DCT
7:25-cv-00227
Cloud Systems Holdco IP LLC v. Siemens Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cloud Systems Holdco IP, LLC (Texas)
- Defendant: Siemens Corporation (Delaware)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 7:25-cv-00227, W.D. Tex., 05/13/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has committed acts of infringement in the district and maintains a regular and established place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s systems, products, and services for controlling device environments infringe a patent related to a client-server architecture for managing and routing connections between various devices.
- Technical Context: The technology relates to hardware-independent systems for managing complex environments containing multiple, disparate devices, such as audio-visual presentation rooms, integrated building systems, or industrial control facilities.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that it and its predecessors have entered into settlement licenses with other entities, which it argues do not trigger marking requirements under 35 U.S.C. § 287(a). An ex parte reexamination certificate for the patent-in-suit, issued shortly after the complaint was filed, confirmed the patentability of asserted independent claim 1.
Case Timeline
| Date | Event |
|---|---|
| 2006-05-03 | '326 Patent Priority Date |
| 2013-09-10 | '326 Patent Issue Date |
| 2025-05-13 | Complaint Filing Date |
| 2025-05-19 | '326 Patent Reexamination Certificate Issued |
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, Issued Sep. 10, 2013
The Invention Explained
- Problem Addressed: The patent describes a technical landscape where audio-visual (A/V) management systems were traditionally custom-designed, closed, and hardware-specific, making it difficult to integrate a wide variety of devices or scale efficiently ('326 Patent, col. 2:57-62). Prior art systems were also described as lacking the ability to provide customized user interfaces based on permissions or to manage complex, multi-device environments in a unified way ('326 Patent, col. 4:26-59).
- The Patented Solution: The invention proposes a hardware-independent, client-server architecture to solve this problem ('326 Patent, col. 1:16-22). A central server maintains an "environment model"—a data representation of all devices, their capabilities, and their physical connections ('326 Patent, col. 8:50-54). A user interacts with a "control client" which sends high-level commands to the server; the server then translates these into specific instructions for the individual devices (e.g., switches, projectors, lighting controls) to establish desired data routes and states ('326 Patent, Abstract; Fig. 1A).
- Technical Importance: This architecture aimed to provide a scalable and flexible platform for controlling heterogeneous device environments, moving beyond the limitations of proprietary, single-vendor systems ('326 Patent, col. 3:1-10).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-20 (Compl. ¶9). The lead independent claim is claim 1.
- Independent Claim 1 requires a method with the following essential elements:
- Accessing a server via a control client and logging in as a user.
- The server querying a user database to retrieve user rights and configuration data.
- Rendering a control panel on the client that is adapted to the environment based on the user's rights.
- Creating a user-defined configuration for source, output, and other associated devices.
- Generating a desired signal path between the source and output device based on an "environment model."
- Identifying an event from an "event generator" and responding via an "event handler."
- Triggering and communicating commands to a control switch to interconnect the devices.
- Commanding the source device to output a signal, which is then outputted by the output device.
- The complaint reserves the right to assert dependent claims by alleging infringement of claims 1-20 (Compl. ¶9).
III. The Accused Instrumentality
Product Identification
- The complaint does not identify specific accused products by name. It refers generally to "systems, products, and services" from Siemens "for enabling a method for controlling an environment" (Compl. ¶9).
Functionality and Market Context
- The complaint alleges that the accused instrumentalities provide a "method for controlling an environment, comprising establishing communication between a server and a control client" (Compl. ¶11). This functionality is alleged to enable the control and monitoring of devices and their interconnections (Compl. ¶8). The complaint does not provide further technical detail on the operation of the accused products or their specific market context.
IV. Analysis of Infringement Allegations
The complaint references a claim chart in Exhibit B, which was not provided (Compl. ¶10). The following table summarizes the infringement theory for claim 1 based on the narrative allegations in the complaint.
