DCT
1:19-cv-00991
Smart Locking Tech LLC v. August Home Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Smart Locking Technologies LLC (Delaware)
- Defendant: August Home, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 1:19-cv-00991, D. Del., 05/29/2019
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant conducts substantial business in the district, including committing a portion of the alleged infringements.
- Core Dispute: Plaintiff alleges that Defendant’s smart lock products, which allow for temporary and recurring guest access, infringe two patents related to generating and using non-permanent or one-time access codes for locking mechanisms.
- Technical Context: The technology concerns electronic smart locks that replace physical keys with digital access codes, particularly codes with limited validity, which are foundational for the modern sharing economy and unattended delivery services.
- Key Procedural History: U.S. Patent No. 6,696,918 is a continuation-in-part of the application that issued as U.S. Patent No. 6,300,873, indicating a direct technological lineage between the two patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1999-09-16 | Priority Date for ’873 and ’918 Patents |
| 2001-10-09 | Issue Date for U.S. Patent No. 6,300,873 |
| 2004-02-24 | Issue Date for U.S. Patent No. 6,696,918 |
| 2019-05-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,696,918 - "Locking Mechanism for Use with Non-Permanent Access Code," Issued Feb. 24, 2004
The Invention Explained
- Problem Addressed: The patent describes the security risks and management burdens associated with static, reusable "vendor codes" for secure storage boxes used for unattended deliveries. Once a reusable code is compromised, the box is insecure until the owner manually reprograms it, and vendors must track multiple codes for different customers. (’918 Patent, col. 1:47-64).
- The Patented Solution: The invention proposes a locking system managed by a third-party service that issues "non-permanent" access codes to vendors or other users upon request. This centralizes key management, frees the device owner from the task, and enhances security by ensuring codes are not indefinitely valid. The system is also capable of communicating access events back to the server or owner. (’918 Patent, Abstract; col. 2:8-21).
- Technical Importance: This approach provided a framework for scalable and secure temporary access to physical locations, a key enabler for the growth of e-commerce delivery and service-based economies where access needs to be granted to third parties dynamically. (’918 Patent, col. 2:8-15).
Key Claims at a Glance
- The complaint asserts at least independent claim 32. (Compl. ¶11).
- Independent Claim 32 is a locking mechanism comprising:
- An actuator configured to unlock in response to entry of an authorized access code.
- An access code entry unit configured to accept a non-permanent use access code issued by a remote server.
- A locking mechanism controller programmed to transmit a message to a server and/or user indicating a non-permanent use access code has been accepted.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 6,300,873 - "Locking Mechanism for Use with One-Time Access Code," Issued Oct. 9, 2001
The Invention Explained
- Problem Addressed: Similar to its continuation-in-part, the patent identifies the security flaw in using static, reusable vendor codes for secure storage devices, noting that an unauthorized person who learns a code has access until it is manually changed. (’873 Patent, col. 2:3-8).
- The Patented Solution: The invention describes a system where a remote server issues a "one-time use access code" for a locking mechanism upon request. These codes, which may be generated by a "cryptographically strong random number generator," expire after use, thus preventing the security risks of compromised static codes. The system is designed to facilitate secure, unattended deliveries. (’873 Patent, Abstract; col. 2:21-34).
- Technical Importance: The patent describes a foundational method for linking a physical lock to a centralized digital key-issuing service, replacing the concept of a permanent key with a disposable, single-use credential for enhanced security. (’873 Patent, col. 2:8-18).
Key Claims at a Glance
- The complaint asserts at least independent claim 36. (Compl. ¶21).
- Independent Claim 36 is a locking mechanism comprising:
- An actuator configured to unlock in response to entry of an authorized access code.
- An access code entry unit configured to accept a one-time use access-code issued by a remote server, wherein the one-time use access code comprises a number generated by a cryptographically strong random number generator.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- August Home, Inc.’s "Smart Lock Pro + Connect" and "Smart Lock Pro + Connect with Smart Keypad" systems, collectively referred to as "Smart Lock Pro". (Compl. ¶11).
Functionality and Market Context
- The Smart Lock Pro is an electronic locking mechanism that can be controlled remotely via a mobile application. (Compl. ¶14). A technical teardown cited in the complaint shows the lock contains a microcontroller (STM32), a Bluetooth Low Energy System-on-Chip (CC2541), and a motor driver to operate the deadbolt. (Compl. ¶15). The teardown diagram illustrates the lock's internal components, including the actuator and control electronics. (Compl. ¶15, p. 4).
- The system allows owners to grant access to guests by issuing "secure codes." (Compl. ¶14). These codes can be configured as "Always, Recurring, [or] Temporary," with temporary access expiring on a specific date and time. (Compl. ¶16, p. 11). Screenshots from the August support website show the user interface for creating these temporary codes. (Compl. ¶16, p. 12).
- The system also features an "activity log" that tracks when the door is locked and unlocked and by whom, and can send notifications to the owner's phone when the lock is operated. (Compl. ¶17, ¶18). A screenshot shows the activity log listing events by user and time. (Compl. ¶17, p. 17).
