DCT

1:26-cv-00899

Samscloud LLC v. Raptor Tech LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00899, D. Del., 09/28/2026
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware limited liability company and has allegedly committed acts of infringement in the district, including sales to the Delaware Department of Education.
  • Core Dispute: Plaintiff alleges that Defendant’s Emergency Management Software suite infringes two patents related to dynamically generating and using grid-based geofences for supervising individuals.
  • Technical Context: The technology pertains to location-based supervision systems, particularly those used for emergency management and safety in environments such as schools.
  • Key Procedural History: The complaint notes that U.S. Patent No. 12,154,421 is a continuation-in-part of U.S. Patent No. 11,468,757. For both patents, the complaint references their prosecution histories, stating that the patent examiner expressly found the claimed grid-generation arrangement was not taught by the prior art of record.

Case Timeline

Date Event
2017-01-01 Earliest alleged purchase of accused products by Delaware Department of Education
2019-03-05 Priority Date for ’757 and ’421 Patents
2022-07-12 ’757 Patent prosecution: Examiner's Amendment noted in complaint
2022-10-11 ’757 Patent Issued
2024-08-05 ’421 Patent prosecution: Corrected Notice of Allowability noted in complaint
2024-11-26 ’421 Patent Issued
2025-03-24 Date of accused marketing material referenced in complaint
2025-08-04 Archived date of accused marketing material referenced in complaint
2026-07-23 Original Complaint Filing Date (establishing notice for willfulness allegations)
2026-09-28 First Amended Complaint Filing Date

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

U.S. Patent No. 11,468,757 - Systems and methods for facilitating supervision of individuals based on geofencing

  • Issued: October 11, 2022.

The Invention Explained

  • Problem Addressed: The patent’s background section describes conventional geofencing systems as limited. These systems often used predefined, static boundaries (e.g., school zones) and did not readily permit users to create dynamic geofences based on factors like criminal activity or crowd density, nor did they facilitate seamless communication with multiple organizations like emergency services Compl. ¶11 ’757 Patent, col. 1:12-34
  • The Patented Solution: The invention proposes a method and system where a supervisor provides parameters to dynamically create a geofence. Specifically, a supervisor supplies a "security parameter" and a "geographical location" to generate the overall geofence. A separate, supervisor-supplied "grid parameter" is then used to determine the area of constituent "grid boxes" and generate a number of these boxes within the geofence. This grid structure is subsequently used to analyze the location of supervised individuals ("supervisees") and generate notifications (Compl. ¶¶12-14; ’757 Patent, abstract; ’757 Patent, Fig. 5).
  • Technical Importance: The invention describes a departure from static, predefined geofences by enabling a parameter-driven, two-tiered approach where an overall boundary and its internal grid structure are generated based on supervisor inputs Compl. ¶14

Key Claims at a Glance

  • The complaint asserts independent method Claim 1 and independent system Claim 10 Compl. ¶51
  • Key elements of independent Claim 1 include:
    • Receiving a "security parameter" and a "geographical location" from a supervisor device.
    • Analyzing the geographical location based on the security parameter.
    • Generating a geofence based on the analysis.
    • Receiving and analyzing supervisee data based on the geofence.
    • Generating and transmitting a supervision notification.
    • A "wherein" clause requiring the geofence to comprise a plurality of "geofence grid boxes", and further comprising the steps of:
      • Receiving at least one "grid parameter" from the supervisor device.
      • Analyzing the grid parameter.
      • Determining the "grid box geofence area" based on that analysis.
      • Generating a number of geofence grid boxes based on the determination.
  • Claim 10 recites a system with a communication device, processing device, and storage device configured to perform the functions analogous to the steps in Claim 1 Compl. ¶27

U.S. Patent No. 12,154,421 - Systems and methods for facilitating supervision of individuals based on geofencing

  • Issued: November 26, 2024.

