DCT
1:24-cv-00602
Luxer Corp v. Butterflymx Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Luxer Corp (Delaware)
- Defendant: Butterflymx Inc (Delaware)
- Plaintiff’s Counsel: Shaw Keller LLP
- Case Identification: 1:24-cv-00602, D. Del., 05/20/2024
- Venue Allegations: Venue is asserted in the District of Delaware on the basis that Defendant is a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s “Package Room” product infringes a patent related to systems and methods for controlling electronic access to a storage room.
- Technical Context: The technology addresses the growing logistical challenge of managing high-volume package deliveries in multifamily residential and commercial buildings.
- Key Procedural History: The complaint alleges Plaintiff launched its patented "Luxer Corp Room" product in 2015, while Defendant launched its accused product in July 2021. The patent-in-suit issued in April 2023, after the launch of the accused product.
Case Timeline
| Date | Event |
|---|---|
| 2014-10-02 | ’675 Patent - Earliest Priority Date |
| 2015-01-01 | Plaintiff's "Luxer Room" product launched |
| 2021-07-01 | Defendant's "Package Room" product launched |
| 2023-04-11 | ’675 Patent - Issue Date |
| 2024-05-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,625,675 - “Method and system for controlling a storage room”
The patent-in-suit is U.S. Patent No. 11,625,675, issued on April 11, 2023 (the “’675 Patent”).
The Invention Explained
- Problem Addressed: The patent recognizes unspecified "issues in controlling electronic locks" for securing storage areas (’675 Patent, col. 2:51-53). As contextualized by the complaint, this problem relates to the logistical task of managing package deliveries in settings like apartment complexes (Compl. ¶9).
- The Patented Solution: The invention is a system that automates access to a shared package room. It centers on a “lock interface” (e.g., a kiosk) that receives an access request from a user, such as a delivery person, containing a user identity and a code (’675 Patent, Abstract). The interface verifies this information against stored data and, upon successful authentication, sends a signal to automatically unlock the door, allowing package drop-off or retrieval (’675 Patent, col. 8:36-65; FIG. 1A(2)). A key feature is that access is granted regardless of whether the storage room is already in use or the size of the package, which differentiates it from single-use locker systems (Compl. ¶23).
- Technical Importance: The technology provides a scalable solution for managing the increasing volume of e-commerce deliveries to multi-tenant buildings, aiming to simplify the process for property managers, couriers, and residents (Compl. ¶9).
Key Claims at a Glance
- The complaint asserts direct and indirect infringement of at least independent claim 1 (Compl. ¶22).
- The essential elements of Claim 1 are:
- An electronic lock for a door to a stationary storage room large enough for various package sizes.
- A "lock interface" with a processor, communicatively coupled to the lock.
- The interface executes a method comprising:
- Receiving a first signal from a terminal requesting access.
- Sending a second signal to the lock with a request to open.
- Opening the lock, irrespective of whether the storage area is in use or the package size.
- Verifying the request by authenticating a "user identity" and a "code" received from the terminal.
- The verification step includes comparing the received identity and code with "data stored in the lock interface."
- Approving the request if the data matches and rejecting it if it does not.
- Sending a message indicating the request is invalid in response to a rejection.
III. The Accused Instrumentality
Product Identification
Defendant's "Package Room" product and associated systems and methods (the "Accused Products") (Compl. ¶14).
Functionality and Market Context
- The Accused Product is a package management solution for buildings that uses a panel mounted at the package room door (Compl. ¶16). Couriers enter a "designated delivery PIN" to access the room, and the panel captures a time-stamped picture of the person (Compl. ¶¶16-17). After delivery, residents are notified via push notification, text, or email and use their own "PIN code" at the panel to retrieve their items (Compl. ¶¶16-17). The complaint includes a marketing infographic from Defendant's website illustrating this three-step process of courier delivery, resident notification, and resident pickup (Compl. p. 5).
- The complaint highlights Defendant’s marketing of "easy package retrieval" and "seamless PMS integration" to connect with property management software and keep the resident directory updated in real-time (Compl. ¶18). It also alleges that Defendant launched the Accused Product in July 2021, six years after Plaintiff introduced its competing Luxer Room product (Compl. ¶15).
