DCT
1:23-cv-00467
SOTAT LLC v. Resideo Tech Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SOTAT, LLC (Florida)
- Defendant: Resideo Technologies, Inc. (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Clayton, McKay & Bailey, PC
- Case Identification: 1:23-cv-00467, D. Del., 04/27/2023
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and has allegedly committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart security camera systems and associated mobile applications infringe two patents related to mobile surveillance systems that transmit data from a camera to a mobile device upon the detection of motion.
- Technical Context: The technology at issue concerns the architecture of modern smart home security systems, where internet-connected cameras are controlled by and stream data to a user's mobile device via a central server.
- Key Procedural History: The ’809 Patent is a continuation of the application that resulted in the ’207 Patent, and the ’207 Patent is subject to a terminal disclaimer. Plaintiff alleges it provided Defendant with pre-suit notice of infringement via a letter dated February 13, 2023.
Case Timeline
| Date | Event |
|---|---|
| 2009-07-31 | Priority Date for '207 and '809 Patents |
| 2017-12-26 | U.S. Patent No. 9,854,207 Issued |
| 2019-12-17 | U.S. Patent No. 10,511,809 Issued |
| 2023-02-13 | Plaintiff sends notice letter to Defendant |
| 2023-04-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,854,207 - “Mobile Surveillance System” (Issued Dec. 26, 2017)
The Invention Explained
- Problem Addressed: The patent’s background section describes prior art electronic surveillance systems as suffering from several shortcomings, including inefficient use of resources, false alarms, delays between an intrusion and user notification, and providing insufficient information to a remote user about the nature of an alarm (Compl. ¶13; ’207 Patent, col. 1:36-67).
- The Patented Solution: The invention proposes a mobile surveillance system comprising a camera at a surveillance area, a server, and a mobile device. The system is designed to provide real-time surveillance by capturing data (e.g., audio, video) and transmitting it from the camera, through the server, to the user's mobile device, allowing the user to control the system remotely (’207 Patent, Abstract; col. 4:30-44). A motion detection mechanism is used to trigger the transfer of surveillance data, aiming to overcome the problems of prior systems (’207 Patent, col. 3:1-9).
- Technical Importance: The technology represents an approach to integrate mobile devices directly into the control and monitoring loop of a security system, aiming for more timely and targeted user alerts compared to older, static alarm systems (Compl. ¶14; ’207 Patent, col. 2:1-4).
Key Claims at a Glance
- The complaint asserts independent claim 19 (Compl. ¶33).
- Essential elements of claim 19 include:
- A mobile device configured to communicate with at least one camera positioned at a surveillance area.
- The mobile device is configured to control activation, start and stop of capture, and transfer of surveillance data.
- The surveillance data is wirelessly communicated directly from a transmitter linked to the camera to the mobile device.
- The mobile device is further configured to activate upon detection of motion at the surveillance area, where the motion measurements exceed a determined threshold.
- The complaint reserves the right to assert other claims (Compl. ¶33).
U.S. Patent No. 10,511,809 - “Mobile Surveillance System” (Issued Dec. 17, 2019)
The Invention Explained
- Problem Addressed: As a continuation of the '207 Patent's application, the ’809 Patent addresses the same set of problems in prior art surveillance systems, such as delays, inefficiency, and a lack of user-friendly control interfaces (Compl. ¶¶12-13; ’809 Patent, col. 1:49-67).
- The Patented Solution: The patent describes a method for conducting surveillance where a mobile device is used to control a camera. Data transfer to the mobile device is triggered when a motion detection measurement exceeds a threshold (’809 Patent, Abstract). A specific improvement recited in the claims is the use of a "datebook" on the mobile device to schedule the recording and transfer of surveillance data, providing more granular user control (’809 Patent, col. 6:12-24).
- Technical Importance: The invention claims to provide an improved graphical user interface that allows for a level of functional control not previously available, specifically through a graphical datebook for scheduling surveillance operations (Compl. ¶16; ’809 Patent, col. 9:36-40).
Key Claims at a Glance
- The complaint asserts independent claim 10 (Compl. ¶35).
- Essential elements of claim 10 include:
- Receiving an instruction from a mobile device to control the start and stop of surveillance data capture.
- Capturing surveillance data with a camera that is operably engaged with a motion detection mechanism.
- Transferring the surveillance data to the mobile device when the motion detection mechanism obtains a measurement exceeding a predetermined threshold.
- The mobile device displays a "datebook" with days of the week and times of day that can be synchronized with an application to schedule the data transfer.
- The complaint reserves the right to assert other claims (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's network-connected surveillance systems, including specific products like the ProSeries Wireless Indoor Motionviewer, High Definition Video Doorbell, and various Wi-Fi security cameras. The system also includes Defendant’s mobile applications, the Resideo App and Total Connect 2.0 App (collectively, the "Resideo Surveillance Systems") (Compl. ¶¶19-20).
Functionality and Market Context
- The complaint alleges that the Resideo Surveillance Systems comprise network-connected cameras with motion detectors that communicate wirelessly with a user's mobile device via a server (Compl. ¶¶18, 26). Users allegedly employ the mobile app to configure the system, activate the camera, control the start, stop, and transfer of surveillance data, and receive notifications when the motion detector is triggered (Compl. ¶¶27-28). The complaint also alleges the mobile app provides a feature to schedule the recording and transfer of surveillance data (Compl. ¶29). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement by summarizing the functionality of the accused systems and referencing claim chart exhibits that were not included with the filed complaint document. The following tables are constructed based on the narrative allegations within the complaint.
