IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

 

 ) 

QUALITATIVE DATA SOLUTIONS, LLC, ) 

 )

 Plaintiff, ) Civil Action No. _________ 

 ) 

 v. ) JURY TRIAL DEMANDED

 ) 

ADT, INC. ) 

 ) 

 Defendant. ) 

 ) 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff Qualitative Data Solutions, LLC (hereinafter “QDS”), by and through its 

undersigned attorneys, files this Complaint for Patent Infringement against Defendant ADT, Inc. 

and alleges as follows. 

NATURE OF ACTION 

1. This is an action for infringement of United States Letters Patent No. 8,818,532 

under the Patent Laws of the United States, 35 U.S.C. § 1, et seq.

THE PARTIES 

 2. Plaintiff QDS is a limited liability company organized and existing under the laws 

of the State of Wyoming with its principal place of business at 1712 Pioneer Ave Suite 500, 

Cheyenne, Wyoming. QDS is in the business of licensing patented technology. QDS is the assignee 

of all right, title, and interest in United States Letters Patent No. 8,818,532. 

 3. On information and belief, Defendant ADT, Inc. is a corporation organized and 

existing under the laws of the State of Delaware, with a principal place of business at 1501 Yamato 

Road, Boca Raton, Florida. On information and belief, Defendant does business itself, directly 

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and/or through its subsidiaries, affiliates, and agents, in the Eastern District of Texas, including at 

Defendant’s place of business at 215 Winchester Drive, Unit 105, Tyler, Texas. 

JURISDICTION 

 4. The claims in this action arise under the Patent Laws of the United States, Title 35 

of the United States Code. Accordingly, this Court has subject matter jurisdiction over the patent 

infringement claims in this action pursuant to 28 U.S.C. §§ 1331 and 1338(a). 

 5. Defendant is subject to this Court’s specific and general personal jurisdiction 

pursuant to the Texas Long Arm Statute, due at least to its substantial business conducted in this 

forum, directly and/or through one or more of its subsidiaries, affiliates, and/or intermediaries, 

including (i) having solicited business in the State of Texas, transacted business within the State 

of Texas, and/or attempted to derive financial benefit from residents of the State of Texas, 

including benefits directly related to the instant patent infringement causes of action set forth 

herein; (ii) having placed products and services into the stream of commerce throughout the United 

States and having been actively engaged in transacting business in Texas and in this District, 

including at Defendant’s place of business at 215 Winchester Drive, Unit 105, Tyler, Texas; and 

(iii) either alone or in conjunction with others, having committed acts of infringement within this 

District, including at Defendant’s place of business at 215 Winchester Drive, Unit 105, Tyler, 

Texas, and/or induced others to commit acts of infringement within this District. Defendant has, 

directly and/or through a distribution network, purposefully and voluntarily placed infringing 

products and services in the stream of commerce knowing and expecting them to be purchased and 

used by consumers in Texas and in this District. 

 6. On information and belief, Defendant, directly and/or through one or more 

subsidiaries, affiliates, and/or intermediaries, has advertised and continues to advertise (including 

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through websites), used, offered to sell, sold, distributed, and/or induced the sale and/or use of 

infringing products and services in the United States and in this District, including at Defendant’s 

place of business at 215 Winchester Drive, Unit 105, Tyler, Texas. Defendant has, directly and/or 

through a distribution network, purposefully and voluntarily placed such products and services in 

the stream of commerce via established channels knowing and expecting them to be purchased 

and used by consumers in the United States and this District. Defendant has committed acts of 

direct infringement in Texas and/or committed indirect infringement based on acts of direct 

infringement by others in Texas and in this District, including Defendant’s customer end-users. 

 7. On information and belief, Defendant conducts business in Texas, including 

advertising, using, offering to sell, distributing, and selling infringing products in this District. 

Defendant places such infringing products and services into the stream of commerce via 

established channels knowing or understanding that such products and services would be offered 

for sale, sold, and/or used in the United States, including in the State of Texas and this District. 

