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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

CTD NETWORKS, LLC,

Plaintiff,

v.

MUSARUBRA US, LLC,

Defendant.

Civil Action No. 2:23-cv-00273

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff CTD Networks LLC (“CTD Networks” or “Plaintiff”), files this Complaint for 

Patent Infringement against Musarubra US LLC d/b/a Trellix (“Trellix” or “Defendant”), and 

would respectfully show the Court as follows:

PARTIES

1. Plaintiff is a Delaware corporation having an address located at 8 The Green, Suite 

#13063, Dover, Delaware 19901.

2. On information and belief, Defendant is a Delaware corporation with a principal 

address of 6000 Headquarters Drive, Suite 600 Plano, Texas, 75024 and has further regular and 

established places of business throughout this District. Defendant is registered to do business in 

Texas and has may be served via its registered agent at CT Corporation System, located at 1999 

Bryan Street, Suite 900 Dallas, Texas 75201, 

3. On information and belief, Defendant directly and/or indirectly develops, designs, 

manufactures, distributes, markets, offers to sell and/or sells infringing products and services in 

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the United States, including in the Eastern District of Texas, and otherwise directs infringing 

activities to this District in connection with its products and services.

JURISDICTION

4. This civil action arises under the Patent Laws of the United States, 35 U.S.C. § 1 et 

seq., including without limitation 35 U.S.C. §§ 271, 281, 283, 284, and 285 based on Defendant's 

unauthorized commercial manufacture, use, importation, offer for sale, and sale of the Accused 

Products in the United States. This is a patent infringement lawsuit over which this Court has 

subject matter jurisdiction under, inter alia, 28 U.S.C. §§ 1331, 1332, and 1338(a).

5. This United States District Court for the Eastern District of Texas has general and 

specific personal jurisdiction over Defendant because, directly or through intermediaries, 

Defendant has committed acts within the District giving rise to this action and are present in and 

transact and conduct business in and with residents of this District and the State of Texas.

6. Plaintiff’s causes of action arise, at least in part, from Defendant’s contacts with 

and activities in this District and the State of Texas.

7. Defendant has committed acts of infringing the patents-in-suit within this District 

and the State of Texas by making, using, selling, offering for sale, and/or importing in or into this 

District and elsewhere in the State of Texas, products claimed by the patents-in-suit, including 

without limitation products made by practicing the claimed methods of the patents-in-suit. 

Defendant, directly and through intermediaries, makes, uses, sells, offers for sale, imports, ships, 

distributes, advertises, promotes, and/or otherwise commercializes such infringing products into 

this District and the State of Texas. Defendant regularly conducts and solicits business in, engages

in other persistent courses of conduct in, and/or derives substantial revenue from goods and 

services provided to residents of this District and the State of Texas.

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8. This Court has personal jurisdiction over Defendant pursuant to TEX. CIV. PRAC. &

REM. CODE § 17.041 et seq. Personal jurisdiction exists over Defendant because Defendant has

minimum contacts with this forum as a result of business regularly conducted within the State of 

Texas and within this district, and, on information and belief, specifically as a result of, at least, 

committing the tort of patent infringement within Texas and this District. This Court has personal 

jurisdiction over Defendant, in part, because Defendant does continuous and systematic business 

in this District, including by providing infringing products and services to the residents of the 

Eastern District of Texas that Defendant knew would be used within this District, and by soliciting 

business from the residents of the Eastern District of Texas. For example, Defendant is subject to 

personal jurisdiction in this Court because, inter alia, Defendant has regular and established places 

of business throughout this District, and directly and through agents regularly does, solicits, and 

transacts business in the Eastern District of Texas. Also, Defendant has hired and is hiring within 

this District for positions that, on information and belief, relate to infringement of the patents-insuit. Accordingly, this Court’s jurisdiction over the Defendant comports with the constitutional 

standards of fair play and substantial justice and arises directly from the Defendant’s purposeful 

minimum contacts with the State of Texas. 

9. This Court also has personal jurisdiction over Defendant, because in addition to

Defendant’s own online website and advertising within this District, Defendant has also made its 

products available within this judicial district and advertised to residents within the District to hire 

employees to be located in this District. 

