DCT

8:22-cv-00272

Edst LLC v. iApartments Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:22-cv-00272, M.D. Fla., 02/01/2022
  • Venue Allegations: Venue is alleged to be proper because the Defendant is a Florida company with a regular and established place of business within the Middle District of Florida.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home systems for multi-family properties infringe three patents related to using a smart thermostat hub to remotely manage and control offline smart devices, particularly door locks.
  • Technical Context: The technology at issue is in the Internet-of-Things (IoT) sector, specifically addressing smart access control and property management in the multi-family residential market.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement of the ’273 Patent, including a claim chart, on August 6, 2021. It further alleges that Defendant’s counsel acknowledged the ’685 Patent and the application that issued as the ’118 Patent on September 15, 2021, and that Plaintiff provided a claim chart for the ’118 Patent on January 7, 2022. This alleged pre-suit notice forms the basis for the willfulness allegations.

Case Timeline

Date Event
2018-10-16 Priority Date for ’273, ’685, and ’118 Patents
2019 Defendant iAPARTMENTS, INC. incorporated
2020-10-13 U.S. Patent No. 10,803,685 issues
2020-11-03 U.S. Patent No. 10,825,273 issues
2021-08-06 Plaintiff provides notice of ’273 Patent infringement to Defendant
2021-09-15 Defendant’s counsel acknowledges existence of ’685 Patent and application for ’118 Patent
2021-11-30 U.S. Patent No. 11,189,118 issues
2022-01-07 Plaintiff provides claim chart for ’118 Patent to Defendant
2022-02-01 Complaint filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,825,273 - "Smart Thermostat Hub"

The Invention Explained

  • Problem Addressed: The patent’s background section describes the high cost and complexity of deploying "online" smart locks, which connect directly to the internet, in multi-family residential properties. Cheaper "offline" locks solve the cost problem but create a security issue, as managing access credentials (e.g., disabling a lost key fob) requires a physical, in-person visit to the lock with a special programming device. (’273 Patent, col. 1:43-61).
  • The Patented Solution: The invention uses a smart thermostat as a local communication hub or gateway. The thermostat hub communicates with a central property management platform over a long-range Wide Area Network (WAN) and simultaneously communicates with the nearby offline door lock over a separate, short-range non-WAN link. This architecture allows property managers to send commands, such as one to disable a specific access credential, from the central platform to the thermostat hub, which then relays the command to the otherwise disconnected offline lock, solving the security problem without requiring expensive network infrastructure for each individual lock. (’273 Patent, col. 2:24-39; Fig. 1).
  • Technical Importance: This approach significantly lowers the barrier to entry for deploying secure, remotely manageable smart access systems in older properties (e.g., "Class B and C") that lack pre-existing network wiring to each door. (’273 Patent, col. 4:15-20).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and notes that it is representative of claims 18 and 26. (Compl. ¶¶19, 23).
  • Independent Claim 1 of the ’273 Patent includes the following essential elements:
    • An "offline door lock" comprising a "first memory" and a "lock processor" configured to determine the validity of received access credentials.
    • A "smart device hub" comprising one or more processors, a second memory, a "first interface" for a "wide area network (WAN) communication link", and a "second interface" for a "non-WAN communication link".
    • The smart hub’s processors are configured to "receive control information" from a property management platform via the WAN link, where the information identifies access credentials to be disabled.
    • The smart hub’s processors are further configured to "generate a command" to disable the identified credentials and "transmit the command" to the offline door lock via the non-WAN link.
    • The lock processor is configured to receive the command and "modify the stored access credential validation information" to disable the credentials.
  • The complaint reserves the right to assert other claims. (Compl. ¶19).

