DCT
8:18-cv-00014
SkyBell Tech Inc v. Ring Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SkyBell Technologies, Inc. (Nevada)
- Defendant: Ring Inc. (Delaware)
- Plaintiff’s Counsel: Susman Godfrey L.L.P.
- Case Identification: 8:18-cv-00014, C.D. Cal., 03/06/2018
- Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant Ring Inc. has its principal place of business in Santa Monica, California, which is within the district.
- Core Dispute: Plaintiff alleges that Defendant’s video doorbells, mobile application, and related accessories infringe five U.S. patents related to visitor detection systems, remote on-demand camera activation, and wireless chime configuration.
- Technical Context: This dispute concerns technology in the smart home and Internet of Things (IoT) sector, specifically video doorbells that allow users to remotely monitor, see, and communicate with visitors via a computing device.
- Key Procedural History: The complaint alleges that Defendant had pre-suit notice of the patents-in-suit based on a May 2016 email from Plaintiff’s CEO to Defendant’s founder, a subsequent meeting between the parties in summer 2016, and Defendant’s own patent prosecution, which cited several of the patents-in-suit as prior art.
Case Timeline
| Date | Event |
|---|---|
| 2011-01-01 | Ring founded (as DoorBot) |
| 2013-01-01 | SkyBell founded (as iDoorCam) |
| 2013-09-01 | SkyBell successfully prototyped its video doorbell |
| 2014-01-01 | SkyBell introduced its first video doorbell product |
| 2014-10-31 | U.S. Patent No. 9,055,202 Priority Date |
| 2015-05-14 | U.S. Patent No. 9,160,987 Priority Date |
| 2015-05-28 | U.S. Patent No. 9,179,107 Priority Date |
| 2015-05-30 | U.S. Patent No. 9,179,109 Priority Date |
| 2015-06-09 | U.S. Patent No. 9,055,202 Issued |
| 2015-10-13 | U.S. Patent No. 9,160,987 Issued |
| 2015-11-03 | U.S. Patent No. 9,179,109 Issued |
| 2015-11-03 | U.S. Patent No. 9,179,107 Issued |
| 2016-05-16 | U.S. Patent No. 9,743,049 Priority Date |
| 2016-05-30 | Plaintiff allegedly provided notice of patent portfolio to Defendant |
| 2017-08-22 | U.S. Patent No. 9,743,049 Issued |
| 2018-03-06 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,055,202 - "Doorbell Communication Systems and Methods" (Issued June 9, 2015)
The Invention Explained
- Problem Addressed: The patent's background section notes that doorbells can be unreliable, either falsely detecting the presence of a visitor (e.g., from moving cars or plants) or failing to detect an actual visitor, which reduces their accuracy. (’202 Patent, col. 2:12-16).
- The Patented Solution: The invention proposes a visitor detection system with at least two sensors (e.g., motion or infrared) that are physically separated by a "wall." (’202 Patent, Abstract). This wall divides the system's field of view into distinct portions, with each sensor monitoring a separate portion. (’202 Patent, Fig. 16). By distinguishing between indications in different zones, the system can more accurately determine if a detected object is a visitor, for example, by ignoring motion in a zone known to have passing street traffic. (’202 Patent, col. 3:5-11).
- Technical Importance: This approach allows for more sophisticated motion detection logic in a compact doorbell unit, aiming to reduce false positive alerts that were a common issue with early smart home security devices. (Compl. ¶18).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 18, and dependent claims 4, 5, 7, 8, and 19. (Compl. ¶¶44-45). The complaint explicitly reserves the right to assert additional claims.
- Essential Elements of Independent Claim 1:
- A button configurable to enable a visitor to sound a chime.
- A visitor detection system comprising a first sensor and a second sensor.
- An outer housing coupled to the visitor detection system.
- A wall that separates the first sensor from the second sensor, which divides the field of view such that the first sensor detects indications in a first portion and the second sensor detects indications in a second portion.
- Note on Subsequent Proceedings: The provided patent includes an Inter Partes Review Certificate, issued July 21, 2021, stating that claims 1, 3-5, 7, 8, 10, 18-21 and 23-25 of the ’202 Patent have been cancelled. (U.S. Patent 9,055,202 K1, p. 2).
U.S. Patent No. 9,179,109 - "Doorbell Communication Systems and Methods" (Issued November 3, 2015)
The Invention Explained
- Problem Addressed: The patent identifies the need for a doorbell to alert a remotely located individual, as traditional chimes are only audible locally. (’109 Patent, col. 1:53-61). Furthermore, such smart devices must manage power consumption, as constant video streaming is inefficient.
- The Patented Solution: The invention describes a method where a doorbell can operate in a low-power "camera sleep mode" where it does not record video. (’109 Patent, Abstract). A user, via a "doorbell control application" on a remote device (e.g., a smartphone), can send a wireless signal that overrides the doorbell's power setting, forcing it to exit sleep mode and enter a "camera recording mode" to stream on-demand video to the user. (’109 Patent, col. 2:48-61).
- Technical Importance: This on-demand activation allows for both power conservation during idle periods and the ability for a user to proactively monitor their entryway without waiting for a visitor-initiated event like a button press. (Compl. ¶21).
