DCT
1:24-cv-00603
Luxer Corporation v. Package Concierge, Inc.
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Luxer Corporation (Delaware)
- Defendant: Package Concierge, Inc. (Delaware)
- Plaintiff’s Counsel: Shaw Keller LLP; Wolf, Greenfield & Sacks, P.C.
- Case Identification: 1:24-cv-00603, D. Del., 05/20/2024
- Venue Allegations: Venue is asserted in the District of Delaware based on Defendant's incorporation in the state.
- Core Dispute: Plaintiff alleges that Defendant’s Access-Controlled Package Rooms infringe a patent related to systems and methods for controlling access to a storage room.
- Technical Context: The technology concerns automated, secure package management systems for buildings, a market segment that has grown in importance with the expansion of e-commerce.
- Key Procedural History: The complaint notes that Plaintiff launched its "Luxer Room" product, which it states features "patented technology," in 2015. It alleges Defendant began offering the accused products in 2020. The patent-in-suit issued in 2023.
Case Timeline
| Date | Event |
|---|---|
| 2014-10-02 | Earliest Priority Date for '675 Patent |
| 2015-01-01 | Plaintiff's "Luxer Room" product launch (During 2015) |
| 2020-01-01 | Defendant's Accused Products launch (During 2020) |
| 2023-04-11 | '675 Patent Issued |
| 2024-05-20 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,625,675 - Method and system for controlling a storage room
- Patent Identification: U.S. Patent No. 11,625,675, Method and system for controlling a storage room, issued April 11, 2023 (the "’675 Patent"). (Compl. ¶12; ’675 Patent, cover).
The Invention Explained
- Problem Addressed: The patent addresses challenges in providing secure, automated access to storage areas, recognizing the issues inherent in controlling electronic locks for shared spaces like package rooms. (’675 Patent, col. 1:47-53).
- The Patented Solution: The invention is a system for managing access to a storage room via an electronic lock. As described, a user interacts with a terminal or kiosk to submit a request with credentials, which is then verified by a lock interface. (’675 Patent, Abstract; Fig. 1A(1)). If the credentials are valid, the system sends a signal to unlock the door; if not, it sends a rejection message. (’675 Patent, Abstract; col. 4:46-65). The system is designed to handle packages of various sizes, accommodating those too large for standard individual lockers. (Compl. ¶22).
- Technical Importance: This technology provides an automated solution for managing the increasing volume of package deliveries, particularly oversized items, in multifamily residential and commercial buildings, which is a significant logistical challenge for property managers. (Compl. ¶¶9, 24).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1. (Compl. ¶21).
- The essential elements of independent claim 1 include:
- An electronic lock for a stationary storage room large enough for oversized packages.
- A communicatively coupled lock interface with a processor and stored machine instructions.
- The instructions cause the processor to implement a method of receiving a first signal with a delivery request, sending a second signal to open the door, and allowing access.
- The request must include a user identity and a code, which the lock interface verifies and approves upon successful authentication.
- The approval triggers the sending of the second signal, which causes the electronic lock to automatically unlock via a specified circuit.
- The verification step involves comparing the received user identity and code with data stored in the lock interface, and approving or rejecting the request based on whether the data matches.
(Compl. ¶22; ’675 Patent, col. 57:41-58:34).
III. The Accused Instrumentality
Product Identification
- Defendant’s "Access-Controlled Package Rooms" ("Accused Products"). (Compl. ¶14).
Functionality and Market Context
- The Accused Products are described as "smart room" systems designed to manage package deliveries and provide secure 24/7 resident access, particularly for items too large for automated locker systems. (Compl. ¶¶16, 24).
- The system's core user-facing component is a "sleek surface-mounted kiosk" that contains a computer, touchscreen, barcode reader, and camera. (Compl. ¶16). A photograph provided in the complaint depicts a kiosk with a touchscreen mounted on the wall outside a package room, with the door open to show packages stored on shelves inside. (Compl. p. 5).
- Functionality is allegedly enabled by "Proprietary cloud-based software" and requires an internet connection via Ethernet or Wi-Fi. (Compl. ¶17, ¶29). Another photograph shows the interior of an accused package room with packages organized on multi-level shelving. (Compl. p. 12).
