Patents and accused products
The case is Interstate Patents, LLC v. ADT Inc. and ADT LLC, No. 4:26-cv-01533 (E.D. Tex.). The complaint is dated October 20, 2026, and the court stamp reads filed October 20, 2026. It says Interstate Patents is a Texas limited liability company with its principal place of business in Lago Vista, Texas. It alleges that ADT Inc. is a Delaware corporation and that ADT LLC is a Delaware limited liability company, does business as ADT Security Services, and is a wholly owned subsidiary of ADT Inc. The complaint cites ADT Inc.'s annual report on Form 10-K, dated March 2, 2026, for that subsidiary allegation. Subject matter jurisdiction is pleaded under 28 U.S.C. 1331 and 1338(a). The complaint says the action arises under 35 U.S.C. 271, 281, 284, and 285, among other sections.
The complaint alleges personal jurisdiction because ADT does business in Texas, because it alleges acts of infringement in Texas, and because ADT LLC is registered to do business in Texas. Venue is pleaded under 28 U.S.C. 1400(b) and 28 U.S.C. 1391. The complaint alleges that ADT has committed acts of infringement in the district and has regular and established places of business in the district, including ADT Security Services locations in Tyler, Texas, and a data center facility in Richardson, Texas, used to house computer and network equipment supporting the accused products, including cloud-based alarm monitoring, video storage, and ADT+ app services.
The accused products, as the complaint lists them, include the ADT Outdoor Camera (VMC3050-1ADNAS), the ADT Indoor Camera (VMC3060-1ADNAS), the ADT Doorbell Camera (AVD4001-1ADNAS), the ADT LTE Cellular Alarm Communicator (LE4000RF-ADTAT), the ADT+ app, the ADT Control app, the plus.adt.com web portal, and the Google Nest Hub (2nd Gen) as offered by ADT, plus substantially similar products and associated hardware, software, and services. The complaint alleges that, using those products, ADT and its customers capture, store, and view video and images from ADT cameras, transmit and receive alarm signals and other data over cellular LTE networks, including with forward error correction, and organize, filter, and retrieve saved media and event history through the ADT+ platform.
The same day, Interstate Patents also filed Interstate Patents, LLC v. BH Security, LLC, No. 4:26-cv-01534 (E.D. Tex.), and Interstate Patents, LLC v. Resideo Technologies, Inc., et al., No. 4:26-cv-01536 (E.D. Tex.), against Resideo Technologies, Inc. and Resideo LLC. The docket entry for each of those complaints lists claim charts for the '591, '856, and '618 patents and an August 2026 letter as exhibits.
What the patents cover
The complaint asserts three patents and alleges infringement of at least one claim of each. U.S. Patent 8,163,591, titled Backside Illuminated Image Sensor, issued April 24, 2012. The complaint alleges direct infringement of at least claim 1. Claim 1 covers a method of providing light at a backside of a substrate, reflecting the provided light onto a front side of a depletion region to generate and store a photoelectric charge, and applying a bias signal at the front side of the depletion region to control the size of the depletion region. Google Patents lists the patent as active, with an anticipated expiration of June 27, 2028.
U.S. Patent 7,853,856, titled Forming of Error Correction Data, issued December 14, 2010. The complaint alleges direct infringement of at least claim 13. Claim 13 covers a device for reconstructing missing data packets. The device includes a communication interface configured to receive one or more data packets and one or more error correction data packets, and a processing module configured to cause the device to determine if all of the data packets were received. If all of them were not received, the module is configured to cause the device to evaluate positioning information of the data packets, distribute the data packets to a block of data symbols that comprises equal size data symbols, with each data packet associated to a known position in the block, distribute the error correction data packets to a block of error correction symbols, and recover the data packets that were not received based on the data symbols and based on the error correction symbols. Google Patents lists the patent as active, with an adjusted expiration of February 1, 2029.
U.S. Patent 8,078,618, titled Automatic Multimode System for Organizing and Retrieving Content Data Files, issued December 13, 2011. The complaint alleges direct infringement of at least claim 21. Claim 21 covers a display device with content data files stored in a storage location accessible by the display device, each including information for being presented on a display. A user interface inputs a user request for the content data files. A controller receives the user request, accesses the content data files, and determines a number of groups generated by each of a plurality of different content data file categorization methods. Those methods are selected from a categorization method group consisting of geographic location of where the content data files were captured, number of steps required to access the content data files in a group, date of when the content data files were captured, the storage file locations in which the content data files are stored, people identified in images in the content data files, object types in images in the content data files, color illumination values of images in the content data files, camera settings used to capture images in the content data files, image formats used to store images in the content data files, special effects applied to images in the content data files, and quality measures of the content data files. The controller selects one method based upon the number of groups being within a predetermined range of numbers, and uses that method for representing the groups on the display. Google Patents lists the patent as active, with an adjusted expiration of March 29, 2027.
