DCT
0:24-cv-61564
Edelta Inc v. Great Innovations LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Edelta, Inc. (Delaware) and John S. Gutierrez (Louisiana)
- Defendant: Great Innovations, LLC (Florida) and Joseph McDonnell (Florida)
- Plaintiff’s Counsel: Louis R. Gigliotti, PA
- Case Identification: 0:24-cv-61564, S.D. Fla., 08/25/2024
- Venue Allegations: Venue is asserted in the Southern District of Florida based on Defendants' residence, regular place of business, and commission of infringing acts within the district.
- Core Dispute: Plaintiffs allege that Defendants’ iFLO Smart Automated A/C Drain Line & Drain Pan Cleaning System infringes a patent related to remotely monitored air conditioning condensate treatment systems.
- Technical Context: The technology concerns devices that prevent clogs and water damage from air conditioning condensate drain lines by automatically dispensing a biocide and providing remote monitoring capabilities.
- Key Procedural History: The complaint alleges that Defendant Joseph McDonnell was issued two U.S. patents for a similar drain cleaning apparatus in 2023, years after the patent-in-suit was issued. Plaintiffs allege that Defendants failed to disclose the patent-in-suit to the U.S. Patent and Trademark Office during the prosecution of those patents, a fact which may be used to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-04 | ’778 Patent Priority Date (Application Filing) |
| 2018-04-17 | ’778 Patent Issued |
| 2021-11-09 | Defendant McDonnell filed application for U.S. Patent No. 11,719,464 |
| 2022-04-19 | Defendant McDonnell filed application for U.S. Patent No. 11,826,799 |
| 2023-08-08 | U.S. Patent No. 11,719,464 Issued to Defendant McDonnell |
| 2023-11-28 | U.S. Patent No. 11,826,799 Issued to Defendant McDonnell |
| End 2023 / Early 2024 | Accused iFLO Device First Sold (approximate) |
| 2024-08-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 9,943,778, Air Conditioning Condensate Treatment System, issued April 17, 2018.
The Invention Explained
- Problem Addressed: Air conditioning condensate drain lines are prone to clogging from microbiological growth, which can lead to overflows that cause severe water damage. Manually clearing these lines or adding chemicals is burdensome, and homeowners or building supervisors are often unaware of a developing problem until it is too late. (’778 Patent, col. 1:17-43).
- The Patented Solution: The invention is an automated treatment module that attaches to the condensate drain line. It houses a biocide cartridge that sterilizes the water. A key feature is a control unit with multiple sensors and Wi-Fi capability. A load cell weighs the biocide cartridge to monitor its remaining supply, while other sensors monitor environmental conditions and condensate levels. This data is transmitted wirelessly to a remote device, like a smartphone, and the system can automatically shut down the air conditioner to prevent an overflow if a clog is detected. (’778 Patent, Abstract; col. 3:42-col. 4:15).
- Technical Importance: The invention seeks to transform a reactive, manual maintenance task into a proactive, automated, and remotely monitored process, thereby reducing labor costs and the risk of property damage. (’778 Patent, col. 2:39-53).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 9, and dependent claim 8.
- Independent Claim 1 includes these essential elements:
- A housing coupled with a condensate drain line.
- A biocide received within the housing.
- A load cell to measure the amount of biocide.
- A means for wirelessly informing a remote user of the biocide amount, comprising a controller and wireless processor.
- A humidity sensor in communication with the controller.
- An infrared thermometer proximal the air handler.
- Independent Claim 9 includes these essential elements:
- An air conditioning system with an air handler, drip pan, and drain line.
- A housing in fluid communication with the drain line.
- A biocide received within the housing.
- A means for disabling the air conditioner if condensate levels exceed a threshold.
- A measuring means for determining the amount of biocide.
- A means for wirelessly informing a remote user of the biocide amount, comprising a controller with a Wi-Fi processor.
- A camera interface included with the controller.
III. The Accused Instrumentality
- Product Identification: The "iFLO Smart Automated A/C Drain Line & Drain Pan Cleaning System" ("iFLO device") (Compl. ¶16).
