AlmondNet Inc v. LiveIntent Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Intent IQ, LLC (Delaware)
  • Defendant: INVIDI Technologies Corporation (Delaware)
  • Plaintiff's Counsel: Farnan LLP
• Case Identification: 1:24-cv-00831, D. Del., 08/25/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated under the laws of the State of Delaware.
• Core Dispute: Plaintiff alleges that Defendant's addressable advertising solution infringes a patent related to systems and methods for taking action on one network-connected device based on activity on another.
• Technical Context: The technology domain is cross-device-based ad targeting, which involves identifying a user across multiple devices to deliver targeted advertisements and measure their impact.
• Key Procedural History: The complaint was filed as part of a consolidated case, combining action C.A. No. 24-cv-831-MN with C.A. No. 25-cv-809-MN. No other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2014-03-18	U.S. Patent No. 8,677,398 Issues
2026-08-25	Complaint Filed

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

U.S. Patent No. 8,677,398 - Systems and methods for taking action with respect to one network-connected device based on activity on another device connected to the same network

• Patent Identification: U.S. Patent No. 8,677,398, titled "systems and methods for taking action with respect to one network-connected device based on activity on another device connected to the same network," issued on March 18, 2014 Compl. ¶9

The Invention Explained

• Problem Addressed: The complaint does not provide sufficient detail for analysis of the technical problem the patent addresses.
• The Patented Solution: The complaint alleges the patent generally relates to "novel internet / network based advertising systems and methods" Compl. ¶1 Based on the patent's title and the plaintiff's description of its own business, the patented solution appears to involve identifying a given user across multiple devices (e.g., laptops, smartphones, televisions) to facilitate delivering targeted ads and measuring their impact Compl. ¶3 Compl. ¶9 The core concept seems to be taking an "action with respect to one network-connected device based on activity on another device connected to the same network" Compl. ¶9
• Technical Importance: The technology is described as being central to the field of "cross-device-based ad targeting, retargeting, audience extension, and attribution" Compl. ¶3

Key Claims at a Glance

• The complaint asserts "one or more method claims of the '398 patent," specifically identifying "independent method claim 1" Compl. ¶10 Compl. ¶12
• The complaint states that a claim chart for independent method claim 1 is attached as Exhibit 2, but this exhibit was not provided with the complaint Compl. ¶12 Therefore, the essential elements of the asserted claim cannot be listed.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are identified as "INVIDI's computer systems that implement and provide INVIDI's addressable advertising solution, including but not limited to components such as Conexus, Edge, and Pulse" Compl. ¶10

Functionality and Market Context

• The complaint describes the accused instrumentalities as providing an "addressable advertising solution" Compl. ¶10 No probative visual evidence provided in complaint. The complaint does not provide further technical detail regarding the specific functionality of the accused products.
• The complaint does not contain allegations regarding the commercial importance or market positioning of the accused instrumentalities.

IV. Analysis of Infringement Allegations

The complaint alleges that a claim chart comparing independent method claim 1 of the '398 patent to the accused instrumentalities is attached as Exhibit 2; however, this exhibit was not provided Compl. ¶12 Consequently, a detailed claim chart analysis cannot be performed.

In prose, the complaint alleges that the Accused Instrumentalities "perform all claim limitations of one or more method claims of the '398 patent" Compl. ¶12 The infringement is attributed to Defendant because it allegedly "directs and controls use of the Accused Instrumentalities to perform acts that result in infringement," "conditioning benefits on participation in the infringement and establishing the timing and manner of the infringement" Compl. ¶11 These allegations suggest a theory of direct infringement under 35 U.S.C. § 271(a), potentially including liability for directing or controlling the actions of others.

• Identified Points of Contention: The complaint's lack of specificity regarding the accused products' operation and the asserted claim's limitations prevents the identification of specific technical or legal points of contention. The analysis will depend entirely on evidence and claim constructions developed during discovery and litigation.

V. Key Claim Terms for Construction

The complaint does not quote the language of any asserted claim, preventing an analysis of key terms for construction.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific counts for indirect infringement (i.e., inducement or contributory infringement). The allegations that Defendant "directs and controls" the use of the accused systems are framed to support a claim of direct infringement Compl. ¶11
• Willful Infringement: The complaint includes a prayer for a judgment of "post-suit willful infringement" Compl. p. 4, prayer b The basis for this allegation appears to be the notice of infringement provided by the filing of the complaint itself, as no pre-suit knowledge is alleged.

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

The complaint as filed presents a high-level, notice-pleading-style case. The resolution of the dispute will likely depend on the answers to several fundamental questions that emerge during discovery.

• An Evidentiary Question of Infringement: A primary issue will be whether the Plaintiff can produce sufficient factual evidence to support its currently conclusory allegation that INVIDI's "addressable advertising solution" practices each and every limitation of at least one asserted claim Compl. ¶12 The viability of the case will depend on the details revealed in the forthcoming, but currently absent, infringement contentions.
• A Definitional Question of Claim Scope: Once the claim language is known, the case will turn on a question of claim construction. Specifically, the scope of the asserted method claims will be defined by the court, and the central dispute will be whether the specific architecture and operation of INVIDI's "Conexus, Edge, and Pulse" systems fall within that judicially-construed scope Compl. ¶10