Cloud Systems Holdco IP LLC v. RGB Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
  • Defendant: RGB Systems, Inc. (California)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-00712, N.D. Tex., 10/08/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Extron Control System infringes a patent related to a system for automating the management, routing, and control of multiple interconnected devices in an environment.
• Technical Context: The technology at issue involves centralized, hardware-agnostic software systems for controlling complex audio-visual (AV) environments, such as conference rooms or auditoriums.
• Key Procedural History: In its First Amended Complaint, Plaintiff identifies itself as a non-practicing entity and discloses that it and its predecessors-in-interest have entered into prior settlement licenses. Plaintiff argues these licenses do not trigger patent marking requirements under 35 U.S.C. § 287, potentially preempting a common defense related to the limitation of pre-suit damages.

Case Timeline

Date	Event
2006-05-03	’912 Patent Priority Date
2019-07-30	’912 Patent Issue Date
2025-10-08	Complaint Filing Date

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

U.S. Patent No. 10,367,912 - System and Method for Automating the Management, Routing, and Control of Multiple Devices and Inter-Device Connections

• Issued: July 30, 2019.

The Invention Explained

• Problem Addressed: The patent describes the technical challenge of configuring and controlling multiple, disparate audio-visual and environmental devices within a given space, where establishing connections and operational states often requires manual and complex setup (’912 Patent, col. 2:46-59).
• The Patented Solution: The invention proposes a client-server architecture to solve this problem. A central server maintains a model of the environment, including all devices and their possible connections, and communicates with a control client (’912 Patent, Abstract). The client renders a user interface that allows a user to manage the entire environment, issue commands to route signals between devices (e.g., from a laptop to a projector), and activate pre-configured "scenes" that adjust multiple devices at once (’912 Patent, col. 6:21-27). This approach abstracts the physical hardware complexity from the end-user.
• Technical Importance: This system simplifies the operation of complex technological environments, enabling non-expert users to manage sophisticated AV setups through a single, intuitive interface (’912 Patent, col. 6:21-27).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-19 (Compl. ¶9). The patent contains three independent claims (1, 10, and 19). The analysis will focus on independent apparatus claim 1.
• Claim 1 (Apparatus):
  • a server configured to host a database that includes information describing a set of static connections and a set of adaptable nodes, and is configured to run a scheduling service;
  • a control client configured to control at least one output device and communicate with the scheduling service;
  • a control client web application with components to render a user interface on the control client;
  • wherein the user interface provides one or more standard widgets with standard control options based on the output device;
  • and one or more specialized widgets providing customizable control options based on the output device.
• The complaint reserves the right to assert dependent claims by alleging infringement of claims 1-19 (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

The accused product is Defendant's "Extron Control System" (Compl. ¶11).

Functionality and Market Context

The complaint alleges the Extron Control System is sold to customers to "manage or control their connected AV devices across an environment" (Compl. ¶11). The allegedly infringing method involves "establishing communication between a server and a control client" (Compl. ¶12). The complaint does not provide further technical detail regarding the architecture or specific operation of the accused system.

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit B, but this exhibit was not included with the filed complaint (Compl. ¶10). The infringement theory must therefore be summarized from the narrative allegations. Plaintiff alleges that Defendant "maintains, operates, and administers systems and services" that perform an infringing method, and that the "Extron Control System" contains elements that map to the patent's claims (Compl. ¶¶9, 11).

The core of the allegation is that the accused system provides for control of an environment by "establishing communication between a server and a control client" (Compl. ¶12). The complaint does not, however, provide specific factual allegations mapping discrete components of the accused system to the specific limitations recited in the asserted claims, such as the database containing "static connections" or the user interface's "specialized widgets."

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "server"

• Context and Importance: The complaint alleges the accused system uses a "server" (Compl. ¶12). The construction of this term will be critical to determining infringement, specifically whether the term is limited to a single physical hardware device or can encompass distributed or cloud-based computing architectures.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a functional definition, stating the server operates on a "general purpose computing platform" and that its elements can be "distributed to different locations across a network" (’912 Patent, col. 7:29-32, col. 8:3-4).
  • Evidence for a Narrower Interpretation: Figures 1A and 1C depict the server (100) as a discrete hardware box, and the specification notes that in some embodiments it "is shown as a single unitary machine" (’912 Patent, Fig. 1A; col. 7:21-23).

The Term: "specialized widgets"

• Context and Importance: This term appears in Claim 1 and distinguishes the claimed user interface from one with only generic controls. Practitioners may focus on this term because its construction will likely define the novelty of the claimed user interface and set the bar for what functionality in the accused product constitutes infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may support an argument that any user interface element tailored to a non-generic device function (e.g., a multi-input source selector for a projector) qualifies as "specialized."
  • Evidence for a Narrower Interpretation: Claim 1 creates a dichotomy between "standard widgets" with "standard control options" and "specialized widgets" with "customizable control options." A party could argue this requires a higher level of unique, configurable functionality. The specification provides an example of a "dialer quick control" tailored to a specific "Audio Conferencing" scene, which might be argued as the type of specialization required by the claim (’912 Patent, col. 14:7-14).

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement by asserting that Defendant encourages and instructs its customers on how to use the accused system in an infringing manner (Compl. ¶12). It also pleads contributory infringement on similar grounds (Compl. ¶13).

Willful Infringement

The complaint alleges that Defendant has known of the ’912 Patent and its underlying technology since "at least the issuance of the patent" (Compl. ¶¶12-13). This allegation serves as the basis for a potential claim of willful infringement, which is explicitly requested in the prayer for relief (Compl. ¶VI.e).

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

• A primary issue will be one of evidentiary sufficiency: What technical evidence will Plaintiff produce to demonstrate that the accused "Extron Control System" contains the specific architectural elements of the asserted claims, such as a database of "static connections" and a user interface with distinct "standard" and "specialized" widgets, which are not detailed in the current complaint?
• The case may also turn on a question of claim scope: How will the term "specialized widgets" be construed? Whether this term is interpreted broadly to cover any device-specific control or narrowly to require unique, scene-based customizable controls could be dispositive for infringement.
• A key legal question will be one of divided infringement: As the complaint alleges Defendant provides a system for its customers' use, the case may center on whether liability is established through direct infringement by Defendant alone or requires proof of indirect infringement, hinging on the actions and intent of Defendant's customers.