DCT
3:25-cv-03383
Origin GPS Ltd v. Qualcomm Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Origin GPS, Ltd. (Israel)
- Defendant: Qualcomm Incorporated (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 3:25-cv-03383, N.D. Tex., 12/09/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Defendant Qualcomm maintains a regular and established place of business in Richardson, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Internet of Things (IoT) integrated circuits infringe two patents related to a "Cloud Programming Sensor Interface Architecture."
- Technical Context: The technology at issue addresses methods for creating flexible and updatable IoT devices by using a generic hardware interface that offloads sensor control logic to a remote cloud server.
- Key Procedural History: The complaint does not allege any pre-suit notice or licensing negotiations; knowledge for the purposes of willfulness is alleged to have begun with the filing of the complaint.
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 |
| 2025-12-09 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,037,300 - "Cloud Programming Sensor Interface Architecture" (Issued July 31, 2018)
The Invention Explained
- Problem Addressed: The patent describes the process of preparing and updating embedded integrated circuits for specific sensors as expensive, complicated, and rigid. When sensors are changed or software requires updates, each hardware unit typically needs to be individually reprogrammed. (’300 Patent, col. 1:36-48).
- The Patented Solution: The invention proposes an integrated circuit that acts as a generic interface between sensors and a network. Instead of containing sensor-specific programming, the circuit connects to a remote server that executes the application for controlling the sensors. The circuit’s role is to relay commands from the server to any connected sensor and transmit sensor data back to the server, thereby decoupling the hardware's programming from the specific function of the sensors it controls. (’300 Patent, Abstract; col. 2:1-9).
- Technical Importance: This architecture centralizes control logic on a remote server, which can simplify the development, deployment, and updating of IoT systems by making the hardware component universal and sensor-agnostic. (’300 Patent, col. 1:50-59).
Key Claims at a Glance
- The complaint asserts independent claims 1 (apparatus) and 10 (method) (Compl. ¶19-20, 41).
- Essential Elements of Independent Claim 1:
- An integrated circuit with a wireless interface (to a network) and an I/O interface (to sensors).
- A microprocessor and memory programmed to connect to a server that executes a sensor-controlling application.
- The microprocessor is further programmed to transmit identification/location information to the server, receive commands from the server, and transfer those commands to the I/O interface for the sensors.
- A key limitation requires that the integrated circuit is configured to control any sensor connected to its I/O interface "without changing the programming of the microprocessor and memory."
- The circuit must include a GNSS receiver to acquire its location.
- The complaint asserts claims 1-18, thereby including dependent claims (Compl. ¶41).
U.S. Patent No. 10,353,854 - "Cloud Programming Sensor Interface Architecture" (Issued July 16, 2019)
The Invention Explained
- Problem Addressed: As a divisional of the application leading to the ’300 Patent, the ’854 Patent addresses the same technical problem: the complexity and inflexibility of traditional embedded systems where control software is tightly coupled with specific sensor hardware. (’854 Patent, col. 1:39-48).
- The Patented Solution: The solution is also a generic integrated circuit that offloads control logic to a remote server. The claims of the ’854 Patent add specific requirements for the structure and handling of commands passed between the server, the circuit, and the sensors. (’854 Patent, Abstract; Claim 1).
- Technical Importance: The invention provides a standardized architecture for command and data flow in a cloud-based IoT control system, aiming to enhance interoperability and scalability. (’854 Patent, col. 1:50-60).
Key Claims at a Glance
- The complaint asserts independent claims 1 (apparatus) and 9 (method) (Compl. ¶23-24, 53).
- Essential Elements of Independent Claim 1:
- An integrated circuit with a wireless interface, an I/O interface, and a programmed microprocessor/memory.
- The microprocessor connects to a server executing a control application and transmits identification/location information.
- It receives commands that include a "destination address identifying a specific sensor, a command type and a command content," where the content is formatted for the specific 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 sensors to the server based on the command type and provided command content."
- The complaint asserts claims 1-16, thereby including dependent claims (Compl. ¶53).
III. The Accused Instrumentality
Product Identification
The complaint identifies "numerous IOT integrated circuits" sold by Qualcomm, including products from the "Qualcomm IOT or Internet of Things processors" line (Compl. ¶25). Specific product families named are the Qualcomm Dragonwing Q8, Q6, Q5, Q4, and Q2 series, with the Qualcomm Dragonwing QCS4290 chip identified as a representative example (Compl. ¶25).
Functionality and Market Context
The Accused Products are described as integrated circuits that include processors, wireless connectivity for local and wide area networks, and sensor input/output connections (Compl. ¶25). Their alleged function is to connect various sensors to a network and the internet, enabling remote control and data monitoring. The complaint provides a block diagram of the QCS4290 processor, illustrating components such as the "Qualcomm® Kryo™ 260 CPU," "LTE Modem," and "3x ISP Camera System" which are alleged to correspond to the claimed microprocessor, wireless interface, and I/O interface, respectively (Compl. ¶33).
IV. Analysis of Infringement Allegations
The complaint alleges infringement but does not include the referenced claim chart exhibits (Compl. ¶31-32). The following summary is based on the complaint's narrative allegations.