U.S. Patent No. 10,803,685 - "Smart Thermostat Hub"

The Invention Explained

  • Problem Addressed: This patent, from the same family as the ’273 Patent, addresses the identical problem of securely and cost-effectively managing offline door locks in multi-family properties. (’685 Patent, col. 1:43-61).
  • The Patented Solution: The solution is structurally identical to that of the ’273 Patent, but the claims specify the use of a particular type of wide area network: a Long Range (LoRa) wide area network (LoRaWAN). This low-power, long-range protocol is particularly well-suited for connecting many IoT devices across a large property without relying on building-wide Wi-Fi or cellular data for each device. The hub acts as a bridge between the LoRaWAN and a local, non-LoRaWAN network used to communicate with the door lock. (’685 Patent, Abstract; col. 2:24-39).
  • Technical Importance: Specifying LoRaWAN as the communication backbone offers a standardized, low-cost method for property-wide IoT connectivity that avoids reliance on either resident-provided Wi-Fi networks or the higher costs of individual cellular plans for each hub. (’685 Patent, col. 6:1-14).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and notes that it is representative of claims 15 and 20. (Compl. ¶¶40, 44).
  • Independent Claim 1 of the ’685 Patent includes the following essential elements:
    • An "offline door lock" comprising a locking mechanism, sensor, memory, and lock processor.
    • A "smart thermostat hub" comprising processors, memory, a "first interface" for a "Long Range (LoRa) wide area network (LoRaWAN) communication link", and a "second interface" for a "non-LoRaWAN communication link".
    • The hub’s processors are configured to receive control information to disable credentials via the "LoRaWAN" link.
    • The hub’s processors are configured to generate and transmit a disable command to the lock via the "non-LoRaWAN" link.
    • The lock processor is configured to receive the command and modify stored credentials.
  • The complaint reserves the right to assert other claims. (Compl. ¶40).

U.S. Patent No. 11,189,118 - "Smart Thermostat Hub"

  • Patent Identification: U.S. Patent No. 11,189,118, "Smart Thermostat Hub," issued November 30, 2021. (Compl. ¶11).
  • Technology Synopsis: This patent describes a system for remotely checking the status of an electronic door lock. A smart hub receives a status check request from a property management platform over a LoRaWAN link, identifies the correct smart device (the lock), transmits a command to the lock over a non-LoRaWAN link, receives status information back from the lock, and transmits that status information back to the platform via the LoRaWAN link. (’118 Patent, Claim 1).
  • Asserted Claims: Independent Claim 1. (Compl. ¶65).
  • Accused Features: The complaint accuses the iApartments system, including the smart hub thermostat and smart lock, of infringing by enabling a user or property manager to retrieve the status of the lock (e.g., locked or unlocked) via the iApartments app, which communicates with the hub over a long-range link. (Compl. ¶¶66, 76-77).

III. The Accused Instrumentality

Product Identification

  • The accused products are iApartments’ "Smart Home, Smart Access, and other products and services," which include a "smart hub thermostat" and a "smart lock." (Compl. ¶¶14, 26, 44).

Functionality and Market Context

  • The iApartments system is marketed as an integrated technology infrastructure for multi-family communities. (Compl. ¶22). The complaint alleges that the "smart hub thermostat" acts as a central controller for other smart devices, including lights and locks. (Compl. ¶26). This hub allegedly connects to a central property management platform via a WAN link (identified as CAT-M1 cellular/LTE) and communicates locally with the smart lock using a non-WAN link (identified as Z-Wave). (Compl. ¶¶27, 28, 50, 52). A screenshot provided in the complaint shows the thermostat hub allows users to control "smart locks and other devices right from your phone." (Compl. ¶26, p.12). The system's functionality is alleged to include the ability to remotely grant and disable temporary access for guests or vendors, as well as check the lock's status. (Compl. ¶¶24, 76).