The exercise of jurisdiction over Defendant would therefore not offend the traditional notions of 

fair play and substantial justice. 

 8. On information and belief, Defendant has appointed C T Corporation System, 1999 

Bryan St., Ste 900, Dallas, Texas, as Defendant’s agent for service of process in the State of Texas. 

VENUE

 9. Venue is proper in this judicial district under 28 U.S.C. § 1391(c)(2) and 1400(b) 

because Defendant employees at least one individual who is conducting Defendant’s business at 

215 Winchester Drive, Unit 105, Tyler, Texas. 

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THE PATENT IN SUIT 

 10. On August 26, 2014, United States Letters Patent No. 8,818,532 (“the ’532 patent”) 

entitled “SYSTEM AND METHOD FOR SELECTIVELY CONTROLLING AND 

MONITORING RECEPTACLES AND FIXTURES CONNECTED TO A POWER CIRCUIT IN 

A BUILDING,” was duly and legally issued by the United States Patent & Trademark Office. A 

copy of the ’532 patent is attached hereto as Exhibit 1. 

 11. The ’532 patent issued from U.S. Patent Application Number 13/217,221, which 

was filed on August 24, 2011. The ’532 patent was granted a term extension of 291 days pursuant 

to 35 U.S.C. § 154(b), which means the ’532 patent will remain in force until at least June 10, 

2032. 

 12. The named inventor of the ’532 patent assigned his rights to Zig Zag Innovations, 

LLC, who assigned its rights to QDS. QDS is therefore the current and sole owner of all rights, 

title and interest in and to the ’532 patent and, at a minimum, of all substantial rights in the ’532 

patent, including the exclusive right to enforce the ’532 patent and all rights to pursue past, present 

and future damages and to seek and obtain injunctive or any other relief for infringement of 

the ’532 patent. 

Overview of the Technology 

 13. The ’532 patent relates to an area circuit in which specific outlets can be 

automatically and individually controlled and to smart outlets for use in such an area circuit. 

14. It has long been known that data can be transmitted through power wire cables, 

while electricity is simultaneously being transmitted through those same cables. This is 

accomplished by transmitting low voltage signals at high frequencies, i.e., frequencies over 100 

kHz. The transmission of the data has no appreciable effect upon the transmission of electricity 

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and vice versa, and so transmitting data through power lines has been used for computer 

networking and even for telephone communication wiring. Data transmission through power 

cables has also been used to control smart outlets, where those outlets can be activated or 

deactivated by data transmission. See the ’532 patent at col. 1, ll. 33-38. 

15. In such systems, the control signals are typically generated using a desktop 

computer. The desktop computer uses a signal converter to convert command signals into data 

signals that can travel through power lines. Since data is being transmitted through active power 

lines, the installation and expense of installing such systems is considerable. See id. at col. 1, ll. 

38-43. 

16. Furthermore, commercially available smart outlets are very expensive. This is due 

to the electronics required within the smart outlet to identify the smart outlet to the overall system. 

A typical home may have over one hundred outlets and dozens of lighting fixtures. See id. at col. 

1, ll. 43-48. 

17. Being able to place an expensive smart outlet into such a multitude has made such 

prior art systems too expensive and too complex for use by the average homeowner. Accordingly, 

smart outlets are typically only installed by professionals in luxury homes and ultra-high energy 

efficient commercial buildings. See id. at col. 1, ll. 48-53. 

 18. A need therefore existed at the time of filing of the application from which the ’532 

patent issued for a system and method of simplifying the use of smart outlets. The ’532 patent 

provided smart outlets that an average homeowner could afford to use and be able to install 

throughout the home. See id. at col. 1, ll. 48-53. 

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The Patented Invention 

 19. The present invention is an area circuit for use in a building or the like which 

includes at least one smart outlet having a receptacle, an internal on/off switch, and a selectively 

changeable identification code, and a control unit coupled to that smart outlet by an electrical 

power cable. See the ’532 patent, col. 5, l. 29 to col. 6, l. 7. 

