Orion Labs Tech LLC v. Zoho Corp Pvt Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Orion Labs Tech, LLC (Washington)
  • Defendant: Zoho Corporation PVT Limited (India), Zoho Corporation (California), and Zoho Technologies Corporation (California)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 7:25-cv-00480, W.D. Tex., 10/21/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain established and regular places of business in the district, including an office in Austin, Texas, and have committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendants’ intelligent digital agents, including the Zoho Voice cloud-based phone system, infringe two patents related to the use of intelligent agents as virtual members within group communication systems.
• Technical Context: The technology concerns the integration of automated, intelligent software agents into real-time communication groups to provide services such as recording, transcription, and voice assistance.
• Key Procedural History: The complaint does not reference prior litigation involving these specific patents, IPR proceedings, or licensing history. The asserted U.S. Patent No. 10,462,003 is a continuation of the application that led to U.S. Patent No. 10,110,430, and both claim priority to the same 2015 provisional application.

Case Timeline

Date	Event
2015-05-27	Earliest Priority Date for ’430 and ’003 Patents
2018-10-23	U.S. Patent No. 10,110,430 Issued
2019-10-29	U.S. Patent No. 10,462,003 Issued
2025-10-21	Complaint Filed

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 background describes that conventional communication devices like smartphones often require distracting user inputs to set up and manage communications, which can be difficult when a user is busy performing other tasks (’430 Patent, col. 1:21-40).
• The Patented Solution: The invention introduces the concept of an "intelligent agent node" that can be instantiated as a secure, virtual member of a communication group alongside human users (’430 Patent, Abstract). This agent can then provide automated services to the group, such as recording conversations, performing audits, or offering voice-based assistance, thereby enhancing the group's functionality without requiring constant manual input (’430 Patent, col. 2:38-58). Figure 1 illustrates this concept by showing an "intelligent agent node" (106) being added to a group of user nodes (102, 103, 104) to form a new, functionally enhanced group (’430 Patent, Fig. 1).
• Technical Importance: This approach allows for the integration of computational services directly into the architecture of a communication session, treating the service provider as a peer participant rather than an external tool.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶41).
• Claim 1 requires a method with the following essential elements:
  • Receiving instructions from a personal communication member node to instantiate an intelligent agent.
  • Instantiating the intelligent agent as a virtual assistant communication member node in the communication group.
  • The instantiated intelligent agent recording and auditing communications among the personal communication member nodes in the group.

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

The Invention Explained

• Problem Addressed: As a continuation sharing its specification with the ’430 Patent, this patent addresses the same problem of simplifying user interaction with communication devices during other tasks (’003 Patent, col. 1:21-40).
• The Patented Solution: The solution is also the instantiation of an intelligent agent as a virtual member of a communication group (’003 Patent, Abstract). The agent provides services that enhance the communication experience, with the system architecture treating the agent as a peer node within the group (’003 Patent, col. 2:38-58; Fig. 1).
• Technical Importance: This architecture enables persistent, automated services to be seamlessly and securely integrated into private communication channels.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶56).
• Claim 1 requires a method with the following essential elements:
  • Receiving instructions from a personal communication member node 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.
  • The instantiated intelligent agent performing a service for one or more personal communication member nodes in the communication group.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the Accused Products as Defendants’ "intelligent digital agents," including but not limited to "Zoho Voice" (Compl. ¶31).

Functionality and Market Context

• Zoho Voice is described as a "cloud-based business phone system" that allows users to connect with customers and teams via web browser or mobile device (Compl. ¶31). The complaint alleges the Accused Products provide features for automating customer service, including "inbound voice contact support, outbound voice contact support, Interactive Voice Response, and call listening, whispering, and barging" (Compl. ¶32). The complaint also alleges that "in particular Sprinklr Service" provides these features, though the surrounding allegations focus on Zoho (Compl. ¶32).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least claim 1 of each asserted patent and states that detailed infringement evidence is provided in Exhibits A and B (Compl. ¶41, ¶56). As these exhibits were not filed with the complaint, a detailed claim chart summary cannot be constructed. The infringement theory appears to be that by providing and operating the Zoho Voice system, which includes automated features like call listening and Interactive Voice Response, Defendants are practicing the claimed methods of instantiating an intelligent agent to perform services within a communication group.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The dispute may turn on whether the automated features of a "cloud-based business phone system" like Zoho Voice can be characterized as an "intelligent agent" that is "instantiated" as a "virtual... member node" within a "communication group" as those terms are used in the patents. The defense may argue that its architecture is a centralized service provider, not a system that creates peer "member nodes" as depicted in the patent figures (’430 Patent, Fig. 1).
• Technical Questions: A factual question will be whether the operation of Zoho Voice involves a user command that constitutes "receiving instructions... to instantiate an intelligent agent." For the ’003 Patent, a further question is what evidence the complaint provides that users provide instructions on "where to instantiate" the agent, as required by claim 1.

