DCT

1:25-cv-01579

Secure Communication Tech LLC v. Apple Inc

Log In
Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01579, W.D. Tex., 12/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district—including a corporate campus and retail stores—employs personnel there, and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and laptops infringe six patents related to methods for secure and efficient wireless communication, particularly systems that use short-range protocols for proximity detection and server-mediated data exchange.
  • Technical Context: The technology concerns proximity-based wireless services, which allow devices to discover each other locally (e.g., via Bluetooth) and then leverage a wide-area network (e.g., cellular) to securely exchange information via a central server, a foundation for modern features like device tracking and local data sharing.
  • Key Procedural History: The complaint alleges a long history of pre-suit knowledge by Defendant, including direct communications between the inventor and Apple employees regarding the patent portfolio dating back to 2011-2012. Plaintiff also alleges Defendant was aware of the technology through its own patent prosecution activities where it cited patents from the asserted family. Plaintiff states it sent formal notice letters regarding several of the patents-in-suit on August 4, 2025, and alleges knowledge from a prior related lawsuit filed in the Eastern District of Texas.

Case Timeline

Date Event
2008-09-08 Earliest priority date for all Patents-in-Suit
2009 Alleged release date for Find My iPhone
2010 Alleged release date for Bluetooth 4.0
2011 Alleged release date for AirDrop
2011-11-18 Inventor allegedly corresponds with Apple about the patent portfolio
2012-02-14 U.S. Patent No. 8,116,749 issue date
2012-02-29 Inventor allegedly informs Apple of the ’749 Patent
2012-03-19 Inventor allegedly provides a "Portfolio Overview" to Apple
2017 Alleged release date for WiFi password sharing
2022-05-17 U.S. Patent No. 11,334,918 issue date
2022-09-13 U.S. Patent No. 11,443,344 issue date
2023-06-27 U.S. Patent No. 11,687,971 issue date
2024-05-28 U.S. Patent No. 11,995,685 issue date
2025-08-04 Plaintiff sends notice letters to Defendant
2025-09-30 U.S. Patent No. 12,430,667 issue date
2025-12-05 First Amended Complaint filing date

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

U.S. Patent No. 8,116,749 - "Protocol for anonymous wireless communication"

  • Patent Identification: U.S. Patent No. 8,116,749, "Protocol for anonymous wireless communication," issued February 14, 2012 (Compl. ¶19).

The Invention Explained

  • Problem Addressed: The patent's background describes shortcomings in existing peer-to-peer "mobile social networking" services, where all information had to be stored locally for direct device-to-device exchange. This architecture made it difficult to enforce policies and created risks of fraud, such as identity spoofing, leading to personal safety and privacy concerns (Compl. ¶71; ’749 Patent, col. 2:35-42).
  • The Patented Solution: The invention facilitates information exchange by separating proximity detection from data transfer. A first device uses a short-range wireless link (e.g., Bluetooth or Wi-Fi) only to detect an identifier from a nearby second device. Rather than transferring application data over that link, one or both devices then use a long-range wireless link (e.g., cellular) to communicate with a central server, which brokers the actual data exchange (Compl. ¶72; ’749 Patent, col. 2:59-3:4). The complaint references the patent's Figure 3 as illustrating this process, where a device finds local identifiers, filters them, and then requests related information from the server (Compl. ¶75; ’749 Patent, col. 7:48-8:11).
  • Technical Importance: This server-mediated approach allowed for the application of security policies and user permissions to proximity-based interactions, a significant improvement over the less secure, direct peer-to-peer data exchange models prevalent at the time (Compl. ¶73; ’749 Patent, col. 6:39-49).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶62).
  • The essential elements of claim 1 include:
    • A method where a first wireless device collects "initial identification information" from a second wireless device via a direct, short-range link.
    • The first device provides this initial information to a central server over a second, different wireless link, where it is associated with the identity of the second device's user.
    • Upon a "predetermined event coordinated with said central server," the second device provides "modified identification information" over the short-range link in place of the initial information.
    • This modified information is also associated at the server with the same user identity.
    • The first wireless device collects the modified information.
  • The complaint notes that dependent claims provide further improvements but does not explicitly assert them in the corresponding infringement count, though it reserves the right to do so (Compl. ¶¶ 62, 79).

