Orion Labs Tech LLC v. Sprinklr Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Orion Labs Tech, LLC (Washington)
  • Defendant: Sprinklr, Inc. (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 7:25-cv-00133, W.D. Tex., 03/20/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district, specifically an office in Austin, Texas, and has committed acts of infringement from that location.
• Core Dispute: Plaintiff alleges that Defendant’s AI-powered customer service platform infringes five patents related to the use of intelligent agents, or bots, for functions like recording, auditing, and transcribing communications within group messaging systems.
• Technical Context: The technology concerns the integration of automated software agents into communication platforms to provide services that would otherwise be manual or require separate applications, a key feature in the modern Contact Center as a Service (CCaaS) market.
• Key Procedural History: The complaint does not allege any prior litigation, inter partes review proceedings, or licensing history concerning the asserted patents. The patents-in-suit constitute a family, with later patents claiming priority to the applications of earlier-issued family members.

Case Timeline

Date	Event
2015-05-27	Earliest Priority Date for ’430, ’003, and ’339 Patents
2017-03-27	Priority Date for ’636 Patent
2017-10-03	Priority Date for ’733 Patent
2018-10-23	’430 Patent Issued
2019-10-29	’003 Patent Issued
2021-02-16	’339 Patent Issued
2021-09-21	’636 Patent Issued
2022-02-22	’733 Patent Issued
2025-03-05	Date of Defendant's article on "Contact Center as a Service"
2025-03-20	Complaint Filing Date

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

U.S. Patent No. 10,110,430 - “Intelligent Agent Features For Wearable Personal Communication Nodes,” Issued October 23, 2018

The Invention Explained

• Problem Addressed: The patent’s background describes that conventional communication devices often require multiple user inputs and preferences before a communication session can begin, which can be difficult and distracting for a user engaged in other tasks (’430 Patent, col. 1:21-34).
• The Patented Solution: The invention proposes a system where an "intelligent agent node" can be created and added as a member to a communication group. This software-based agent can then provide automated services to the human members, such as recording conversations, auditing communications for compliance, or providing voice assistance, all within the group’s secure communication framework (’430 Patent, Abstract; col. 2:36-54). Figure 1 illustrates this concept by showing an "Agent System" that can add an intelligent "Node 106" into "Group B" alongside human-operated nodes (’430 Patent, Fig. 1).
• Technical Importance: The technology aimed to integrate automated services directly into the architecture of a group communication system, rather than having them function as separate, external applications (’430 Patent, col. 1:16-25).

Key Claims at a Glance

• The complaint asserts independent claims 1, 7, and 13 (Compl. ¶30).
• Independent Claim 1 recites a method with the following essential elements:
  • receiving instructions from at least one of the plurality of personal communication member nodes to instantiate an intelligent agent;
  • instantiating the intelligent agent as a virtual assistant communication member node in the communication group; and
  • the instantiated intelligent agent recording and auditing communications among and between the plurality of personal communication member nodes in the communication group.
• The complaint alleges infringement of "one or more claims," which may imply the right to assert dependent claims later in the litigation (Compl. ¶30).

U.S. Patent No. 10,462,003 - “Intelligent Agent Features For Wearable Personal Communication Nodes,” Issued October 29, 2019

The Invention Explained

• Problem Addressed: The patent, which is a continuation of the application leading to the ’430 Patent, addresses the same problem of user distraction and inefficiency when interfacing with communication devices (’003 Patent, col. 1:23-36).
• The Patented Solution: The solution is also centered on instantiating an intelligent agent into a communication group. The claims of this patent add a specific focus on receiving instructions that dictate where the intelligent agent should be instantiated, such as on a specific host computer or in a particular physical location, providing more granular control over the agent's execution environment (’003 Patent, Abstract; col. 5:47-55).
• Technical Importance: This patent builds on the family’s foundational concept by adding a layer of control over the deployment and location of the automated software agents within the communication system (’003 Patent, col. 2:39-58).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 4, 8, 11, 15, 16, and 17 (Compl. ¶45).
• Independent Claim 1 recites a method with the following essential elements:
  • receiving instructions from at least one of the plurality of personal communication member nodes to: instantiate an intelligent agent; and where to instantiate the intelligent agent;
  • instantiating the intelligent agent as a virtual assistant communication member node in the communication group; and
  • the instantiated intelligent agent performing a service for one or more personal communication member nodes in the communication group.