What the lawsuit is about
Count I alleges direct infringement of at least claim 1 of the '591 patent, literally and/or under the doctrine of equivalents, by ADT cameras, and names the Outdoor Camera, Indoor Camera, and Doorbell Camera as examples. The complaint alleges that those cameras correspond to camera models also sold under the Arlo brand, model numbers VMC3050-100NAS, VMC3060-100NAS, and AVD4001-100NAS, and, on information and belief, incorporate backside-illuminated CMOS image sensors, such as those supplied by OMNIVISION and/or Sony. It alleges that, in operation, light is provided at the backside of the image sensor substrate and reflected onto the front side of the photodiode depletion region to generate and store a photoelectric charge, and a bias signal is applied at the front side of the depletion region to control its size. The complaint alleges direct infringement when ADT or its agents use the cameras, including during testing, when a customer or end user uses them, and when ADT exercises direction or control over use by affiliates, dealers, installers, customers, or end users. Exhibit 1 is a claim chart for claim 1. Exhibits 2 and 3, the claim charts for the '856 and '618 patents, and Exhibit 4, the August 2026 letter, are not on the public docket.
Count II alleges direct infringement of at least claim 13 of the '856 patent, literally and/or under the doctrine of equivalents, by ADT LTE cellular alarm communicators. The complaint identifies model LE4000RF-ADTAT as an example and alleges that the communicator, FCC ID F5317LE4000, incorporates a Telit LE910-NA1 LTE module. It alleges that the communicator receives data packets and error correction data packets and reconstructs missing data packets from the received data symbols and error correction symbols, including in accordance with the forward error correction scheme specified in 3GPP TS 26.346.
Count III alleges direct infringement of at least claim 21 of the '618 patent, literally and/or under the doctrine of equivalents, by the ADT+ platform, including the ADT+ app, the ADT Control app, and the plus.adt.com web portal, including as used with display devices offered by ADT such as the Google Nest Hub (2nd Gen). The complaint alleges that the platform stores customers' saved media, including video clips and images captured by ADT cameras, and event history in ADT's cloud platform, receives user requests for that content, and groups and presents the content on the display according to multiple categorization methods, including by camera, date, media type, event type, device type, and detected object type, for example people, vehicles, and animals.
The complaint also alleges induced infringement and contributory infringement of all three patents, including at least claim 1 of the '591 patent, claim 13 of the '856 patent, and claim 21 of the '618 patent. It alleges that ADT induced end users, customers, affiliates, and others in the supply chain to infringe, with knowledge of the patents and knowledge that the induced acts constitute infringement, and that the inducement is ongoing. On contributory infringement, it alleges that the accused products have special features specially designed to be used in an infringing way and that have no substantial uses other than infringing ones, and that those features are not staple articles of commerce suitable for substantial non-infringing use.
The complaint alleges that ADT had knowledge of all three patents at least as of August 20, 2026, when Interstate Patents sent a letter to the president and chief executive officer of ADT Inc. It alleges that the letter identified the patents, enclosed claim charts, and stated that it was meant to constitute actual notice under 35 U.S.C. 287(a). It also alleges knowledge as of notice of this action. It alleges that direct and indirect infringement has been willful at least since that August 20, 2026 letter. It further alleges that ADT has a policy or practice of not reviewing the patents of others and has been willfully blind of Interstate Patents' patent rights. For each patent, the complaint alleges that Interstate Patents has neither made nor sold unmarked articles and is entitled to pre-filing damages for the full period allowed by law. It alleges damages of not less than a reasonable royalty under 35 U.S.C. 284.
The prayer asks for judgment of infringement, literally and/or under the doctrine of equivalents, a permanent injunction against infringement of all three patents or, in the alternative, an ongoing royalty, damages including increased damages under 35 U.S.C. 284, pre-judgment and post-judgment interest, and a declaration that the case is exceptional with attorney fees under 35 U.S.C. 285. Interstate Patents demands a jury. Counsel are Matthew J. Antonelli, Zachariah S. Harrington, Larry D. Thompson, Jr., and Rehan M. Safiullah of Antonelli, Harrington & Thompson LLP.
What it means
The complaint puts a different asserted claim against different ADT products: claim 1 of the '591 patent against cameras, claim 13 of the '856 patent against an LTE alarm communicator, and claim 21 of the '618 patent against the ADT+ platform and displays. Claim 1 is a method claim about light at a backside of a substrate, a depletion region, and a bias signal. Claim 13 is a device claim about reconstructing missing data packets from data symbols and error correction symbols. Claim 21 is a display-device claim about selecting a categorization method from a listed group when the number of groups falls within a predetermined range of numbers. The complaint alleges pre-suit knowledge from the August 20, 2026 letter, pleads willful infringement, and asks for an injunction against all three patents. Google Patents lists each patent as active, with expiration dates of June 27, 2028 for the '591 patent, February 1, 2029 for the '856 patent, and March 29, 2027 for the '618 patent.
What to watch next
Watch for service on ADT Inc. and ADT LLC and for an answer or a Rule 12 motion. The case can end at any time, including by settlement or voluntary dismissal.