U.S. Patent No. 11,334,918 - "Exchanging identifiers between wireless communication to determine further information to be exchanged or further services to be provided"

  • Patent Identification: U.S. Patent No. 11,334,918, "Exchanging identifiers between wireless communication to determine further information to be exchanged or further services to be provided," issued May 17, 2022 (Compl. ¶24).

The Invention Explained

  • Problem Addressed: The patent addresses similar problems as the ’749 Patent, highlighting the fraud and privacy risks of direct peer-to-peer communication systems that lack a mechanism for policy enforcement (Compl. ¶107; ’918 Patent, col. 2:50-57).
  • The Patented Solution: The invention claims a mobile device with two radios. The first (long-range) radio receives "identifier related information" from a server. The second (short-range) radio receives "proximity beacon transmissions" from nearby transmitters. These beacon transmissions contain a MAC address, a unique identifier, and a "Proximity Beacon Service Identifier" (PBSI). The device uses the PBSI to confirm the transmission is from the relevant service and then uses the unique identifier from the beacon and the information from the server to determine if a specific entity or object is nearby (’918 Patent, Abstract; Compl. ¶113). The patent's Figure 1 depicts this architecture, with a central server (101) communicating with devices (106, 108) over a wide-area network while the devices also interact over a local link (107) (’918 Patent, Fig. 1).
  • Technical Importance: This system creates a structured framework for using low-power beacons for proximity detection while leveraging a central server to provide richer, more secure services, enabling features like finding lost items or receiving location-based offers without direct data exchange with the beacon itself (Compl. ¶108; ’918 Patent, col. 3:8-20).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a device claim) and 9 (a method claim) (Compl. ¶98).
  • The essential elements of independent claim 1 include:
    • A mobile wireless device with first and second radios.
    • Receiving, via the first radio, "identifier related information" for a proximity beacon service from a server.
    • Receiving, via the second radio, proximity beacon transmissions that include a MAC address, a unique identifier, and a Proximity Beacon Service Identifier (PBSI).
    • Determining if a transmission is a valid proximity beacon transmission based on the presence of a MAC address and a valid PBSI.
    • Determining if an entity is in proximity by using the server's information and the beacon's unique identifier.
  • The essential elements of independent claim 9 mirror the device operations of claim 1 in method form.
  • The complaint details numerous dependent claims but does not explicitly assert them in the infringement count, reserving the right to do so (Compl. ¶¶ 98, 117).

U.S. Patent No. 11,443,344 - "Efficient and secure communication using wireless service identifiers"

  • Patent Identification: U.S. Patent No. 11,443,344, "Efficient and secure communication using wireless service identifiers," issued September 13, 2022 (Compl. ¶29).
  • Technology Synopsis: The patent describes a method where a wireless device receives beacon transmissions (comprising a MAC address, a unique identifier, and a beacon service identifier) via a short-range protocol. The device filters these transmissions based on the service identifier and uses stored information, received from a server via a second protocol, to take action if a specific unique identifier is present (Compl. ¶¶ 145-146, 151).
  • Asserted Claims: Independent claims 1, 29, and 30 (Compl. ¶136).
  • Accused Features: The complaint accuses Apple's Find My network, including its Offline Finding feature and AirTags, which allegedly use Bluetooth beacons from Apple devices to report their location to a central server network (Compl. ¶¶ 50, 137).

U.S. Patent No. 11,687,971 - "Efficient and secure communication using wireless service identifiers"

  • Patent Identification: U.S. Patent No. 11,687,971, "Efficient and secure communication using wireless service identifiers," issued June 27, 2023 (Compl. ¶34).
  • Technology Synopsis: This patent claims a method where a device receives beacon transmissions whose service identifier indicates that the unique identifier is relevant to stored information "not otherwise accessible" via the short-range protocol. The device then receives this stored information from a server over a second protocol before taking action (Compl. ¶¶ 185-186, 191).
  • Asserted Claims: Independent claims 1, 37, and 50 (Compl. ¶176).
  • Accused Features: The complaint targets Apple's Find My network and AirTags, which use a crowd-sourced network of devices to securely and privately relay the location of lost items to their owner via Apple's servers (Compl. ¶¶ 50, 177).

