compl. ¶82).
- The mobile apps are alleged to use SIP for intercom communications and for viewing live or recorded video streams from IP-based cameras (Compl. ¶¶35, 89).
IV. Analysis of Infringement Allegations
7,091,898 Infringement Allegations
| Claim Element (from Independent Claim 25) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| storing a sequence of activations of keys of the remote control device; | The Crestron system stores a "Quick Action Sequence" created by the user. | ¶68 | col. 11:1-8 |
| searching the stored sequence to select one or more sequence subsets; | The system allows a user to "choose/assing actions" from a menu to build a sequence. A screenshot shows a user selecting an action from a list of available actions and devices. | ¶69; Compl. p. 22 | col. 11:46-56 |
| presenting the selected sequence subsets to a user; | The system presents a "series/list of actions" to the user for selection. The complaint includes a screenshot of the "Action Settings" interface displaying "Associated Sequences" for a Quick Action. | ¶70; Compl. p. 22 | col. 11:57-60 |
| allowing a user to assign one of the selected sequence subsets to an activity key whereby, in response to a subsequent activation of the activity key, the remote control performs actions in accordance with assigned, selected sequence subset. | The system allows a user to "add/edit/reorder a step to the selected sequence for Quick Action," which is then performed upon activation of the Quick Action button. | ¶71 | col. 11:61-67 |
- Identified Points of Contention:
- Scope Questions: A central question may be the interpretation of "searching the stored sequence." The complaint alleges that a user selecting predefined commands from a menu to build a macro meets this limitation (Compl. ¶69). The court may need to determine if "searching" requires an automated process of discovering patterns in a user's past command history, as described in the ’898 Patent’s detailed description (e.g., ’898 Patent, col. 11:46-56), or if it can be read more broadly to cover a user-driven selection from a pre-existing library of commands.
7,305,467 Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A sensor network comprising a plurality of nodes, | The Crestron system is alleged to comprise a "multicamera systems network" with "two or more devices comprising cameras." | ¶77 | col. 5:10-14 |
| wherein the plurality of nodes are coupled to communicate with at least one remote system via at least one coupling with components of a wide area network, | The camera nodes are allegedly coupled to a "Crestron control system," with functions controllable via "internetworking." | ¶77 | col. 6:46-50 |
| wherein the nodes automatically organize to form the sensor network in response to information communicated among the nodes, | The system allegedly features "Multicamera Capability with Automate Systems," which can be set to "autoswitch between multiple 1 Beyond cameras to focus on the active speaking participant." | ¶77; Compl. p. 30 | col. 7:48-54 |
| wherein the automatic organizing comprises automatically coupling and configuring the nodes to form the sensor network and automatically controlling data transfer, processing, and storage within the sensor network, | The complaint alleges the system performs "automatically coupling and configuring the nodes" and "automatically controlling data (e.g., video) transfer." | ¶77 | col. 8:58-64 |
| wherein functions of the nodes are remotely controllable and programmable via internetworking among the nodes. | The accused cameras have "Manual Control Options" allowing control via a "Crestron® control system" and configuration from a computer on the network. | ¶77; Compl. p. 30 | col. 8:65-67 |
- Identified Points of Contention:
- Technical Questions: The infringement theory hinges on whether the "autoswitch" feature in a multi-camera system constitutes nodes that "automatically organize to form the sensor network." A key question will be what "information communicated among the nodes" causes this organization. The analysis may focus on whether this feature is merely an operational mode of a pre-configured network or if it meets the claim's requirement of the nodes autonomously forming the network itself in response to internodal communication.
V. Key Claim Terms for Construction
For the ’898 Patent:
- The Term: "searching the stored sequence"
- Context and Importance: This term is critical to distinguishing the claimed invention from a simple macro-creation tool. The infringement dispute may turn on whether the accused system's user-driven menu selection constitutes "searching" in the claimed sense. Practitioners may focus on this term because the patent's specification appears to describe an automated discovery of user habits, while the complaint's evidence shows a manual macro-building interface.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the claim does not explicitly require that the "searching" be automated or based on a historical log of user behavior; it merely requires "searching the stored sequence."
- Evidence for a Narrower Interpretation: The detailed description and figures repeatedly illustrate a process where the system analyzes a "history file" of past key presses to find "oft repeated" sequences to suggest to the user (’898 Patent, col. 8:30-40; Fig. 15). This may support a narrower construction where "searching" implies a discovery process based on monitored user activity, not just selection from a static list.
For the ’467 Patent:
- The Term: "automatically organize to form the sensor network"
- Context and Importance: This phrase defines the core autonomous nature of the claimed network. The viability of the infringement allegation depends on whether the accused "autoswitch" feature qualifies as this claimed organizing process.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language "in response to information communicated among the nodes" could be read to cover any automated coordination between nodes, such as one camera yielding control to another based on microphone data indicating an active speaker.
- Evidence for a Narrower Interpretation: The specification describes the nodes as being "capable of self-configuration, that is, the organization and maintenance of their own network" (’467 Patent, col. 2:64-66). It also uses terms like "self-assembly" (col. 8:61), which may suggest a more fundamental process of establishing or dynamically reconfiguring the network topology itself, rather than a pre-configured system switching between operational modes.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Crestron induces infringement by third parties (Compl. ¶18). This allegation may be supported by evidence cited in the complaint, such as Crestron's product documentation and user guides that allegedly instruct customers on how to use the accused features, such as creating "Quick Actions" (Compl. pp. 19-26) or combining cameras into a multi-camera system (Compl. p. 29).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional scope: does the accused Crestron system's user-directed process of building a "Quick Action" from a menu of pre-defined functions meet the ’898 Patent’s claimed step of "searching the stored sequence to select...sequence subsets," a process the patent specification heavily implies is an automated analysis of a user's historical command patterns?
- A key definitional question will be whether the accused multicamera system's "autoswitch" feature, which directs camera focus based on an active speaker, constitutes the ’467 Patent’s claimed process where nodes "automatically organize to form the sensor network," which the patent describes in the context of autonomous self-assembly and network configuration.
- For the family of streaming media patents (’835, ’994, and ’573), a central evidentiary question will be the technical mapping of the accused products' SIP and RTSP communications to the specific header fields, indicators, and protocol parameters recited in the asserted claims, a fact-intensive inquiry that will likely require examination of network traffic and source code.