20. The inventive circuit may form part of a system that enables specific outlets and 

fixture switches in the circuit to be automatically and individually controlled. Such a system may 

also include smart fixture switches. Each such smart fixture switch has an internal on/off switch, 

and a selectively changeable address code. See the ’532 patent at col. 1, l. 62 to col. 2, l. 3. 

21. An electrical power cable extends throughout the area circuit providing power to 

the various smart outlets and smart fixture switches. The smart outlets only conduct electricity to 

their receptacles when their internal on/off switches are “on.” Likewise, the fixture switches are 

only capable of passing electricity when their internal on/off switches are turned “on.” See id. at 

col. 2, ll. 4-10. 

22. A control unit is coupled to the electrical power cable at a point in the circuit before 

the first smart outlet or smart fixture switch. The control unit generates an addressed control signal 

within the electrical power cable. The addressed control signal selectively controls the internal 

on/off switches in the smart outlets and the smart fixture switches. The addressed control signal 

generated by the control unit, however, must be properly addressed to a smart outlet or a smart 

fixture switch in order for that smart outlet or smart fixture switch to respond. By changing the 

address codes associated with each smart outlet and smart fixture switch, different elements of an 

area circuit can be controlled using a single command signal. Likewise, many different elements 

can be controlled using different command signals. See id. at col. 2, ll. 11-24. 

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23. Referring to FIG. 1, a schematic for the wiring of a typical residential home is 

shown. As can be seen, the home receives power through electrical power cables 12 that run to the 

house 10 from a local power utility. The electrical power cables 12 run into a main circuit breaker 

panel 14. The circuit breaker panel 14 contains multiple circuit breakers. Each circuit breaker 

controls a specific area circuit 18 within the home 10. See the ’532 patent at col. 2, ll. 50-56. 

24. System 20 includes the use of control unit 22, smart outlets 24 and smart fixture 

switches 26 that enable each individual circuit to be separately programmed and controlled. See

the ’532 patent at col. 2, ll. 57-60. 

25. Referring to both FIG. 1 and FIG. 2 of the ’532 patent, it can be seen that a control 

unit 22 is provided for each area circuit 18 within a home. Area circuit 18 can also be deployed in 

commercial real estate, such as office buildings, and large residential complexes, such as 

apartments or condominiums. Control unit 22 is placed in series between the primary circuit 

breaker panel 14 and the first smart outlet 24 in area circuit 18. Control unit 22 generates control 

signals to operate the various smart outlets 24 present in area circuit 18. Control unit 22 also 

prevents reply signals or looped signals from passing back into the main wiring and affecting other 

area circuits 18. See the ’532 patent at col. 2, l. 61 to col. 3, l. 3. 

26. Each smart outlet 24 contains control circuitry 28a, 28b that controls an internal 

on/off switch 30a, 30b. The control circuitry 28a, 28b responds to command signals 32 sent by 

control unit 22, provided those command signals 32 are addressed to the smart outlet 24. The 

address of each smart outlet 24 is determined by the use of a set of pin switches 34a, 34b. Although 

the use of pin switches 34a, 34b is illustrated, other code setting devices, such as memory cards 

or ID chips can be used. The use of pin switches 34a, 34b is preferred because of the ease in 

changing between preset codes. See the ’532 patent at col. 3, ll. 4-15. 

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27. In addition to an internal on/off switch 30a, 30b, each smart outlet 24 also 

preferably contains a current meter 46a, 46b and a signal generator 48a, 48b that enables each 

smart outlet 24 to send signals back to the control unit 22. See the ’532 patent at col. 3, ll. 16-20. 

28. Each control unit 22 contains its own central processing unit (CPU) 36. CPU 36 is 

coupled to a display 38 and to one or more user inputs 40. Display 38 and user inputs 40 enable a 

user to interact with program control software being run by control unit 22. The program control 

software provides two program functions to each smart outlet 24 connected to area circuit 18. The 

first program function is for the on/off control of each smart outlet 24. Using this program function, 

a user can immediately send a signal to a specific smart outlet 24 that causes that device to 

immediately turn either on or off. See the ’532 patent at col. 3, ll. 21-32. 

