Cloud Systems Holdco IP LLC v. Climatec LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
  • Defendant: Climatec, LLC (Arizona)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-01065, N.D. Tex., 04/30/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Extron Control System infringes a patent related to the integrated management, routing, and control of electronic devices in an environment.
• Technical Context: The technology at issue involves systems for centralized, hardware-independent control over disparate audio-visual, environmental, and other electronic devices, a key capability in smart buildings, conference rooms, and integrated control applications.
• Key Procedural History: Plaintiff, a non-practicing entity, discloses that it and its predecessors have entered into settlement licenses with other entities. The complaint argues these prior settlements, which did not include admissions of infringement, do not trigger patent marking requirements under 35 U.S.C. §287.

Case Timeline

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

• Patent Identification: 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 numerous, often incompatible, electronic devices within an environment, such as an audio-visual presentation space. This includes establishing data routes between devices and managing devices that are not directly part of the data flow, like lighting or window shades (’912 Patent, col. 2:49-57).
• The Patented Solution: The invention proposes a centralized, server-based system that abstracts hardware complexity. A server, communicating over a network with a control client, manages a database of device configurations and connections (’912 Patent, col. 8:3-12). This allows a user, via a graphical interface on the control client, to manage, route, and control various source, output, and environmental devices, often by creating and recalling predefined "scenes" that represent a complete state of the environment (’912 Patent, col. 6:20-26; FIG. 1A).
• Technical Importance: This architecture provides a unified, hardware-independent method for managing complex environments, solving the problem of integrating disparate devices that would otherwise require separate, and often proprietary, control systems (’912 Patent, col. 1:11-20).

Key Claims at a Glance

• The complaint asserts claims 1-19, with claims 1 and 10 being independent (’912 Patent, col. 47:52-48:40; Compl. ¶8).
• Independent Claim 1 (Apparatus Claim) requires:
  • A server configured to host a database (with static connections and adaptable nodes) and run a scheduling service.
  • A control client to control an output device and communicate with the scheduling service.
  • A control client web application to render a user interface with standard and specialized widgets.
  • A control switch that communicates with the control client.
  • An output device configurator to request device access from the scheduling service and send configuration/control information to the output device.
• The complaint reserves the right to assert all dependent claims (’912 Patent, col. 49:1-50:48; Compl. ¶8).

III. The Accused Instrumentality

Product Identification

Defendant’s Extron Control System (Compl. ¶10).

Functionality and Market Context

• The complaint alleges the Accused Instrumentality is a system offered to customers to "manage or control their connected AV devices across an environment" (Compl. ¶10).
• Its functionality is characterized as a "method for controlling an environment, comprising establishing communication between a server and a control client" (Compl. ¶11).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an unattached "Exhibit B" and provides a high-level narrative theory of infringement. The following chart summarizes these allegations as they map to the elements of the lead independent claim.

’912 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The complaint's allegations are general. A central question will be whether the "Extron Control System" architecture includes components that meet the specific definitions of a "control switch" and an "output device configurator" as required by the claim.
• Technical Questions: A key evidentiary issue will be whether the accused "server" and "database" perform the claimed functions related to "adaptable nodes" and a "scheduling service," particularly concerning the management of shared or pooled devices as described in the patent specification (e.g., ’912 Patent, col. 20:10-29). The complaint lacks specific factual allegations on these technical operations.

V. Key Claim Terms for Construction

• The Term: "adaptable nodes"
• Context and Importance: This term appears in the "server" limitation of claim 1. Its meaning is critical for defining the required capability of the server's database. Practitioners may focus on this term because its construction could determine whether a generic device database infringes, or if the database must support the specific dynamic resource allocation and device pooling functionalities described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not explicitly defined, which could support an argument for its plain and ordinary meaning related to nodes that can be changed or modified. The specification refers generally to nodes as part of the system's data model (’912 Patent, FIG. 9B).
  • Evidence for a Narrower Interpretation: The specification links the concept of "adaptable nodes" to managing pooled devices and scheduling services, suggesting a node is "adaptable" if it can be dynamically associated with different sub-environments or users (’912 Patent, col. 20:10-47; Claim 1). This could narrow the term to systems capable of such resource management.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant actively encouraging and instructing customers on how to use its products to perform the claimed methods (Compl. ¶11). Contributory infringement is alleged on a similar basis (Compl. ¶12).
• Willful Infringement: The complaint alleges Defendant has known of the ’912 patent and the underlying technology "from at least the issuance of the patent" (Compl. ¶¶11-12). The prayer for relief seeks enhanced damages for willful infringement based on alleged pre-suit knowledge (Compl. Prayer for Relief ¶e).

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

• A central issue will be one of evidentiary sufficiency: Does the complaint's high-level allegation that the "Extron Control System" infringes provide adequate factual support, which will be tested through discovery, to demonstrate that the accused system contains each specific element of the asserted claims, including the "control switch" and "output device configurator"?
• The case will also turn on a question of claim scope: How will the court construe the term "adaptable nodes"? A narrow construction tied to the patent's detailed description of device pooling and dynamic resource allocation may create a higher bar for Plaintiff to prove infringement than a broader interpretation.
• A third key question relates to indirect infringement: Can Plaintiff develop sufficient evidence to prove that Defendant possessed the specific intent to encourage its customers' infringement, moving beyond the general allegation that it provides instructions on how to use its products?