10. The amount in controversy exceeds $75,000 exclusive of interests and costs.

11. Venue is proper in this Court under 28 U.S.C. § 1400(b) based on information set 

forth herein, which is hereby repeated and incorporated by reference. Further, upon information 

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and belief, Defendant has committed or induced acts of infringement, and/or advertise, market, 

sell, and/or offer to sell products, including infringing products, in this District. In addition, and 

without limitation, Defendant has regular and established places of business throughout this 

District for which it is hiring over 70 positions at the time of the filing of this Complaint. See

https://trellix.dejobs.org/austin/texas/usa/jobs/.

THE PATENTS-IN-SUIT

12. On December 4, 2012, United States Patent No. 8,327,442 (“the ’442 Patent”), 

entitled “System and method for a distributed application and network security system (SDISCAM)” was duly and legally issued by the United States Patent and Trademark Office 

(“USPTO”). The ’442 Patent claims patent-eligible subject matter and is valid and enforceable. 

CTD Networks is the exclusive owner by assignment of all rights, title, and interest in the ’442

Patent, including the right to bring this suit for damages, and including the right to sue and recover 

all past, present, and future damages for infringement of the ’442 Patent. Defendant is not licensed 

to the ’442 Patent, either expressly or implicitly, nor do they enjoy or benefit from any rights in or 

to the ’442 patent whatsoever. A true and correct copy of the ’442 patent is attached hereto as 

Exhibit A. Defendant has known of the ‘442 patent from at least December 27, 2022, the filing 

date of a previous lawsuit in the Western District of Texas.

13. On September 6, 2016, United States Patent No. 9,438,614 (“the ’614 Patent”), 

entitled “Sdi-scam” was duly and legally issued by the United States Patent and Trademark Office 

(“USPTO”). The ’614 Patent claims patent-eligible subject matter and is valid and enforceable. 

CTD Networks is the exclusive owner by assignment of all rights, title, and interest in the ’614

Patent, including the right to bring this suit for damages, and including the right to sue and recover 

all past, present, and future damages for infringement of the ’614 Patent. Defendant is not licensed 

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to the ’614 Patent, either expressly or implicitly, nor do they enjoy or benefit from any rights in or 

to the ’614 patent whatsoever. A true and correct copy of the ’614 patent is attached hereto as 

Exhibit B. Defendant has known of the ‘614 patent from at least December 27, 2022, the filing 

date of a previous lawsuit in the Western District of Texas.

14. On November 22, 2016, United States Patent No. 9,503,470 (“the ’470 Patent”), 

entitled “Distributed agent based model for security and response” was duly and legally issued by 

the United States Patent and Trademark Office (“USPTO”). The ’470 Patent claims patent-eligible 

subject matter and is valid and enforceable. CTD Networks is the exclusive owner by assignment 

of all rights, title, and interest in the ’470 Patent, including the right to bring this suit for damages, 

and including the right to sue and recover all past, present, and future damages for infringement of 

the ’470 Patent. Defendant is not licensed to the ’470 Patent, either expressly or implicitly, nor do 

they enjoy or benefit from any rights in or to the ’470 patent whatsoever. A true and correct copy 

of the ’470 patent is attached hereto as Exhibit C. Defendant has known of the ‘470 patent from 

at least December 27, 2022, the filing date of a previous lawsuit in the Western District of Texas.

15. On November 9, 2021, United States Patent No. 11,171,974 (“the ’974 Patent”), 

entitled “Distributed agent based model for security monitoring and response” was duly and legally 

issued by the United States Patent and Trademark Office (“USPTO”). The ’974 Patent claims 

patent-eligible subject matter and is valid and enforceable. CTD Networks is the exclusive owner 

by assignment of all rights, title, and interest in the ’974 Patent, including the right to bring this 

suit for damages, and including the right to sue and recover all past, present, and future damages 

for infringement of the ’974 Patent. Defendant is not licensed to the ’974 Patent, either expressly 

or implicitly, nor do they enjoy or benefit from any rights in or to the ’974 patent whatsoever. A 

true and correct copy of the ’974 patent is attached hereto as Exhibit D. Defendant has known of 

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the ‘974 patent from at least December 27, 2022, the filing date of a previous lawsuit in the Western 

District of Texas.

