DCT
2:23-cv-00343
DaVinci Lock LLC v. Spiderdoor LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: DaVinci Lock, LLC (North Carolina) and DaVinci Lock Self Storage, Inc. (Delaware)
- Defendant: SpiderDoor, LLC (Alabama)
- Plaintiff’s Counsel: Lightfoot, Franklin & White, LLC
- Case Identification: 2:23-cv-00343, N.D. Ala., 06/29/2023
- Venue Allegations: Venue is alleged to be proper as Defendant is organized under Alabama law, maintains its principal place of business and a regular and established place of business within the district, and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s software and systems for managing over-locks on self-storage units infringe patents related to remotely providing unlock codes for non-electronic physical locks.
- Technical Context: The technology addresses operational inefficiencies in the self-storage industry by allowing tenants to remove temporary "over-locks" themselves via electronically-delivered codes, eliminating the need for on-site staff intervention.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendant of the '513 Patent and its alleged infringement on January 19, 2023. After an exchange of correspondence, including claim charts provided by the Plaintiff, Defendant allegedly refused to cease its infringing conduct on March 2, 2023, forming the basis for allegations of pre-suit knowledge and willfulness.
Case Timeline
| Date | Event |
|---|---|
| 2017-09-20 | U.S. Patent No. 11,663,650 Priority Date |
| 2018-08-24 | U.S. Patent No. 11,232,513 Priority Date |
| 2022-01-25 | U.S. Patent No. 11,232,513 Issued |
| 2023-01-19 | Pre-suit notice letter sent to Defendant |
| 2023-05-30 | U.S. Patent No. 11,663,650 Issued |
| 2023-06-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,232,513 - "System and Method for Securing and Removing Over-Locks," issued January 25, 2022
The Invention Explained
- Problem Addressed: The patent's background describes the process of placing and removing "over-locks" on self-storage units for delinquent or vacant accounts as "burdensome," "time-consuming and costly," and a source of delayed access for customers who have paid their balance, particularly outside of business hours (ʼ513 Patent, col. 1:46-54; col. 2:11-23).
- The Patented Solution: The invention is a distributed management system that uses non-electronic combination locks with unique identifiers. A central database associates a lock's identifier with its specific unlock code. A user can access a software portal, provide credentials for verification, and if their account is in good standing, the system electronically transmits the unlock code to them, allowing for immediate, self-service removal of the over-lock (ʼ513 Patent, Abstract; col. 5:44-col. 6:44).
- Technical Importance: This approach sought to reduce operational costs and improve customer satisfaction in the self-storage industry by enabling contactless, 24/7 access for tenants after payment without requiring expensive, powered electronic locks on each unit (ʼ513 Patent, col. 2:37-47).
Key Claims at a Glance
- The complaint asserts independent claim 16 (Compl. ¶46).
- The essential elements of independent claim 16 are:
- Securing a location with an over-lock that is not capable of electronic communication.
- Mapping the location to an over-lock identifier in a lock management system, where the identifier is associated with an unlock code.
- A user accessing a lock management system portal that accepts a user credential.
- Transmitting the user credential from the lock management system to an access management system via an API.
- The access management system determining if the user is verified.
- Transmitting the unlock code to the user via an electronic method from the lock management system.
- The complaint reserves the right to assert additional claims (Compl. ¶56).
U.S. Patent No. 11,663,650 - "System and Method for Transmitting Unlock Codes Based on Event Triggers," issued May 30, 2023
The Invention Explained
- Problem Addressed: The patent identifies the challenge of securing vacant storage units, which, if left unsecured, can be used illegally, and if secured with traditional locks, require manual removal by staff when a new tenant rents the unit, causing delays (ʼ650 Patent, col. 2:31-44).
- The Patented Solution: The invention describes a method where a vacant unit is secured with a non-electronic over-lock. The system architecture involves a "lock management system" that communicates with a separate "property management system" via an API. The rental of the unit by a new customer acts as a trigger event, causing the unlock code to be transmitted from the lock management system to the customer, automating access for the new tenant (ʼ650 Patent, Abstract; col. 17:15-26; FIG. 14).
- Technical Importance: The invention aims to streamline the new-tenant onboarding process by automating the delivery of access codes for previously secured vacant units, further reducing the need for on-site staff and manual intervention (ʼ650 Patent, col. 2:45-58).