Key Claims at a Glance
- The complaint asserts independent claims 1, 15, and 20, and dependent claim 7. (Compl. ¶¶54-55).
- Essential Elements of Independent Claim 1 (Method Claim):
- Entering, by the doorbell, a camera sleep mode where the camera does not record.
- Opening a doorbell control application on a remote computing device.
- Overriding a power setting of the doorbell via a wireless communication from the remote device.
- Forcing the doorbell to exit the camera sleep mode and enter a camera recording mode.
- Receiving a first video from the doorbell at the remote device.
- Note on Subsequent Proceedings: The provided patent includes an Inter Partes Review Certificate, issued July 23, 2021, stating that claims 1, 7, 15, and 20 of the ’109 Patent have been cancelled. (U.S. Patent 9,179,109 K1, p. 2).
U.S. Patent No. 9,179,107 - "Doorbell Chime Systems and Methods" (Issued November 3, 2015)
- Technology Synopsis: The patent is directed to methods for configuring the sound of a remote doorbell chime. A user can select a sound on a remote device, such as a phone or tablet, and then send a data file representing that sound to the chime accessory. (Compl. ¶24).
- Asserted Claims: Claims 12 and 18. (Compl. ¶64). Note: The IPR certificate for the '107 Patent indicates claim 12 has been cancelled. (U.S. Patent 9,179,107 K1, p. 2).
- Accused Features: The accused functionality is the Ring App's feature that allows users to select a chime sound and upload that sound file to a remotely located Ring Chime accessory. (Compl. ¶63).
U.S. Patent No. 9,743,049 - "Doorbell Communication Systems and Methods" (Issued August 22, 2017)
- Technology Synopsis: The patent describes a doorbell system where a mobile application on a remote device can cause the doorbell's camera to exit a sleep mode and enter a "live view mode" for on-demand video access. (Compl. ¶27).
- Asserted Claims: Claims 1-4, 7-9, 11-15, 18, and 19. (Compl. ¶74). Note: The IPR certificate for the '049 Patent indicates claims 1-4, 7-15, and 18-21 have been cancelled. (U.S. Patent 9,743,049 K1, p. 2).
- Accused Features: The accused instrumentality is the Ring App's "Live View" feature, which allegedly provides on-demand access that enables a user to override or exit the doorbell's sleep mode setting. (Compl. ¶73).
U.S. Patent No. 9,160,987 - "Doorbell chime systems and methods" (Issued October 13, 2015)
- Technology Synopsis: The patent is directed to a system that communicatively couples a doorbell and a separate chime via a wireless network to a remote computing device. The system provides notifications of visitors to the user on the remote device. (Compl. ¶30).
- Asserted Claims: Claim 1. (Compl. ¶85). Note: The IPR certificate for the '987 Patent indicates claims 1-4 and 10-13 have been cancelled. (U.S. Patent 9,160,987 K1, p. 2).
- Accused Features: The accused system is the combination of the Ring Video Doorbell Pro, the Ring Chime Pro, and the Ring App, which are alleged to communicatively couple via Wi-Fi to provide visitor alerts on a smartphone, tablet, or PC. (Compl. ¶83).
III. The Accused Instrumentality
Product Identification
- The complaint accuses Defendant’s "Ring Hardware" and "Ring App." (Compl. ¶33). The Ring Hardware is identified as including the Ring Video Doorbell, Ring Video Doorbell 2, Ring Video Doorbell Pro, and Ring Video Doorbell Elite, as well as the accessory Ring Chime and Ring Chime Pro. (Compl. ¶¶34-35). The complaint provides an image showing four different Ring doorbell models. (Compl. ¶34, p. 8).
Functionality and Market Context
- The complaint alleges that the accused products provide video doorbell functionality, allowing users to receive alerts and view live video from their doorsteps. (Compl. ¶¶83-84). Specific accused features include a visitor detection system with multiple infrared motion sensors that can be configured into different zones, a "Live View" feature for on-demand camera access, and the ability to select and upload custom sounds to an accessory chime. (Compl. ¶¶43, 53, 63). The complaint alleges that Ring has focused on advertising and marketing rather than innovation, and has copied its technology from SkyBell. (Compl. ¶¶2, 17).
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,055,202 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a button configurable to enable a visitor to sound a chime | The accused Ring Hardware includes a doorbell button. | ¶34 | col. 14:30-31 |
| a visitor detection system ... comprising a first sensor ... and a second sensor | The Ring Doorbell allegedly has a visitor detection system with three infrared motion sensors. | ¶43 | col. 13:15-21 |
| an outer housing coupled to the visitor detection system | The Ring Hardware products have an outer housing that contains the sensor components. | ¶34 | col. 15:11-13 |
| a wall that separates the first sensor from the second sensor, wherein the wall divides the field of view... | The Ring Doorbell allegedly contains a physical wall that separates the sensors to divide the field of view, as shown in teardown photographs. The complaint includes a photograph purporting to show the internal sensor array and separating wall structure. (Compl. p. 11). | ¶43 | col. 33:5-22 |
- Identified Points of Contention:
- Scope Questions: A central question will concern the term "a wall that separates." The infringement theory depends on whether the internal physical structures within the accused Ring products, as shown in the complaint's teardown photograph (Compl. p. 11), meet the structural and functional requirements of the claimed "wall." The patent's specification and figures, particularly Figure 16, which depicts a distinct and solid wall, may inform the construction of this term.
