Circuit Ventures LLC v. Siemens Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Circuit Ventures LLC (Delaware)
  • Defendant: Siemens Corporation (Delaware)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Identification: 1:20-cv-00080, D. Del., 02/13/2020
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and is therefore deemed to be a resident of the District.
• Core Dispute: Plaintiff alleges that Defendant’s LOGO! Logic Modules for building and home automation infringe three patents related to configurable circuit monitoring devices.
• Technical Context: The technology concerns flexible monitoring systems designed to overcome the limitations of proprietary, vendor-locked security and building management systems by allowing for configurability with third-party components.
• Key Procedural History: The three patents-in-suit are part of the same family, all claiming priority to a 2000 Australian application. The '869 and '893 patents are continuations of the application that issued as the '744 patent, which itself is a continuation of an earlier U.S. patent. This shared lineage suggests the patents cover closely related aspects of the same core invention.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,834,744 - "Circuit Monitoring Device," issued November 16, 2010

The Invention Explained

• Problem Addressed: The patent describes conventional security management systems (SMS) as proprietary and inflexible. Customers are often locked into a single manufacturer for upgrades or replacement parts because the systems are designed to work with specific, fixed-value "field resistors" in their sensor circuits. Changing or upgrading the system often requires costly and difficult rewiring. (Compl. ¶12; ’744 Patent, col. 1:30-39, col. 2:39-50).
• The Patented Solution: The invention is a flexible "end-of-line" (EOL) monitoring module that can be programmed to work with a wide range of field resistor values. The module measures an electrical parameter (e.g., resistance) of a sensor circuit, converts it to a digital "count value," and compares that value against user-configurable thresholds to determine the circuit's status (e.g., "Normal," "Alarm," "Open Circuit"). This adaptability allows the module to be retrofitted into existing, disparate systems without needing to replace or rewire the legacy components. (Compl. ¶15; ’744 Patent, Abstract; col. 7:12-19).
• Technical Importance: The technology aimed to decouple monitoring hardware from proprietary system constraints, offering a universal, "open technology" solution that reduces installation time and eliminates dependency on the original equipment manufacturer. (Compl. ¶15; ’744 Patent, col.8:37-43).

Key Claims at a Glance

• The complaint asserts at least independent claim 1. (Compl. ¶19).
• Essential elements of Claim 1:
  • An apparatus for monitoring a circuit and for coupling to a central system comprising:
  • a circuit module to determine a status of the circuit;
  • a network communications module coupled to the circuit module to communicate a signal indicative of the assigned status to the central system via a network, said network communications module limiting all status communications with the central system to only the signal indicative of the assigned status; and
  • a display to present an indication of a status of the circuit based on the signal indicative of the assigned status,
  • wherein the circuit module measures a magnitude of a parameter of the circuit and generates a count value representative of said magnitude.
• The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation of infringing "one or more claims." (Compl. ¶19).

U.S. Patent No. 8,816,869 - "Circuit Monitoring Device," issued August 26, 2014

The Invention Explained

• Problem Addressed: As with the '744 Patent, this patent addresses the problem of proprietary security systems that are expensive and difficult to upgrade or modify due to their reliance on manufacturer-specific components and fixed-value resistors. (Compl. ¶30; ’869 Patent, col. 2:46-58).
• The Patented Solution: The patent describes a functionally similar device that measures a circuit parameter, compares it to a plurality of threshold values to assign a status, and communicates that status over a network. The claims emphasize the efficiency of this communication, which is limited to only the digital bits necessary to describe the status, rather than transmitting the full raw data. (Compl. ¶32; ’869 Patent, Abstract; col. 4:13-22).
• Technical Importance: This invention provides a flexible, retrofittable monitoring solution that reduces installation costs and removes reliance on proprietary hardware, consistent with the goals of the '744 Patent. ('869 Patent, col. 4:25-33).

Key Claims at a Glance

• The complaint asserts at least independent claim 1. (Compl. ¶35).
• Essential elements of Claim 1:
  • A device for monitoring the status of a circuit based on a measurable parameter of the circuit, the device comprising:
  • measurement means to measure the parameter of the circuit;
  • comparison means to compare the measured parameter to a plurality of threshold values and to assign a status based on a result of the comparison; and
  • transmission means to communicate the status over a network and to limit the communicated status to only digital bits indicating the status and being sufficient to describe the status,
  • wherein the status communication is transmitted over the network to an output means configured to present an indication of the assigned status.
• The complaint alleges infringement of "one or more claims." (Compl. ¶35).