IV. Analysis of Infringement Allegations

10,825,273 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an offline door lock comprising: a first memory storing access credential validation information; and a lock processor configured to: determine validity of received access credential information... The accused "Smart Lock" is alleged to be an offline lock that stores credential information to enable temporary access for guests and includes a processor to validate those credentials. ¶¶23-25 col. 1:47-53
a smart device hub comprising: one or more processors; a second memory...; a first interface configured to communicatively couple the one or more processors to a property management platform via a wide area network (WAN) communication link... The accused "smart hub thermostat" allegedly contains processors and memory and connects to a property management platform via a WAN link, described as CAT-M1 cellular/LTE. ¶¶26-27 col. 2:25-34
...and a second interface configured to communicatively couple the one or more processors to the offline door lock via a non-WAN communication link; The smart hub thermostat allegedly uses a non-WAN link, identified as Z-Wave, to communicate with the smart lock, as shown in an FCC report. This report is provided as a visual in the complaint. ¶28 col. 2:34-36
where the one or more processors are configured to: receive control information associated with the offline door lock from the property management platform via the WAN communication link... generate a command... and transmit the command to the offline door lock via the non-WAN communication link, The hub's processor is alleged to perform these steps to enable remote management, such as disabling temporary access previously granted to a vendor or guest. ¶29 col. 2:39-47
where the lock processor is configured to receive the command via the non-WAN communication link and to modify the stored access credential validation information to disable the one or more access credentials... The smart lock's processor is alleged to receive commands from the hub via the Z-wave link and modify its stored information to disable temporary access codes. ¶30 col. 2:47-51

10,803,685 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an offline door lock comprising: a locking mechanism; a sensor configured to receive access credential information... a first memory... a lock processor... The accused "Smart Lock" is alleged to be an offline lock with a locking mechanism, a sensor for receiving credentials, memory for storing validation information, and a processor for determining validity. ¶¶44-48 col. 1:47-53
a smart thermostat hub comprising: ...a first interface configured to communicatively couple the... processors to a property management platform via a Long Range (LoRa) wide area network (LoRaWAN) communication link... The accused smart hub thermostat allegedly connects to a management platform via an LTE connection. The complaint alleges that both LTE-M and LoRaWAN are LPWAN technologies and cites Defendant's own Terms of Use, which explicitly mention "LoRa" and "LoRaWan." ¶¶49-51 col. 6:5-10
...and a second interface configured to communicatively couple the... processors to the offline door lock via a non-LoRaWAN communication link; The hub is alleged to use a non-LoRaWAN link, such as Z-Wave, Zigbee, or Bluetooth, to communicate with the smart lock. ¶52 col. 6:35-40
where the one or more processors are configured to: receive control information... via the LoRaWAN communication link... generate a command... and transmit the command... via the non-LoRaWAN communication link, The hub's processor is alleged to utilize the LTE (as LoRaWAN) and Z-Wave (as non-LoRaWAN) links to perform the claimed steps of receiving control information and transmitting a corresponding command to the lock to, for example, disable temporary access. ¶53 col. 8:10-22
where the lock processor is configured to receive the command via the non-LoRaWAN communication link and to modify the stored... information to disable the... access credentials... The smart lock's processor is alleged to receive commands from the hub via a Z-wave link and modify stored credentials to disable access for a vendor, guest, or maintenance personnel. ¶54 col. 10:10-24

Identified Points of Contention

  • Scope Questions: A central dispute for the ’685 Patent may be whether the accused system's use of LTE/CAT-M1 cellular technology for its WAN connection meets the specific "LoRaWAN communication link" limitation of claim 1. The complaint attempts to bridge this gap by noting both are LPWAN technologies and by citing Defendant's Terms of Use mentioning "LoRaWan" (Compl. ¶¶50-51). The question for the court will be whether this is sufficient for literal infringement or, alternatively, infringement under the doctrine of equivalents.
  • Technical Questions: The complaint alleges that the hub processors "generate a command" based on received "control information." A potential point of contention is what evidence exists to show that the accused hub performs this specific two-step logical process (receive info -> generate separate command -> transmit), as opposed to simply relaying or passing through data from the platform to the lock.