V. Key Claim Terms for Construction

• The Term: "instantiating the intelligent agent as a virtual assistant communication member node in the communication group" (’430 Patent, Claim 1; ’003 Patent, Claim 1).

  • Context and Importance: This lengthy limitation is the architectural heart of the invention. Its construction will be critical to determining whether the patents cover centralized cloud services or are limited to systems where an agent is created as a distinct, peer-level participant in a defined group. Practitioners may focus on whether the accused Zoho Voice features operate as a background service for all users or are specifically "instantiated" as a new "member" of a specific call or group upon request.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the agent can be executed as "a virtual node comprising software or firmware executed by one or more of nodes... or management system" or as "virtualized software executed by a virtual machine that is instantiated upon demand" (’430 Patent, col. 5:36-41). This could support an argument that execution in a cloud system falls within the claim's scope.
    • Evidence for a Narrower Interpretation: Figure 1 depicts the agent node (106) as a discrete entity added to a group of user nodes (102, 103, 104) to form a new group, suggesting a peer-to-peer relationship (’430 Patent, Fig. 1). The term "member node" itself suggests the agent functions as a participant equivalent to other users, not as an overarching system utility.

• The Term: "intelligent agent" (’430 Patent, Claim 1; ’003 Patent, Claim 1).

  • Context and Importance: The definition of this term will determine what level of functionality is required to infringe. The case will explore whether standard telephony features like Interactive Voice Response or call recording qualify as an "intelligent agent."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification lists a wide variety of services the agent can provide, including "recording communications, auditing communications, providing audio transcription, annotating media, and paging communication devices" (’430 Patent, col. 2:48-52). This list of discrete functions could support a broader definition that does not require sophisticated AI.
    • Evidence for a Narrower Interpretation: The specification also describes more advanced capabilities, such as a "natural language interface" for voice commands, adapting to "individual language usage and preferences," and providing "group context-aware" features like reporting a user's location upon verbal query (’430 Patent, col. 5:67-6:45; col. 8:28-39). This could support a narrower construction requiring more than basic automation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement based on Defendants providing instructions, advertising, and promoting the use of the Accused Products in an infringing manner (Compl. ¶42, ¶57). It also alleges contributory infringement, asserting the Accused Products have "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶43, ¶58).
• Willful Infringement: The willfulness claim is based on alleged knowledge of the patents since at least the filing of the action (Compl. ¶44, ¶59). The complaint also alleges willful blindness, claiming Defendants have a "policy or practice of not reviewing the patents of others" (Compl. ¶45, ¶60).

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

• A core issue will be one of architectural scope: Can the claims, which describe "instantiating" an agent as a "member node" within a "communication group," be construed to cover the functionality of a centralized, multi-tenant, cloud-based phone system like Zoho Voice? The outcome may depend on whether the patents are read to require a specific peer-to-peer architecture or can encompass a more general client-server model.
• A second key question will be definitional: What level of sophistication is required for a software feature to be considered an "intelligent agent" under the patents? The case will likely require the court to decide if automated but conventional telephony services (e.g., call recording, IVR) meet the threshold for an "intelligent agent" as described and claimed in the patents-in-suit.
• A third issue will be evidentiary, particularly for U.S. Patent No. 10,462,003: What factual support can be developed to show that users of the accused system provide instructions not only to activate a service, but also on "where to instantiate the intelligent agent," as explicitly required by claim 1 of the ’003 patent?