DCT
1:24-cv-00604
Luxer Corporation v. Parcel Pending, Inc.
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Luxer Corp (Delaware)
- Defendant: Parcel Pending Inc (Delaware)
- Plaintiff’s Counsel: Shaw Keller LLP
- Case Identification: 1:24-cv-00604, 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 Package Room Solutions for controlled-access package management infringe a patent related to systems and methods for controlling access to a storage room.
- Technical Context: The technology addresses the logistical challenges of managing high-volume package deliveries in multi-family residential and commercial buildings, a market that has grown significantly with the rise of e-commerce.
- Key Procedural History: The complaint alleges that Plaintiff launched its "Luxer Room" product in 2015, which it publicly identified as utilizing patented technology. This allegation may be used to support claims of willful infringement by suggesting Defendant had pre-suit awareness of Plaintiff's patented technology in the same market.
Case Timeline
| Date | Event |
|---|---|
| 2014-10-02 | Earliest Priority Date for U.S. Patent No. 11,625,675 |
| 2015-01-01 | Plaintiff's "Luxer Room" product launched (approximate date) |
| 2021-06-01 | Defendant began offering Accused Products for sale (approximate date) |
| 2023-04-11 | U.S. Patent No. 11,625,675 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 Invention Explained
- Problem Addressed: The patent recognizes technical issues in controlling electronic locks for storage areas, while the complaint contextualizes this problem as the "daunting task for property managers to keep track of packages and ensure timely delivery to residents" in multi-family communities due to increased online shopping (Compl. ¶9; ’675 Patent, col. 1:53-54).
- The Patented Solution: The invention is a system that automates access to a secure storage room. A central "lock interface" or kiosk receives an access request from a user (e.g., a courier or resident) who provides credentials like a code. The system verifies these credentials and, if approved, sends an electronic signal to unlock the door, managing both package drop-off and retrieval workflows (’675 Patent, Abstract; Fig. 1A(2)).
- Technical Importance: The technology provides a secure, automated solution for package management, aiming to reduce the logistical burden on building staff and streamline the delivery and retrieval process for couriers and residents (Compl. ¶9).
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:
- A system with an electronic lock for a storage room door.
- A lock interface communicatively coupled to the lock, with a processor and stored instructions.
- The processor implements a method that includes: receiving a first signal from a terminal requesting access; sending a second signal to the lock to open the door; and opening the lock.
- The request includes a user identity and a code.
- The method further includes verifying the request by authenticating the user identity and code.
- The verification step includes comparing the received user identity and code with data stored in the lock interface, approving if they match, and rejecting if they do not.
- The second signal (to unlock the door) is sent only after the request is approved.
III. The Accused Instrumentality
Product Identification
Defendant’s "Package Room Solutions" ("Accused Products") (Compl. ¶14).