Key Claims at a Glance
- The complaint asserts independent claim 21 (Compl. ¶65).
- The essential elements of independent claim 21 are:
- Securing a vacant storage unit with an over-lock that is not capable of electronic communication.
- Mapping the vacant unit to an over-lock identifier in a lock management system, where the identifier is associated with an unlock code.
- Transmitting the unlock code to a property management system from the lock management system via an API.
- Upon rental of the vacant unit by a customer, transmitting the unlock code to the customer electronically from the lock management system.
- The lock management system and property management system must be two separate, distinct systems operating on different servers.
- The complaint reserves the right to assert additional claims (Compl. ¶76).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "Spider Over Locks" products and systems, which include the "SpiderDoor Software" (Compl. ¶3). This software comprises a "web-based lock management portal" and associated tenant and administrator mobile applications (Compl. ¶¶27-28).
Functionality and Market Context
- The complaint alleges the SpiderDoor system is marketed for managing self-storage facilities and provides an "overlocking flow for tenant units" (Compl. ¶25). Functionally, it allows facility managers to remotely provide unlock codes to tenants for non-electronic combination padlocks, eliminating manual lock removal (Compl. ¶28). The system is alleged to use a lock's unique identifier (e.g., serial number) to map it to a specific unit and unlock code within the software (Compl. ¶¶48, 51). The complaint also alleges the SpiderDoor Software integrates with a third-party property management system known as SiteLink (Compl. ¶72). A screenshot from the SpiderDoor software shows a table mapping a storage unit '106A' to a "Padlock Serial" of '00043' and an "Unlock Code" of '9912' (Compl. p. 13).
IV. Analysis of Infringement Allegations
'513 Patent Infringement Allegations
| Claim Element (from Independent Claim 16) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| securing a location with the over-lock, wherein the over-lock is not capable of electronic communication; | SpiderDoor instructs users to secure units with standard padlocks having a unique identifier, which are incapable of electronic communication. | ¶¶48-50 | col. 5:48-64 |
| mapping the location with an over-lock identifier in a lock management system, where the over-lock identifier is further associated with an unlock code; | The SpiderDoor Software is a lock management system that maps a storage unit to an over-lock identifier and an associated unlock code, as shown in a provided software screenshot. | ¶¶51-52 | col. 13:45-55 |
| accessing, by a user, a lock management system portal, wherein the lock management system portal is configured to accept a user credential; | The SpiderDoor lock management system is accessed via a mobile application that requires a user credential, such as a login and password, as shown in a screenshot of the login interface. | ¶53 | col. 8:29-47 |
| transmitting the user credential from the lock management system to an access management system via an application programming interface (API); | The complaint alleges the user credential is transmitted via API to an access management system to determine if the user is verified. | ¶53 | col. 19:5-8 |
| determining by the access management system if the user is verified; and | The complaint alleges the access management system determines if the user is verified after the credential is transmitted via API. | ¶53 | col. 14:35-39 |
| transmitting the unlock code to the user via an electronic method from the lock management system. | SpiderDoor's software transmits the unlock code to the user via mobile app or text message. A visual depicts a text message sent to a customer, providing the 'padlock code' to remove an overlock after payment (Compl. p. 15). | ¶54 | col. 9:22-39 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused "SpiderDoor Software" architecture contains two distinct systems corresponding to the claimed "lock management system" and "access management system." The defense could argue that a single software platform performs both functions, potentially creating a mismatch with the claim language which implies two separate entities interacting via an API.
- Technical Questions: What evidence demonstrates that a user credential, specifically, is transmitted to a separate access management system via an API for verification, as opposed to other data or a different verification architecture? The complaint's allegations on this point are less detailed than on other elements.
