Cloud Systems Holdco IP LLC v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
  • Defendant: Honeywell International Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00226, W.D. Tex., 05/13/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining a regular and established place of business within the Western District of Texas and having allegedly committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services for controlling and monitoring devices within an environment infringe a patent related to hardware-independent management of inter-device connections.
• Technical Context: The technology falls within the domain of integrated control systems, often used in "smart" environments like conference rooms or automated buildings, to manage heterogeneous devices from a central point.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has entered into prior settlement licenses with other parties, asserting that none of those licenses involved the production of a patented article. To preemptively address potential marking-related damages limitations, Plaintiff indicates it will limit its infringement claims to method claims.

Case Timeline

Date	Event
2006-05-03	’326 Patent Priority Date
2013-09-10	’326 Patent Issue Date
2013-09-10	Alleged date of Defendant's knowledge of the patent
2025-05-13	Complaint Filing Date

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

U.S. Patent No. 8,533,326 - "Method for managing, routing, and controlling devices and inter-device connections"

• Patent Identification: U.S. Patent No. 8,533,326, "Method for managing, routing, and controlling devices and inter-device connections," issued September 10, 2013.

The Invention Explained

• Problem Addressed: The patent addresses the challenge of integrating and controlling a growing number of disparate devices (e.g., audio/visual sources, displays, lighting) in modern environments like conference rooms. Traditional solutions were described as inflexible, "closed-system, hardware specific solutions" unable to easily accommodate a variety of devices. (’326 Patent, col. 2:58-65).
• The Patented Solution: The invention proposes a hardware-agnostic system architecture centered on a server that maintains a software representation, or "environment model," of all connected devices and their possible interconnections. (’326 Patent, col. 8:50-54). A user interacts with a "control client," which communicates high-level requests to the server. The server then uses the environment model and a routing engine to generate and issue specific low-level commands to the appropriate devices (e.g., switches, projectors, lighting controllers) to achieve a desired configuration, or "scene." (’326 Patent, col. 9:45-54; Abstract).
• Technical Importance: This server-based, model-driven approach provided a path toward more flexible, scalable, and centralized control over complex, multi-vendor environments, separating the user-facing control logic from the underlying hardware specifics. (’326 Patent, col. 8:60-65).

Key Claims at a Glance

• The complaint asserts independent claim 1.
• The essential elements of independent claim 1 include:
  • Accessing a server via a control client and logging in as a user to retrieve rights and configuration data.
  • Rendering a control panel on the client that is "adapted to the environment based on said rights and said configuration data."
  • Creating a user-defined configuration of devices.
  • Generating a "desired path" between a source and output device based on an "environment model" stored on the server.
  • Identifying an event from an event generator and, in response, triggering commands to interconnect the devices.
  • Communicating commands from the server to a control switch and the source device.
  • Outputting a signal on the output device.
• The complaint reserves the right to assert claims 1-20, which would include dependent claims. (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused product, method, or service by name. It refers generally to Defendant’s "systems, products, and services for enabling a method for controlling an environment." (Compl. ¶9).

Functionality and Market Context

• The allegedly infringing functionality is described as a "method for controlling an environment, comprising establishing communication between a server and a control client." (Compl. ¶11). The complaint does not provide further technical details about the operation of any specific Honeywell product or its market position.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit B as support for its infringement allegations but does not include the exhibit. (Compl. ¶10). In the absence of a claim chart, the infringement theory must be inferred from the complaint's narrative. The core allegation is that Defendant makes, uses, sells, or offers for sale systems that practice the patented method for controlling an environment. (Compl. ¶9). However, the complaint lacks specific factual allegations linking the features of any particular Honeywell product to the elements of the asserted claims. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Specificity Question: A primary issue for the litigation will be the complaint's lack of specificity. The Plaintiff will need to identify which of Defendant's products or services are accused and provide evidence demonstrating how they meet each limitation of the asserted claims.
  • Technical Questions: The infringement analysis will turn on whether any accused Honeywell system performs the specific functions recited in the claims. For example: Does the accused system utilize an "environment model" to generate a "desired path" via a routing algorithm, or does it use a different control logic? Does it "render" a control panel that is "adapted" based on user rights and configuration data in the manner described by the patent? The complaint provides no technical evidence to address these points.

V. Key Claim Terms for Construction

The Term: "environment model"

• Context and Importance: This term is the conceptual core of the invention. The infringement analysis will depend heavily on whether an accused system's data representation of devices qualifies as an "environment model." Practitioners may focus on this term because its construction will determine whether a simple device registry is sufficient for infringement, or if a more complex, state-aware, and topological representation is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself requires only that the model is "stored in a data structure on said server," which could be argued to encompass a wide range of data representations. (’326 Patent, cl. 1).
  • Evidence for a Narrower Interpretation: The specification describes the model as representing not just devices but also the "topology of these static connections" (’326 Patent, col. 8:49-50) and being used by an "intelligent routing engine" to traverse a "routing map" and establish paths. (’326 Patent, col. 33:1-15). This suggests the model is a structured, relational map of the environment, not merely a list of devices.

The Term: "rendering a control panel ... adapted to the environment based on said rights and said configuration data"

• Context and Importance: This limitation defines a key dynamic feature of the user interface. The dispute may focus on the degree of "adaptation" required to infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: This could be argued to cover any user interface that changes in any way after a user logs in (e.g., showing a different home screen).
  • Evidence for a Narrower Interpretation: The specification suggests a more sophisticated adaptation, where the server evaluates the control client's capabilities (e.g., handheld vs. desktop) and provides a "customized user interface" accordingly. (’326 Patent, col. 14:35-42). It also describes tailoring the interface based on user permissions to prevent users from seeing options for which they lack rights. (’326 Patent, col. 14:1-9). This points to a more deeply integrated and context-aware rendering process.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed others (e.g., its customers...)" on how to use its products and services in a manner that infringes the patent. (Compl. ¶11).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’326 patent "from at least the issuance of the patent." (Compl. ¶11). The prayer for relief seeks treble damages. (Compl. p. 6, ¶e).

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

• A central threshold question will be one of specificity and evidence: Can the Plaintiff identify a specific Honeywell product and then provide concrete, technical evidence that it practices each element of the asserted claims, particularly the more complex functions like generating a "desired path" from an "environment model" and "rendering" a dynamically "adapted" control panel? The current complaint's lack of factual detail on these points presents a significant initial hurdle.
• The case will also likely involve a core issue of definitional scope: How broadly will the term "environment model" be construed? The outcome may depend on whether the court finds the term requires a sophisticated, topological map of device states and connections used by a routing algorithm, as detailed in the patent's specification, or if it can be read more broadly to cover simpler device databases used in control systems.