DCT
1:24-cv-01236
Woodstream Corporation v. Bird Buddy, Inc.
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Woodstream Corporation (Pennsylvania) and Frederick Perkins (Massachusetts)
- Defendant: Bird Buddy, Inc. (Delaware/Michigan)
- Plaintiff’s Counsel: Womble Bond Dickinson (US) LLP; Barley Snyder
- Case Identification: 1:24-cv-01236, D. Del., 02/05/2025
- Venue Allegations: Venue is asserted in the District of Delaware based on Defendant’s incorporation in that state.
- Core Dispute: Plaintiffs allege that Defendant’s line of smart bird feeders infringes a patent related to a self-contained bird feeder incorporating a camera for streaming video over a wireless network.
- Technical Context: The technology integrates consumer electronics and wireless connectivity into traditional wildlife observation products, a segment of the growing Internet of Things (IoT) market.
- Key Procedural History: The complaint alleges that inventor Frederick Perkins contacted Defendant via email on May 14, 2023, to discuss licensing the patent-in-suit. Defendant allegedly acknowledged the patent in a response dated May 18, 2024. These communications may be central to Plaintiffs' allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-06-10 | ’242 Patent Priority Date |
| 2023-04-11 | ’242 Patent Issue Date |
| 2023-05-14 | Plaintiff Perkins allegedly emails Defendant regarding a license for the ’242 Patent |
| 2023-05-26 | Plaintiff Perkins allegedly sends subsequent email regarding licensing negotiations |
| 2024-05-18 | Defendant allegedly responds to Plaintiff Perkins regarding the ’242 Patent |
| 2025-02-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,627,242 - "Self-Contained Bird Feeder with Camera and Streaming Video"
- Patent Identification: U.S. Patent No. 11,627,242 (“Self-Contained Bird Feeder with Camera and Streaming Video”), issued April 11, 2023. (Compl. ¶8).
The Invention Explained
- Problem Addressed: The patent seeks to provide "improved viewing and of birds at a feeder" by creating a single, integrated device that does not rely on external components for operation. (’242 Patent, col. 2:1-3).
- The Patented Solution: The invention is a "self-contained platform" for capturing and streaming video of feeding birds over the internet. (’242 Patent, col. 2:4-6). It achieves this by integrating a camera, a computer controller (such as a Raspberry Pi), an internal power source (like a battery), and a WiFi adapter directly within the housing of a bird feeder. (’242 Patent, col. 1:40-49; Fig. 4). The camera is specifically positioned to be aligned with a feed port to observe birds as they eat. (’242 Patent, col. 2:40-45).
- Technical Importance: The patented approach combines a traditional consumer product with accessible, low-cost computing and wireless technology to create a mobile, untethered IoT device for wildlife observation. (’242 Patent, col. 2:4-6).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claim 3. (Compl. ¶14).
- Independent Claim 1 requires:
- A self-contained bird feeder configured to provide detailed images over a wireless network
- Comprising a feeder housing and a feeder bottom
- A feed port disposed on the feeder bottom
- A camera internally mounted to the bird feeder and aligned with the feed port
- A computer located within the feeder housing
- An internal power source located within the feeder housing
- A WiFi adapter located within the feeder housing
- The complaint does not explicitly reserve the right to assert additional claims.
III. The Accused Instrumentality
Product Identification
The accused products include the "Bird Buddy Smart Bird Feeder," the "Smart Hummingbird Feeder," and various bundled versions of these products such as those with a solar roof or "PRO" models. (Compl. ¶¶12, 24, 27, 30).
Functionality and Market Context
The complaint alleges the accused products are "self-contained bird feeder[s]" that provide "detailed images over a wireless network." (Compl. ¶14). The functionality centers on a camera that is internally mounted within the feeder housing and aligned to observe feeding birds. (Compl. ¶15). The complaint emphasizes the integrated nature of the device, alleging the camera is specifically shaped to fit the feeder, is secured internally by a magnet and optional screw, and "cannot operate as a standalone device." (Compl. ¶¶17, 19, 23). The complaint includes a photograph, attached as Exhibit D, that depicts the accused product's rear hatch door and internal compartment. (Compl. ¶18). Another visual, Exhibit B, is referenced as showing the Smart Bird Feeder. (Compl. ¶12).
IV. Analysis of Infringement Allegations
The complaint does not include a claim chart exhibit, but alleges infringement based on the features of the accused products.