The Invention Explained

  • Problem Addressed: As a continuation-in-part, the ’421 patent addresses the same limitations of conventional geofencing as its parent, the ’757 patent, citing the use of predefined boundaries and constraints on creating geofences based on security factors Compl. ¶64 ’421 Patent, col. 1:20-39
  • The Patented Solution: The ’421 patent describes a similar parameter-driven system for generating a geofence with an internal grid structure. It connects supervisor-supplied information to the generation of both the geofence and its grid-box areas, which are then used for processing supervisee data Compl. ¶64 ’421 Patent, abstract The complaint also highlights dependent claims that specify parameters such as altitude and building floor, as well as a separate independent claim directed to real-time, sensor-based tracking Compl. ¶¶66-68
  • Technical Importance: The invention claims to provide an unconventional configuration by linking distinct supervisor-supplied parameters to the generation of a geofence and its internal grid, rather than using generic computing components for simple alerts within a predefined area Compl. ¶62 Compl. ¶64

Key Claims at a Glance

  • The complaint asserts independent method Claim 1 and independent system Claim 11 Compl. ¶90
  • Key elements of independent Claim 1 are substantially identical to Claim 1 of the ’757 patent, including steps for receiving and analyzing a "security parameter" and a separate "grid parameter" to generate a geofence comprising a plurality of grid boxes Compl. ¶60
  • Claim 11 recites a system configured to perform the functions analogous to the steps in Claim 1 of the ’421 patent Compl. ¶61
  • The complaint also discusses dependent claim 9 (defining altitude as a security parameter), dependent claim 21 (adding grid-specific emergency contact functionality), and independent claim 22 (reciting sensor-based tracking) to support its arguments of non-conventionality Compl. ¶¶66-68

III. The Accused Instrumentality

Product Identification

  • The accused products are Defendant's "Emergency Management Software suite," which includes Raptor Emergency Management, Raptor Alert, Raptor Team Assist, Raptor Connect, Raptor Accountability, and Raptor Reunification Software Compl. ¶21

Functionality and Market Context

  • The accused software is marketed to schools to "know exactly where students, staff, and visitors are—and their status—during emergencies" Compl. ¶20 The system uses "Collaborative Response Graphics" (CRGs) provided by a third party, Critical Response Group, which are described as "grid-based maps to be used with geofencing to supervise individuals" Compl. ¶20
  • Supervisors, such as school administrators, can allegedly upload school maps and floorplans (geographical locations) and customize "emergency protocols," which are alleged to be security parameters Compl. ¶33 Compl. ¶34 The complaint alleges these products use geofencing to determine if an emergency is initiated within a designated building Compl. ¶37
  • A key allegation is that the accused products utilize "Critical Incident Mapping," which is described as displaying a map of a geofenced area overlaid with geofence grid boxes Compl. ¶46 A screenshot from CRG shows a school floorplan overlaid with a grid and key landmarks, described as a "gridded reference system" Compl. ¶35 Compl. p.16 This image from CRG's website illustrates a gridded map of a building's interior and exterior Compl. p.16