'650 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| securing a vacant storage unit with the over-lock, wherein the over-lock is not capable of electronic communication; | SpiderDoor instructs users to place a padlock, which is not capable of electronic communication, on vacant units. | ¶¶67-69 | col. 2:31-39 |
| mapping the vacant storage unit with an over-lock identifier in a lock management system, where the over-lock identifier is further associated with an unlock code; | The SpiderDoor Software maps a vacant or overdue unit to an over-lock identifier and an associated unlock code, as evidenced by a screenshot. | ¶¶70-71 | col. 15:1-12 |
| transmitting the unlock code to a property management system from the lock management system via an application programming interface (API); and | The complaint alleges an unlock code is transmitted from the SpiderDoor software to its integrated property management system (SiteLink) via an API. A screenshot of the SiteLink property management software interface displays an 'Unlock Code' of '9912' associated with a specific tenant account (Compl. p. 21). | ¶72 | col. 17:15-20 |
| upon rental of the vacant storage unit by a customer, transmitting the unlock code to the customer via an electronic method from the lock management system, | Upon rental, the system transmits the unlock code to the new customer via the mobile app or text message. | ¶74 | col. 17:21-26 |
| wherein the lock management system and the property management system are two separate and distinct systems that operate on different servers. | Plaintiff alleges the SpiderDoor Software (lock management) and the SiteLink system (property management) are separate, distinct systems that operate on different servers. | ¶75 | col. 17:6-14 |
- Identified Points of Contention:
- Technical Questions: A key factual dispute will likely concern whether the SpiderDoor Software and the SiteLink system are truly "two separate and distinct systems that operate on different servers." Evidence of the server architecture and the nature of the integration will be critical.
- Scope Questions: Does the integration between the SpiderDoor Software and SiteLink constitute "transmitting the unlock code to a property management system from the lock management system" in the manner contemplated by the patent, or does the defense have grounds to argue a different functional relationship?
V. Key Claim Terms for Construction
The Term: "access management system" (’513 Patent, claim 16)
- Context and Importance: The infringement theory for the '513 Patent requires mapping the accused architecture to separate "lock management" and "access management" systems. The definition of "access management system" is therefore critical to determining if the accused product meets this limitation. Practitioners may focus on this term because the complaint's evidence for a separate system performing this role is less explicit than for other elements.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide a standalone definition, which may support an argument for giving the term its plain and ordinary meaning, such as any system component that verifies user identity or credentials (ʼ513 Patent, col. 8:32-35).
- Evidence for a Narrower Interpretation: Claim 1 of the '513 Patent, from which claim 16 depends, recites transmitting the unlock code to an access management system from the lock management system, and claim 5 recites transmitting the credential between them. This language suggests they are structurally distinct entities, not just different software modules within a single platform (ʼ513 Patent, col. 18:49 - col. 19:8).
The Term: "property management system" (’650 Patent, claim 21)
- Context and Importance: The '650 Patent's core novelty is tied to the interaction between a lock system and a separate property management system. The definition will determine whether the accused SiteLink integration falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to a "third-party property management system" and lists several commercial examples, suggesting the term is meant to encompass industry-standard software for tenant and facility management (ʼ650 Patent, col. 16:55-66). A screenshot of the SiteLink main menu shows distinct property management functions such as "Move In," "Payments," and "Access" (Compl. p. 22).
- Evidence for a Narrower Interpretation: Claim 21 requires the systems be "separate and distinct" and "operate on different servers." A defendant may argue this requires a higher degree of separation than a typical API integration and that the evidence must rigorously prove operation on different physical or virtual servers (ʼ650 Patent, col. 18:18-21).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for both patents. It claims Defendant provides the SpiderDoor Software to its customers and actively encourages them to perform the patented methods through marketing materials, its website, and instructional content (Compl. ¶¶ 3, 26, 43, 62).
- Willful Infringement: Willfulness is alleged for both patents. For the ʼ513 Patent, the claim is based on Defendant's alleged actual knowledge from a pre-suit notice letter dated January 19, 2023, and subsequent refusal to cease infringement (Compl. ¶¶ 33-39). For the ʼ650 Patent, the allegation is based on alleged knowledge of the patent's existence and its relation to the asserted patent family (Compl. ¶40).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of "architectural mapping": Does the accused SpiderDoor Software, in its integration with the SiteLink platform, embody the "lock management system" and "access management system" of the '513 patent and the "lock management system" and "property management system" of the '650 patent as separate and distinct systems as required by the claims, or is it a more integrated platform that falls outside the literal scope?
- A key evidentiary question will be one of "functional proof": What evidence will be presented to demonstrate that the accused systems operate on different servers and that data—specifically user credentials and unlock codes—is transmitted between these distinct systems via an API in the precise manner claimed by each patent?
- An important question for damages will be one of "willful conduct": Given the explicit pre-suit notice for the '513 patent and the family relationship to the newly issued '650 patent, can Plaintiff establish that Defendant's conduct was sufficiently egregious to warrant enhanced damages?