Sensor360 LLC v. Siemens Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sensor360 LLC (Delaware)
  • Defendant: Siemens Corporation (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:23-cv-00808, W.D. Tex., 11/25/2023
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the Western District of Texas.
• Core Dispute: Plaintiff alleges that certain unidentified Siemens products infringe a patent related to self-organizing, networked sensor modules capable of dynamically switching between sensing and controlling roles.
• Technical Context: The technology at issue involves networks of deployable sensors used for area monitoring, with applications in fields such as military reconnaissance and disaster relief.
• Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history concerning the patent-in-suit. It asserts that the filing of the complaint provides Defendant with actual knowledge of infringement.

Case Timeline

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

U.S. Patent No. 8,510,076 - "Sensor apparatus and system," issued August 13, 2013

The Invention Explained

• Problem Addressed: The patent describes a need for rapidly deployable sensor systems for monitoring large areas, such as a battlefield, to detect events like vehicle movement or artillery fire. It notes that traditional networks using distinct, specialized "control modules" are vulnerable; if a control module is disabled, a portion of the network becomes useless (Compl. ¶ 9; ’076 Patent, col. 1:8-14, col. 2:40-54).
• The Patented Solution: The invention is a homogenous sensor module designed for use in a self-organizing network. Each module contains sensors, a locator, a transceiver, and a processor. The core innovation is that the processor within each module is capable of communicating with other modules and determining whether it should operate in a "sensing mode" (to detect events) or a "controlling mode" (to receive, process, and relay data from other modules). This allows any module to take on a leadership role, creating a more flexible and resilient network that can adapt to damage or changing conditions (’076 Patent, Abstract; col. 2:27-39, col. 2:60-64).
• Technical Importance: This design approach provides a "self organising sensor network that avoids vulnerability and increases flexibility," which is particularly advantageous in scenarios requiring rapid deployment where precise placement of specialized hardware is not feasible (’076 Patent, col. 3:28-33).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, referring only to "Exemplary '076 Patent Claims" in an unprovided exhibit (Compl. ¶ 11). Independent Claim 1 is representative of the core apparatus invention.
• Independent Claim 1 Elements:
  • A sensor module for use in a sensor network,
  • comprising at least one sensor,
  • a locator for determining the location of the at least one sensor,
  • a transceiver for communicating with other sensor modules and/or a base station,
  • and a processor wherein the processor is adapted, in use, to communicate with other sensor modules and to determine whether the sensor module should operate in a sensing mode or a controlling mode within the network.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint alleges infringement by "Exemplary Defendant Products" but does not identify them by name within the body of the document (Compl. ¶ 11). It states these products are detailed in an attached but unprovided "Exhibit 2" (Compl. ¶¶ 16-17).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '076 Patent" and that they "satisfy all elements of the Exemplary '076 Patent Claims" (Compl. ¶ 16). However, it does not provide specific factual allegations or claim charts within the body of the complaint itself. Instead, it incorporates by reference an "Exhibit 2," which was not included with the provided filing, that allegedly contains charts comparing the asserted claims to the accused products (Compl. ¶¶ 16-17). As a result, a detailed analysis of the infringement allegations is not possible from the provided documents.

Identified Points of Contention

Based on the technology of the ’076 Patent, the infringement analysis will likely raise several key questions.

• Scope Questions: A central question will concern the scope of the claimed dual-mode functionality. The dispute may focus on whether the processor in the accused products is merely executing a pre-set, static function or if it dynamically "determine[s] whether [it] should operate in a sensing mode or a controlling mode" based on communication with other modules, as taught in the patent's specification (’076 Patent, col. 2:3-8).
• Technical Questions: A key technical question will be what evidence demonstrates that the accused products' processors perform the claimed "determination." For instance, does the processor consider network-aware factors like the location and density of other modules, or the power levels of other potential control modules, as described in the patent (’076 Patent, col. 2:8-17, col. 3:10-14), or is its mode-switching based on simpler, non-networked criteria?

V. Key Claim Terms for Construction

The Term: "controlling mode"

• Context and Importance: The distinction between a "sensing mode" and a "controlling mode" is fundamental to the patent's claimed invention. The definition of "controlling mode" will be critical to determining whether the accused products perform the claimed function, as this term defines the advanced capability that differentiates the invention from a simple network of sensors.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests that a controlling module's duties can include relaying information, stating it "passes anything of interest back to a base station, possibly via other sensor modules acting as relays" (’076 Patent, col. 2:62-64). This could support a construction where simple data relaying qualifies as a "controlling mode."
  • Evidence for a Narrower Interpretation: The patent also describes more sophisticated functions for a controlling module, such as "receives information relating to events from the sensor modules, possibly processes the information" and "may need to process the raw data from two nearby sensor modules to improve identification and/or location of events" (’076 Patent, col. 2:51-54, col. 2:60-62). This language may support a narrower construction requiring active data processing, not just relaying.

The Term: "determine whether the sensor module should operate in a sensing mode or a controlling mode"

• Context and Importance: This term addresses the intelligence and autonomy of the individual module. Practitioners may focus on this term because the nature of this "determination" distinguishes a truly self-organizing network from a centrally managed one.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify the inputs for the determination, which could allow for an interpretation covering any internal logic that causes a switch between modes.
  • Evidence for a Narrower Interpretation: The specification repeatedly links this determination to network awareness. It states the processor "may compare the location of the module with the location of other modules" and "consider the density of sensor modules" to make its decision (’076 Patent, col. 2:3-9). This suggests the "determination" must be based on data received from other modules about the state of the network, not just on a module's own isolated condition.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on an infringing use of the accused products. The complaint references the unprovided "Exhibit 2" for evidence supporting this allegation (Compl. ¶ 14).

Willful Infringement

The complaint does not use the term "willful" but alleges that service of the complaint itself "constitutes actual knowledge of infringement" (Compl. ¶ 13). This forms a basis for potential post-suit enhanced damages. No allegations of pre-suit knowledge are made.

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

1. An Evidentiary Question of Functionality: Given the complaint's lack of specific factual allegations, a threshold issue will be evidentiary. What are the precise technical functionalities of the accused Siemens products, and what evidence can Plaintiff produce to show that they perform the specific dual-mode, self-organizing operations required by the asserted claims?

2. A Definitional Question of "Control": The case will likely turn on claim construction, specifically the definition of "controlling mode." Will the court adopt a narrow definition requiring active data processing and network management as described in the patent's embodiments, or will a broader definition that includes simple data relaying be sufficient for Plaintiff to prove infringement?

3. A Technical Question of Distributed Intelligence: A core technical dispute will likely be whether the accused system's architecture matches the decentralized intelligence model claimed in the patent. Does each individual accused module autonomously "determine" its role based on network communications, or is mode-switching managed by a central server or pre-programmed logic, which may represent a fundamental mismatch with the claimed invention?