U.S. Patent No. 11,995,685 - "Efficient and secure communication using wireless service identifiers"

  • Patent Identification: U.S. Patent No. 11,995,685, "Efficient and secure communication using wireless service identifiers," issued May 28, 2024 (Compl. ¶39).
  • Technology Synopsis: The patent describes processing beacon transmissions received via a short-range protocol, where the unique identifier is a numeric value. Stored information related to that identifier is transferred between the device and a server via a different protocol. The device filters beacons and takes action based on the server-provided information (Compl. ¶¶ 227-228, 233).
  • Asserted Claims: Independent claim 1 (Compl. ¶218).
  • Accused Features: The Find My network and AirTags are again identified as the infringing functionalities (Compl. ¶¶ 50, 219).

U.S. Patent No. 12,430,667 - "Efficient and secure communication using wireless service identifiers"

  • Patent Identification: U.S. Patent No. 12,430,667, "Efficient and secure communication using wireless service identifiers," issued September 30, 2025 (Compl. ¶44).
  • Technology Synopsis: This patent claims a mobile device configured as a beacon transmitter for a "particular beacon location service." A separate detecting device filters these beacon transmissions and sends location reports to a server, which in turn informs the entity associated with the transmitting device of its location. The system also contemplates the use of rotating MAC addresses and unique identifiers over different time periods (Compl. ¶¶ 267-268, 273, 275).
  • Asserted Claims: Independent claim 1 (Compl. ¶258).
  • Accused Features: The complaint targets the Find My network, where Apple devices can act as beacon transmitters whose locations are reported by a network of other Apple devices acting as receivers (Compl. ¶¶ 50, 259).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are Apple-branded smartphones (iPhone 14 through 17 series), tablets (iPad, iPad Pro, iPad Air, iPad mini), and laptops (MacBook Air, MacBook Pro) (Compl. ¶49).

Functionality and Market Context

  • The complaint targets specific functionalities within the Accused Products, namely "Find My" (including "Offline Finding" and support for "AirTags") and "Continuity" features (including "AirDrop" and "WiFi password sharing") (Compl. ¶50). These features utilize short-range wireless technologies like Bluetooth and Wi-Fi for device discovery and data exchange, often in coordination with Apple's backend cloud infrastructure. The Find My network, in particular, is alleged to create a crowd-sourced network where hundreds of millions of Apple devices can help locate a lost device, even when it is offline, by detecting its Bluetooth beacons and securely reporting its location. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references external claim chart exhibits (Exhibits 7-20) for its detailed infringement allegations, but these exhibits are not included in the provided document. The analysis below summarizes the narrative infringement theory for the lead patents based on the complaint's text.

’749 Patent Infringement Allegations

  • The complaint does not provide a narrative mapping of the elements of claim 1 to the Accused Products. It states that an exemplary claim chart is attached as Exhibit 7 (Compl. ¶63). The general theory suggests that Apple's proximity services use a short-range link for an initial identifier exchange and a long-range link for server-mediated communication, and that the services employ "modified identification information" for security, as required by the claim (Compl. ¶¶ 77-78).
  • Identified Points of Contention:
    • Scope Questions: A central question will be whether the identifier rotation schemes in Apple's products (e.g., changing Bluetooth addresses for privacy) meet the claim limitation of providing "modified identification information... upon an occurrence of a predetermined event coordinated with said central server." The defense may argue that such rotations are autonomous and not "coordinated" with a server for the specific purpose recited in the claim.
    • Technical Questions: The analysis may turn on evidence demonstrating how and why identifiers change in the accused systems. The question is whether an identifier is modified "in place of the initial" one specifically to maintain a persistent but anonymized identity association at the server, as the claim appears to require.

’918 Patent Infringement Allegations

  • The complaint states that exemplary claim charts for claims 1 and 9 are attached as Exhibits 8-10 (Compl. ¶99). The narrative theory suggests that Apple’s Find My network is the claimed "proximity beacon service." In this system, an Apple device (the "mobile wireless device") uses its cellular/Wi-Fi radio to receive "identifier related information" (e.g., public keys of devices reported lost) from Apple's servers. It then uses its Bluetooth radio to detect beacons from lost devices or AirTags, which allegedly contain the claimed MAC address, unique identifier, and a "Proximity Beacon Service Identifier (PBSI)." The device then validates the beacon and uses the server data and beacon identifier to determine an object is "in proximity" and generate an encrypted location report (Compl. ¶¶ 113, 115).
  • Identified Points of Contention:
    • Scope Questions: A key dispute may be whether a specific data field in Apple's Find My beacon transmissions can be properly construed as a "Proximity Beacon Service Identifier (PBSI)" that "indicates the particular short range transmission is a proximity beacon transmission," or if that functionality is inherent in the overall data structure rather than a distinct identifier.
    • Technical Questions: Plaintiff must present evidence showing that the Accused Products perform the specific three-part "determining" step of claim 9: a) confirming a MAC address, b) confirming a PBSI is present, and c) confirming the PBSI indicates association with the service. The defense may argue that the actual validation process operates differently.

