DCT
1:19-cv-01570
Lutron Electronics Co Inc v. Savant Systems LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lutron Electronics Co., Inc. (Pennsylvania) and Lutron Technology Company LLC (Delaware)
- Defendant: Savant Systems, LLC (Delaware)
- Plaintiff’s Counsel: Richards, Layton & Finger, P.A.
- Case Identification: 1:19-cv-01570, D. Del., 08/26/2019
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware limited liability company and therefore resides in the district.
- Core Dispute: Plaintiff alleges that the ornamental design of Defendant’s ASCEND line of lighting control keypads infringes its design patent for a control device.
- Technical Context: The technology at issue is high-end, wall-mounted electronic keypads used for controlling lighting, shades, and other aspects of home and commercial automation systems.
- Key Procedural History: The complaint notes that the asserted patent protects the design for Lutron's "award-winning, clean and sleek Palladiom® keypads." No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2013-11-15 | U.S. Patent No. D734,277 Priority Date (Application Filing) |
| 2015-07-14 | U.S. Patent No. D734,277 Issued |
| 2019-05-22 | Accused Ascend Keypads observed at a tradeshow |
| 2019-08-26 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. D734277, titled “Control device,” issued July 14, 2015.
The Invention Explained
- Problem Addressed: The complaint suggests a market need for aesthetically refined lighting controls to replace earlier, "inefficient and unattractive" devices like bulky rheostats (Compl. ¶14). The patent is presented as part of Lutron's effort to protect "innovative, ornamental designs" for its modern control products (Compl. ¶15).
- The Patented Solution: The patent claims the ornamental design for a control device, which is depicted in the patent's figures (’277 Patent, Claim). The design features a flat, rectangular faceplate with a central, vertically-oriented rectangular region containing a stack of horizontally-oriented buttons ('277 Patent, Figs. 1-2). The description notes that oblique lines in some figures indicate a "transparent or translucent surface" ('277 Patent, Description).
- Technical Importance: The complaint alleges that this design is embodied in Lutron's "award-winning, clean and sleek Palladiom® keypads" and that its aesthetic was a "stark difference" from prior keypad designs in the industry (Compl. ¶18, ¶23).
Key Claims at a Glance
- The single claim is for "the ornamental design for a control device, as shown and described" ('277 Patent, Claim). The key ornamental features depicted in the figures include:
- A rectangular faceplate with a low-profile outer periphery.
- A central, inset rectangular area.
- A vertical arrangement of multiple rectangular buttons within the inset area.
- An overall appearance of the buttons being substantially flush with the surrounding faceplate.
III. The Accused Instrumentality
Product Identification
- Defendant's "ASCEND keypads" (Compl. ¶19).
Functionality and Market Context
- The Accused Ascend Keypads are described as wall-mounted control devices for functions such as lights, dimmers, blinds, and drapes (Compl. ¶26).
- Technically, they are alleged to have a "cover housing with a flat front surface faceplate and low profile rectangular outer periphery" (Compl. ¶27). The complaint further alleges they have buttons, "typically four," that are "substantially flush with the faceplate" (Compl. ¶28).
- The complaint provides a front-view, side-by-side comparison of the Accused Ascend Keypad, Lutron's commercial Palladiom keypad, and Figure 2 of the '277 patent (Compl. p. 5).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. The complaint alleges infringement bypointing to similarities in the overall ornamental appearance.
- D734,277 Infringement Allegations
| Claimed Design Feature (from '277 Patent) | Alleged Infringing Feature of ASCEND Keypad | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a control device | Savant has applied the patented design to an article of manufacture | ¶36 | '277 Patent, Claim |
| A rectangular faceplate with a low-profile periphery | The accused keypads include a "cover housing with a flat front surface faceplate and low profile rectangular outer periphery." | ¶27 | '277 Patent, Fig. 1 |
| A vertical stack of rectangular buttons | The accused keypads have "buttons (typically four)" provided at the front surface. A visual shows these in a vertical stack. | ¶28, p. 5 | '277 Patent, Fig. 2 |
| Buttons substantially flush with the faceplate | The buttons "are substantially flush with the faceplate." A perspective-view comparison is provided to illustrate this aspect. | ¶28, p. 6 | '277 Patent, Fig. 3 |
| Overall aesthetic equivalence | The complaint alleges that the "aesthetic equivalence... is substantial" and that "Savant clearly copied Lutron's patented design." | ¶22-23 | '277 Patent, Figs. 1-2 |
- Identified Points of Contention:
- Scope Questions: The core legal question will be the application of the "ordinary observer" test. The dispute will center on whether the overall visual impression of the Accused Ascend Keypad is substantially the same as the patented design.
- Technical Questions: The patent description states that shade lines in the drawings "indicate a transparent or translucent surface" ('277 Patent, Description), while the complaint describes an example of the accused product as having "metal buttons and faceplate" (Compl. ¶20). This raises the question of whether an opaque, metallic finish is encompassed by a design that explicitly notes a translucent characteristic.
V. Key Claim Terms for Construction
In design patent litigation, analysis focuses on the scope of the claimed design as a whole rather than construction of specific text-based terms. The key issues revolve around interpreting the visual elements shown in the patent's figures.
- The Term: "ornamental design for a control device"
- Context and Importance: The scope of the design as shown in the patent's figures is the central issue. The court's interpretation of what an ordinary observer would perceive as the overall design, and how much variation that design permits, will be determinative of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The design is depicted in simple line drawings, which typically do not limit the claim to a specific color, texture, or material beyond what is explicitly described or shown. The use of broken lines to illustrate the rear housing indicates those elements are not part of the claimed design, focusing protection on the front-facing ornamental appearance ('277 Patent, Description; Fig. 3).
- Evidence for a Narrower Interpretation: The specification contains an explicit statement that "The oblique shade lines shown in the drawings indicate a transparent or translucent surface" ('277 Patent, Description). A defendant may argue this language limits the scope of the protected design to products with translucent properties, potentially distinguishing it from accused products made of opaque materials like metal (Compl. ¶20).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement based on Savant's provision of "installation and user guides" and "training and instruction" to dealers, distributors, and end-users, which allegedly instruct on the infringing use of the keypads (Compl. ¶37, ¶41). Contributory infringement is also alleged, based on the keypads having "special features... specially designed to be used in an infringing manner" with no substantial non-infringing uses (Compl. ¶44).
- Willful Infringement: Willfulness is alleged based on Savant's status as a direct competitor allegedly aware of Lutron's patent portfolio (Compl. ¶38). The complaint further alleges that Savant was willfully blind to Lutron's rights by "copying of Lutron's Palladiom 4-button keypad" (Compl. ¶40) and acted with objective recklessness (Compl. ¶42).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of overall appearance: Will an ordinary observer, viewing the Savant ASCEND keypad in the context of prior art designs, find its overall ornamental appearance to be substantially the same as the design claimed in the '277 patent?
- A key evidentiary question will be one of material scope: Does the '277 patent's specific reference to a "transparent or translucent surface" limit the scope of the design, or is the claimed design broad enough to be infringed by a product made of different, opaque materials such as the "metal" alleged in the complaint?
- The outcome may also depend on the impact of prior art: The complaint asserts that the patented design represented a "stark difference" from what came before. The strength of this assertion, when tested against the actual prior art, will influence the perceived scope of the patent and the degree of similarity required for a finding of infringement.