DCT
3:25-cv-02596
Origin GPS Ltd v. Texas Instruments Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Origin GPS, Ltd. (Israel)
- Defendant: Texas Instruments, Inc. (Texas)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 3:25-cv-02596, N.D. Tex., 09/24/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because Defendant Texas Instruments is a Texas corporation with its headquarters and a regular and established place of business located in Dallas, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s SimpleLink line of Internet of Things (IoT) integrated circuits infringes two patents related to a cloud-programmable sensor interface architecture.
- Technical Context: The technology concerns integrated circuits designed to function as universal interfaces, enabling remote cloud servers to control a wide variety of physical sensors without requiring sensor-specific programming on the circuit itself, a key concept in scaling IoT deployments.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2016-08-23 | Priority Date for ’300 and ’854 Patents |
| 2018-07-31 | U.S. Patent 10,037,300 Issues |
| 2019-07-16 | U.S. Patent 10,353,854 Issues |
| 2025-09-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,037,300 - "Cloud Programming Sensor Interface Architecture" (Issued Jul. 31, 2018)
The Invention Explained
- Problem Addressed: The patent describes the process of preparing traditional embedded integrated circuits for controlling sensors as expensive, complicated, and inflexible. Any improvements, bug fixes, or changes to the connected sensors typically require reprogramming each individual hardware unit. (’300 Patent, col. 1:36-48).
- The Patented Solution: The invention proposes a generic integrated circuit that acts as a universal hardware interface between sensors and a remote network server. The control logic resides in an application on the server, which sends commands to the circuit. The circuit’s role is simply to relay these commands to the appropriate sensor via a standard I/O interface. This architecture decouples the control software from the hardware, meaning the circuit’s own programming does not need to change when different sensors are connected or the control application is updated. (’300 Patent, col. 1:50-2:3; Abstract).
- Technical Importance: This approach aims to simplify the development of sensor-based systems (like IoT devices) by making the core integrated circuit independent of the specific functions of the sensors it controls. (’300 Patent, col. 1:56-60).
Key Claims at a Glance
- The complaint asserts independent apparatus Claim 1 and independent method Claim 10, and reserves the right to assert claims 1-18. (Compl. ¶¶19, 20, 41).
- Essential Elements of Independent Claim 1:
- An integrated circuit comprising a wireless interface, an I/O interface, and a microprocessor with memory.
- The microprocessor is programmed to connect to a server that executes a sensor-control application.
- It transmits identification and/or location information to the server application.
- It receives commands for the sensors from the server application.
- It transfers those commands to the I/O interface for relay to the sensors.
- A key functional limitation requires that the circuit is configured to control any sensor connected to its I/O interface "without changing the programming of the microprocessor and memory."
- The circuit is further required to include a GNSS receiver to acquire its location.
U.S. Patent No. 10,353,854 - "Cloud Programming Sensor Interface Architecture" (Issued Jul. 16, 2019)
The Invention Explained
- Problem Addressed: This patent, a divisional of the application that led to the ’300 Patent, addresses the same problem of inflexible, sensor-specific embedded systems. (’854 Patent, col. 1:20-48).
- The Patented Solution: The ’854 Patent also describes the generic, cloud-controlled sensor interface. Its claims add further detail regarding the structure of the commands sent from the server. The claims specify that commands must include elements like a destination address for a specific sensor and "command content" formatted for that sensor. The integrated circuit’s function is to "transfer the command content as is" to the sensor, reinforcing its role as a simple conduit rather than a processor of the command's substance. (’854 Patent, col. 9:16-32; Abstract).
- Technical Importance: By defining a structured command protocol that the generic interface passes through without interpretation, the invention provides a specific mechanism for how a single, unchanged circuit can manage a diverse array of different sensors. (’854 Patent, col. 5:47-52).
Key Claims at a Glance
- The complaint asserts independent apparatus Claim 1 and independent method Claim 9, and reserves the right to assert claims 1-16. (Compl. ¶¶23, 24, 53).
- Essential Elements of Independent Claim 1:
- An integrated circuit with a wireless interface, I/O interface, and a programmed microprocessor with memory.
- The microprocessor connects to a server, transmits identification/location information, and receives commands.
- A key command structure limitation requires that received commands include a "destination address" for a specific sensor, a "command type", and "command content" formatted for that sensor.
- The microprocessor must "transfer the command content as is to the I/O interface for relaying to the specific sensor."
- It must also return data from the sensor to the server based on the command.
III. The Accused Instrumentality
Product Identification
The complaint accuses "numerous IOT integrated circuits" sold by Texas Instruments under the "SimpleLink" product line. (Compl. ¶25). Specific product families named include the CC3200, CC3220, CC3551E, CC1352P, and various CC330x, 335x, 350x, and 355x series chips. (Compl. ¶25).
Functionality and Market Context
The accused products are described as integrated circuits designed to "connect sensors to a network, including local and wide areas networks and to the internet." (Compl. ¶25). They allegedly incorporate "processors and wireless connectivity as well as sensor input and output connections." (Compl. ¶25). The complaint provides a diagram showing a SimpleLink IC connecting a camera (sensor) to a network, allowing a user to control the sensor via a smartphone application that communicates with a server. This diagram depicts the SimpleLink IC's Wi-Fi and BLE core, various interfaces (SDIO/SPI, UART), and memory. (Compl. ¶33).