V. Key Claim Terms for Construction

  • The Term: "modified identification information" (’749 Patent, claim 1)

  • Context and Importance: This term is critical to the infringement analysis of the ’749 patent. The dispute will likely center on whether routine privacy-enhancing features, like rotating Bluetooth addresses in Apple's products, constitute a "modification" that occurs upon a "predetermined event coordinated with" a server, as the claim requires. Practitioners may focus on this term because its construction will determine whether standard privacy features fall within the claim's scope.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The complaint quotes dependent claim 5 of the patent, which specifies that identifiers are "changed over time," suggesting that any temporal change could be considered a modification (Compl. ¶79). The general description of facilitating anonymous communication could also support a broader reading (Compl. ¶19).
    • Evidence for a Narrower Interpretation: The independent claim language "upon an occurrence of a predetermined event coordinated with said central server" suggests a specific, triggered, and server-directed change rather than an autonomous, periodic one (Compl. ¶77). This coordination requirement could be construed to narrow the term to non-routine identifier changes.

  • The Term: "Proximity Beacon Service Identifier (PBSI)" (’918 Patent, claims 1 and 9)

  • Context and Importance: The infringement reading for the ’918 patent hinges on locating a "PBSI" in Apple's Find My beacon signals. This term's construction is crucial because if it is construed to require a dedicated, explicit data field that is absent in the accused signals, infringement may be difficult to prove.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A related patent, the '344 patent, is quoted as defining the "beacon service identifier" as something that "identifies a wireless beacon service as opposed to identifying a communication network or a device" (Compl. ¶151). This could support an argument that any data pattern that distinguishes a Find My beacon from other Bluetooth traffic serves as a PBSI.
    • Evidence for a Narrower Interpretation: The claim separately recites the PBSI, a "MAC address," and a "unique identifier." This structure suggests the PBSI must be a distinct element from the other two. The defense may argue that in Apple's system, any service-level information is inherently part of the "unique identifier" (e.g., the encrypted key) and not a separate PBSI.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all patents-in-suit. The factual basis for this allegation is that Defendant provides customers with extensive support and instructions—via its website, YouTube channel, and in-store Genius Bar—that allegedly instruct and encourage users to operate the Accused Products in a manner that directly infringes the asserted claims (Compl. ¶¶ 92, 130, 170, 212, 252, 289).
  • Willful Infringement: The complaint alleges willful infringement based on extensive and long-standing pre-suit knowledge. This knowledge is alleged to have been acquired through multiple channels, including: (1) direct communications between the inventor and Apple employees regarding the patent portfolio starting in 2011; (2) Defendant's retention of the inventor as an expert witness in prior, unrelated litigations; (3) Defendant's citation of patents in the asserted family during its own patent prosecution; and (4) formal notice letters sent by Plaintiff in August 2025 (Compl. ¶¶ 51-57, 85-89).

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

  • A central issue will be one of definitional scope: For the patents related to beacon services (e.g., the ’918 Patent), can a specific data field within Apple's Find My beacon transmissions be proven to function as the claimed "Proximity Beacon Service Identifier (PBSI)," or does the evidence suggest this functionality is embedded in a way that falls outside the specific claim limitation?
  • A key evidentiary question will concern technical operation: For the '749 patent, do Apple's identifier rotation schemes constitute the claimed method of providing "modified identification information" upon a "predetermined event coordinated with said central server," or do they represent a distinct technical process for general device privacy that is not directed by a server in the manner claimed?
  • Given the extensive pre-suit history alleged, a significant focus of the case will likely be on willfulness: The court will need to examine the nature and extent of Apple's knowledge of the patent portfolio from as early as 2011 and what, if any, good faith beliefs it formed regarding non-infringement after being made aware of the technology.