29. Similarly, using a clock 42 and memory 44 that are coupled to CPU 36, a user can 

program specific times that each smart outlet 24 can be activated or be deactivated. It will therefore 

be understood that a user can turn on/off lights, appliances or any other electrical item that is 

plugged into a smart outlet 24. See the ’532 patent at col. 3, ll. 32-39. 

30. The second program function is used for power monitoring. Each smart outlet 24

contains an amp meter 46. The amp meter 46 measures how much current is presently flowing 

through smart outlet 24. The current flow is converted into a data signal by the control circuitry 

28a, 28b. The data signal is then sent back to control unit 22 using signal generators 48a, 48b in 

smart outlet 24. See the ’532 patent at col. 3, ll. 40-47. 

31. It will therefore be understood that a user can go to control unit 22 and display how 

much electrical current is passing through a particular outlet 24. In this manner, a person can 

calculate the costs of running various appliances, fixtures, and other electrical items. See the ’532 

patent at col. 3, ll. 47-52. 

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32. In one embodiment of the invention, control unit 22 may contain a plurality of pin 

switch devices 50. In such an embodiment, it is preferred that control unit 22 have up to ten pin 

switch devices 50. Each pin switch device 50 can be set to a unique identification code that is 

shared by one of the smart outlets 24 in the same area circuit 18 as control unit 22. If a pin switch 

device 50 on control unit 22 is set to the same identifier code as a pin switch device 34a, 34b in 

smart outlet 24, then control unit 22 is capable of communicating with that smart outlet 24 and 

vice versa. See the ’532 patent at col. 3, ll. 53-64. 

33. Furthermore, it should be understood that more than one smart outlet 24 can be set 

to the same identification code. If this is done, all smart outlets 24 set to the same code will turn 

on together and off together upon the sending of a single command signal 32 from control unit 22. 

See the ’532 patent at col. 3, l. 64 to col. 4, l. 3. 

The Claims are Directed to Patentable Subject Matter 

 34. The inventions claimed in the ’532 patent include an area circuit within a building, 

such as a home or office building, comprising: (i) at least one outlet assembly having a receptacle, 

an on/off switch, and a selectively changeable outlet identification code, wherein the on/off 

switch(es) is configurable between an “on” condition and an “off” condition; and (ii) a control unit 

coupled to the outlet assembly (or assemblies) by an electrical power cable, wherein the control 

unit(s) generates an addressed control signal within the electrical power cable(s) that selectively 

controls the on/off switch(es) in the outlet assembly (or assemblies) only when the outlet 

identification code(s) is accurately addressed by the addressed control signal(s). 

The Claims Are Not Directed to an Abstract Idea or Law of Nnature 

35. The claims of the ’532 patent are not directed to an abstract idea or law of nature. 

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 36. Claim 9 of the ’532 patent is directed to an area circuit within a building, such as a 

home or office building, comprising at least one outlet assembly and a control unit coupled to the 

outlet assembly (or assemblies) by an electrical power cable. As would be known and recognized 

by person of ordinary skill in the art (“POSITA”), an outlet assembly, a control unit, and an 

electrical power cable are all real, tangible, physical devices. 

The Claims Do Not Preempt Their Field 

 37. The claims of the ’532 patent do not merely recite an area circuit having one or 

more smart outlets and a control unit. Rather, the claimed invention is directed to an area circuit 

in which both the smart outlet(s) and the control unit that have certain specific attributes, such as 

a selectively changeable identification code, and/or perform certain specific functions, such as 

generating an addressed control signal. 

 38. Alternative embodiments of an area circuit having one or more smart outlets and a 

controller exist and were known prior to the filing of the application from which the ’532 patent 

issued, such as those described in the specification. 

DEFENDANT’S SYSTEM AND SERVICES 

 39. On information and belief, Defendant makes or has made, distributes, markets, sells, 

offers for sale, and installs or has installed smart home systems and devices, including, without 

limitation, ADT smart plugs (https://www.adt.com/smart-switch) and devices and software for 

controlling, inter alia, ADT smart plugs, such as the ADT Command Smart Security Panel or ADT 

Pulse Gateway. 