IV. Analysis of Infringement Allegations
’918 Patent Infringement Allegations
| Claim Element (from Independent Claim 32) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An actuator configured to unlock in response to entry of an authorized access code | The Smart Lock Pro includes an actuator, motor, and gears that physically rotate the deadbolt to unlock the door upon receiving an authorized code. | ¶15 | col. 17:56-58 |
| an access code entry unit configured to accept a non-permanent use access code issued by a remote server | The Smart Lock Pro, via its keypad and associated mobile app, is configured to accept "non-permanent" access codes, which the complaint supports with evidence of "Temporary" and "Recurring" access types that can be created for guests. These codes are issued via the August app, which communicates with a remote server. | ¶16 | col. 17:59-61 |
| a locking mechanism controller programmed to transmit a message to a server and/or user indicating a non-permanent use access code has been accepted | The Smart Lock Pro system includes a controller that, via the August app and August Connect Wi-Fi bridge, sends notifications to the owner's phone and creates an entry in an activity log when a guest uses an access code. The complaint provides a screenshot of a "Smart Alert" notification on a phone indicating a user has unlocked the door. | ¶18 | col. 17:62-65 |
- Identified Points of Contention:
- Scope Questions: The primary question may be whether the term "non-permanent use access code" reads on the accused product's "Recurring" access feature. A defendant could argue "non-permanent" implies a code that expires and is not re-usable, whereas a "recurring" code is, by definition, reusable on a set schedule.
- Technical Questions: What is the specific mechanism by which the controller transmits the message "indicating a non-permanent use access code has been accepted"? Does the general activity log entry or push notification meet the specificity required by this limitation, or does the claim imply a more direct confirmation message to the issuing server for backend processing?
’873 Patent Infringement Allegations
| Claim Element (from Independent Claim 36) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an actuator configured to unlock in response to entry of an authorized access code | The Smart Lock Pro includes an actuator and associated mechanical and electronic components that unlock the door when an authorized code is entered. | ¶25 | col. 15:16-18 |
| an access code entry unit configured to accept a one-time use access-code issued by a remote server... | The Smart Lock Pro, through its keypad and app, accepts access codes for guests. The complaint alleges these can be "one-time use" by pointing to the "Temporary" access feature, which allows an owner to grant access for a limited, expiring duration. The complaint shows a user interface for setting a start and end date/time for guest access. | ¶26 | col. 15:19-21 |
| wherein the one-time use access code comprises a number generated by a cryptographically strong random number generator. | The complaint alleges, upon information and belief, that the one-time use access code is a number generated by a cryptographically strong random number generator. It cites a third-party review stating the app can "generate a random code itself for each new user." | ¶27, ¶34 | col. 15:21-24 |
- Identified Points of Contention:
- Scope Questions: Does the accused product's "Temporary" access feature, which is valid for a period of time during which it may be used multiple times, meet the "one-time use" limitation? A defendant may argue "one-time use" has a plain meaning of single, discrete use, not time-boxed access.
- Technical Questions: The complaint's allegation for the "cryptographically strong random number generator" element is conclusory and based on a third-party product review that merely mentions a "random code." (Compl. ¶27, ¶34). A significant technical question will be what evidence Plaintiff can produce to demonstrate that the accused product's code generation algorithm meets the specific and high technical standard of "cryptographically strong."
V. Key Claim Terms for Construction
For the ’918 Patent
- The Term: "non-permanent use access code"
- Context and Importance: This term is central to the infringement analysis for the ’918 patent. Its scope will determine whether access codes that are time-limited but reusable within that time (like the accused "Temporary" codes) or reusable on a schedule (like the accused "Recurring" codes) fall within the claims. Practitioners may focus on this term because its breadth is a key point of potential dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses a code expiring after a "pre-determined usage allocation," which suggests the code could be valid for more than one use. (’918 Patent, col. 2:57-59). The term "non-permanent" itself is broader than "one-time," suggesting any code that is not perpetual could be covered.
- Evidence for a Narrower Interpretation: The patent's background focuses on the problems of "static, reusable codes," which could suggest an intent to cover only codes that are not reused. (’918 Patent, col. 1:49-51). The parent '873 patent is explicitly for "one-time" codes, which could be used to argue the family of inventions is directed at non-reusable codes.
For the ’873 Patent
- The Term: "cryptographically strong random number generator"
- Context and Importance: This is a highly specific technical limitation. Infringement of claim 36 hinges on whether the accused product's method for generating access codes meets this standard, which is a term of art in computer security. The complaint provides minimal factual support for this element, making it a likely focus of discovery and expert testimony.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not define the term or provide examples of specific algorithms. A party could argue it should be given its plain and ordinary meaning to a person of ordinary skill in the art at the time of the invention, without being tied to a specific implementation.
- Evidence for a Narrower Interpretation: The context of providing secure access against unauthorized entry implies a high standard for "strong." A party could argue that this term requires a generator that passes specific statistical tests for randomness and is resistant to prediction, distinguishing it from simpler pseudo-random functions. The abstract and summary emphasize security, which could support a narrower, more stringent definition. (’873 Patent, Abstract).
VI. Other Allegations
- Indirect Infringement: The complaint's prayer for relief seeks a judgment of induced infringement. (Compl. p. 35, ¶B). Factual support is alleged through Defendant's marketing and instructional materials, such as YouTube videos and support articles, which allegedly instruct and encourage users to operate the Smart Lock Pro system in a manner that performs the claimed methods, such as creating temporary access codes for guests. (Compl. ¶13, ¶16).
- Willful Infringement: The complaint does not contain specific factual allegations of pre-suit knowledge or willful infringement. However, the prayer for relief requests a declaration that the case is exceptional under 35 U.S.C. § 285, which provides a basis for seeking attorneys' fees, often in cases of willful or egregious conduct. (Compl. p. 35, ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "one-time use access-code" (’873 patent) be construed to cover the accused product’s "Temporary" access feature, which is valid for a period of time rather than a single use? Similarly, does the broader term "non-permanent use access code" (’918 patent) encompass the product's "Recurring" access feature?
- A key evidentiary question will be one of technical proof: What factual evidence can Plaintiff provide to meet its burden of proving that the accused product's number generation algorithm satisfies the specific technical limitation of being a "cryptographically strong random number generator", as required by the '873 patent? The complaint's current allegations on this point appear to be based on inference rather than direct evidence.