Intent Iq LLC v. Invidi Tech Corp

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: 1:25-cv-00809, D. Del., 08/24/2026
• Venue Allegations: Venue is asserted in the District of Delaware based on the defendant's incorporation in the state of Delaware.
• Core Dispute: Plaintiff alleges that Defendant's addressable advertising platform infringes a patent related to identifying multiple devices on a single network and using activity on one device to trigger an action, such as serving a targeted advertisement, on another.
• Technical Context: The technology operates in the digital advertising sector, addressing the challenge of cross-device ad targeting, which seeks to identify a single user or household across multiple devices (e.g., smartphones, laptops, smart TVs) to deliver more consistent and relevant advertising.
• Key Procedural History: The asserted patent claims priority back to an application filed in 2007, potentially predating some modern cross-device tracking technologies. The complaint does not reference any prior litigation, licensing history, or administrative challenges to the patent's validity.

Case Timeline

Date	Event
2007-04-17	Earliest Priority Date for U.S. Patent No. 8,677,398
2014-03-18	U.S. Patent No. 8,677,398 Issued
2026-08-24	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, "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 March 18, 2014. Compl. ¶9

The Invention Explained

• Problem Addressed: The patent addresses the technical challenge of targeting advertisements across different media-specifically, linking a user's online internet activity with their television viewing-without relying on personally identifiable information (PII) to make the connection ʼ398 Patent, col. 7:13-23 ʼ398 Patent, col. 7:51-60
• The Patented Solution: The invention proposes a system where a remote computer system associates different devices (e.g., a computer and a television set-top box) that are connected to the same local area network (LAN) ʼ398 Patent, abstract This association is typically made by recognizing that both devices route their traffic through a common external IP address assigned to the user's modem or router ʼ398 Patent, col. 8:1-4 ʼ398 Patent, Fig. 1 Based on this association, online activity observed from the first device (the computer) can be used to select and deliver a targeted advertisement to the second device (the set-top box) ʼ398 Patent, abstract ʼ398 Patent, col. 11:1-8
• Technical Importance: This method provides a mechanism for cross-device advertising and analytics that can enhance ad relevance while avoiding the privacy concerns associated with collecting and correlating PII across different platforms ʼ398 Patent, col. 8:7-12

Key Claims at a Glance

• The complaint asserts independent method claim 1 Compl. ¶12 Compl., Ex. 2, p. 1
• The essential elements of independent claim 1 include:
  • Receiving an electronic identifier of a first device at a computer system.
  • Automatically generating and storing electronic indicia of an association between the first device and a second device.
  • This association is based on automatically recognizing that both devices were connected independently to a common local area network.
  • A key architectural limitation requires that the computer system performing the association is itself connected to the local area network through the Internet, but is not part of the local area network.
  • Based on the association, automatically sending an electronic transmission that causes another computer system to take an action with respect to the second device, based on profile data from the first device.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's computer systems that implement its "addressable advertising solution," including components named Conexus, Edge, and Pulse Compl. ¶10

Functionality and Market Context

The complaint alleges the accused solution provides cross-device ad targeting by identifying multiple devices within a single household Compl., Ex. 2, p. 11 The system is alleged to collect unique device identifiers, such as advertising identifiers for mobile devices (IDFA) or cookie IDs Compl., Ex. 2, p. 1 It then allegedly uses "probabilistic matching" techniques, which include comparing the public IP addresses of different devices, to generate a "probable household classification" and associate devices with each other Compl., Ex. 2, pp. 5-7 This association allows the system to track user activity across devices to "target households" and measure the effectiveness of advertising campaigns Compl., Ex. 2, p. 11 Compl., Ex. 2, p. 23

IV. Analysis of Infringement Allegations

Claim Chart Summary

The complaint incorporates a claim chart (Exhibit 2) that maps elements of claim 1 of the '398 Patent to the functionality of the accused advertising platform. A diagram included in the complaint shows various "Enabled Devices," including smart TVs, desktops, and mobile devices, connected via a common "IP/Broadband" network, which is central to the infringement theory Compl., Ex. 2, p. 10

