DCT
1:25-cv-02572
Guangzhou Lightsource Electronics Ltd v. Pine Locks
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Lightsource Electronics Ltd; Guangzhou Zhuyun Trading Co., Ltd.; and Changting County Huimei Technology Co., Ltd. (China)
- Defendant: Pine Locks (Isle of Man)
- Plaintiff’s Counsel: Rimon, P.C.
- Case Identification: 1:24-cv-00543, D. Del., 09/03/2024
- Venue Allegations: Plaintiffs allege venue is proper in the District of Delaware because Defendant submitted infringement complaints to Amazon.com that targeted Plaintiffs’ products sold to customers in the district. Plaintiffs also allege on information and belief that Defendant has entered into license agreements designating Delaware as the forum for resolving disputes.
- Core Dispute: Plaintiffs seek a declaratory judgment that their smart lock products do not infringe Defendant’s patent related to electronically operable locks, and that the patent is invalid over prior art.
- Technical Context: The technology at issue involves "smart locks" that can be electronically locked and unlocked using commands from a separate mobile device, such as a smartphone.
- Key Procedural History: The complaint states this action was precipitated by infringement notifications sent from Defendant to Amazon.com, which threatened the removal of Plaintiffs’ products from the e-commerce platform. The complaint also alleges that Defendant was previously put on notice of invalidating prior art in separate litigation involving the same patent.
Case Timeline
| Date | Event |
|---|---|
| 2011-08-05 | Publicly available video of "Lockitron" prior art smart lock captured |
| 2012-11-08 | "Lockitron" prior art U.S. patent application published |
| 2013-05-03 | ’239 Patent Priority Date |
| 2019-08-13 | ’239 Patent Issue Date |
| 2023-03-28 | Complaint filed in Smonet Technology Co Ltd v. Pine Locks, allegedly putting Defendant on notice of prior art |
| 2024-04-16 | Plaintiffs receive Amazon infringement complaints from Defendant |
| 2024-09-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,378,239 - "SMART LOCK"
- Patent Identification: U.S. Patent No. 10378239, "SMART LOCK", issued August 13, 2019.
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience of carrying numerous physical keys and the difficulty of creating miniature, key-operated locks for shrinking modern electronic devices like laptops and tablets (Compl. ¶1; ’239 Patent, col. 1:16-33).
- The Patented Solution: The invention is a locking system that can be operated electronically by a separate mobile device, such as a smartphone or tablet (’239 Patent, Abstract). The mobile device sends electrical commands, either through a wired (e.g., USB) or wireless connection, to a controller within the lock body, which in turn actuates a mechanism to move a locking element between locked and unlocked positions (’239 Patent, col. 1:47-61). One embodiment describes a user-operable "slider" for manual mechanical locking (’239 Patent, Fig. 5b).
- Technical Importance: The technology aims to provide a unified, keyless method for securing various items, from residential doors to personal electronics, using a single, commonly-carried mobile device (’239 Patent, col. 1:34-39).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1, 2, and 5 (Compl. ¶24).
- Independent Claim 1 recites, among other elements, a locking system including:
- A lock body with a locking element and a moving mechanism
- An electrical controller
- A separate mobile electronic device for providing electrical commands
- "a user operable slider which is configured to be moved to mechanically operate the locking system to move the locking element into the locked position"
- Independent Claim 2 recites a similar system wherein the moving mechanism comprises:
- "a thumb slider, which is mechanically positioned to push an actuator"
- The actuator is coupled to a lock head
- A latch configured to assume a latched position
- Independent Claim 5 recites a locking system for a device or structure, including:
- A lock body with a locking element and moving mechanism
- A separate mobile cell phone device to provide electrical commands
- "a short term electrical power storage device" configured to "store said electrical power temporarily for a duration sufficient to operate the moving mechanism"
- The storage device is "without any connection to an external DC and/or AC power source"
- The storage device is configured to receive power to operate the lock "solely from said mobile cell phone device"
III. The Accused Instrumentality
Product Identification
- The "Accused Smart Locks" are the Yamiry brand smart lock (ASIN B0CGLQ4N2Y) and the Kucacci brand smart lock (ASIN B0CGRRHXT6) (Compl. ¶¶8-9, 19).
Functionality and Market Context
- The complaint describes the Accused Smart Locks as products sold primarily through Amazon.com (Compl. ¶¶8-9). For manual operation, the products are alleged to use a "knob rotation method" rather than a linear slider (Compl. ¶27). The complaint includes a photo of the interior assembly of an accused lock, showing a large rotatable knob used to manually extend or retract the deadbolt (Compl. p. 7). The products are powered by four AA batteries housed in an internal compartment, which the complaint alleges constitutes a long-term, conventional power source (Compl. ¶30). A photo from the complaint shows this battery compartment (Compl. p. 9).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiffs' primary arguments for why the Accused Smart Locks do not meet certain limitations of the asserted claims.
