Cloud Systems Holdco IP LLC v. ABB Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
  • Defendant: ABB, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:25-cv-03860, S.D. Tex., 08/15/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Extron Control System infringes a patent related to the automated management, routing, and control of multiple interconnected devices in an environment.
• Technical Context: The technology at issue involves centralized software control systems for managing complex audiovisual (AV) and environmental devices, a market where interoperability and ease-of-use are significant factors.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors-in-interest have entered into settlement licenses with other entities, but asserts that none of these licenses involved an admission of infringement or were for producing a patented article, a point raised to address potential patent marking requirements under 35 U.S.C. § 287.

Case Timeline

Date	Event
2006-05-03	’912 Patent - Earliest Priority Date
2019-07-30	’912 Patent - Issue Date
2025-08-15	Complaint Filing Date

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

U.S. Patent No. 10,367,912 - "System and Method for Automating the Management, Routing, and Control of Multiple Devices and Inter-Device Connections"

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of controlling, managing, and routing data streams (such as AV signals) among multiple, disparate devices within a given environment in a hardware-independent way, which can be complex to configure and operate (Compl. ¶8; ’912 Patent, col. 1:11-17, col. 2:48-58).
• The Patented Solution: The invention proposes a client-server architecture where a central server communicates with a control client to provide a user interface for managing an entire "presentation environment" (’912 Patent, col. 3:54-62). This server can command various source devices (e.g., DVD players, laptops), output devices (e.g., monitors, projectors), and control devices (e.g., AV switches) to establish connections and manage their operational states, abstracting the underlying hardware complexity from the user (’912 Patent, Fig. 1A, col. 4:1-11).
• Technical Importance: This approach provides a centralized and abstracted control layer for complex device ecosystems, aiming to simplify the configuration and operation of multi-device environments like conference rooms or integrated building systems (’912 Patent, col. 2:23-31).

Key Claims at a Glance

• The complaint asserts infringement of claims 1-19 (Compl. ¶9).
• Independent claim 1, a method claim, recites the essential elements:
  • Configuring a server to host a database describing a set of static connections and adaptable nodes, and to run a scheduling service.
  • Configuring a control client to control at least one output device and communicate with the scheduling service.
  • Configuring a control client web application to render a user interface on the client with standard and specialized control options.
  • Configuring a control switch to communicate with the client.
  • Configuring an output device configurator to send requests and control information to the output device via the switch.
  • Configuring the scheduling service to manage the availability of the output device.
• The complaint does not explicitly reserve the right to assert dependent claims, but the general assertion of claims 1-19 covers them.

III. The Accused Instrumentality

Product Identification

Defendant’s "Extron Control System" (Compl. ¶11).

Functionality and Market Context

• The complaint alleges the Extron Control System is a system offered and sold to customers for the purpose of managing or controlling their connected AV devices across an environment (Compl. ¶11).
• The complaint asserts that Defendant provides these systems for its customers to use, and that Defendant profits from its customers' use of the infringing methods by selling the equipment (Compl. ¶11). The complaint does not provide further technical detail on the specific operation or architecture of the accused system.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit B to support its infringement allegations; however, this exhibit was not filed with the complaint (Compl. ¶10). The narrative allegations state that the Defendant "maintains, operates, and administers systems and services that performs a method that infringes" one or more claims of the ’912 Patent (Compl. ¶9). The infringement theory appears to be grounded in the functionality of the Extron Control System, which allegedly provides customers with the ability to "manage or control their connected AV devices," a function that mirrors the purpose of the patented method (Compl. ¶11). The complaint also asserts a theory of vicarious liability, stating that "Defendant infringes vicariously by profiting from its customers use of the Defendant's system" (Compl. ¶11). Without the referenced claim chart, a detailed element-by-element analysis of the infringement allegations is not possible based on the complaint alone.

V. Key Claim Terms for Construction

• The Term: "a control client web application"
• Context and Importance: This term appears in claim 1 and is central to defining the nature of the user interface component. The infringement analysis may turn on whether the accused Extron Control System utilizes an interface that can be properly characterized as a "web application," as opposed to a native software application, a dedicated hardware interface, or another form of control software. Practitioners may focus on this term because the specific technical implementation of the user-facing control software is a common point of distinction in such systems.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes that the control client can be a "Windows® computer" and the interface can be implemented "using a standard internet or web browser" (’912 Patent, col. 11:51-57). This could support an interpretation that covers various browser-based or internet-enabled applications.
  • Evidence for a Narrower Interpretation: The patent explicitly discloses the "control client web application" as having components that "render a user interface on the control client" (’912 Patent, col. 47:58-62; col. 48:47-49). A defendant may argue this requires a specific client-side rendering architecture, potentially distinguishing it from server-side or thin-client systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement (Compl. ¶¶12-13). It claims Defendant actively encourages and instructs customers on how to use the accused products in a manner that performs the claimed method, such as by "establishing communication between a server and a control client" (Compl. ¶12). Knowledge of the patent is alleged from at least its date of issuance (Compl. ¶12).
• Willful Infringement: The complaint makes a conditional allegation of willful infringement, contingent on discovery revealing pre-suit knowledge of the ’912 Patent (Compl. p. 7, ¶e). The pleading asserts Defendant "knew, or should have known, that its conduct amounted to infringement" (Compl. p. 7, ¶e).

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

• A core issue will be one of definitional scope: can the term "control client web application," as recited in claim 1, be construed to cover the specific software architecture and user interface of the accused Extron Control System? The resolution of this construction will be fundamental to the infringement analysis.
• A key evidentiary question will be one of technical implementation: as the complaint lacks a detailed, public claim chart, the case will depend on evidence developed during discovery to establish how, if at all, the components and operation of the Extron Control System map to the specific elements of the asserted method claims.
• The case also raises a question of indirect liability: what specific actions did the Defendant take that demonstrate an intent to encourage its customers to perform the patented method, beyond simply selling a system with the alleged capability to do so?

No probative visual evidence provided in complaint.