 40. On information and belief, ADT smart plugs can be controlled as part of an ADT 

smart security system via the platform ADT Command. On information and belief, ADT 

Command (formerly called ADT Pulse) is software that enables a customer-user to control 

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connected security and home automation devices via a physical Command Panel installed on the 

circuit or via the ADT Control mobile app. On information and belief, a customer-user can 

program lights to turn on or off at a specific time and remotely turn on or off any electrical device(s) 

connected to the smart plug. 

 41. On information and belief, Defendant markets, sells, offers for sale, and/or 

distributes to, and/or makes or has made and/or installs or has installed for, customer-users 

packages including one or more ADT smart plugs (each of which is an outlet assembly) and an 

ADT Command Smart Security Panel or ADT Pulse Gateway (a control unit) connected thereto 

by an electrical power cable. 

 42. On information and belief, each ADT smart plug has a selectively changeable 

identification code that is used by the control unit (e.g., an ADT Command Smart Security Panel 

or ADT Pulse Gateway) to activate/de-activate that specific smart plug (i.e., turn the smart plug(s) 

with that identification code “on” or “off”). 

 43. Despite not having a license to the ’532 Patent, Defendant’s devices nevertheless 

incorporate the technology covered by the claims of the ’532 Patent, including at least claim 9. 

FIRST CAUSE OF ACTION 

(Direct Infringement of the ’532 Patent) 

 44. QDS hereby repeats and re-alleges the allegations contained in paragraphs 1 to 43 

as if fully set forth herein. 

 45. The ’532 patent is presumed valid under 35 U.S.C. § 282. 

 46. QDS has complied with the requirements of 35 U.S.C. § 287 as have all prior 

owners of the ’532 patent. 

 47. The accused devices are covered by one or more claims of the ’532 patent, 

including at least claim 9, and therefore infringe the ’532 patent. 

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 48. Defendant’s direct infringement of the ’532 patent has injured and continues to 

injure QDS and QDS is entitled to recover damages adequate to compensate for that infringement 

in an amount to be proven at trial, but not less than a reasonable royalty. 

 49. Despite Defendant’s knowledge of the ’532 patent and its infringing activities, 

Defendant has continued to market, sell, offer for sale, and/or distribute to, and/or make or have 

made and/or install or have installed for, customer-users devices that infringe the ’532 patent, 

without authority from QDS. Defendant has therefore acted recklessly and Defendant’s direct 

infringement of the ’532 patent has been willful, egregious, deliberate and intentional, justifying 

an award to QDS of increased damages and attorneys’ fees and costs. 

 50. Even after becoming aware of its direct infringement of the ’532 Patent, on 

information and belief, Defendant has made no effort to alter its products or services or otherwise 

attempt to design around the claims of the ’532 Patent in order to avoid infringement. These 

actions demonstrate Defendant’s blatant and egregious disregard for QDS’s patent rights. 

 51. As a result of Defendant’s unlawful activities, QDS has suffered and will continue 

to suffer irreparable harm for which there is no adequate remedy at law. Defendant’s continued 

direct infringement of the ’532 patent causes harm to QDS in the form of loss of goodwill, damage 

to reputation, loss of business opportunities, lost profits, inadequacy of monetary damages, and/or 

direct and indirect competition. Monetary damages are insufficient to compensate QDS for these 

harms. Accordingly, QDS is also entitled to preliminary and permanent injunctive relief. 

SECOND CAUSE OF ACTION 

(Indirect Infringement of the ’532 Patent) 

 52. QDS hereby repeats and re-alleges the allegations contained in paragraphs 1 to 51 

as if fully set forth herein. 

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 53. Defendant’s customer-users directly infringe one or more claims of the ’532 patent, 

including at least claim 9 thereof, through their use in the United States of Defendant’s devices in 

their normal and customary way. 