IV. Analysis of Infringement Allegations
'675 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system comprising: at least one electronic lock for locking a door of a storage room that is stationary and part of a building, the storage room being large enough to accommodate packages that are small, medium, and oversized; | The Accused Products are systems comprising an electronic lock for a "smart room" that provides "secure space for packages that are too large to fit in the automated locker system." | ¶24 | col. 5:14-20 |
| a lock interface that is communicatively coupled to the at least one electronic lock, the lock interface having at least one processor that implements one or more machine instructions...; | The Accused Products comprise a kiosk that serves as a lock interface, which is communicatively coupled to the electronic lock and contains a computer (processor) that implements machine instructions. | ¶25 | col. 9:8-12 |
| wherein the one or more machine instructions, when implemented, cause the processor of the lock interface to implement a method including at least receiving, at the lock interface from a terminal, a first signal...requesting access...; opening the electronic lock... | The processor in the Accused Products' kiosk allegedly implements a method of receiving access requests from a terminal, which causes the system to unlock the door to the storage room to allow for package delivery and retrieval, regardless of package size. The complaint includes a photograph of the accused kiosk's "TOUCH SCREEN TO BEGIN" interface. (Compl. p. 6). | ¶26 | col. 19:61-20:6 |
| wherein the request includes at least a user identity and a code, wherein the method further includes... verifying, by the lock interface, the request by authenticating the user identity and the code...; approving the request... | The Accused Products allegedly receive a request that includes a user identity and a code. The system then allegedly verifies the request by authenticating these credentials before approving access. The complaint alleges the system includes "intuitive software for delivery carrier ease of use." (Compl. p. 13). | ¶27 | col. 20:7-28 |
| in response to the approving of the request, sending the second signal...causing the at least one electronic lock to automatically unlock, the at least one electronic lock including a circuit that includes at least a signal input port...an electronic switch... | Upon successful authentication, the Accused Products allegedly send a signal that causes the electronic lock to unlock automatically via a circuit. The complaint alleges the products provide "24/7 resident access, all with the touch of a few buttons!" (Compl. p. 13). | ¶28 | col. 13:35-14:14 |
| the step of verifying...further including at least comparing, by the lock interface, the user identity and the code received from the terminal with data stored in the lock interface; approving...when the user identity and code received match...and rejecting...when...does not match... | The Accused Products allegedly perform verification by comparing the user identity and code with stored data. The complaint alleges that "access codes are stored locally, and authentication is done using locally stored data." It also alleges the products use "Proprietary cloud-based software" and require an internet connection. | ¶29 | col. 20:15-40 |
Identified Points of Contention
- Scope Questions: Claim 1 requires a "lock interface" to receive a signal from a "terminal". The complaint appears to allege that Defendant's kiosk fulfills the role of the "lock interface". This raises the question of what component constitutes the "terminal" in the accused system. The analysis may focus on whether the claim requires two structurally distinct components or if the kiosk's architecture allows it to embody both the "lock interface" and the "terminal" from which it receives signals.
- Technical Questions: The claim requires the verification step to include "comparing... with data stored in the lock interface." (Compl. ¶22). The complaint alleges both that "access codes are stored locally" and that the system uses "cloud-based software." (Compl. ¶¶17, 29). This creates a central factual question: What evidence does the complaint provide that the accused product performs authentication by comparing credentials against data stored locally in the kiosk (the alleged "lock interface"), as opposed to performing this comparison on a remote server via its cloud-based software? A mismatch on this point could be significant for the infringement analysis.
V. Key Claim Terms for Construction
- The Term: "lock interface"
- Context and Importance: This term defines a core component of the claimed system. Its construction is critical because the claim requires that authentication data be "stored in the lock interface." Practitioners may focus on this term because its scope—whether it is limited to a local device or can encompass distributed, cloud-based components—will be central to determining infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "lock interface" as "a device and/or a system" that can be communicatively connected to a network, which could support an interpretation that includes remote or distributed elements. (’675 Patent, col. 9:8-12, 9:36-41).
- Evidence for a Narrower Interpretation: The claim language recites "comparing... with data stored in the lock interface," which suggests a local data storage and comparison function. (’675 Patent, col. 58:20-22). Additionally, Figure 1A(2) depicts the "Lock Interface 112" as a distinct block separate from the "Network 140", potentially supporting a narrower construction as a self-contained local unit. (’675 Patent, Fig. 1A(2)).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant actively aids and abets infringement by advertising, distributing, and providing instructions for its Accused Products. (Compl. ¶30). It also alleges contributory infringement on the basis that the Accused Products are especially made for infringing use and are not staple articles of commerce suitable for substantial non-infringing use. (Compl. ¶31).
- Willful Infringement: Willfulness is alleged based on Defendant's purported pre-suit knowledge of Luxer and its "Luxer Room" product, which the complaint states Luxer "identifies as being patented." (Compl. ¶32). This allegation appears to be based on general market awareness rather than a specific notice of infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "lock interface", which the claim requires to perform verification using locally "stored data," be construed to read on the accused system, which allegedly utilizes "cloud-based software"? The interpretation of this limitation's geographical and architectural scope may be dispositive.
- A key evidentiary question will be one of technical operation: does the accused system, in fact, perform authentication locally at its kiosk, or is that function offloaded to a remote server? Discovery regarding the system's software architecture and data flow will be crucial to resolving the factual dispute over where the "comparing" step of the claim actually occurs.