V. Key Claim Terms for Construction

  • The Term: "LoRaWAN communication link" (’685 Patent, Claim 1)

  • Context and Importance: This term is the primary distinction between the asserted claims of the ’685 and ’273 Patents. The infringement analysis for the ’685 Patent will depend entirely on whether the accused product's LTE cellular link can be considered a "LoRaWAN communication link." Practitioners may focus on this term because the complaint's infringement theory relies on equating different LPWAN technologies.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests LoRaWAN is an exemplary embodiment of a broader category, stating that the communication link "may be a communication link within a low-power, wide area network (LPWAN) or another type of network topology utilizing low power- or LoRa-based communication links." (’685 Patent, col. 6:11-14). This language could support an argument that the claim term should not be limited to the specific LoRaWAN protocol but should encompass functionally similar LPWAN technologies like LTE-M.
    • Evidence for a Narrower Interpretation: The claim explicitly recites "LoRaWAN," not the broader term "LPWAN." The abstract, summary, and detailed description repeatedly and specifically name "LoRaWAN" as the technology for the first communication interface. (’685 Patent, Abstract; col. 2:30-32). This consistent, specific language could support a narrower construction limited to the LoRaWAN standard itself.

  • The Term: "offline door lock" (’273 and ’685 Patents, Claim 1)

  • Context and Importance: The patents' stated purpose is to solve a security problem unique to offline locks. The definition is therefore critical. If the accused lock is determined not to be "offline," a core premise of the infringement allegation may fail.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification defines an offline door lock by what it cannot do: it cannot be "controlled (e.g., locked and unlocked) remotely through an Internet-accessible network connection." (’273 Patent, col. 1:45-47). It can only be controlled locally by a device in proximity. This functional definition could be argued to cover any lock that lacks its own independent, direct IP address or internet connection.
    • Evidence for a Narrower Interpretation: The same definition states that "offline door locks can only be controlled... by a device... that is placed in proximity to a sensor of the offline door lock." (’273 Patent, col. 1:50-53). A defendant could argue that a lock that can be controlled remotely through the hub is not "offline" in the manner contemplated by the patent, which distinguishes such locks from "online door locks [that] can be managed remotely." (’273 Patent, col. 1:61-62).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all three asserted patents. The factual basis for inducement includes Defendant's advertising, distribution, provision of instruction materials, user guides, and software, which allegedly instruct and encourage customers and end-users to operate the Accused Products in an infringing manner. (Compl. ¶¶32-33, 56-57, 85).
  • Willful Infringement: Willfulness is alleged for all three patents. The complaint asserts that Defendant had pre-suit knowledge based on a series of specific communications, including an August 6, 2021 notice letter with a claim chart for the ’273 Patent; a September 15, 2021 communication where Defendant's counsel acknowledged the ’685 Patent and the application leading to the ’118 Patent; and a January 7, 2022 communication providing a claim chart for the ’118 Patent. (Compl. ¶¶15-17, 31, 55, 83).

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

  • A core issue will be one of protocol scope: can the term "LoRaWAN communication link," as claimed in the ’685 Patent, be construed to cover the accused system's use of LTE/CAT-M1 cellular technology, or are these technically distinct and non-equivalent protocols? The outcome of this question will likely determine the viability of the infringement count for that patent.
  • A key evidentiary question will be one of functional implementation: what specific technical evidence will show that the accused smart hub performs the claimed steps of receiving control information, generating a new and distinct command based on that information, and then transmitting that command, as opposed to merely acting as a simple data passthrough or relay between the cloud and the lock?
  • Given the detailed allegations of pre-suit notice, including the provision of claim charts, a central question for damages will be willfulness: did the Defendant's continued marketing and sale of the accused systems after receiving specific notice constitute objectively reckless disregard of the Plaintiffs' patent rights, potentially justifying an award of enhanced damages?