’207 Patent Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile device configured to communicate with at least one camera positioned at a surveillance area... | The Resideo mobile application is installed on a user's mobile device and communicates with Resideo's network-connected cameras. | ¶¶18, 27 | col. 12:9-13 |
| the mobile device is configured to control activation of the mobile surveillance system, and control start and stop of the capture of the surveillance data, and transfer of the surveillance data... | End users allegedly use the mobile application to activate the camera, start and stop data capture, and control the transfer of data from the camera to the mobile device. | ¶27 | col. 12:14-18 |
| the surveillance data is wirelessly communicated directly from a transmitter linked to the camera to the mobile device... | The complaint alleges surveillance data is wirelessly communicated from the Resideo camera product to the end user's mobile device via a server. | ¶28 | col. 12:19-22 |
| and the mobile device is further configured to activate upon detection of motion at the surveillance area... wherein mobile device activates when the motion measurements exceeds a determined threshold. | Upon detection of motion that exceeds a threshold, data is communicated to the mobile device, which then "activates" by emitting or displaying a notification. | ¶28 | col. 12:23-29 |
’809 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving an instruction from a mobile device to control start and stop of capture of surveillance data at a surveillance area; | Users allegedly use the Resideo mobile application to send instructions to start and stop the capture of surveillance data by the cameras. | ¶27 | col. 10:9-12 |
| capturing the surveillance data by a camera at the surveillance area, wherein the camera is operably engaged to a motion detection mechanism... | Each Resideo camera product includes a camera and is operably engaged to a motion detection mechanism for detecting motion at the surveillance area. | ¶22 | col. 10:13-17 |
| transferring said surveillance data to the mobile device when the motion detection mechanism obtains a motion detection measurement that exceeds a predetermined threshold... | When the motion detection mechanism detects motion exceeding a threshold, the system wirelessly communicates the surveillance data to the user's mobile device. | ¶28 | col. 10:18-24 |
| wherein the mobile device displays a datebook comprising days of the week and times of day that can be synchronized with an application of the user device to schedule the transferring of surveillance data. | The complaint alleges that end users use the mobile application to schedule recording and transfer of data "using a datebook that includes days of the week and times of day." | ¶29 | col. 10:25-33 |
- Identified Points of Contention:
- Scope Questions: A central question for the ’207 Patent is the meaning of "wirelessly communicated directly from a transmitter... to the mobile device." The complaint alleges the accused system operates "via a server" (Compl. ¶28), which raises the question of whether communication through an intermediary server falls within the scope of the term "directly."
- Technical Questions: For the ’809 Patent, a key factual question will be whether the scheduling feature in the accused Resideo apps functions as a "datebook" as required by claim 10. The analysis may depend on the specific user interface and capabilities of the accused scheduling feature compared to the description in the patent.
V. Key Claim Terms for Construction
1. "wirelessly communicated directly" (’207 Patent, Claim 19)
- Context and Importance: The interpretation of "directly" is critical. If construed to mean a point-to-point connection without any intermediary components, the infringement allegation may be difficult to sustain, as both the accused system and the patent's own embodiments appear to rely on a server.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's specification consistently describes and depicts a system architecture where a server is an intermediary between the camera and the mobile device (’207 Patent, Fig. 1, Fig. 4; col. 4:35-38). This may support an argument that "directly" is meant to describe the overall data path to the user's device, rather than precluding the use of a standard client-server architecture.
- Evidence for a Narrower Interpretation: The plain meaning of "directly" suggests an unmediated path. A defendant may argue that if the patentee intended to include a server, the claim would not have used the word "directly," and that its inclusion must be given limiting effect.
2. "datebook" (’809 Patent, Claim 10)
- Context and Importance: This term is a key limitation in the asserted method claim of the ’809 Patent. Infringement will depend on whether the accused apps' scheduling feature meets this definition. Practitioners may focus on this term because it appears to be a specific implementation of a scheduling function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself provides a functional definition, stating the datebook "compris[es] days of the week and times of day that can be synchronized... to schedule the transferring of surveillance data" (’809 Patent, col. 10:29-33). Plaintiff may argue that any scheduling interface that allows users to select days and times meets this functional requirement.
- Evidence for a Narrower Interpretation: The detailed description provides a more specific example, stating the datebook "depicts a month of dates associated with a time of day and/or event" (’809 Patent, col. 6:13-15). A defendant could argue this language requires a calendar-style interface depicting a full month, potentially distinguishing it from a simpler list-based or recurring-schedule interface.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. Inducement is based on allegations that Defendant instructs users on how to use the Resideo Surveillance Systems in an infringing manner through user manuals, websites, and demonstration videos (Compl. ¶¶ 32, 58, 69). Contributory infringement is based on allegations that the accused products are material components especially made for use in the infringing system and are not suitable for substantial non-infringing use (Compl. ¶¶ 37-38, 59, 70).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents and their infringement since at least February 13, 2023, the date of a notice letter sent by Plaintiff's counsel. It is alleged that Defendant continued its infringing activities despite this knowledge (Compl. ¶¶ 47-48, 51, 55, 66).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction scope: Can the term "wirelessly communicated directly" in the ’207 Patent be interpreted to cover a system architecture where data is routed through an intermediary server, a configuration described in the patent's own specification and allegedly used by the accused products?
- A key evidentiary question will be one of technical and functional mapping: Does the scheduling feature within Defendant's mobile applications constitute a "datebook" as that term is used and described in the ’809 Patent, or does its functionality fall outside the claimed scope?
- The case will also examine the actions of the end-user: As the claims are directed to systems and methods used by end-users, the court will need to assess whether Defendant is liable for indirect infringement by providing the necessary components and instructing users to operate them in a manner that satisfies every element of the asserted claims.