DCT

3:25-cv-01677

Focus Global Solutions LLC v. Backbox Software US Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-01677, N.D. Tex., 06/30/2025
  • Venue Allegations: Venue is alleged to be proper because Defendant maintains an established place of business in the district and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s network automation software infringes a patent related to device-agnostic network configuration using templates.
  • Technical Context: The technology addresses the challenge of managing heterogeneous computer networks composed of devices from multiple vendors, a common complexity in enterprise IT.
  • Key Procedural History: The patent-in-suit is a continuation-in-part of five parent applications. The complaint does not mention any other prior litigation, licensing history, or administrative proceedings involving the patent.

Case Timeline

Date Event
2000-12-06 '301 Patent Priority Date
2001-03-06 '301 Patent Application Filing Date
2005-12-20 '301 Patent Issue Date
2025-06-30 Complaint Filing Date

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

U.S. Patent No. 6,978,301 - "System and method for configuring a network device"

  • Patent Identification: U.S. Patent No. 6,978,301, "System and method for configuring a network device," issued December 20, 2005.

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty and complexity of configuring and managing computer networks composed of devices from different manufacturers (e.g., Cisco, Juniper) ('301 Patent, col. 2:31-39). This process was described as requiring significant, device-specific technical skill, making it laborious, error-prone, and a barrier to adopting new hardware from different vendors ('301 Patent, col. 2:40-48, col. 3:42-53).
  • The Patented Solution: The invention proposes a centralized network management system that uses a "global graphical user interface (GUI)" and a "template library" to abstract away device-specific complexities ('301 Patent, Abstract). A network administrator can select a target device and use a corresponding template to input configuration data; the system then automatically formats this data into the device-specific commands and provides them to the network device, regardless of its manufacturer ('301 Patent, col. 4:1-34). This process is illustrated in Figure 2, which shows a "Network Manager Unit" (140) positioned between the administrator and the various network devices (135).
  • Technical Importance: This approach sought to create a unified, holistic management platform for multi-vendor networks, thereby simplifying administration, reducing the potential for human error, and lowering barriers to entry for new device manufacturers ('301 Patent, col. 3:42-62).

Key Claims at a Glance

  • The complaint asserts unspecified "Exemplary '301 Patent Claims" (Compl. ¶11). Independent method claim 1 is representative of the core invention.
  • Independent Claim 1 of the '301 Patent recites the following essential elements:
    • Receiving a network device identifier corresponding to the network device;
    • Retrieving a command-format template from a repository, where the template indicates how to construct a device-specific command and includes an attribute field;
    • Identifying attribute data corresponding to the attribute field;
    • Generating the device-specific command for the network device using the retrieved template and the identified attribute data; and
    • Providing the generated device-specific command to the network device.
  • The complaint does not specify whether dependent claims are asserted.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" which are detailed in claim charts in an "Exhibit 2" (Compl. ¶11, 13). This exhibit was not filed with the complaint and is not publicly available.

Functionality and Market Context

The complaint does not describe the specific functionality of the accused products. It alleges that the products "practice the technology claimed by the '301 Patent" (Compl. ¶13) and are internally tested and used by Defendant's employees (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the products' market context or commercial importance.

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating by reference claim charts contained in an "Exhibit 2" (Compl. ¶13-14). As this exhibit was not provided, a detailed element-by-element analysis is not possible. The complaint's narrative theory alleges that the "Exemplary Defendant Products" satisfy all elements of the asserted claims either literally or under the doctrine of equivalents (Compl. ¶11, 13).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Evidentiary Questions: A primary issue will be one of proof. Given the complaint's lack of specific factual allegations describing how the accused products operate, a key question is what evidence Plaintiff will produce to show that the accused software performs each step of the asserted claims, such as retrieving a "command-format template" from a "repository".
  • Technical Questions: The case may turn on the specific mechanism by which the accused products generate and apply configurations. A key technical question is whether the accused products' method of automation aligns with the claimed process of using a template to "generate" a "device-specific command", or if they operate on a different technical principle that does not map to the claim elements.

V. Key Claim Terms for Construction

  • The Term: "command-format template"

  • Context and Importance: This term appears in every independent claim and is the central mechanism of the invention. The scope of the patent hinges on its definition. Practitioners may focus on this term because its construction will determine whether a wide range of modern network configuration tools (e.g., those using YAML, JSON, or other modeling languages) fall within the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Claim 1 defines the term functionally as something that "indicates how to construct a device-specific command" and "includes an attribute field" ('301 Patent, col. 12:49-52). This language could support a broad interpretation covering any data structure or file that serves this purpose.
    • Evidence for a Narrower Interpretation: The specification describes the templates as part of a "template library" ('301 Patent, col. 4:12) and provides an embodiment using a hierarchical "directory tree" (FIG. 9) to locate the appropriate formatting instructions ('301 Patent, col. 11:26-34). This may support a narrower interpretation requiring a more structured, pre-defined library architecture.

  • The Term: "repository"

  • Context and Importance: This term defines the source of the "command-format template" and is a required limitation. Its construction is important to determine the required architecture of an infringing system.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself is generic and could be construed to mean any location from which a template can be retrieved.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to a "central repository" in the context of the "network manager unit" ('301 Patent, col. 5:47, col. 7:31). This could support an argument that the claims require a centralized storage architecture, which might not be met by systems using distributed or on-demand template generation.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain allegations of indirect infringement.
  • Willful Infringement: The complaint does not include a count for willful infringement and makes no allegations regarding pre-suit knowledge of the patent. However, the prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. p. 4, ¶E.i).

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

  • A core issue will be one of evidentiary sufficiency: As the complaint lacks any description of the accused product's operation, the case will depend on what discovery reveals. A central question for the court will be whether the Plaintiff can produce evidence showing the accused software performs the specific steps recited in the claims, particularly the use of a "template" retrieved from a "repository" to generate device-specific commands.

  • The case will also turn on a question of claim scope: Can the term "command-format template", as described in a 2001-filed patent, be construed to cover the methods used by modern network automation software? The outcome of the case may depend on whether the court adopts a broad, functional definition of this term or a narrower one tied to the specific "template library" architectures disclosed in the patent.