U.S. Patent No. 8,912,893 - "Circuit Monitoring Device," issued December 16, 2014

• Technology Synopsis: This patent continues the theme of the asserted family, addressing the inflexibility of proprietary security systems. It discloses a circuit monitoring device comprising one or more processors and configurable software modules. The device compares a measured electrical parameter from a circuit against a plurality of stored, and potentially user-defined, threshold values to determine the circuit's status (e.g., normal, alarm) and communicates this determined status to a central monitoring system. (Compl. ¶48; ’893 Patent, Abstract; col. 10:1-27).
• Asserted Claims: At least independent claim 1 is asserted. (Compl. ¶51).
• Accused Features: The Siemens LOGO! Logic Modules are accused of being the circuit monitoring device that measures parameters from associated sensors and determines their status for display and communication. (Compl. ¶52).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the Siemens LOGO! Logic Modules, including but not limited to models LOGO! 24CE, LOGO! 230RCE, LOGO! 24RCE, and LOGO! 12/24 RCE. (Compl. ¶20, ¶36, ¶52).

Functionality and Market Context

• The complaint alleges these are compact, user-friendly logic modules for small building and home automation projects, such as controlling heating, lighting, irrigation, and security systems. (Compl. p. 6). They are designed to connect with and monitor various sensors, including temperature, light, rain, and motion sensors. (Compl. ¶20). The complaint includes a table from a Siemens document illustrating that the LOGO! modules are used with various sensors that have analog (0-10V DC) outputs, which suggests the modules perform measurement of a variable electrical parameter. (Compl. p. 9). The modules include a built-in display and can communicate over networks like Wi-Fi. (Compl. ¶20, p. 6). The complaint provides a screenshot of a Siemens product page listing "LOGO! basic modules with display." (Compl. p. 6).

IV. Analysis of Infringement Allegations

'744 Patent Infringement Allegations

'869 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The '744 Patent claims an "apparatus for monitoring a circuit and for coupling to a central system." The complaint alleges the accused LOGO! module is a "central system" (Compl. ¶20). This raises the question of whether the accused device can simultaneously be the claimed "apparatus" and the "central system" to which the apparatus is meant to couple, an architecture that appears inconsistent with the patent's description of a monitoring module (10, 20) communicating with a separate controller (5). ('744 Patent, Fig. 2).
  • Technical Questions: A central feature of the patented technology is the comparison of a measured value against multiple, configurable thresholds. The complaint does not provide sufficient detail for analysis of how, or if, the accused LOGO! modules perform this specific function. Similarly, the complaint does not provide factual support for the key limitation that network communications are "limited" to a minimal status signal, which the patents distinguish from transmitting a full analog value. ('744 Patent, col. 8:36-40). The case may depend on evidence regarding the internal software architecture and network protocols of the accused modules.

V. Key Claim Terms for Construction

• The Term: "central system" ('744 Patent, Claim 1)

• Context and Importance: The infringement theory for the '744 patent may depend heavily on this term's construction. The complaint alleges the LOGO! module, which has a display, is itself a "central system," potentially arguing for a self-contained interpretation. A defendant may argue the "central system" must be a distinct component that the accused "apparatus" communicates with, which could create a non-infringement defense if the LOGO! module is only the "apparatus."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims do not explicitly require the "central system" to be in a separate housing from the "circuit module." A party could argue that as long as the functions are performed, a single integrated device can meet the limitations.
  • Evidence for a Narrower Interpretation: The specification consistently depicts the "centralised SMS control unit" (5) as a distinct entity from the "monitoring devices" (10, 20, 30). ('744 Patent, Fig. 2). The detailed description states the monitoring module is "plugged directly into the back plane of the PLC" or communicates remotely to it, implying two separate components. ('744 Patent, col. 5:31-32, col. 5:46-49).

• The Term: "limiting all status communications... to only the signal indicative of the assigned status" ('744 Patent, Claim 1)

• Context and Importance: This limitation defines a key technical advantage of the invention—data transmission efficiency. The complaint provides no factual detail on this point. Practitioners may focus on this term because infringement will depend on whether the accused device's network protocol is merely for general communication or if it specifically performs this data-slimming function.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that if the primary data payload of a packet is the status, it meets the spirit of the claim, even with standard network overhead.
  • Evidence for a Narrower Interpretation: The specification highlights this as a significant feature, stating "merely a few bits of information needs to be transferred, rather than a whole word representing the analog value." ('744 Patent, col. 8:36-40). This suggests the limitation requires more than just sending a status; it requires sending only the status in a minimalist fashion, which could be used to distinguish it from general-purpose protocols.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant "causes infringement by its customers and users and encourages the use of accused devices through distribution, support and customer services." (Compl. ¶19, ¶35, ¶51).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of architectural scope: Can the claims, which describe a monitoring module communicating with a "central system," be construed to read on the accused LOGO! products, which appear to be self-contained automation controllers? The resolution may depend on whether the court views the patent's architecture as requiring two distinct devices or allows for a single, integrated interpretation.
• A key evidentiary question will be one of functional operation: Can the Plaintiff produce evidence from the accused products' software and hardware to show they perform the specific, claimed functions of (1) comparing measured circuit parameters against a plurality of configurable thresholds and (2) limiting network communications to a minimal-bit status signal, as opposed to using a more generic measurement and communication scheme? The complaint's current allegations are conclusory on these critical technical points.