Christopher Robert Stanton v. Consumer 20 Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Christopher Robert Stanton (Colorado)
  • Defendant: Consumer 2.0, Inc. (California)
  • Plaintiff’s Counsel: Plaintiff In Pro Se
• Case Identification: 2:25-cv-07726, C.D. Cal., 08/18/2025
• Venue Allegations: Venue is alleged to be proper in the Central District of California because the Defendant is headquartered, maintains its principal place of business, and derives substantial revenue from sales within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products and software for providing self-guided tours of rental properties infringe a patent related to methods for providing secure, temporary access to geographic locations.
• Technical Context: The technology relates to automated, secure access control systems, particularly for real estate applications, which allow prospective tenants or buyers to tour properties without a human agent present.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,680,811 - “Security Key for Geographic Locations”

The patent (“the ’811 Patent”) issued on June 9, 2020.

The Invention Explained

• Problem Addressed: The patent describes a need for property owners to grant temporary, secure access to entrants (e.g., prospective renters, inspectors) without having to be physically present, while still ensuring the entrant is trustworthy and access is limited ʼ811 Patent, col. 1:8-30 The system aims to balance convenience with security.
• The Patented Solution: The invention is a computer-implemented method that automates this process. It receives information about a property, including "security thresholds" set by the owner (e.g., minimum credit score, no criminal record) ʼ811 Patent, col. 5:1-7 It then receives information from a potential entrant and compares it against these thresholds ʼ811 Patent, col. 6:46-53 If the entrant qualifies, the system sends them a notice with an approved access time and date ʼ811 Patent, col. 26:19-24 Access is only granted when the system confirms three conditions simultaneously: the entrant's device is physically "proximate" to the location, the current time matches the approved access window, and the entrant is authorized ʼ811 Patent, col. 26:25-32 Upon verification, the system sends a "security key" to the entrant's device or actuates a locking mechanism ʼ811 Patent, col. 26:33-34
• Technical Importance: This technology automates the vetting and access-granting process for unattended property showings, a significant operational challenge in the real estate and property management industries ʼ811 Patent, col. 1:8-15

Key Claims at a Glance

• The complaint asserts infringement of both claims of the patent, with Claim 1 being the sole independent claim Compl. ¶2 Compl. ¶7
• The essential elements of independent Claim 1 are:
  • receiving geographic location information, including a plurality of security thresholds;
  • receiving entrant information;
  • comparing the entrant information to the security thresholds;
  • determining, based on the comparison, that an entrant may access the location;
  • sending a notice to the entrant with at least one approved time and date for access;
  • receiving a location of an entrant device;
  • determining that the device location is proximate to the geographic location;
  • determining that the current time and date matches an approved time and date while the device is proximate;
  • performing at least one of: sending a security key to the entrant device or actuating a locking mechanism.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant’s products, software, services, and electronic locks offered through its website at www.rently.com Compl. ¶9 Compl. ¶11

Functionality and Market Context

The complaint alleges that the accused products provide a "computer-implemented method of providing self-guided tours for renters" Compl. ¶9 The functionality centers on enabling potential renters to tour properties without a leasing agent present, which involves scheduling, identity verification, and remote access control via smart locks Compl. ¶1 Compl. ¶11 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or sufficient technical detail to map specific features of the accused Rently system to the elements of the asserted patent claim. The complaint makes a general allegation that the Defendant's system for self-guided tours practices the patented method Compl. ¶9 Compl. ¶11

Identified Points of Contention

• Scope Questions: A central question may be whether the verification steps performed by the accused Rently system constitute a comparison against a plurality of "security thresholds" as contemplated by the patent. The patent provides examples such as credit scores, loan approval amounts, and criminal records ʼ811 Patent, col. 8:12-16 ʼ811 Patent, col. 10:34-39 The analysis will depend on what specific checks the Rently system performs and whether they fall within the construed scope of this term.
• Technical Questions: The infringement analysis will raise the question of whether the accused system performs the specific temporal and spatial checks required by the claim. Specifically, what evidence does the complaint provide that the accused system determines that the current time and date matches an approved access window while simultaneously determining the user's device is "proximate" to the property before sending a key or actuating a lock.

V. Key Claim Terms for Construction

Term for Construction: "security thresholds"

• Context and Importance: This term is foundational to the vetting process at the core of the invention. Its construction will determine what types of automated checks on an entrant are covered by the claim. A broad construction could cover basic identity or payment verification, while a narrower one might require more substantive financial or background checks.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is general, referring to "a plurality of security thresholds" without limitation ʼ811 Patent, col. 26:11-12 The specification also lists a wide variety of possible checks, including personal referrals and scheduling availability ʼ811 Patent, col. 8:12-16
  • Evidence for a Narrower Interpretation: The detailed examples provided in the specification repeatedly focus on substantive financial and background criteria, such as "minimum credit score," "loan approval," and absence of a "felony record" ʼ811 Patent, col. 5:4-6 A defendant may argue these examples limit the term to more rigorous checks beyond simple identity verification.

Term for Construction: "proximate to the geographic location"

• Context and Importance: This term defines the geographic trigger for granting final access. The dispute will likely center on how close an entrant must be for their device to be considered "proximate."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not explicitly defined with a specific distance. The specification mentions that proximity can be determined by various means, including "wireless communications, near field technology, cellular technology, and the like" ʼ811 Patent, col. 10:29-31, suggesting flexibility.
  • Evidence for a Narrower Interpretation: The specification provides specific examples, such as determining an entrant device "must be within 5 feet from the geographic location in order to provide a copy of the security key" ʼ811 Patent, col. 12:44-47 A defendant could argue this specific embodiment suggests a very close-range requirement, such as that enabled by NFC or RFID, as mentioned in dependent claim 2 ʼ811 Patent, col. 26:35-42

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that the Defendant encourages and instructs customers like property owners and managers to use its products in an infringing manner Compl. ¶12 Knowledge is alleged to exist "since at least the filing of this Complaint" Compl. ¶12

Willful Infringement

The complaint seeks enhanced damages, alleging willfulness based on Defendant's alleged actual knowledge of the ’811 Patent and the alleged infringement from the date the complaint was filed Compl. ¶12 Compl., Prayer 4 No facts are alleged to support pre-suit knowledge.

VII. Analyst’s Conclusion: Key Questions for the Case

1. Evidentiary Sufficiency: A primary challenge for the plaintiff will be to demonstrate, through discovery and technical evidence, that the accused Rently system performs every step of the claimed method. A key factual question will be what specific "security thresholds" the Rently system uses for vetting renters and whether its access-granting logic performs the simultaneous time-and-proximity check required by the claim.
2. Claim Scope and Construction: The case will likely turn on the court's interpretation of key claim terms. A central legal issue will be one of definitional scope: how broadly will the term "security thresholds" be construed? Will it cover standard identity and credit card verification common in online services, or will it be limited to the more substantive background and financial checks detailed in the patent’s embodiments? The resolution of this and other claim construction disputes will likely determine the outcome of the infringement analysis.