'326 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for controlling an environment, comprising: Accessing a server associated with the environment via a control client; | Defendant's systems and services enable a "method for controlling an environment" that involves "establishing communication between a server and a control client" (Compl. ¶8, 11). | ¶8, ¶11 | col. 37:2-5 |
| Creating a user defined configuration of a source device, an output device, and a device associated with the environment; | Defendant’s systems are alleged to enable the control and monitoring of devices and inter-device connections within an environment. | ¶8 | col. 38:12-15 |
| Generating a desired path in the environment based on an environment model to connect said source device to said output device and adapted to allow signal transfer between said source device and said output device... | Defendant's systems allegedly perform infringing methods, which implies the creation of paths between devices. The "environment model" is a core component of the patented method. | ¶9 | col. 38:16-24 |
| Communicating said one or more commands from said server to a control switch; | The accused method is alleged to control inter-device connections, which the patent describes as being implemented via control switches. | ¶8 | col. 38:29-30 |
| Sending a command from said server to command said source device to output a signal; and Outputting said signal on said output device. | The accused method is alleged to control devices within an environment, which would include commanding source devices to send signals to be rendered on output devices. | ¶8, ¶9 | col. 38:31-35 |
Identified Points of Contention
- Scope Questions: The patent's specification is heavily focused on audio-visual "presentation environments" ('326 Patent, col. 2:21-24), whereas Siemens is primarily an industrial and infrastructure company. A central dispute may arise over whether the term "environment" can be construed broadly enough to cover the industrial, building automation, or other complex systems that Siemens provides.
- Technical Questions: The complaint's allegations are high-level and lack technical specifics. A key point of contention will be factual: what evidence exists that Siemens' products incorporate each specific element of the claims? For instance, what evidence will show that the accused systems use an "environment model" and an "event generator" that function in the manner described and claimed in the patent ('326 Patent, col. 38:17, 25)?
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
The Term: "environment"
- Context and Importance: This term's scope is critical. If construed narrowly to mean only A/V "presentation environments," the patent may not read on Siemens' core industrial products. If construed broadly, it could cover a wide range of Siemens' offerings. Practitioners may focus on this term because the specification’s heavy emphasis on A/V examples could be used to argue for a narrower scope than its more general language might otherwise suggest.
- Intrinsic Evidence for a Broader Interpretation: The patent explicitly states that the invention applies to "a variety of different environments" and provides non-A/V examples, including "a distributed data acquisition and control system" for a vehicle, "integrated building systems" (e.g., HVAC, security), and "a manufacturing or chemical process facility" ('326 Patent, col. 1:24-27; col. 2:7-33).
- Intrinsic Evidence for a Narrower Interpretation: The detailed description, summary, and figures overwhelmingly focus on A/V components like projectors, DVD players, and audio systems ('326 Patent, col. 1:40-42; Figs. 1A-1C, 5-8). A party could argue these specific embodiments define the true scope of the invention.
The Term: "environment model"
- Context and Importance: Claim 1 requires generating a path "based on an environment model." Infringement will depend on whether Siemens' accused systems use a data structure that meets this definition. The case may turn on how specifically this model must be structured and used.
- Intrinsic Evidence for a Broader Interpretation: The patent describes the model at a high level as representing "the devices 270 and other details of the presentation environment 110," including the "topology of these static connections" ('326 Patent, col. 8:50-54). This could support a reading on any data structure that serves this representative function.
- Intrinsic Evidence for a Narrower Interpretation: The patent provides a detailed data model diagram (Fig. 9) and description, breaking the model into specific components like "device_configs", "routes", and "scene_device_states" ('326 Patent, col. 11:1-col. 12:4). A party may argue that the term requires a data structure with this level of specified detail and interrelation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement allegation is based on claims that Siemens "actively encouraged or instructed" its customers on how to use its products in an infringing manner (Compl. ¶11). The contributory infringement allegation claims the accused products are not staple articles of commerce and their "only reasonable use is an infringing use" (Compl. ¶12).
- Willful Infringement: The complaint alleges that Siemens has known of the '326 patent "from at least the issuance of the patent" and seeks a finding of willful infringement and enhanced damages (Compl. ¶11; p. 6, ¶e). The complaint does not, however, plead specific facts supporting pre-suit knowledge beyond this conclusory statement.
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: Can the term "environment", which is described extensively in the context of audio-visual "presentation environments," be construed to cover the industrial automation, building management, or other complex systems offered by Siemens? The outcome of this claim construction dispute will likely define the battlefield for the infringement analysis.
A key evidentiary question will be one of technical implementation: As discovery proceeds, the central question will be whether Siemens' accused systems, in their actual operation, incorporate the specific architectural elements recited in the claims, particularly the "environment model" and the "event generator" and "event handler" subsystems. The current complaint lacks the factual detail to assess this, making it a primary focus for future proceedings.