IV. Analysis of Infringement Allegations

’757 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving, using a communication device, at least one security parameter from at least one supervisor device... Supervisors can "customize Raptor to [their] emergency protocols," which include security parameters like designated safe areas, emergency rules, and alert configurations, and send them to Raptor's cloud-based platform. ¶33 col. 1:48-51
receiving, using the communication device, a geographical location from the at least one supervisor device; School administrators can upload school maps and floorplans ("geographical locations") to the platform for use in emergency situations. ¶34 col. 1:51-53
generating, using the processing device, a geofence corresponding to a geographical area based on the analyzing; The products use geofencing to "determine true emergency or drill initiations" by designating a geofence for a building. The complaint alleges these geofences can be created and modified. ¶37; ¶38 col. 1:56-59
receiving, using the communication device, at least one supervisee data associated with a supervisee from at least one supervisee device; Teachers use the Raptor mobile app on supervisee devices to provide "real-time status and location information" regarding themselves, students, and visitors. ¶39 col. 2:1-4
generating, using the processing device, a supervision notification based on the analyzing of the at least one supervisee data; The products generate notifications during drills or emergencies, such as critical alerts, and create "after-incident reports" that summarize supervisee data. ¶41; ¶44 col. 2:7-9
the geofence comprises a plurality of geofence grid boxes associated with the geofence area... The products utilize "Critical Incident Mapping," which displays a map of the geofenced area overlaid with geofence grid boxes. An included visual shows a school floorplan with a grid overlay. ¶46; p.16 col. 13:10-13
receiving, using the communication device, at least one grid parameter from the at least one supervisor device... Geofences are created with "school administration guidance," which is alleged to be a supervisor-provided parameter. CRG's graphics incorporate "key landmarks," "site specific labels," and other parameters to establish the grid. ¶47; ¶48 col. 13:26-40
determining, using the processing device, the grid box geofence area... and generating... a number of geofence grid boxes... The complaint alleges that the products are configured to analyze the received grid parameters to determine a grid box geofence area and generate geofence grid boxes. The ability to adjust geofences "at any time" is cited as evidence of this generation. ¶49 col. 13:41-45

’421 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving, using a communication device, at least one security parameter from at least one supervisor device... Supervisors can "customize Raptor to [their] emergency protocols," which include security parameters such as designated safe areas, and send them to Raptor's cloud-based platform. ¶72 col. 1:51-54
receiving, using the communication device, a geographical location from the at least one supervisor device; School administrators can upload school maps, floorplans, and evacuation plans ("geographical locations") to be used in emergency situations. ¶73 col. 1:54-56
generating, using the processing device, a geofence corresponding to a geographical area based on the analyzing; The products use geofencing to "determine true emergency or drill initiations." Geofences are designated for a building and can be created or modified based on a new analysis. ¶76; ¶77 col. 1:59-62
receiving, using the communication device, at least one supervisee data associated with a supervisee from at least one supervisee device; Teachers use the Raptor mobile app to provide "real-time status and location information" for supervisees (students, staff, visitors) within the geofence. ¶78 col. 2:3-6
generating, using the processing device, a supervision notification based on the analyzing of the at least one supervisee data; The products generate notifications during emergencies via various methods and automatically create "after-incident reports" that summarize supervisee data. A screenshot shows a critical alert notification. ¶80; ¶83; p.41 col. 2:10-12
the geofence comprises a plurality of geofence grid boxes associated with the geofence area... The products are advertised as using "Critical Incident Mapping," which displays a map of a geofenced area overlaid with grid boxes. A screenshot shows a gridded reference system on an aerial image. ¶85; ¶86; p.44 col. 13:28-31
receiving, using the communication device, at least one grid parameter from the at least one supervisor device... Geofences are created via a "Raptor Implementations Engineer with school administration guidance," which is alleged to be a supervisor-provided parameter. The complaint also points to CRG's use of parameters like landmarks and imagery to establish the grid. ¶86; ¶87 col. 13:45-48
determining, using the processing device, the grid box geofence area... and generating... a number of geofence grid boxes... The complaint alleges that because the geofences can be adjusted "at any time," the products are configured to analyze the grid parameters and newly generate or modify the geofence grid boxes. ¶88 col. 13:51-57
  • Identified Points of Contention:
    • Scope Questions: The claims recite a specific sequence: generating a geofence based on a security parameter, and then generating grid boxes within it based on a grid parameter. The complaint alleges Raptor's partner, CRG, provides pre-gridded maps. A question for the court will be whether applying a geofence to a pre-gridded map is the same as the claimed method of generating the grid boxes within a newly generated geofence.
    • Technical Questions: The complaint alleges that "school administration guidance" provided to a "Raptor Implementations Engineer" constitutes the claimed "receiving... at least one grid parameter" by the system Compl. ¶48 Compl. ¶87 This raises the question of whether this human-mediated process meets the claim requirement of a "communication device" receiving a "parameter" that is then analyzed by a "processing device."
    • Direct Infringement: The complaint alleges that Defendant's cloud-based platform, operating from U.S.-based servers, performs the claimed method steps Compl. ¶50 Compl. ¶89 A potential point of contention may be whether Raptor exercises sufficient direction or control over the entire system (including supervisor and supervisee devices) to be considered the single entity "using" the system and performing all steps of the method claim, as required for direct infringement.