 54. Defendant indirectly infringes by inducing infringement of the claims of the ’532 

patent by aiding and abetting consumer-users to use Defendant’s devices in their normal and 

customary way in the United States and in this District and by contributing to infringement of the 

claims of the ’532 patent by supplying components and providing instructions to consumer-users 

for using those components. 

 55. Defendant aids and abets consumer-users in infringing the claims of the ’532 patent 

with the knowledge of, and the specific intent to cause, the acts of direct infringement performed 

by these consumer-users. 

 56. Defendant’s indirect infringement of the ’532 patent has injured and continues to 

injure QDS and QDS is entitled to recover damages adequate to compensate for that infringement 

in an amount to be proven at trial, but not less than a reasonable royalty. 

 57. Despite Defendant’s knowledge of the ’532 Patent and its infringing activities and 

the infringing activities of consumer-users of Defendant’s devices, Defendant has continued to 

market, sell, offer for sale, and/or distribute to, and/or make or have made and/or install or have 

installed for, customer-users devices that infringe the ’532 patent, without authority from QDS. 

Defendant has therefore acted recklessly and Defendant’s indirect infringement of the ’532 patent 

has been willful, egregious, deliberate and intentional, justifying an award to QDS of increased 

damages and attorneys’ fees and costs. 

 58. Even after becoming aware of its indirect infringement of the ’532 Patent, on 

information and belief, Defendant has made no effort to alter its devices or otherwise attempt to 

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design around the claims of the ’532 patent in order to avoid infringement. These actions 

demonstrate Defendant’s blatant and egregious disregard for QDS’s patent rights. 

 59. As a result of Defendant’s unlawful activities, QDS has suffered and will continue 

to suffer irreparable harm for which there is no adequate remedy at law. Defendant’s continued 

indirect infringement of the ’532 patent causes harm to QDS in the form of loss of goodwill, 

damage to reputation, loss of business opportunities, lost profits, inadequacy of monetary damages, 

and/or direct and indirect competition. Monetary damages are insufficient to compensate QDS for 

these harms. Accordingly, QDS is entitled to preliminary and permanent injunctive relief. 

PRAYER FOR RELIEF 

 Wherefore, QDS respectfully prays this Court enter judgment in its favor on each and every 

Claim for Relief and award to QDS relief, including, but not limited to, the following: 

 A. Entry of judgment in favor of QDS, and against Defendant, on each and every 

Claim in this Complaint; 

 B. Entry of judgment in favor of QDS, and against Defendant, that Defendant has 

directly infringed the claims of the ’532 patent; 

 C. Entry of judgment in favor of QDS, and against Defendant, that Defendant has 

indirectly infringed the claims of the ’532 Patent by inducing the infringement thereof and/or 

contributing to the infringement thereof; 

 D. Entry of judgment in favor of QDS, and against Defendant, that this case is an 

exceptional case and awarding QDS its reasonable attorney fees and costs pursuant to 35 U.S.C. § 

285 and any other applicable statutes, laws, and/or rules; and 

 E. Entry of preliminary and permanent injunctions against Defendant, and its officers, 

directors, principals, agents, sales representatives, servants, employees, successors, assigns, 

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affiliates, divisions, subsidiaries, and all those acting in concert or participation with them, from 

directly infringing, inducing infringement and/or contributing to the infringement of any claim of 

the ’532 patent. 

 F. A determination that QDS is the prevailing party and therefore entitled to its taxable 

costs; and 

 G. Entry of judgment in favor of QDS, and against Defendant, awarding QDS such 

other relief the Court deems just, equitable, and proper. 

DEMAND FOR A JURY TRIAL

 QDS requests a trial by jury, under Rule 38 of the Federal Rules of Civil Procedure, for all 

issues so triable. 

Dated: June 6, 2023 Respectfully submitted, 

 /s/ Donald R. McPhail

 Donald R. McPhail (admitted) 

 OBLON, MCLELLAND, MAIER 

 & NEUSTADT LLP 

 1940 Duke Street 

 Alexandria, VA 22314 

 dmcphail@oblon.com 

 Telephone: 703-413-3000 

 Facsimile: 703-413-2220 

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