DCT
1:24-cv-00543
Guangzhou Lightsource Electronics Ltd v. Pine Locks
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guangzhou Lightsource Electronics Limited; Guangzhou Zhuyun Trading Co., Ltd.; and Changting County Huimei Technology Co., Ltd. (China)
- Defendant: Pine Locks (Isle of Man)
- Plaintiff’s Counsel: Rimon, P.C.
- Case Identification: Guangzhou Lightsource Electronics Limited et al. v. Pine Locks, 1:24-cv-00543, D. Del., 09/03/2024
- Venue Allegations: Plaintiffs allege venue is proper because Defendant is subject to personal jurisdiction in the district, stemming from Defendant's submission of patent infringement complaints to Amazon.com that sought to delist Plaintiffs' products, which are sold to customers in Delaware. Plaintiffs also allege Defendant is not a U.S. resident and may be sued in any judicial district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their smart lock products do not infringe Defendant’s patent related to electronically controlled locks, and that the patent is invalid.
- Technical Context: The technology concerns smart locks that can be electronically operated by a separate mobile device, a field relevant to both consumer home security and the security of portable electronics.
- Key Procedural History: The complaint states that this action was precipitated by infringement complaints filed by Defendant Pine Locks with Amazon under its patent evaluation program, which threatened the removal of Plaintiffs' products from the Amazon marketplace unless a lawsuit for declaratory judgment was filed. The complaint also references prior litigation involving Pine Locks and the same patent, indicating Pine Locks was previously put on notice of certain prior art.
Case Timeline
| Date | Event |
|---|---|
| 2011-07-01 | Lockitron Manual (prior art) allegedly published |
| 2011-08-05 | Lockitron smart lock (prior art) demonstrated in video |
| 2012-11-08 | Lockitron prior art publication ('789 publication) filed |
| 2013-05-03 | ’239 Patent Priority Date |
| 2019-08-13 | ’239 Patent Issue Date |
| 2023-03-28 | Pine Locks allegedly put on notice of Lockitron prior art |
| 2024-04-16 | Amazon notifies Plaintiffs of Pine Locks' infringement complaint |
| 2024-09-03 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,378,239 - "Smart lock"
The Invention Explained
- Problem Addressed: The patent identifies the inconvenience of carrying numerous physical keys and the risk of forgetting combination codes for conventional locks. It also notes the challenge of designing sufficiently thin miniature locks for modern, shrinking electronic devices like laptops and tablets (’239 Patent, col. 1:16-32).
- The Patented Solution: The invention is a locking system where a lock body is controlled by a separate mobile electronic device, such as a smartphone (’239 Patent, Abstract). The lock body contains a locking element, a mechanism to move it, and an electrical controller that receives commands from the mobile device to lock or unlock the mechanism (’239 Patent, col. 1:46-58). In some embodiments, the lock can be temporarily powered by the mobile device itself, for example via a physical USB connection or wirelessly, eliminating the need for a long-term internal power source in the lock body (’239 Patent, col. 3:8-14).
- Technical Importance: The technology proposes a way to create compact, electronically-controlled locks for modern devices without the bulk of traditional key or combination mechanisms (’239 Patent, col. 1:26-32).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1, 2, and 5 (Compl. ¶24).
- Independent Claim 1: A locking system comprising a lock body, a moving mechanism, an electrical controller, and a separate mobile electronic device, which includes:
- a user operable slider which is configured to be moved to mechanically operate the locking system to move the locking element into the locked position.
- Independent Claim 2: A locking system similar to claim 1, wherein the moving mechanism includes:
- a thumb slider, mechanically positioned to push an actuator,
- the actuator is coupled to a lock head,
- a latch configured to assume a latched position when the locking element is in the locked position.
- Independent Claim 5: A locking system for a device, comprising a lock body, a moving mechanism, an electrical controller, and a separate mobile cell phone device, which includes:
- a short term electrical power storage device,
- the storage device is configured to store power temporarily for a duration sufficient to operate the moving mechanism to the unlocked position,
- the storage device is "without any connection to an external DC and/or AC power source," and
- the storage device is configured to receive power to operate "solely from said mobile cell phone device."
III. The Accused Instrumentality
Product Identification
- The "Yamiry" (ASIN B0CGLQ4N2Y) and "Kucacci" (ASIN B0CGRRHXT6) brand smart locks (collectively, the "Accused Smart Locks") (Compl. ¶¶ 8-10, 19).
Functionality and Market Context
- The complaint describes the Accused Smart Locks as being manually operated via a "knob rotation method" rather than a linear sliding mechanism (Compl. ¶27). An image provided in the complaint shows the interior portion of an Accused Smart Lock, which features a prominent rotatable knob (Compl. p. 7).
- The complaint further states that the Accused Smart Locks are powered by four AA batteries, which are housed in an internal battery compartment (Compl. ¶30). An image from the complaint displays this battery compartment holding four standard AA batteries (Compl. p. 9). The products are sold to U.S. customers primarily through Amazon.com (Compl. ¶16).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiffs' core arguments for why their products do not meet the limitations of the asserted claims.
