Woodstream Corp 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)
  • Plaintiff’s Counsel: Womble Bond Dickinson (US) LLP; Barley Snyder
• Case Identification: 1:24-cv-01236, D. Del., 01/30/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware.
• Core Dispute: Plaintiffs allege that Defendant’s line of smart bird feeders infringes a patent related to a self-contained bird feeder with an integrated camera for streaming video over a wireless network.
• Technical Context: The technology at issue operates within the consumer market for "smart home" and internet-of-things (IoT) devices, specifically applying integrated camera and wireless communication technology to wildlife observation products.
• Key Procedural History: The complaint alleges that the patent’s inventor, Frederick Perkins, contacted Defendant on May 14, 2023, to offer a license to the recently issued patent-in-suit. Following a brief correspondence, Plaintiffs allege no further communications were received from Defendant. These allegations form the basis for the willfulness claim.

Case Timeline

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.

The Invention Explained

• Problem Addressed: The patent background describes a need for improved bird feeders, specifically those that are self-contained and capable of providing streaming video, suggesting a gap in the market for integrated, mobile, and internet-connected observation feeders (’242 Patent, col. 2:1-6).
• The Patented Solution: The invention is a bird feeder that incorporates a camera, a computer controller (such as a Raspberry Pi), an internal power source (e.g., a battery), and a wireless internet connection, all within the feeder's housing (’242 Patent, col. 2:15-22; Fig. 4). This design allows the feeder to operate as a self-contained unit that can capture images and stream live video of feeding birds to a remote user over the internet (’242 Patent, col. 2:40-48).
• Technical Importance: This approach integrates several common technologies into a novel application, creating a standalone device for wildlife observation that does not require external wiring for power or data, thereby increasing its versatility and ease of deployment (’242 Patent, col. 2:4-6).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 3 (’242 Patent, Compl. ¶14).
• Independent Claim 1 requires:
  • A bird feeder with a built in camera, computer, and internet connection
  • A feeder housing
  • A feeder bottom
  • A feed port disposed on the feeder bottom
  • The camera internally mounted to the bird feeder such that the camera is aligned with the feed port to observe feeding birds
  • The computer located within the feeder housing
  • An internal power source
  • A WiFi adapter located within the feeder housing
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint names the Bird Buddy Smart Bird Feeder, Bundled Bird Feeders (including PRO and Solar versions), the Smart Hummingbird Feeder, and the Birdbuddy 2 Smart Feeder as the accused instrumentalities (Compl. ¶12, 24, 27, 33).

Functionality and Market Context

• The accused products are described as self-contained bird feeders that provide detailed images over a wireless network (Compl. ¶14, 29, 40). They feature an internally mounted camera designed to capture images of birds at the feeder (Compl. ¶15-16). The complaint alleges the camera is a module that is inserted into the feeder housing and secured by a magnet and an optional screw (Compl. ¶19-21). A photograph provided in the complaint as Exhibit D is described as showing the internal compartment and magnet for mounting the camera (Compl. ¶19). The complaint also asserts that the camera is shaped to fit a specific opening and only works when integrated with the feeder housing, lacking standalone functionality (Compl. ¶17, 23).

IV. Analysis of Infringement Allegations

’242 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may arise over whether the accused products' integrated camera module, which likely contains a system-on-a-chip (SoC), meets the claim limitations of a "computer" and a "WiFi adapter" as distinct components located "within the feeder housing." The patent’s specification details an embodiment using a Raspberry Pi computer and a separate WiFi dongle (’242 Patent, col. 4:47-53), which could be used to argue for a narrower construction requiring physically separate components.
• Technical Questions: The complaint alleges the camera is "internally mounted" via a magnet and optional screw (Compl. ¶19-21). A question for the court may be whether this user-removable, magnetically-coupled module meets the "mounted to" limitation, especially when compared to the patent’s embodiment describing a camera attached by "four bolts that extend from the feeder shell" (’242 Patent, col. 4:36-38).

V. Key Claim Terms for Construction

• The Term: "computer"

• Context and Importance: The definition of "computer" is critical. The infringement analysis may turn on whether the term is construed broadly to cover any processing unit, such as an integrated SoC within the camera module, or more narrowly to mean a general-purpose, programmable device like the Raspberry Pi explicitly described in the patent's preferred embodiment (’242 Patent, col. 4:45-46).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim itself simply recites "a computer" without further qualification (’242 Patent, col. 7:9), and the patent summary describes a "computer controller" generally (’242 Patent, col. 2:41).
  • Evidence for a Narrower Interpretation: The specification's only detailed example of a "computer" is a "Raspberry Pi B+ computer" (’242 Patent, col. 4:45-46), which is a specific type of single-board computer. This detailed embodiment could support an argument that the term should be limited to devices with similar architecture.

• The Term: "internally mounted to the bird feeder"

• Context and Importance: The complaint describes the accused camera as a removable module that fits into the feeder housing (Compl. ¶17, 36). Practitioners may focus on this term because the method of attachment could create a non-infringement argument if "mounted to" is construed to require a more permanent or integral fixation than the magnetic coupling alleged.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The plain language of the claim does not specify a particular method of mounting, leaving room for various forms of attachment that are "internal."
  • Evidence for a Narrower Interpretation: The detailed description discloses an embodiment where the camera is "attached to the feeder by four bolts that extend from the feeder shell" (’242 Patent, col. 4:36-38). This language suggests a semi-permanent installation and may be used to argue against the accused products' user-removable, magnetically-seated camera module.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by providing the accused products to customers with the knowledge and specific intent that the customers will use them in an infringing manner. It is also alleged that the products have no substantial non-infringing use (Compl. ¶13, 25, 28, 31, 34).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported pre-suit knowledge of the ’242 Patent. The complaint pleads that the inventor contacted Defendant on May 14, 2023, identifying the patent and the accused products and offering a license, but that no license was taken (Compl. ¶41-44).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of component scope: does the claim language requiring a distinct "computer" and "WiFi adapter" read on the likely integrated system-on-a-chip (SoC) architecture of the accused modern smart feeders, or does the patent's specific embodiment of a Raspberry Pi with a separate WiFi dongle limit the claim scope to a multi-component system?
• A second key question will involve definitional scope: can the term "mounted to," as taught in a patent embodiment using bolts for fixation, be construed to cover the accused product's magnetically-coupled and user-removable camera module?
• Finally, a central factual dispute for damages will be the question of willfulness, which will depend on the evidence surrounding the alleged pre-suit licensing communications between the inventor and Defendant.