U.S. Patent No. 9,179,109 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| entering, by the doorbell, a camera sleep mode wherein the camera is configured to not record | It is alleged that the Ring doorbell operates in a power-saving or sleep mode when not actively being viewed. | ¶53 | col. 2:48-61 |
| opening a doorbell control application on the remote computing device | A user opens the "Ring App" on their smartphone or other device. | ¶33 | col. 18:20-24 |
| overriding... a power setting of the doorbell to force the doorbell to exit the camera sleep mode and enter a camera recording mode | The complaint alleges that activating the "Live View" feature in the Ring App provides on-demand access that overrides the doorbell's power setting. | ¶53 | col. 2:48-61 |
| receiving a first video, by the remote computing device, from the doorbell at least partially in response to remotely overriding the power setting | The user's device receives a live video stream from the Ring doorbell after activating the "Live View" feature. The complaint provides a screenshot of Ring's instructions for using this feature. (Compl. p. 17). | ¶53 | col. 2:58-61 |
- Identified Points of Contention:
- Technical Questions: What evidence does the complaint provide that the accused products actually implement distinct "camera sleep mode" and "camera recording mode" states as required by the claim? The infringement analysis may turn on whether activating "Live View" causes a transition between two technically distinct operational modes as described in the patent, or if it simply activates a single-state streaming function from a standby state.
V. Key Claim Terms for Construction
From the ’202 Patent:
- The Term: "a wall that separates the first sensor from the second sensor"
- Context and Importance: This structural limitation is the core of Claim 1's novelty. Infringement will depend heavily on whether the internal componentry of the accused Ring doorbells can be characterized as a "wall" that performs the claimed function of dividing the field of view. Practitioners may focus on this term because the allegation relies on reverse-engineering and interpretation of internal product architecture.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the wall can be, for example, a "plastic blade" and that the division can be accomplished with software rather than a physical wall, suggesting the term may not be limited to a solid, impenetrable barrier. (’202 Patent, col. 6:40-47).
- Evidence for a Narrower Interpretation: Figure 16 of the patent depicts a distinct, solid, and centrally located physical wall (1060) that cleanly bisects the field of view. The abstract similarly describes "A wall can separate the first sensor from the second sensor," which may suggest a physical, structural element is required. (’202 Patent, Abstract).
From the ’109 Patent:
- The Term: "exiting a camera sleep mode and enter a camera recording mode"
- Context and Importance: This two-part functional limitation is critical to the infringement allegation against Ring's "Live View" feature. The dispute may center on whether the accused products perform two distinct and sequential actions—exiting one mode and entering another—or if they perform a single action of "waking up" to stream video.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the system transitioning from a state where the camera is "configured to not record" to one where it is, which could be broadly interpreted as any transition from a non-recording to a recording state. (’109 Patent, col. 2:50-55).
- Evidence for a Narrower Interpretation: The claim language requires two distinct steps: "exiting" one mode and "enter[ing]" another. This phrasing may suggest that a system must have two separately defined operational states, "sleep" and "recording," and that a simple "on/off" or "standby/active" functionality might not meet the limitation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all five patents-in-suit. The allegations state that Ring actively induces its customers and end users to infringe by providing the Ring Hardware and Ring App along with "instructions and technical assistance relating to the installation, download, set up, use, operation, and maintenance" of the products, which allegedly encourages use in an infringing manner. (Compl. ¶¶45, 55, 65, 75, 86).
- Willful Infringement: The complaint alleges willful infringement based on alleged pre-suit knowledge of the patents. The basis for this allegation is threefold: (1) a May 30, 2016 email from SkyBell's CEO to Ring's founder which included a link to SkyBell's patent portfolio; (2) a meeting in the summer of 2016 between executives of both companies to discuss patent rights; and (3) Ring's own U.S. Patent No. 9,819,713, which cites the '202, '109, '107, and '987 patents as prior art. (Compl. ¶¶37-39).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural interpretation: Does the internal physical layout of the accused Ring doorbells constitute "a wall that separates" sensors in the specific manner claimed by the '202 Patent, or is there a fundamental mismatch between the patent's depiction of a distinct dividing structure and the accused product's integrated design?
- A key evidentiary question will be one of operational equivalence: Does activating the accused "Live View" feature cause the Ring doorbell to execute the discrete, sequential software steps of "exiting a camera sleep mode" and "enter[ing] a camera recording mode" as required by the '109 and '049 patents, or does it perform a single, undifferentiated transition from a standby to an active state?
- A central question for the viability of the lawsuit itself will be the validity of the asserted claims: Given that the provided patent documents include certificates indicating that every asserted independent claim across all five patents-in-suit was subsequently cancelled in Inter Partes Review proceedings, a threshold issue will be whether any asserted claims remain enforceable to support an infringement action.