’239 Patent Infringement Allegations (Claim 1)
| Claim Element | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a user operable slider which is configured to be moved to mechanically operate the locking system | The Accused Smart Locks utilize a "knob rotation method" for manual operation, not a "user operable slider." | ¶27 | col. 7:30-32 |
’239 Patent Infringement Allegations (Claim 2)
| Claim Element | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a thumb slider, which is mechanically positioned to push an actuator | The Accused Smart Locks do not have a "thumb slider"; they use a rotatable knob. | ¶27 | col. 7:46-47 |
’239 Patent Infringement Allegations (Claim 5)
| Claim Element | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a short term electrical power storage device... being without any connection to an external DC and/or AC power source, and said storage device being configured to receive said electrical power to temporarily power and operate said electrical controller and said moving mechanism solely from said mobile cell phone device | The Accused Smart Locks are powered by four AA batteries, which the complaint contends is not a "short term" power source and is not powered "solely" from a mobile device. | ¶¶29-30 | col. 8:16-24 |
- Identified Points of Contention:
- Scope Questions: A central dispute will be the interpretation of "slider." The complaint argues that a "rotatable knob" is distinct from and not covered by the term "slider" (Compl. ¶27). The case may turn on whether "slider" is limited to linear motion, as depicted in the patent's figures (e.g., ’239 Patent, Fig. 5b), or if it can be construed more broadly to cover any user-manipulated mechanical actuator.
- Technical Questions: For claim 5, the dispute centers on the power source. The complaint asserts that four AA batteries do not meet the claim requirements for a "short term" power storage device that receives power "solely" from a mobile phone (Compl. ¶¶28, 30). This raises the question of whether a conventional, self-contained battery power source falls within the scope of this highly specific limitation, which the patent specification links to temporary power sources like capacitors or batteries charged for a "minute or two" by an external device (’239 Patent, col. 3:8-14, 3:23-27).
V. Key Claim Terms for Construction
The Term: "user operable slider" / "thumb slider" (Claims 1 and 2)
Context and Importance: This term is critical because the Plaintiffs' primary non-infringement argument for claims 1 and 2 is that their products use a "rotatable knob" instead of a "slider" (Compl. ¶27). The outcome of the infringement analysis for these claims depends almost entirely on whether a knob can be considered a type of slider.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee may argue that "slider" should be given its plain and ordinary meaning to encompass a component that a user slides or moves to actuate a mechanism, without being strictly limited to linear motion.
- Evidence for a Narrower Interpretation: The specification consistently depicts the "thumb slider 530" as a component that moves linearly back and forth within a "slide channel 532" (’239 Patent, col. 4:47-49). Figure 5b, which the complaint references, illustrates this linear motion with a directional arrow (Compl. ¶26; ’239 Patent, Fig. 5b). This specific embodiment may be used to argue that "slider" implies linear, not rotational, movement.
The Term: "short term electrical power storage device" ... configured to receive said electrical power ... "solely from said mobile cell phone device" (Claim 5)
Context and Importance: The Plaintiffs' non-infringement argument for claim 5 hinges on this limitation. They contend their use of four AA batteries is a conventional, long-term power source, not a "short term" one powered "solely" by a mobile device (Compl. ¶¶29-30).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee could argue that any battery is a "storage device" and that "short term" is a relative term not explicitly defined, potentially giving them latitude in their interpretation.
- Evidence for a Narrower Interpretation: The specification provides specific examples that suggest a narrow meaning, describing a "short term storage capacitor" or an internal battery that is charged by the mobile device "in order to temporarily power the lock body" for a "short period on the order of a minute or two" (’239 Patent, col. 3:8-14, 3:23-27). The claim's additional requirements that the device be "without any connection to an external DC and/or AC power source" and receive power "solely from said mobile cell phone device" further support an interpretation that excludes standard, replaceable AA batteries.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement. It seeks a declaration of non-infringement, both directly and indirectly, as part of its requested relief (Compl. ¶33), but does not plead specific facts on these issues. The complaint does, however, request that the case be declared "exceptional" under 35 U.S.C. § 285, entitling Plaintiffs to attorneys' fees, based on the contention that the Defendant's infringement allegations are "unreasonable and frivolous" (Compl. ¶¶34, 49).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "slider," which the patent specification illustrates as a linearly-moving component, be construed to cover the "rotatable knob" used in the Accused Smart Locks?
- A second key issue is one of technical non-conformance: Do the Accused Smart Locks, which are powered by four standard AA batteries, practice the claimed "short term electrical power storage device" that is required to be powered "solely from said mobile cell phone device," or is this a fundamental mismatch in the claimed power system?
- The case also presents a significant validity question: The complaint alleges that prior art, such as the "Lockitron" system from as early as 2011, disclosed smart locks with rotatable knobs controlled by smartphones (Compl. ¶¶39-44). A central question for the court will be whether the asserted claims of the ’239 patent are valid and non-obvious in light of this alleged prior art.