DCT
2:22-cv-07888
LPI Inc v. Reboot Labs LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LPI Inc. (Tennessee)
- Defendant: REBOOT LABS LLC, D/B/A “PLUNGE” (California)
- Plaintiff’s Counsel: One LLP; Blanchard Horton PLLC
- Case Identification: 2:22-cv-00846, E.D. Cal., 08/11/2022
- Venue Allegations: Venue is alleged to be proper because Defendant resides in the district, maintains a regular and established place of business in the district, and has committed the alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s hot and cold tub products infringe a patent related to a combination spa system with an integrated water chilling assembly.
- Technical Context: The technology concerns recreational and therapeutic water tubs, specifically systems that integrate both heating and cooling functions into a single unit to provide either a hot tub or a cold plunge experience.
- Key Procedural History: Plaintiff alleges it provided Defendant with notice of the asserted patent and its infringement allegations via correspondence on February 4, 2022, approximately six months prior to filing the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2005-05-26 | '161 Patent Priority Date |
| 2010-05-11 | '161 Patent Issue Date |
| 2022-02-04 | Plaintiff's notice letter sent to Defendant |
| 2022-08-11 | Complaint Filing Date |
| 2026-01-13 | '161 Patent Expiration Date (as alleged in complaint) |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,712,161 - Combination Spa System With Water Chilling Assembly
- Patent Identification: U.S. Patent No. 7,712,161, Combination Spa System With Water Chilling Assembly, issued May 11, 2010.
The Invention Explained
- Problem Addressed: The patent's background section notes that prior art hot tubs and spas, while advanced in hydrotherapy, were not versatile enough to provide users with the benefits of both hot and chilled water in a single, integrated system ('161 Patent, col. 2:28-32). The art suffered from a lack of systems that could efficiently offer both functions.
- The Patented Solution: The invention is a spa system that combines water heating and cooling devices into a single circulating loop ('161 Patent, col. 6:1-11). As illustrated in the patent's schematic diagram (e.g., FIG. 2), water is drawn from the tub, passed in series through both a heating device (31) and a cooling device (32), and then returned to the tub. A single thermostat (45) is operatively coupled to both devices to control the water temperature, allowing a user to select either a hot or cold spa experience from the same unit ('161 Patent, col. 8:32-48).
- Technical Importance: This approach aimed to "increase the usefulness of spa systems" by creating a single, cost-effective, and easy-to-construct product that could function as either a traditional hot tub or a cold water therapy tub ('161 Patent, col. 2:48-49).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('161 Patent, col. 18:26-44).
- The essential elements of independent claim 1 are:
- A tub.
- Water heating and cooling devices operatively coupled in series to a water circulating system that conveys water from the tub, through one device, then the other, and back to the tub.
- A thermostat operatively coupled to both the heating and cooling devices to control their operation and set a desired water temperature.
- The complaint does not explicitly reserve the right to assert dependent claims, though this is common practice.
III. The Accused Instrumentality
Product Identification
- Defendant's "Hot & Cold Plunge" and "Hot & Cold Plunge Pro" products (collectively, the "Infringing Products") (Compl. ¶21).
Functionality and Market Context
- The complaint alleges that the Infringing Products are spa systems that comprise a tub, water heating and cooling devices, and a thermostat (Compl. ¶17). It further alleges that these components are arranged in a water circulating system that functions in the same manner as that recited in the asserted patent claim (Compl. ¶¶18-23). The complaint does not provide further technical details about the specific design or operation of the accused products' systems.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint's infringement allegations consist of conclusory statements that map the elements of claim 1 onto the accused products.
