DCT
1:10-cv-00064
Kwikset Corp v. Schlage Lock Co LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kwikset Corporation (Delaware) and Newfrey LLC (Delaware)
- Defendant: Schlage Lock Company LLC (Delaware)
- Plaintiff’s Counsel: Morris, Nichols, Arsht & Tunnell LLP; Niro, Haller & Niro
- Case Identification: 1:10-cv-00064, D. Del., 03/08/2011
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware limited liability company that resides and does business in the district.
- Core Dispute: Plaintiffs allege that Defendant’s "SecureKey" line of rekeyable locks infringes three patents related to the technology for user-rekeyable lock cylinders.
- Technical Context: Rekeyable pin-tumbler locks allow a user to change the operating key for a lock without professional assistance or disassembly, a significant convenience and security feature in the consumer and commercial door hardware market.
- Key Procedural History: The operative pleading is a Second Amended Complaint. The complaint also includes claims for false advertising under the Lanham Act, alleging that Defendant has made false and misleading statements regarding the security and keying capabilities of its products compared to Plaintiffs' competing products.
Case Timeline
| Date | Event |
|---|---|
| 2002-09-26 | Earliest Priority Date (’429, ’431, and ’036 Patents) |
| 2007-05-08 | U.S. Patent No. 7,213,429 Issues |
| 2008-10-14 | U.S. Patent No. 7,434,431 Issues |
| 2011-02-01 | U.S. Patent No. 7,878,036 Issues |
| 2011-03-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,213,429 - "Rekeyable Lock Assembly"
- Issued: May 8, 2007 (’429 Patent)
The Invention Explained
- Problem Addressed: The patent background describes the traditional method of rekeying a lock cylinder as a complex process requiring the user to remove the cylinder from the lockset, disassemble it to replace the pins, and possess a working knowledge of the mechanism, often necessitating a trained professional (col. 1:17-33).
- The Patented Solution: The invention provides a lock cylinder that can be rekeyed without disassembly. It features a plug assembly containing pins and an adjacent "carrier sub-assembly" that holds a series of "racks" for engaging those pins. To rekey the lock, the user inserts a tool that moves the carrier sub-assembly along the lock's longitudinal axis. This movement disengages the racks from the pins, allowing a new key to be inserted. When the carrier is moved back, the racks re-engage the pins, which are now positioned according to the new key's pattern, thus rekeying the lock (’429 Patent, Abstract; col. 1:44-59).
- Technical Importance: This design allows an end-user to rekey a lock in seconds using a simple tool and a new key, eliminating the need for a locksmith and specialized equipment.
Key Claims at a Glance
The complaint does not specify which claims of the ’429 Patent are asserted (Compl. ¶12). Independent claim 1 is representative of the core technology and its elements include:
- a cylinder body with a longitudinal axis;
- a plurality of pins disposed in the cylinder body; and
- a carrier sub-assembly disposed in the cylinder body and including a carrier and a plurality of racks for engaging the pins, the carrier sub-assembly being moveable parallel to the longitudinal axis of the cylinder body between a first position and a second position to disengage the racks from the pins.
The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,434,431 - "Keying System and Method"
- Issued: October 14, 2008 (’431 Patent)
The Invention Explained
- Problem Addressed: The patent seeks to overcome the disadvantages of both conventional lock cylinders and traditional master keying systems, which can be complicated for consumers to manage (’431 Patent, col. 1:37-40).
- The Patented Solution: This patent frames the rekeying technology as a complete system and method. It describes a lock cylinder with a "first member" (the carrier) that is coupled to the racks. A tool inserted into a dedicated aperture can move this member, which in turn simultaneously disengages all of the racks from their corresponding pins, placing the lock in a rekeyable state (’431 Patent, Abstract). The patent also claims the specific steps of the rekeying method itself (col. 2:20-68).
- Technical Importance: By claiming the system and method, the patent aims to protect not just the physical device but also the process of using the device to achieve the rekeying function.