’239 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a user operable slider which is configured to be moved to mechanically operate the locking system... | The Accused Smart Locks use a rotatable knob for manual operation, which Plaintiffs contend is not a "slider." | ¶27 | col. 7:31-34 |
’239 Patent Infringement Allegations
| Claim Element (from Independent Claim 5) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a short term electrical power storage device... configured to store said electrical power temporarily... | The Accused Smart Locks are powered by four AA batteries, which Plaintiffs contend are a conventional, long-term power source, not a "short term" or "temporary" one. | ¶30 | col. 8:16-19 |
| and said storage device being configured to receive said electrical power... solely from said mobile cell phone device. | The AA batteries in the Accused Smart Locks are a self-contained power source and do not receive power from a mobile phone. | ¶30 | col. 8:21-24 |
- Identified Points of Contention:
- Scope Questions: The complaint raises the question of whether the claim term "slider" can be construed to read on the "rotatable knob" used in the accused products (Compl. ¶27). Plaintiffs' position is that these are mechanically distinct structures.
- Technical Questions: The complaint puts forth the question of whether a power source consisting of four standard AA batteries meets the claim limitations of a "short term electrical power storage device" that stores power "temporarily" and receives it "solely" from a mobile phone (Compl. ¶¶28, 30). Plaintiffs argue that the operation of the accused product's battery system is fundamentally different from the system described and claimed in the patent. The complaint includes a screenshot from the Lockitron prior art video to suggest that smart locks with rotatable knobs operated by phones existed prior to the patent's priority date (Compl. p. 12).
V. Key Claim Terms for Construction
The Term: "user operable slider" (Claim 1) / "thumb slider" (Claim 2)
Context and Importance: The distinction between a "slider" and the "rotatable knob" of the accused products is a central pillar of Plaintiffs' non-infringement argument for claims 1 and 2 (Compl. ¶27). Practitioners may focus on this term because its construction could be dispositive of infringement for these claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant might argue that "slider" should be given its plain and ordinary meaning as a general user-manipulable input, which could arguably include a rotational input.
- Evidence for a Narrower Interpretation: The patent specification describes and depicts the "thumb slider 530" as a component that moves linearly. The description states a user applies "thumb pressure on the thumb slider 530 in the direction of the arrow 580," which illustrates linear, not rotational, movement (’239 Patent, col. 5:3-6; Fig. 5b). This specific embodiment may be used to argue for a narrower construction limited to linearly-actuated mechanisms.
The Term: "short term electrical power storage device"
Context and Importance: This term is critical for Plaintiffs' non-infringement argument regarding claim 5, as the accused products use standard AA batteries (Compl. ¶30). The viability of the infringement allegation depends on whether conventional batteries fall within the scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant could argue that any battery stores power "temporarily" relative to an infinite timeline and is therefore a "short term" device in a literal sense.
- Evidence for a Narrower Interpretation: The specification provides specific examples, stating the storage device "may be a battery or a capacitor that can hold power for an extended period, or even for a short period on the order of a minute or two" (’239 Patent, col. 3:23-27). It also describes a configuration where an "internal battery or a short term storage capacitor" is charged by an external source to "temporarily power the lock body" (’239 Patent, col. 3:9-14). This language, combined with the claim 5 requirement that power is received "solely from said mobile cell phone device," suggests a device that is not self-powered for long durations, unlike standard AA batteries.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiffs have not infringed "directly or indirectly" any claim of the '239 patent, but as a DJ complaint, it does not set forth a specific factual basis for any indirect infringement theory that might be asserted by the Defendant (Compl. ¶33).
- Willful Infringement: Not applicable, as this is a declaratory judgment action filed by the accused infringers. However, Plaintiffs allege that this is an "exceptional case" under 35 U.S.C. § 285, which would entitle them to attorneys' fees, based on the contention that Defendant's infringement accusations are "unreasonable and frivolous" in light of the accused products' design and the existence of known prior art (Compl. ¶¶34, 49, 50).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on three fundamental questions for the court:
- A core issue will be one of definitional scope: Can the term "slider," which the patent specification depicts as a linearly moving component, be construed broadly enough to encompass the "rotatable knob" used for manual operation in the accused smart locks?
- A second key issue is one of technical mismatch: Does a conventional power system using four AA batteries meet the specific claim limitations of a "short term electrical power storage device" that stores power "temporarily" and receives that power "solely from [a] mobile cell phone device"?
- A third critical question relates to patent validity: Does the "Lockitron" prior art, which the complaint alleges discloses a smartphone-controlled lock with a rotatable knob from as early as 2011, anticipate or render obvious the asserted claims of the ’239 patent?