Cloud Systems Holdco IP LLC v. Hall Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
  • Defendant: Hall Technologies, Inc. (New Jersey)
  • Plaintiff’s Counsel: Ramey, LLP
• Case Identification: 3:25-cv-02564, N.D. Tex., 09/22/2025
• 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 audio-visual control and automation systems infringe a patent related to the remote management and routing of signals between devices in a networked environment.
• Technical Context: The technology relates to centralized, software-based control systems for managing complex environments with numerous interconnected devices, a market with significance in corporate, educational, and high-end residential settings.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity and notes that it and its predecessors have entered into prior settlement licenses. The complaint includes extensive allegations arguing that these prior licenses do not trigger patent marking requirements under 35 U.S.C. § 287(a), preemptively addressing a potential defense that could limit damages.

Case Timeline

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

U.S. Patent No. 8,533,326 - Method for managing, routing, and controlling devices and inter-device connections

• Patent Identification: U.S. Patent No. 8,533,326, issued September 10, 2013.

The Invention Explained

• Problem Addressed: The patent addresses the limitations of traditional audio-visual (A/V) management systems, which it describes as "custom designed, closed-system, hardware specific solutions designed to operate with only a limited number of hardware devices" (’326 Patent, col. 2:58-61). Such systems struggle to manage the multiple streams of information from a variety of sources to a wide array of output devices found in modern conference rooms or media centers (’326 Patent, col. 2:61-66).
• The Patented Solution: The invention discloses a hardware-independent system architecture centered on a server that communicates with a control client (’326 Patent, Abstract). The server maintains a software "model" of the physical environment, including all devices and their possible connections, and translates user commands from the client into specific instructions for the hardware, such as A/V switches, projectors, lighting, and window shades (’326 Patent, col. 2:25-33; Fig. 1A).
• Technical Importance: This approach sought to create an "effective, open-architecture system" capable of providing adaptable and customized controls for sophisticated A/V environments, moving away from rigid, hardware-specific solutions (’326 Patent, col. 3:3-9).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 13, among others (’326 Patent, col. 38:1-38:21, col. 39:60-40:20; Compl. ¶9).
• Independent Claim 1 recites a method for controlling an environment, with key elements including:
  • Accessing a server via a control client and rendering a control panel adapted to the user's rights.
  • Creating a "user defined configuration" of devices.
  • "Generating a desired path in the environment based on an environment model" stored on the server.
  • Identifying an event and, in response, triggering commands to a control switch to interconnect a source and output device.
• Independent Claim 13 recites a method for configuring information flow, with key elements including:
  • Mapping static connections between a plurality of devices.
  • Receiving an event to trigger the configuration.
  • "Applying a means for identifying a reverse path" from an output device to a source device "with a recursive algorithm."
  • Configuring a subset of devices along that path to enable information flow.
• The complaint asserts infringement of claims 1-20, reserving the right to pursue dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify specific accused products by name. It broadly accuses Defendant’s "systems, products, and services for enabling a method for controlling an environment" (Compl. ¶9). The complaint also notes that in 2025, Defendant acquired the product line of Atlona, Inc., a known manufacturer of A/V distribution and control products (Compl. ¶2).

Functionality and Market Context

• The accused functionality is described generally as a "method for controlling an environment, comprising establishing communication between a server and a control client" (Compl. ¶11). The complaint does not provide sufficient detail for analysis of the specific technical operation or market positioning of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s systems perform the patented methods but does not provide a claim chart or detailed technical comparison (Compl. ¶9). It references a claim chart in an external "Exhibit B," which was not filed with the complaint document (Compl. ¶10). The narrative infringement theory suggests Defendant's systems employ a server-client architecture to control and route signals within an environment, thereby practicing the methods of the ’326 Patent (Compl. ¶11).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: As the complaint lacks specific technical details linking accused products to claim limitations, a primary issue for the court will be what evidence Plaintiff can produce during discovery to demonstrate that Defendant's systems practice each element of the asserted claims, including the "generating a desired path... based on an environment model" as required by claim 1.
  • Technical Question: For claim 13, the infringement analysis may focus on whether the pathfinding methodology used in Defendant's systems meets the "recursive algorithm" limitation. The case may require a technical deep-dive into the accused software architecture to determine if it performs the claimed function.

V. Key Claim Terms for Construction

The Term: "environment model" (from claim 1)

• Context and Importance: This term defines the core data structure that enables the server to manage the hardware-agnostic control system. The infringement analysis for claim 1 depends on whether Defendant’s systems utilize a data structure that meets this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself defines the model simply as a "data structure on said server" used to generate a path, which suggests a broad functional definition (’326 Patent, col. 38:12-14).
  • Evidence for a Narrower Interpretation: The specification states this model "represents the devices 270 and other details of the presentation environment 110," which may imply it must contain specific information about device types, states, and static connections to qualify (’326 Patent, col. 8:50-54).

The Term: "recursive algorithm" (from claim 13)

• Context and Importance: This term recites a specific type of computational process for pathfinding. Whether Defendant's routing logic falls within the scope of this term will be a dispositive issue for infringement of claim 13.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term has a well-understood, broad definition in computer science as an algorithm that calls itself to solve a problem.
  • Evidence for a Narrower Interpretation: The specification lists several examples of recursive search algorithms, including "breadth-first search, depth limited search, A*, Dijkstra's algorithm, [and] best-first search" (’326 Patent, col. 35:12-15). A defendant may argue that the claim scope should be guided by or limited to these disclosed examples and their functional equivalents.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement on the basis that Defendant has "actively encouraged or instructed" customers on how to use its products in an infringing manner, specifically by establishing communication between a server and a control client to manage an environment (Compl. ¶11). Contributory infringement is alleged on a similar basis (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’326 Patent and its underlying technology "from at least the issuance of the patent" (Compl. ¶11-12). The prayer for relief requests treble damages (Compl. ¶ VI.e).

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

• A primary issue will be one of evidentiary sufficiency: Given the complaint’s general allegations, can Plaintiff produce discovery showing that Defendant’s accused systems, which are not identified by name, implement the specific software architecture—including an "environment model" and an event-driven command structure—recited in claim 1?
• A central technical question will be one of algorithmic scope: Does the pathfinding logic within Defendant’s control systems meet the specific "recursive algorithm" limitation of claim 13, or does it employ a distinct, non-infringing method for determining signal routes?
• A key threshold issue, which Plaintiff has proactively addressed, will be patent marking: Will Defendant succeed in limiting pre-suit damages by arguing that Plaintiff’s prior settlement agreements with third parties triggered marking duties under 35 U.S.C. § 287 that were not fulfilled?