Multi-Patent Capsule: U.S. Patent No. 10,924,339

• Patent Identification: “Intelligent Agent Features For Wearable Personal Communication Nodes,” Issued February 16, 2021 (Compl. ¶56).
• Technology Synopsis: As a continuation in the same family, this patent also describes instantiating an intelligent agent into a communication group. It addresses the problem of needing to manually transcribe group audio by claiming an agent that specifically performs the function of transcribing communications between group members (Compl. ¶58; ’339 Patent, claim 1).
• Asserted Claims: 1, 4, 8, 11, 15, 18, and 19 (Claim 1 is independent) (Compl. ¶60).
• Accused Features: The complaint targets the AI-driven features of the Sprinklr Service that process voice communications, such as its "Conversational AI," which would logically include transcription for analysis, record-keeping, or routing (Compl. ¶20, ¶22, Fig. 1).

Multi-Patent Capsule: U.S. Patent No. 11,127,636

• Patent Identification: “Bot Group Messaging Using Bot-Specific Voice Libraries,” Issued September 21, 2021 (Compl. ¶71).
• Technology Synopsis: This patent addresses the technical challenge of integrating multiple, specialized bots into a single messaging system. It describes a group messaging service that routes audio messages to a bot, which then processes the audio using a "bot-specific voice library" to perform designated actions, allowing for bots with different capabilities to coexist (Compl. ¶73; ’636 Patent, Abstract).
• Asserted Claims: 1, 5, 10, and 16 (Claim 1 is independent) (Compl. ¶75).
• Accused Features: The allegations target the Sprinklr Service’s "AI-powered" platform, which unifies various communication channels and employs "Conversational AI," suggesting a system that routes user inputs to different specialized bots for processing based on the context or channel (Compl. ¶20, Fig. 1).

Multi-Patent Capsule: U.S. Patent No. 11,258,733

• Patent Identification: “Transcription Bot For Group Communications,” Issued February 22, 2022 (Compl. ¶86).
• Technology Synopsis: The patent describes a system to streamline the process of getting audio from a group communication session transcribed and published elsewhere. It discloses a "transcription bot" that is launched upon user request to receive audio content and automatically deliver the transcribed text to one or more external "destination services" (Compl. ¶88; ’733 Patent, Abstract).
• Asserted Claims: 1, 5, and 15 (Claim 1 is independent) (Compl. ¶90).
• Accused Features: The allegations focus on the Sprinklr Service’s core function of unifying customer queries from voice and social media channels and integrating this data, which implies a process of transcription and routing content to different destinations like knowledge bases or analytics platforms (Compl. ¶20, Fig. 1).

III. The Accused Instrumentality

Product Identification

• The accused products are Defendant’s "intelligent digital agents," including but not limited to its "Sprinklr Service" (Compl. ¶20).

Functionality and Market Context

• The complaint describes the Sprinklr Service as an "AI-powered customer service platform that unifies customer queries from all traditional and modern support channels — like voice, digital and social media" (Compl. ¶20). A diagram from Defendant's materials illustrates this unified approach, showing "Sprinklr Service" at the center of functions like "Voice," "Live Chat," "Social," "Contact Center AI," and "Quality Management" (Compl. p. 5, Fig. 1). The service is marketed as a "Contact Center as a Service (CCaaS)" provider, offering features such as inbound and outbound voice support, social media integration, and live chat (Compl. ¶21, ¶22, Fig. 2). Defendant’s materials also provide educational content on implementing CCaaS solutions (Compl. p. 7, Fig. 3). The platform’s alleged commercial importance lies in its ability to consolidate multiple customer service functions onto a single platform (Compl. p. 5, Fig. 1).

IV. Analysis of Infringement Allegations

The complaint references Exhibits A and B, which purportedly detail the infringement of the ’430 and ’003 patents, but these exhibits were not filed with the complaint (Compl. ¶30, ¶45). The infringement theory is therefore summarized from the narrative allegations.

’430 Patent Infringement Allegations

Narrative Summary

The complaint alleges that the Sprinklr Service infringes the ’430 patent when Defendant and its customers use the platform (Compl. ¶30). The theory suggests that using Sprinklr's AI features constitutes "instantiating an intelligent agent" into a "communication group" (e.g., a company's customer service team). This agent then allegedly performs the claimed functions of "recording and auditing communications," which correspond to advertised features of the Sprinklr Service such as "Quality Management" and "Contact Center AI" (Compl. ¶20-22; p. 5, Fig. 1).