U.S. Patent No. 8,677,398 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
(a) receiving, at the computer system, an electronic identifier of a first device;	The accused system receives persistent electronic identifiers from devices, such as cookie IDs or the unique advertising identifier for iOS devices (IDFA). A screenshot from INVIDI's software development kit documentation shows the collection of the IDFA Compl., Ex. 2, p. 2	¶12	col. 10:43-45
(b) with the computer system, automatically generating and storing electronic indicia of an association between the first device identifier and an electronic identifier of a second device based on automatically recognizing that each of the first and second devices was connected, independently of the other, to a common local area network, wherein the computer system is connected to the local area network through the Internet but is not in the local area network;	The system allegedly generates and stores an association between device identifiers by using "probabilistic matching" to determine a "probable household classification." This is allegedly based on comparing the IP addresses that devices use to connect to the Internet to infer they are on the same local network. The system performing this association is a remote server, not part of the user's local network.	¶12	col. 13:1-17
(c) with the computer system, based on the electronic indicia of the association... automatically sending an electronic transmission that causes another programmed hardware computer system to take an action, based on first electronic profile data associated with the first device identifier, with respect to the second device...	Based on the cross-device association, the system allegedly sends an electronic transmission to a third-party system (like a Demand Side Platform, or DSP) or an internal Ad Decision Engine. This transmission causes an action, such as displaying a targeted advertisement or creating an attribution event, on the second device based on profile data gathered from the first device's activity.	¶12	col. 11:1-8

Identified Points of Contention

• Scope Questions: A primary dispute may arise over whether the accused "probabilistic matching" to determine a "probable household" meets the claim limitation of "automatically recognizing that each of the first and second devices was connected... to a common local area network." The question for the court may be whether a statistical inference of a shared location (based on a common public IP address) is the same as recognizing a connection to a specific "local area network."
• Technical Questions: The complaint relies on marketing documents, technical documentation, and third-party descriptions of industry practices to allege how the accused system functions Compl., Ex. 2, pp. 5-7 A key factual question will be whether discovery confirms that the accused system actually performs the claimed steps of "generating and storing electronic indicia of an association" between specific device identifiers in the manner alleged.

V. Key Claim Terms for Construction

• The Term: "common local area network"

• Context and Importance: This term is the foundation of the patented method for associating devices. The infringement allegation centers on the idea that devices sharing a public IP address are on a "common local area network." The construction of this term will be critical to determining whether the accused "probabilistic matching" or "household classification" techniques fall within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the commonality in functional terms, relating to devices sharing a connection to the internet through a single modem or router, which is assigned a single IP address by an ISP ʼ398 Patent, col. 13:1-17 This could support a broader construction where any group of devices sharing a single public IP address constitutes a "common local area network" for the purposes of the patent.
  • Evidence for a Narrower Interpretation: The patent consistently depicts the "user" environment (30) as a physically co-located set of devices, such as a computer and a television set-top box within a home ʼ398 Patent, Fig. 1 ʼ398 Patent, Fig. 7 A defendant may argue that "local area network" has a specific technical meaning (e.g., devices on the same Ethernet or Wi-Fi network behind a router) that is not necessarily satisfied merely by observing a shared public IP address, which could be the result of carrier-grade NAT or other network configurations.

• The Term: "automatically recognizing"

• Context and Importance: This term defines the required action for establishing the device association. Practitioners may focus on this term because the accused system uses "probabilistic" methods, which implies a degree of uncertainty. The dispute will likely be whether a high-probability inference satisfies the "recognizing" requirement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not specify a required level of certainty for the "recognizing" step. Plaintiff may argue that in the context of large-scale data processing, probabilistic methods are a standard way to "recognize" patterns, and the term should be construed functionally to include such techniques.
  • Evidence for a Narrower Interpretation: A defendant could argue that "recognizing" implies a more definitive or deterministic confirmation of the network relationship, rather than a statistical likelihood. They may contend that merely observing a shared IP address is an inference, not a recognition of the underlying network topology as required by the claim.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant "directs and controls" the use of the accused systems, which results in infringement Compl. ¶11 This appears to be an allegation of direct infringement under a "direction or control" theory rather than a separate claim for indirect infringement. The complaint does not plead specific facts to support induced or contributory infringement, such as knowledge or intent to cause infringement by third parties.
• Willful Infringement: The complaint seeks a finding of post-suit willful infringement, based on the notice of infringement provided by the filing of the lawsuit itself Compl., Prayer for Relief ¶b No allegations supporting pre-suit knowledge or willfulness are made.

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

• A core issue will be one of definitional scope: can the term "common local area network," which has a specific meaning in network engineering, be construed broadly enough to encompass the concept of a "household" that the accused system allegedly identifies via "probabilistic matching" based on a shared public IP address?
• A second key issue will be one of evidentiary proof: what technical evidence will demonstrate that the accused system "automatically recognizes" the network connection and "generat[es] and stor[es] electronic indicia of an association" between specific devices, as opposed to performing a more generalized analysis of IP address data that does not create the specific association required by the claim?