’300 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An integrated circuit... comprising: a. a wireless interface configured to connect to a network; | The Accused Products are integrated circuits that include wireless connectivity modules, such as an LTE Modem, for connecting to networks. | ¶25, 33 | col. 4:14-24 |
| b. an I/O interface configured to connect to sensors; | The Accused Products include sensor input and output connections, such as the "3x ISP Camera System." | ¶25, 33 | col. 4:35-49 |
| c. a microprocessor and memory that are programmed to: connect to a server via the network; wherein said server executes an application for controlling the sensors; | The Accused Products contain a CPU (e.g., Kryo™ 260) and memory, and are used in systems where a user controls sensors via a smartphone connected to a server-based application. | ¶25, 33 | col. 2:1-4 |
| transmit... location information of the integrated circuit... | The Accused Products include location capabilities (e.g., Bluetooth/Wi-Fi positioning or GNSS). | ¶33 | col. 2:31-33 |
| receive commands for the sensors from the application... and transfer the commands to the I/O interface for relaying to the sensors; | The Accused Products are allegedly programmed to receive commands from a server-based application and relay them to connected sensors. | ¶33 | col. 2:25-28 |
| wherein the integrated circuit is configured to control any sensor that can connect electronically to the I/O interface without changing the programming of the microprocessor and memory; | The complaint alleges the Accused Products satisfy this element, but provides no specific facts regarding how programming is or is not changed. | ¶33 | col. 2:29-32 |
| wherein the integrated circuit includes a GNSS receiver to acquire location information... | The Accused Products include a "Location" module, which is alleged to be or include a GNSS receiver. The patent itself makes a GNSS receiver a required element. | ¶19, 33 | col. 2:31-33 |
’854 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receive commands for the sensors from the application executed by the server; wherein the commands include a destination address identifying a specific sensor, a command type and a command content... | The complaint does not provide sufficient detail for analysis of the specific command structure used by the Accused Products. | ¶33 | col. 9:23-28 |
| transfer the command content as is to the I/O interface for relaying to the specific sensor; | The complaint does not provide sufficient detail for analysis of how command content is transferred by the Accused Products. | ¶33 | col. 9:29-31 |
| return data from the sensors to the server based on the command type and provided command content. | The complaint does not provide sufficient detail for analysis of how the Accused Products return data to the server. | ¶33 | col. 9:32-34 |
- Identified Points of Contention:
- Scope Questions: A primary issue for the ’300 Patent may be the scope of the negative limitation "without changing the programming of the microprocessor and memory." The dispute may center on whether routine firmware, driver, or operating system updates on the accused chips constitute a "change" in programming that would place them outside the scope of the claim.
- Technical Questions: For the ’854 Patent, a key question will be evidentiary: What proof can be offered that the accused products' communication protocols utilize the specific command structure recited in the claim (e.g., "destination address," "command content") and that this content is transferred "as is"? The complaint does not provide factual allegations on this point.
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 negative limitation is central to the patent's purported advance over the prior art of sensor-specific embedded systems. Its construction will determine whether any software modification on the accused chip, such as a firmware or driver update, is sufficient to avoid infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (Plaintiff-favored): The specification frames the problem as avoiding the need to reprogram the embedded software when "a change in the sensors requires" it (’300 Patent, col. 1:46-48). This context suggests "programming" refers to the high-level, sensor-specific application logic, not underlying firmware or drivers that might be updated for other reasons.
- Evidence for a Narrower Interpretation (Defendant-favored): The Abstract states the circuit is configured to control any sensor "without changing the programming." This could be read as an absolute prohibition on altering any executable code on the device, positioning it as a simple, immutable hardware relay.
The Term: "transfer the command content as is" (’854 Patent, Claim 1)
- Context and Importance: This term defines the nature of the circuit's function as a mere conduit for a specific piece of data. If the accused Qualcomm chip repackages, translates, or otherwise modifies the "command content" before sending it to the sensor, it may not infringe. Practitioners may focus on this term because modern system-on-chip devices often perform protocol translation between network-level commands and low-level hardware bus commands.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (Plaintiff-favored): The specification does not explicitly define "as is." An argument could be made that it means the substantive payload of the command is preserved, even if it is encapsulated in different headers or protocols for transmission over various interfaces.
- Evidence for a Narrower Interpretation (Defendant-favored): A plain reading suggests a bit-for-bit, unmodified transfer of the "command content" data block from the received network packet to the I/O interface. The lack of further definition in the specification could support an argument for this strict, literal meaning.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement on the basis that Qualcomm provides the accused circuits to customers with instructions for their use, which allegedly causes customers to practice the claimed methods (Compl. ¶36, 57). Contributory infringement is alleged on the theory that the accused circuits are a material part of the invention and are not staple articles of commerce (Compl. ¶37, 61).
- Willful Infringement: Willfulness is alleged based on knowledge of the patents "at least as early as the filing of this suit" (Compl. ¶2, 38). This constitutes an allegation of post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the limitation "without changing the programming" be construed to permit routine firmware, security, or driver updates common in modern integrated circuits, or does it impose a strict prohibition on any software modification that would render the accused products non-infringing?
- A key evidentiary question will be one of technical operation: Does the complaint, and subsequent discovery, provide sufficient evidence that Qualcomm's products actually implement the specific command architecture of the ’854 Patent, particularly the requirement to "transfer the command content as is" from a server to a sensor without material translation or modification?
- The case also presents a classic question of system vs. component infringement: The dispute will likely involve whether Qualcomm's integrated circuit, as a standalone component, meets all limitations of the apparatus claims, or if infringement only occurs when a third-party customer integrates the chip into a complete system with servers and sensors, making indirect infringement theories central to the case.