Key Claims at a Glance
The complaint does not specify which claims of the ’431 Patent are asserted (Compl. ¶12). Independent claim 1 is representative and its elements include:
- a cylinder body with a longitudinal axis;
- a locking bar disposed in the cylinder body for movement transverse to, and rotationally about, the longitudinal axis;
- a plug assembly disposed in the cylinder body and being rotateable, the plug assembly having a lock face with a tool receiving aperture;
- a plurality of pins and a corresponding plurality of racks disposed in the plug assembly; and
- a first member coupled to the plurality of racks, the first member being moveable in response to application of a force by a tool... to simultaneously disengage all of the plurality of racks from the plurality of pins.
The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 7,878,036 - "Rekeyable Lock Cylinder"
- Issued: February 1, 2011 (’036 Patent)
Technology Synopsis
This patent addresses the problem of conventional lock rekeying by disclosing specific structural details of the rekeyable mechanism. The patented solution focuses on the precise interaction between components: "cup-shaped pins" with an "engagement protrusion" are restrained within conforming "guide channels," and these protrusions selectively engage corresponding "engagement grooves" on a plurality of movable racks to operate the lock (’036 Patent, Abstract, col. 2:1-17).
Asserted Claims and Accused Features
- Asserted Claims: The complaint does not specify which claims are asserted (Compl. ¶12).
- Accused Features: The "SecureKey" line of products with rekeyable lock cylinders is alleged to infringe the patent (Compl. ¶12).
III. The Accused Instrumentality
Product Identification
The Schlage "SecureKey" line of products with rekeyable lock cylinders (Compl. ¶12).
Functionality and Market Context
- The complaint identifies the accused products as "rekeyable door locks" and "rekeyable lock cylinders" (Compl. ¶4, ¶12). It alleges these products compete directly with Plaintiffs' "SmartKey" products, which are described as "industry-leading rekeyable locks" (Compl. ¶26).
- The complaint does not provide sufficient detail for analysis of the specific internal mechanism or technical operation of the accused SecureKey products.
IV. Analysis of Infringement Allegations
The complaint alleges infringement in general terms without providing a claim chart or mapping specific features of the accused products to the elements of the asserted claims. The following analysis is based on the representative independent claims identified in Section II and the complaint's general allegation that the SecureKey products infringe.
No probative visual evidence provided in complaint.
’429 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cylinder body with a longitudinal axis | The complaint alleges the SecureKey products are rekeyable lock cylinders, which inherently include a cylinder body. | ¶12 | col. 4:21-25 |
| a plurality of pins disposed in the cylinder body | The SecureKey products are alleged to be lock cylinders, which would be expected to contain pins as part of the locking mechanism. | ¶12 | col. 4:50-52 |
| a carrier sub-assembly...including a carrier and a plurality of racks for engaging the pins... | The complaint's allegation of infringement implies the SecureKey products contain a structure that meets the definition of the claimed carrier sub-assembly. | ¶12 | col. 4:64-68 |
| the carrier sub-assembly being moveable parallel to the longitudinal axis...between a first position and a second position to disengage the racks from the pins | The allegation of infringement implies the SecureKey products contain a mechanism that moves parallel to the lock's axis to disengage internal components, thereby enabling the rekeying function. | ¶12 | col. 5:36-44 |
’431 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cylinder body with a longitudinal axis; a locking bar disposed in the cylinder body...; a plug assembly disposed in the cylinder body... | The complaint alleges the SecureKey products are rekeyable lock cylinders, which would include these fundamental lock components. | ¶12 | col. 5:40-49 |
| the plug assembly having a lock face with a tool receiving aperture | The allegation implies the SecureKey products have a feature on the lock face for inserting a tool to initiate the rekeying process. | ¶12 | col. 6:40-42 |
| a plurality of pins and a corresponding plurality of racks disposed in the plug assembly | The allegation implies the SecureKey products contain interacting pins and racks. | ¶12 | col. 6:19-27 |
| a first member coupled to the plurality of racks, the first member being moveable...by a tool...to simultaneously disengage all of the plurality of racks from the plurality of pins | The infringement allegation implies the SecureKey products contain a member that, when acted upon by a tool, disengages all the racks from the pins at once. | ¶12 | col. 11:39-50 |
Identified Points of Contention
- Technical Questions: Because the complaint lacks technical details about the accused products, a central point of contention will be factual: does the internal mechanism of the Schlage SecureKey product actually operate as claimed? Discovery will be necessary to determine if the accused locks contain a "carrier sub-assembly" that moves "parallel to the longitudinal axis" to disengage "racks" from "pins" as required by the ’429 Patent.