Functionality and Market Context
The Accused Products are described as providing "A Secure Room with Controlled Access" for package delivery (Compl. ¶17). The system's operation involves couriers delivering packages into a secure room using a "unique access code," after which residents are notified and provided an "individual access code" for retrieval (Compl. ¶17). The complaint includes a marketing image of the accused system's lock interface, showing a touchscreen keypad mounted on the wall next to the package room door (Compl. ¶25, p. 8). The complaint alleges these products are "Versatile," with "100% deliverability for multiple package sizes" (Compl. ¶16).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,625,675 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 a system with an electronic lock for a "Secure Room with Controlled Access" that is described as "Versatile" for "multiple package sizes." | ¶24 | col. 4:41-47 |
| 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 lock interface with a processor and machine instructions. A provided image shows a touchscreen keypad interface next to a room door. | ¶25 | col. 9:8-11 |
| receiving, at the lock interface from a terminal, a first signal associated with a delivery, requesting access by unlocking the door; | Couriers and residents use the lock interface to enter an access code to request entry to the secure room. | ¶26, ¶17 | col. 7:46-54 |
| 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 received from the terminal; | The system uses "unique access code[s]" for couriers and "individual access code[s]" for residents to authenticate and grant access. | ¶27, ¶17 | col. 8:1-17 |
| 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 the request... when the user identity and the code received match the data stored... and rejecting the request... when... does not match... | It is alleged that the Accused Products require internet access to be able to authenticate codes, and that "access codes are stored locally, and authentication is done using locally stored data." | ¶29 | col. 6:58-65 |
| in response to the approving of the request, sending the second signal, from the lock interface to the at least one electronic lock, the second signal causing the at least one electronic lock to automatically unlock... | Upon successful authentication of an access code, the system grants access by unlocking the door to the secure room. | ¶28, ¶26 | col. 7:55-60 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges both that the Accused Products "require Internet access to be able to authenticate the codes" and that "authentication is done using locally stored data" (Compl. ¶29). This raises a central question of claim scope: does the limitation "comparing... with data stored in the lock interface" require the authentication data to reside physically on the local device, or can it be satisfied by a device that queries a remote server over the internet? The resolution of this issue will depend on the court's construction of the term "lock interface" and the phrase "data stored in the lock interface".
- Technical Questions: Claim 1 requires comparing a "user identity and a code." The complaint repeatedly refers to a single "access code" (Compl. ¶17, ¶27). A factual question for discovery will be whether the Accused Products distinguish between a "user identity" and a "code" as separate data points during the authentication process, as required by the claim language.
V. Key Claim Terms for Construction
- The Term: "lock interface"
- Context and Importance: The definition of this term is critical because the claim requires authentication to occur via "comparing... with data stored in the lock interface" ('675 Patent, col. 6:58-60). The complaint’s allegation that the accused system uses an internet connection for authentication puts the physical and logical boundaries of the "lock interface" at the center of the dispute (Compl. ¶29). Practitioners may focus on this term because its scope—whether it is limited to on-site hardware or can include networked components—could be determinative of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent depicts the "lock interface 112" as part of a larger networked system, communicating with a "control terminal 110" (which can be a server) and "user devices 130a-n" via a "network 140" ('675 Patent, Fig. 1A(2)). This may support an argument that the "lock interface" is not a standalone component but a system element that works in concert with remote resources.
- Evidence for a Narrower Interpretation: Claim 1 recites that the lock interface itself performs the comparing and approving steps with data "stored in" it ('675 Patent, col. 6:55-65). The specification shows a block diagram where a computer system that can serve as the "lock interface" includes its own "processor system 402" and "memory system 406" containing a "user database 408", suggesting a self-contained unit capable of local authentication ('675 Patent, Fig. 4A).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant’s advertising and user instructions for the Accused Products encourage and facilitate infringing use by its customers (e.g., property managers, couriers, and residents) (Compl. ¶30). Contributory infringement is also alleged on the basis that the Accused Products are especially adapted for infringing use and are not staple articles of commerce (Compl. ¶31).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of Plaintiff’s "Luxer Corp Room" product, which was launched in 2015 and allegedly identified in the market as being "patented" (Compl. ¶32). The complaint provides a screenshot from Plaintiff's website stating "2015 Luxer Corp ROOM Patented new product, Luxer Room, hits the market" as evidence supporting this allegation of pre-suit knowledge (Compl. ¶32, p. 11).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and construction: can the claim phrase "data stored in the lock interface" be construed to read on a system that, as alleged in the complaint, requires an internet connection to a remote server to authenticate users? The outcome will likely depend on whether the "lock interface" is interpreted as a purely local device or a gateway to a distributed system.
- A key evidentiary question will be one of technical implementation: discovery will need to establish the precise architecture of the Accused Products. Specifically, where does the authentication logic reside and operate? Answering this will determine whether there is a literal match with the claim's requirement that the "lock interface" itself performs the comparison of credentials with data "stored in" it.