IV. Analysis of Infringement Allegations
’300 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wireless interface configured to connect to a network | The SimpleLink ICs are alleged to include a "Wi-Fi & BLE Core" and "2.4GHz Wi-Fi / BLE RF" module for network connectivity. | ¶¶25, 33 | col. 4:14-24 |
| an I/O interface configured to connect to sensors | The products allegedly possess "sensor input and output connections," with the provided diagram showing interfaces like SDIO/SPI and UART. | ¶¶25, 33 | col. 4:35-49 |
| a microprocessor and memory that are programmed to: connect to a server via the network...receive commands...transfer the commands | The products are alleged to be used in systems where a user controls a sensor via a server-based application, which necessarily involves the IC connecting to the server and relaying commands. | ¶33 | col. 2:15-27 |
| wherein the integrated circuit is configured to control any sensor... without changing the programming of the microprocessor and memory | The complaint alleges infringement, which implies this functionality, but does not provide specific facts demonstrating how the SimpleLink products achieve this. | ¶¶26, 33 | col. 2:28-31 |
| wherein the integrated circuit includes a GNSS receiver to acquire location information of the integrated circuit | The complaint does not contain specific factual allegations or evidence that the accused SimpleLink products include a GNSS receiver. | ¶¶26, 33 | col. 2:32-34 |
- Identified Points of Contention:
- Technical Question: A central factual question is whether the accused SimpleLink products include a "GNSS receiver," as the complaint provides no evidence to support this express claim limitation. The absence of this component could present a significant challenge to allegations of literal infringement of claims requiring it, such as Claim 1.
- Scope Questions: The dispute may focus on the meaning of "without changing the programming." The question for the court will be whether this phrase precludes routine software configurations, driver loading, or firmware updates that Defendant may argue are necessary to operate its products with new sensors.
’854 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receive commands for the sensors... wherein the commands include a destination address identifying a specific sensor, a command type and a command content... | The complaint's general allegations of infringement imply the accused products receive and process commands, but it does not provide any detail on the specific format or structure of those commands. | ¶¶26, 33 | col. 5:21-52 |
| transfer the command content as is to the I/O interface for relaying to the specific sensor | The complaint alleges infringement, which requires this function, but offers no specific facts about the internal data handling of the SimpleLink ICs to show that command content is passed without modification. | ¶¶26, 33 | col. 9:29-31 |
| return data from the sensors to the server based on the command type and provided command content | The complaint alleges this functionality as part of the infringing method but does not provide details on the data return path or mechanism in the accused products. | ¶¶26, 33 | col. 9:31-32 |
- Identified Points of Contention:
- Technical Question: A key evidentiary issue will be the actual command structure and data flow within the SimpleLink ecosystem. The complaint does not provide evidence that the accused system uses the specific "destination address", "command type", and "command content" structure required by the claim.
- Scope Questions: The term "as is" will likely be a focal point. The infringement analysis may turn on whether the accused ICs perform any processing, re-formatting, or protocol translation on the command data received from the server before sending it to a sensor, which could place their operation outside the literal scope of this limitation.
V. Key Claim Terms for Construction
The Term: "without changing the programming of the microprocessor and memory" (’300 Patent, Claim 1)
- Context and Importance: This phrase is the cornerstone of the patent's claimed advance over the prior art, defining the "generic" nature of the interface. Its construction will determine whether a wide range of common software configuration activities fall within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the embedded software "is generic and remains the same for all sensors connected to the integrated circuit," contrasting it with prior art requiring units to be "reprogrammed." (’300 Patent, col. 2:1-3, col. 1:41-43). This may support an interpretation that only fundamental changes to the core operating firmware constitute "changing the programming."
- Evidence for a Narrower Interpretation: The patent discloses that "a sub application can be accepted from the server to locally execute some or all of the functions." (’300 Patent, col. 2:55-58). A defendant may argue that downloading and executing such a "sub application" in memory constitutes "changing the programming," thereby narrowing the claim's scope to only devices with strictly static software.
The Term: "transfer the command content as is" (’854 Patent, Claim 1)
- Context and Importance: This term is critical for defining the accused device's role as a pure conduit. Infringement depends on whether the accused IC acts as a simple pass-through for command data or performs some level of substantive processing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide explicit language supporting a broad reading (e.g., allowing for minor protocol-level re-framing). Parties might argue that "as is" refers to the substantive content, not necessarily the low-level data packet structure.
- Evidence for a Narrower Interpretation: The specification notes that "the content 350 is the actual commands for controlling the sensors 250 of which integrated circuit 100 is oblivious of." (’854 Patent, col. 5:47-49). This language supports a strict, literal interpretation where the circuit performs no analysis or modification of the command content itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant provides instructions to its customers on how to use the accused circuits in an infringing manner. (Compl. ¶¶27, 45, 57). Contributory infringement is based on allegations that the accused circuits are a material part of the invention, are not staple articles of commerce, and are incapable of substantial non-infringing use. (Compl. ¶¶29, 49, 61).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's knowledge of the patents acquired "at least as early as the filing of this suit." (Compl. ¶¶2, 38). This is a standard allegation of post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof: can Plaintiff demonstrate that the accused SimpleLink products include a "GNSS receiver," a specific hardware component required by asserted independent claims of the ’300 Patent, which is not mentioned or shown in the complaint's own technical descriptions?
- A central dispute will be one of definitional scope: how will the court construe the phrase "without changing the programming"? The case may hinge on whether this limitation permits common IoT device management practices like loading drivers or configuration files, or if it requires a completely static software environment on the integrated circuit.
- A key technical question will be one of operational fidelity: for the ’854 Patent, does the accused architecture transfer command data "as is" from server to sensor, or does it perform intermediate processing or translation? The answer will determine whether the accused products function as the simple "oblivious" conduit described in the patent.