IV. Analysis of Infringement Allegations
’675 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one electronic lock for locking a door of a storage room that is stationary and part of a building... | The Accused Products comprise a system with an electronic lock for a package room in a building, designed to accommodate packages of various sizes. | ¶25 | col. 4:33-41 |
| a lock interface that is communicatively coupled to the at least one electronic lock, the lock interface having at least one processor... | The Accused Products include a panel or intercom mounted at the package room door which functions as a lock interface containing a processor and is coupled to the electronic lock. | ¶26 | col. 9:8-12 |
| receiving, at the lock interface from a terminal, a first signal associated with a delivery, requesting access by unlocking the door... | Couriers use the panel (terminal) to enter a PIN, which constitutes a signal requesting access to the package room for a delivery. | ¶27 | col. 8:41-45 |
| opening the electronic lock... regardless of whether a storage area associated with the door is in use and regardless of whether the package is small, medium, or oversized... | The system allows access to the communal package room, which by nature operates regardless of existing packages or package sizes. | ¶27 | col. 4:26-33 |
| wherein the request includes at least a user identity and a code... verifying, by the lock interface... by authenticating the user identity and the code received from the terminal... | The courier's entry of a PIN at the panel is alleged to represent a "user identity and a code," which the system authenticates to grant access. | ¶28 | col. 8:46-49 |
| comparing, by the lock interface, the user identity and the code received from the terminal with data stored in the lock interface... | The Accused Products allegedly authenticate codes by comparing them to data. The complaint alleges on information and belief that access codes are stored locally. | ¶30 | col. 8:1-2 |
| approving the request... when the user identity and the code received match the data stored... and rejecting the request... when... does not match... | The system allegedly approves access when the entered PIN matches stored data and rejects it otherwise. | ¶30 | col. 8:5-18 |
| in response to the rejecting of the request, sending, from the lock interface to the terminal, a message indicating that the request is invalid. | The complaint does not provide specific factual allegations for this element but makes a conclusory allegation that all elements of claim 1 are met. | ¶30 | col. 8:15-18 |
- Identified Points of Contention:
- Scope Questions: A central issue may be the scope of "data stored in the lock interface." The complaint alleges on information and belief that data is stored locally (Compl. ¶30), but also cites Defendant's marketing of "seamless PMS integration" and real-time directory updates, which suggests reliance on a remote, networked database (Compl. ¶18). The case may turn on whether a system that authenticates against a remote server can meet the "stored in the lock interface" limitation.
- Technical Questions: The claim requires verifying a "user identity" and a "code." The complaint alleges that a courier's or resident's PIN fulfills this dual requirement (Compl. ¶¶17, 28). A question for the court will be whether a single PIN can be proven to function as both a distinct "user identity" and a "code" as required by the claim language, or if this represents a potential mismatch in operation.
V. Key Claim Terms for Construction
The Term: "lock interface"
Context and Importance: This term defines the central control component of the claimed invention. The complaint maps this term to the "panel mounted at the package room door" in the accused system (Compl. ¶¶16, 26). The construction of this term will be critical for determining the physical and logical boundaries of the infringing system, particularly whether it is a self-contained local controller or can encompass a distributed, network-connected architecture.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines a lock interface as a "device and/or a system" that is "communicatively connected" to the locks and includes a "controller with circuits" (’675 Patent, col. 9:8-21). This language may support an interpretation that includes networked components.
- Evidence for a Narrower Interpretation: The claim requires "the processor of the lock interface" to implement the method steps, which could suggest a more localized, self-contained unit (’675 Patent, col. 7:22-26). Figures such as FIG. 1A(2) depict the "lock interface 112" as a discrete component between the network and the locks, which could be argued to support a narrower construction.
The Term: "data stored in the lock interface"
Context and Importance: The "comparing" step of the claim, which is core to the authentication process, acts upon this data. The location of this data—whether it must be physically stored in the local "lock interface" or can be accessed from a remote server—is a pivotal question for infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly prohibit the lock interface from communicating with a server to retrieve or verify data. Practitioners may argue that "stored in" could be interpreted as "accessible by" the lock interface's processor for the purpose of the comparison.
- Evidence for a Narrower Interpretation: The plain language "stored in the lock interface" suggests local storage within the physical component defined as the interface. The complaint itself appears to anticipate this dispute, alleging on "information and belief" that "access codes are stored locally, and authentication is done using locally stored data," even while citing Defendant's marketing of cloud-dependent features like real-time property management software integration (Compl. ¶¶ 18, 30).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by "actively aiding and abetting" customers and end-users to infringe, supported by allegations of advertising and distributing the Accused Products (Compl. ¶31). It alleges contributory infringement on the basis that the Accused Products are a material part of the invention, are especially adapted for infringing use, and are not a staple article of commerce (Compl. ¶32).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported awareness of "Luxer and the Luxer Room, which Luxer introduced in 2015, and identifies as being patented" (Compl. ¶33). This allegation appears to ground pre-suit knowledge in awareness of a competitor's product, rather than specific knowledge of the ’675 Patent, which was issued in 2023, after the accused product's launch.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of system architecture and claim scope: Can the limitation "data stored in the lock interface" be construed to cover a system that authenticates users by communicating with a remote, networked database, as suggested by the defendant's marketing materials? The resolution of this claim construction dispute may be dispositive of infringement.
- A key evidentiary question will be one of functional satisfaction: Does the accused system's use of a single PIN for access satisfy the claim's requirement for both a "user identity" and a "code"? The parties will likely dispute whether the single data point provided by the user performs the distinct functions required by the claim.