- Scope Questions: The infringement analysis for the ’431 Patent will raise the question of whether the accused product’s mechanism includes a "first member" that "simultaneously disengages" all racks. The interpretation of "simultaneously" could be a key issue—whether it requires an instantaneous event or allows for a sequential disengagement as part of a single, rapid user action.
V. Key Claim Terms for Construction
"carrier sub-assembly" (’429 Patent, Claim 1)
- Context and Importance: This term describes the central moving part of the claimed rekeying mechanism. Whether the corresponding component in the Schlage product falls within the scope of this term is critical to the infringement analysis. Practitioners may focus on this term because its definition could either confine the claim to the specific embodiment shown or allow it to cover a wider range of rekeying mechanisms.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is not explicitly defined in the patent. A party could argue it should be given its plain and ordinary meaning to one of skill in the art, covering any assembly that functions to "carry" the racks.
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment, namely a "carrier 90" with a "body 100 in the form of a cylinder section" that is complementary to the plug body (’429 Patent, col. 4:1-5). A party could argue the term should be limited to structures consistent with this disclosed embodiment.
"simultaneously disengage" (’431 Patent, Claim 1)
- Context and Importance: This functional language defines how the racks must be disengaged from the pins. Proving that the accused device performs this function is essential for a finding of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract describes the first member as "configured to simultaneously disengage all of the plurality of racks." This could be interpreted to mean that a single user action causes all racks to disengage as part of one unified process, not necessarily at the exact same microsecond.
- Evidence for a Narrower Interpretation: An opposing party may argue for a strict temporal definition, requiring proof that all racks separate from all pins at the same instant. The specification of the parent ’429 Patent, which is incorporated by reference, describes the action as moving the carrier, which in turn causes the racks to disengage, without a specific discussion of strict simultaneity (’429 Patent, col. 5:40-44).
VI. Other Allegations
Indirect Infringement
The complaint alleges that Defendant has induced and contributed to infringement by others (e.g., customers and end-users) "with knowledge of the '429, '431 and '036 patents" (Compl. ¶13, ¶14). The basis for this claim includes Defendant's alleged acts of "marketing, distributing, providing, testing, configuring, promoting, [and] soliciting business for" the accused products, which may imply that user manuals or marketing materials instruct users on how to perform the allegedly infringing rekeying process (Compl. ¶13).
Willful Infringement
The complaint seeks increased damages for willful infringement (Request for Relief, ¶B). The basis for this allegation is the assertion that Defendant's infringement was committed "with knowledge" of the patents-in-suit (Compl. ¶13, ¶14).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of technical operation: once details are produced in discovery, does the internal mechanism of the Schlage SecureKey product actually employ a longitudinally-moving carrier that disengages racks from pins, as claimed in the patents, or does it achieve its rekeying function through a distinctly different, non-infringing design? The complaint's lack of technical detail makes this the primary unanswered question.
- A key legal issue will be one of claim scope: can the term "carrier sub-assembly" (’429 patent), which is central to the invention, be construed broadly enough to read on the specific structure used in the accused Schlage lock? The outcome of claim construction for this and other key terms will be pivotal in defining the boundaries of the patented technology.