16. The ’442 Patent, ’614 Patent, ’470 Patent, and the ’974 Patent are referred to herein 

as the “patents-in-suit.” 

17. Plaintiff CTD Networks is the owner of the entire right, title, and interest in and to 

the patents-in-suit. The patents-in-suit are presumed valid under 35 U.S.C. § 282.

ACCUSED INSTRUMENTALITIES

18. The term “Accused Instrumentalities” or “Accused Products” refers to, by way of 

example and without limitation, the Trellix Platform (e.g. https://www.trellix.com/enus/products.html).

COUNT I

PATENT INFRINGEMENT OF THE ’442 PATENT

19. Plaintiff restates and realleges the preceding paragraphs of this Complaint as if fully 

set forth herein.

20. Defendant has, under 35 U.S.C. §271(a), directly infringed, and continues to 

directly infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 1 of the ’442 Patent, by making, using, testing, selling, offering 

for sale and/or importing into the United States Defendant’s Accused Products. 

21. On information and belief, Defendant’s infringement of the ’442 Patent has been 

willful and merits increased damages.

22. On information and belief, Defendant has known that its activities concerning the 

Accused Products infringed on or more claims of the ’442 Patent since at least February 2, 2021

based on knowledge from Trellix’s predecessor, McAfee.

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23. On information and belief, Defendant has made no attempt to design around the 

claims of the ’442 Patent.

24. On information and belief, Defendant did not have a reasonable basis for believing 

that the claims of the ’442 Patent were invalid.

25. On information and belief, Defendant’s Accused Products are available to 

businesses and individuals throughout the United States and in the State of Texas, including in this 

District.

26. CTD Networks has been damaged as the result of Defendant’s infringement.

27. The claim chart attached hereto as Exhibit E describes how the elements of an 

exemplary claim 1 from the ’442 Patent are infringed by the Accused Products. This provides 

details regarding only one example of Defendant’s infringement, and only as to a single patent 

claim. Plaintiff reserves its right to amend and fully provide its infringement arguments and 

evidence thereof until its Preliminary and Final Infringement Contentions are later produced 

according to the court’s scheduling order in this case.

COUNT II

PATENT INFRINGEMENT OF THE ’614 PATENT

28. Plaintiff restates and realleges the preceding paragraphs of this Complaint as if fully 

set forth herein.

29. Defendant has, under 35 U.S.C. §271(a), directly infringed, and continues to 

directly infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 10 of the ’614 Patent, by making, using, testing, selling, offering 

for sale and/or importing into the United States Defendant’s Accused Products. 

30. On information and belief, Defendant’s infringement of the ’614 Patent has been 

willful and merits increased damages.

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31. On information and belief, Defendant has known that its activities concerning the 

Accused Products infringed on or more claims of the ’614 Patent since at least February 2, 2021 

based on knowledge from Trellix’s predecessor, McAfee.

32. On information and belief, Defendant has made no attempt to design around the 

claims of the ’614 Patent.

33. On information and belief, Defendant did not have a reasonable basis for believing 

that the claims of the ’614 Patent were invalid.

34. On information and belief, Defendant’s Accused Products are available to 

businesses and individuals throughout the United States and in the State of Texas, including in this 

District.

35. CTD Networks has been damaged as the result of Defendant’s infringement.

36. The claim chart attached hereto as Exhibit F describes how the elements of an 

exemplary claim 10 from the ’614 Patent are infringed by the Accused Products. This provides 

details regarding only one example of Defendant’s infringement, and only as to a single patent 

claim. Plaintiff reserves its right to amend and fully provide its infringement arguments and 

evidence thereof until its Preliminary and Final Infringement Contentions are later produced 

according to the court’s scheduling order in this case.

COUNT III

PATENT INFRINGEMENT OF THE ’470 PATENT

37. Plaintiff restates and realleges the preceding paragraphs of this Complaint as if fully 

set forth herein.

38. Defendant has, under 35 U.S.C. §271(a), directly infringed, and continues to 

directly infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

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without limitation at least claim 1 of the ’470 Patent, by making, using, testing, selling, offering 

for sale and/or importing into the United States Defendant’s Accused Products.