’242 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A self-contained bird feeder configured to provide detailed images over a wireless network... | The accused Smart Bird Feeder is described as a "self-contained bird feeder" that "provides detailed images over a wireless network." | ¶14 | col. 7:2-4 |
| a feeder housing; b. a feeder bottom; c. a feed port disposed on the feeder bottom... | The accused product is a bird feeder with a housing that contains feed and a specifically designed opening for birds to access it. | ¶16 | col. 7:5-7 |
| the camera internally mounted to the bird feeder such that the camera is aligned with the feed port to observe feeding birds... | The accused product's camera is allegedly "internally mounted to the bird feeder" and "aligned to observe feeding birds" through a "specifically designed opening." | ¶¶15-16 | col. 7:7-10 |
| the computer located within the feeder housing... | The complaint alleges the product is a "self-contained" device that provides images wirelessly, which implies an internal computer or processor. | ¶14 | col. 7:10-11 |
| an internal power source... | The product's self-contained nature implies an internal power source. | ¶14 | col. 7:12 |
| a WiFi adapter located within the feeder housing. | The product's ability to provide images over a "wireless network" implies the presence of a WiFi adapter or equivalent wireless transmitter. | ¶14 | col. 7:12-13 |
- Identified Points of Contention:
- Scope Questions: A central issue may be the construction of "computer." The complaint does not specify the type of processing unit in the accused device. The defense may argue that its device uses a specialized microcontroller or application-specific integrated circuit (ASIC) that does not meet the definition of a "computer" as contemplated by the patent, which provides a "Raspberry Pi B+" as its primary example. (’242 Patent, col. 3:22).
- Technical Questions: The complaint emphasizes that the accused camera "cannot operate as a standalone device." (Compl. ¶23). While this fact may support the argument that the camera is "internally mounted" and integrated, the claims do not explicitly require non-standalone functionality. The dispute will focus on whether the components of the accused device, as they are arranged and operate, meet the structural and functional requirements of the claim language itself.
V. Key Claim Terms for Construction
The Term: "computer"
Context and Importance: This term is critical because the nature of the processing unit within the accused device is not detailed in the complaint. The definition of "computer" could determine infringement. Practitioners may focus on this term because if the accused device's processor is deemed not to be a "computer," a core element of the claim would not be met.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself simply recites "a computer" without further qualification, suggesting it should be given its plain and ordinary meaning, which could encompass a wide range of processing devices. (’242 Patent, col. 7:10-11).
- Evidence for a Narrower Interpretation: The specification's only detailed embodiment uses a "Raspberry Pi B+ computer," a general-purpose programmable device. (’242 Patent, col. 4:46-47). A defendant may argue that this repeated, specific example limits the term "computer" to devices with similar general-purpose capabilities, as opposed to a more limited-function processor.
The Term: "self-contained"
Context and Importance: This term appears in the patent's title and the preamble of the asserted independent claim. Its construction could be important for defining the overall scope of the invention, particularly regarding the integration of the power source and other components.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term could be interpreted to mean the device is capable of operation without being physically tethered to an external power or data source, containing all necessary components for its primary function within its housing. (’242 Patent, col. 2:4-6).
- Evidence for a Narrower Interpretation: The specification describes a battery as the internal power source and also discusses the possibility of augmentation with solar panels. (’242 Patent, col. 2:18, col. 2:26-32). A dispute could arise over whether a model that relies on a physically separate but connected solar panel (as some of the accused bundled products may include) still qualifies as "self-contained."
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, stating that Defendant was aware of the ’242 Patent and "specifically intended its customers to use the Smart Bird Feeder," which has "no substantial non-infringing use." (Compl. ¶13).
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It claims the inventor, Mr. Perkins, sent an email to Defendant on May 14, 2023, referencing the ’242 Patent and Bird Buddy products, and that Defendant later responded. (Compl. ¶¶33-35, 42).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "computer," as used in the patent and exemplified by a "Raspberry Pi," be construed to read on the specific processing hardware used in the accused Bird Buddy feeders, or will Defendant be able to distinguish its technology as falling outside the claim’s scope?
- A second key question will be one of evidentiary proof: beyond the product's external features and marketing claims, what evidence will emerge during discovery about the internal architecture of the accused devices, and will that evidence demonstrate the presence of each element required by the asserted claims, particularly the "computer" and "internal power source"?