Identified Points of Contention

• Scope Questions: A central question may be whether the term "communication member node," which the patent often associates with "wearable personal communication" devices, can be construed to read on the enterprise software accounts of users on a large-scale SaaS platform (’430 Patent, col. 2:47-49). Another question is whether a customer's act of enabling a feature in a cloud service constitutes "instantiating" an agent "as a... member node" in the manner claimed.
• Technical Questions: The complaint does not specify the technical mechanism by which the accused "Contact Center AI" or "Quality Management" features perform the combined function of "recording and auditing" as required by claim 1 (Compl. p. 5, Fig. 1).

’003 Patent Infringement Allegations

Narrative Summary

The infringement theory for the ’003 patent is similar, but focuses on the additional claim element of receiving instructions on "where to instantiate the intelligent agent" (Compl. ¶45). The complaint’s theory appears to be that a customer, by selecting and configuring the Sprinklr Service, implicitly provides an instruction to instantiate the AI agent on Sprinklr's cloud infrastructure, thereby satisfying this limitation. The "instantiated intelligent agent" then "perform[s] a service," such as handling inbound voice calls or managing live chats, as advertised by Sprinklr (Compl. ¶22, Fig. 2).

Identified Points of Contention

• Scope Questions: The dispute may turn on whether a customer's general selection of a cloud-based service qualifies as providing a specific instruction on "where to instantiate" the agent. The patent specification gives examples like selecting a "specific host node or host computing system" or a "country of execution," raising the question of whether a user of the Sprinklr Service performs an equivalent action (’003 Patent, col. 5:47-55).
• Technical Questions: The complaint does not identify a specific user action, configuration setting, or command within the Sprinklr Service that constitutes the instruction "where to instantiate the intelligent agent."

V. Key Claim Terms for Construction

For the ’430 Patent:

• The Term: "instantiating the intelligent agent as a virtual assistant communication member node"
• Context and Importance: This phrase is the core of the invention. Its construction will determine whether the act of using a feature on a cloud-based enterprise platform falls within the scope of the claims, which are rooted in the context of adding agents to groups of personal communication devices.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that an agent may be executed "as a virtual node comprising software or firmware executed by one or more of nodes... or management system" and can be "virtualized and established... as secure members of a communication group," language that may support application to a cloud-based service (’430 Patent, col. 5:35-39; col. 2:21-26).
  • Evidence for a Narrower Interpretation: The patent's title, "Intelligent Agent Features For Wearable Personal Communication Nodes," and its repeated references to "wearable push-to-talk communication device[s]" could support a narrower construction tied to discrete, user-operated hardware nodes rather than a diffuse software service (’430 Patent, Title; col. 2:47-49).

For the ’003 Patent:

• The Term: "where to instantiate the intelligent agent"
• Context and Importance: This limitation is a key addition in the ’003 patent. Infringement will depend on whether any action by a Sprinklr user can be mapped to providing an instruction that specifies the agent's execution location.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad list of what this instruction could be, including "selecting a specific host node or host computing system... a home or business server, a country of execution for distributed computing systems, and others," which could be argued to encompass selecting a data center region if Sprinklr offers such a choice (’003 Patent, col. 5:47-55).
  • Evidence for a Narrower Interpretation: The examples given ("home or business server") suggest a degree of user control over the physical or logical location of the agent that may not be present when using a standard SaaS product, where the vendor controls the infrastructure. This could be used to argue that simply using the service does not constitute providing an instruction on "where" it runs.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides the Accused Products and distributes instructions, advertising, and promotional materials that guide and encourage customers to use the service in an infringing manner (Compl. ¶32, ¶47, ¶62, ¶77, ¶92).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the patents from at least the date of the complaint's filing (post-suit knowledge) (Compl. ¶34, ¶49, ¶64, ¶79, ¶94). The complaint also alleges willful blindness, asserting on information and belief that Defendant has a "policy or practice of not reviewing the patents of others" (Compl. ¶35, ¶50, ¶65, ¶80, ¶95).

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

• A core issue will be one of definitional scope: can the patent family's concept of an "intelligent agent" being "instantiated" as a "member node" within a group of "personal communication nodes" be construed to cover a customer's use of an enterprise-grade, cloud-based SaaS platform?
• A key evidentiary question will be one of user action: what specific actions taken by a user or administrator of the Sprinklr Service, if any, constitute the "receiving instructions" limitations recited in the asserted claims, particularly the instruction on "where to instantiate the intelligent agent" required by the ’003 patent?
• A third question will concern technical functionality: does the evidence show that the AI-driven features of the Sprinklr Service perform the specific functions recited in the claims (e.g., "recording and auditing," using "bot-specific voice libraries") in the manner described and claimed by the patents, or is there a fundamental mismatch in technical operation?