'161 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a tub; | The Infringing Products are alleged to be spa systems that comprise a tub. | ¶17 | col. 5:7-10 |
| water heating and cooling devices operatively coupled in series to a water circulating system adapted to withdraw and return water relative to the tub to convey water from the tub in series first to one of the water heating and cooling devices and then to the other... | The Infringing Products are alleged to have water heating and cooling devices operatively coupled in series to a water circulating system that withdraws, conveys, and returns water as claimed. | ¶¶18, 19 | col. 6:1-11 |
| the water heating device operative to heat water passing through the circulating system, and the water cooling device operative to chill water passing through the circulating system; and | The heating device in the Infringing Products is alleged to be operative to heat water, and the cooling device is alleged to be operative to chill water. | ¶¶20, 21 | col. 6:16-24 |
| a thermostat operatively coupled to both the heating and cooling devices, the thermostat operative to control the operation of both the heating and cooling devices to set a desired temperature of water passing through the circulating system. | The Infringing Products are alleged to have a thermostat that is operatively coupled to, and controls the operation of, both the heating and cooling devices to set a desired temperature. | ¶¶22, 23 | col. 8:32-44 |
- Identified Points of Contention:
- Scope Questions: The claim requires the heating and cooling devices to be "operatively coupled in series." A potential point of dispute is whether the accused products' plumbing architecture meets this limitation as it would be construed by the court, particularly since the claim allows water to flow "first to one... and then to the other," suggesting the specific order may not matter.
- Technical Questions: The complaint provides no technical detail on how the accused thermostat and control system operate. A key question will be whether the accused thermostat is "operatively coupled to both" devices and is "operative to control the operation of both" in the manner required by the claim, or if it functions differently (e.g., as a simple sensor input to a more complex, multi-component control system not described by the claim).
V. Key Claim Terms for Construction
The Term: "operatively coupled in series"
Context and Importance: This term is the architectural linchpin of the asserted claim. Its construction will determine what physical and functional relationship between the heating device, cooling device, and circulating system is required to infringe. Practitioners may focus on this term because the specific configuration of the accused product's plumbing and control logic relative to this limitation will be a central factual issue.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is broad, reciting conveyance "first to one of the water heating and cooling devices and then to the other," which may support an interpretation that the sequence (heater-then-cooler vs. cooler-then-heater) is not limiting ('161 Patent, col. 18:32-35).
- Evidence for a Narrower Interpretation: The patent's detailed description and figures consistently disclose a single embodiment where water flows first through the heating device (31) and then through the cooling device (32) ('161 Patent, FIG. 2; col. 6:6-9). A party could argue that "in series" should be limited to this disclosed sequence.
The Term: "thermostat"
Context and Importance: The definition of "thermostat" and its required function ("operative to control the operation of both") is critical to determining whether the accused products, which likely use modern digital controllers, meet this limitation. The dispute may center on whether a simple temperature sensor that sends data to a separate microprocessor controller qualifies as the claimed "thermostat."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "thermostat" is used generally in the specification. A party may argue it should be given its plain and ordinary meaning: a device that regulates temperature to a desired setpoint, regardless of its internal components.
- Evidence for a Narrower Interpretation: The patent describes thermostat (45) being used "in conjunction with" and "coupled to" a "controller 70" ('161 Patent, col. 8:41-48). A party could argue that the claimed "thermostat" refers to the entire control system, including the user interface and the separate controller box, not just a temperature sensor.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing reference to 35 U.S.C. §§ 271(a)-(c) but pleads no specific facts to support a claim for either induced or contributory infringement, such as allegations related to user manuals, marketing materials, or the sale of non-staple components (Compl. ¶8). The substantive allegations focus exclusively on direct infringement.
- Willful Infringement: The complaint alleges willful infringement based on the assertion that Defendant had knowledge of the '161 Patent and its alleged infringement "no later than February 4, 2022," the date of a notice letter from Plaintiff's counsel (Compl. ¶¶ 24, 29). The claim is therefore based on alleged post-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and scope: Can the term "operatively coupled in series," as described in a patent with one disclosed plumbing sequence, be construed to cover any system where water flows sequentially through heating and cooling units, regardless of their order or the specifics of their integration?
- A second central question will be one of evidentiary proof and technical function: Does the accused products' control system, likely a modern digital unit, meet the "thermostat operative to control" limitation? The case may turn on whether the accused system's functionality matches the specific control function required by the claim, as opposed to merely achieving a similar result through a different technical operation.