V. Key Claim Terms for Construction

  • The Term: "grid parameter"

    • Context and Importance: This term is central to the patents' alleged point of novelty over prior art. The claims require this parameter to be received from a supervisor and analyzed to determine the "grid box geofence area" and generate a "number of geofence grid boxes". The complaint broadly alleges that "school administration guidance" and inputs like "key landmarks" and "site specific labels" are "grid parameters" Compl. ¶47 Compl. ¶48 Whether these varied inputs meet the claim's functional requirements will be a critical issue.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification does not provide a specific, limiting definition, leaving room to argue that any supervisor-provided input that influences the grid's configuration could qualify. The patent's objective is to allow dynamic, user-driven geofence creation, which may support a more flexible interpretation of the inputs used to achieve that goal ’757 Patent, col. 1:23-34
      • Evidence for a Narrower Interpretation: The claim language recites "analyzing... the at least one grid parameter" and "determining... the grid box geofence area based on the analyzing" ’757 Patent, claim 1 Practitioners may argue this requires a direct, computational relationship where the parameter is a data value used in an algorithm to calculate grid dimensions, rather than general "guidance" provided to a human engineer.

  • The Term: "analyzing... the geographical location based on the at least one security parameter"

    • Context and Importance: This term appears in the step of "generating... a geofence". Its construction is important for determining whether the accused system actually generates a geofence boundary from security inputs, or merely applies security rules within a pre-existing geographical area (e.g., an uploaded floorplan). The complaint alleges the former Compl. ¶36
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent background criticizes conventional systems that use "predefined boundaries" ’757 Patent, col. 1:17-18, suggesting the invention is meant to be more dynamic. This could support an interpretation where analyzing security parameters helps define the shape or extent of the geofence itself.
      • Evidence for a Narrower Interpretation: The claim recites receiving a "geographical location" and a "security parameter" as two separate inputs. One could argue that the "geographical location" defines the boundary, and the "analyzing" step simply applies security attributes or rules to that pre-defined location, rather than using the security parameter to create the boundary from scratch.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Raptor actively induces infringement by instructing customers and end users on how to use the accused products in an infringing manner through user manuals and other materials Compl. ¶53 Compl. ¶92 Knowledge of the patents is alleged to have begun at least upon receipt of the original complaint on July 23, 2026 Compl. ¶53 Compl. ¶92
  • Willful Infringement: The complaint alleges willful infringement based on Raptor's continued infringement after having notice of the patents, with notice established as of the filing date of the original complaint Compl. ¶55 Compl. ¶94

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

  • A core issue will be one of claim construction and scope: can the term "grid parameter", which must be computationally "analyzed" to "determine" the grid's structure, be construed to cover the general "school administration guidance" provided to a human engineer, as alleged in the complaint? Or does it require a more specific data input directly processed by the system?
  • A second key issue will be one of infringement and operational sequence: does the accused system, which allegedly uses pre-gridded maps from a partner (CRG), perform the specific sequence required by the claims—generating a geofence first, and then generating grid boxes within it? The evidence may raise the question of whether the accused system's operation is a reversal of the claimed method.
  • A third question will be one of direct infringement and control: given the alleged role of a "Raptor Implementations Engineer" in setting up geofences, a central question for the court will be whether the Defendant directly infringes by controlling the performance of all claimed method steps on its cloud platform, or if the involvement of its personnel and customers fractures the performance of the steps across multiple actors.