39. On information and belief, Defendant’s infringement of the ’470 Patent has been 

willful and merits increased damages.

40. On information and belief, Defendant has known that its activities concerning the 

Accused Products infringed on or more claims of the ’470 Patent since at least February 2, 2021 

based on knowledge from Trellix’s predecessor, McAfee.

41. On information and belief, Defendant has made no attempt to design around the 

claims of the ’470 Patent.

42. On information and belief, Defendant did not have a reasonable basis for believing 

that the claims of the ’470 Patent were invalid.

43. On information and belief, Defendant’s Accused Products are available to 

businesses and individuals throughout the United States and in the State of Texas, including in this 

District.

44. CTD Networks has been damaged as the result of Defendant’s infringement.

45. The claim chart attached hereto as Exhibit G describes how the elements of an 

exemplary claim 1 from the ’470 Patent are infringed by the Accused Products. This provides 

details regarding only one example of Defendant’s infringement, and only as to a single patent 

claim. Plaintiff reserves its right to amend and fully provide its infringement arguments and 

evidence thereof until its Preliminary and Final Infringement Contentions are later produced 

according to the court’s scheduling order in this case.

COUNT IV

PATENT INFRINGEMENT OF THE ’974 PATENT

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46. Plaintiff restates and realleges the preceding paragraphs of this Complaint as if fully 

set forth herein.

47. Defendant has, under 35 U.S.C. §271(a), directly infringed, and continues to 

directly infringe, literally and/or under the doctrine of equivalents, one or more claims, including 

without limitation at least claim 1 of the ’974 Patent, by making, using, testing, selling, offering 

for sale and/or importing into the United States Defendant’s Accused Products. 

48. On information and belief, Defendant has made no attempt to design around the 

claims of the ’974 Patent.

49. On information and belief, Defendant did not have a reasonable basis for believing 

that the claims of the ’974 Patent were invalid.

50. On information and belief, Defendant’s Accused Products are available to 

businesses and individuals throughout the United States and in the State of Texas, including in this 

District.

51. CTD Networks has been damaged as the result of Defendant’s infringement. 

52. The claim chart attached hereto as Exhibit H describes how the elements of an 

exemplary claim 1 from the ’974 Patent are infringed by the Accused Products. This provides 

details regarding only one example of Defendant’s infringement, and only as to a single patent 

claim. Plaintiff reserves its right to amend and fully provide its infringement arguments and 

evidence thereof until its Preliminary and Final Infringement Contentions are later produced 

according to the court’s scheduling order in this case.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff CTD Networks respectfully requests the following relief:

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A. A judgment that Defendant has directly infringed either literally and/or under the 

doctrine of equivalents and continue to directly infringe the patents-in-suit;

B. A judgment and order requiring Defendant to pay Plaintiff damages under 35

U.S.C. § 284 including past damages based on, inter alia, any necessary compliance with 35 

U.S.C. §287, treble damages for willful infringement as provided by 35 U.S.C. § 284, and 

supplemental damages for any continuing post-verdict infringement through entry of the final 

judgment with an accounting as needed;

C. A judgment that this is an exceptional case within the meaning of 35 U.S.C. § 285 

and Plaintiff is therefore entitled to reasonable attorneys’ fees;

D. A judgment and order requiring Defendant to pay Plaintiff pre-judgment and postjudgment interest on the damages awarded;

E. A judgment and order awarding a compulsory ongoing royalty;

F. A judgment and order awarding Plaintiff costs associated with bringing this action;

G. Such other and further relief as the Court deems just and equitable.

JURY TRIAL DEMANDED

Pursuant to FED. R. CIV. P. 38, Plaintiff CTD Networks hereby demands a trial by jury on

all issues so triable.

Respectfully submitted,

Ramey LLP

William P. Ramey, III

Texas State Bar No. 24027643

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5020 Montrose Blvd., Suite 800

Houston, Texas 77006

(713) 426-3923 (telephone)

(832) 900-4941 (fax)

wramey@rameyfirm.com

Attorney for CTD Networks LLC

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