Unwired Global Systems LLC v. SAP Se

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Unwired Global Systems LLC (Delaware)
  • Defendant: SAP Se (Germany)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00277, W.D. Tex., 06/19/2025
• Venue Allegations: Venue is alleged to be proper because Defendant has an established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that certain unidentified SAP products infringe a patent related to a middleware interface for translating data between different network communication protocols.
• Technical Context: The technology concerns middleware that enables interoperability between devices on heterogeneous networks, such as smart home devices using various protocols and standard computer networks using TCP/IP.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,488,624 - "Method and apparatus for providing an area network middleware interface," issued July 16, 2013

The Invention Explained

• Problem Addressed: The patent describes the difficulty of integrating household or "home area network" (HAN) devices, which often use low-power, specialized communication protocols (e.g., ZigBee, Bluetooth), with conventional computer networks that primarily use TCP/IP. This incompatibility creates "significant programming overhead" and requires substantial computing power to manage multiple protocol stacks simultaneously ('624 Patent, col. 1:30-59).
• The Patented Solution: The invention proposes a middleware system, referred to as a "frame engine," that acts as a universal translator. This engine receives a data packet in a "first communication protocol," decodes it into a standardized, "platform independent data object" using a set of "protocol frame definitions," and can then re-encode that object for transmission in a "second communication protocol" ('624 Patent, col. 1:65-col. 2:13; col. 11:9-22). As illustrated in Figure 1, a central routing computer (102) containing the frame engine (124) can mediate communications between different types of devices (104, 108) on different networks (106, 110), obviating the need for each device to understand every other device's native protocol ('624 Patent, Fig. 1).
• Technical Importance: This approach aims to simplify the creation of integrated "smart" environments by providing a modular, extensible way to ensure interoperability between devices from different manufacturers using disparate communication standards ('624 Patent, col. 1:26-42).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and "Exemplary '624 Patent Claims" but does not identify specific claims in the body of the complaint, instead referring to an unprovided exhibit (Compl. ¶¶11, 16). Independent claim 1 is representative of the patented method.
• Independent Claim 1: A method performed by a computer programmed by a frame engine, comprising the steps of:
  • receiving one or more data packets encoded in a first communication protocol;
  • decoding the data packets into a set of data objects in accordance with a machine-readable set of protocol frame definitions containing one or more sub-fields for parsing; and
  • encoding the data objects into a second communication protocol in accordance with the machine-readable set of protocol frame definitions.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products or services by name. It refers generally to "Defendant products identified in the charts" and "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context, as these details are allegedly contained in an external document, Exhibit 2, which was not provided with the complaint (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2, which is incorporated by reference but not attached to the public filing (Compl. ¶¶16-17). The complaint itself contains no factual allegations mapping specific features of any accused product to the limitations of the patent claims. The narrative theory asserts that the "Exemplary Defendant Products practice the technology claimed by the '624 Patent" and "satisfy all elements of the Exemplary '624 Patent Claims" (Compl. ¶16). Without Exhibit 2, a detailed analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on an analysis of representative independent claim 1, the construction of the following terms may be central to resolving the dispute.

The Term: "platform independent data objects"

• Context and Importance: This term is the core of the invention's intermediate, translated state. The dispute may turn on whether the accused system's internal data representation qualifies as "platform independent." Practitioners may focus on this term because the patent appears to tie the concept to a specific technology, stating that "the natural data types of the Java language... is a platform independent representation" ('624 Patent, col. 4:59-62). Defendant may argue this language limits the claim scope to Java-based or similarly architected systems.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the objects are not limited to simple primitives, noting they "may consist of complex data objects" ('624 Patent, col. 4:22-23). The term itself, on its face, does not imply a specific programming language.
  • Evidence for a Narrower Interpretation: The patent explicitly links the concept to a specific implementation, stating, "Note that in one embodiment, JAVA is the 'native language', and the platform independence of the data representation is due to the platform independence of Java's data representation" ('624 Patent, col. 4:62-64).

The Term: "machine-readable set of protocol frame definitions"

• Context and Importance: This term defines the mechanism for translation. The infringement analysis will likely question whether the accused system uses a comparable "set of definitions" or a different architecture, such as a monolithic, hard-coded translator. The patent describes these definitions as being modular and configurable, for instance via XML files ('624 Patent, col. 8:27-31).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is broad, requiring only a "set" of "definitions." The specification describes this in functional terms as containing "instructions for translating the data within the data packet" ('624 Patent, col. 5:65-col. 6:2).
  • Evidence for a Narrower Interpretation: The specification repeatedly provides examples of these definitions as discrete files, such as XML metadata, stored in a specific directory structure (e.g., "C:\glue-1.0.0\frames\zcl\header.xml") ('624 Patent, col. 5:35-44). This could support an argument that the term requires a system of separate, configurable definition files rather than an integrated software module.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, asserting that since being served with the complaint, SAP has continued to sell products and distribute "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the '624 Patent (Compl. ¶¶14-15).

Willful Infringement

• The complaint alleges willful infringement based on knowledge obtained from the service of the complaint itself. It asserts that despite this "actual knowledge," SAP "continues to make, use, test, sell, offer for sale, market, and/or import" infringing products (Compl. ¶¶13-14).

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

1. Evidentiary Sufficiency: The primary threshold question is whether the complaint, which identifies neither the accused products nor the specific asserted claims and relies entirely on an unprovided exhibit, can survive a motion to dismiss for failure to state a claim under the pleading standards established by Iqbal/Twombly.
2. Definitional Scope: A core technical and legal issue will be the construction of "platform independent data objects". The case may turn on whether this term is limited to the JAVA-based implementation described as an exemplary embodiment in the patent or can be read more broadly to cover other forms of intermediate data representations used in protocol translation.
3. Architectural Mismatch: A key infringement question will be whether the accused products, once identified, utilize a modular system of "machine-readable... protocol frame definitions" as taught in the patent. The court will have to determine if the accused architecture, which may use a different method for translation, falls within the scope of the claims.