- Functionality and Market Context: The complaint alleges the iFLO device is sold via Defendants' website, television advertising, and authorized retailers (Compl. ¶16). It is described as a system that dispenses biocide into a condensate drain line and is accessible and controllable by a user's mobile phone. The complaint further alleges the device "wirelessly accesses environmental data to customize performance parameters accordingly" (Compl. ¶16).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint alleges infringement but does not provide a detailed element-by-element analysis or claim chart. The following tables synthesize the allegations by mapping the complaint’s description of the accused product against the elements of the asserted independent claims.
’778 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing coupled with a condensate drain line exiting an air handler, said housing having an interior chamber in fluid communication with said drain line | The iFLO device is a system attached to an A/C drain line. | ¶16 | col. 3:46-50 |
| a biocide received within said interior chamber | The iFLO device "dispenses biocide to a condensate drain line." | ¶16 | col. 3:54-56 |
| a load cell within said interior chamber...to measure an amount of biocide | The complaint does not provide sufficient detail for analysis of this element. | col. 3:62-65 | |
| a means for wirelessly informing a remote user of the amount of biocide...comprises a controller...having a wireless communication processor | The iFLO device is "accessible and controllable by a user's mobile phone." | ¶16 | col. 4:1-6 |
| a humidity sensor in communication with said controller | The iFLO device "wirelessly accesses environmental data to customize performance parameters." | ¶16 | col. 4:27-29 |
| an infrared thermometer proximal the air handler and in communication with said controller | The iFLO device "wirelessly accesses environmental data to customize performance parameters." | ¶16 | col. 4:27-29 |
’778 Patent Infringement Allegations (Claim 9)
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a means for disabling said air conditioner when a condensate level...exceeds a predetermined threshold | The complaint describes this function as part of the patented invention but does not allege that the accused iFLO device performs this function. | ¶15 | col. 4:23-26 |
| a measuring means for determining an amount of said biocide in said interior chamber | The complaint does not provide sufficient detail for analysis of this element. | col. 5:46-48 | |
| a means for wirelessly informing a remote user of the amount of said biocide...comprises a controller...having a Wi-Fi processor | The iFLO device is "accessible and controllable by a user's mobile phone." | ¶16 | col. 5:49-56 |
| said controller further including a camera interface for visually recording a surrounding area or equipment | The complaint does not allege that the accused iFLO device contains a camera interface. | col. 5:57-59 |
- Identified Points of Contention:
- Technical Questions: A primary question will be what mechanism, if any, the iFLO device uses to measure the remaining biocide and whether that mechanism meets the "load cell" limitation of Claim 1 or the more general "measuring means" of Claim 9. The complaint's general allegation that the iFLO device "accesses environmental data" raises the question of whether it specifically uses the "humidity sensor" and "infrared thermometer" required by Claim 1.
- Scope Questions: The infringement case for Claim 9 appears to raise significant scope questions, as the complaint does not allege that the accused iFLO device includes a "means for disabling said air conditioner" or a "camera interface," both of which are required elements of the claim.
V. Key Claim Terms for Construction
The Term: "load cell" (Claim 1)
Context and Importance: This term is highly specific. The infringement analysis for Claim 1 will depend on whether the accused product's mechanism for tracking biocide levels falls within the scope of this term. Practitioners may focus on this term because the complaint does not specify how the accused product measures biocide, suggesting a potential mismatch.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide language supporting a significantly broader interpretation beyond a weight-measuring device.
- Evidence for a Narrower Interpretation: The specification explicitly describes the structure and function: "A load cell 9...includes a weight-bearing member that supports the cartridge. The load cell continuously measures the total weight of the cartridge to calculate a remaining biocide supply." (’778 Patent, col. 3:62-65). This language suggests the term is limited to a device that operates by measuring weight.
The Term: "means for wirelessly informing a remote user" (Claims 1 and 9)
Context and Importance: As a means-plus-function term, its scope is limited to the corresponding structure disclosed in the specification and its equivalents. The dispute will center on whether the accused product's wireless communication hardware and software are structurally equivalent to what is disclosed in the patent.
Intrinsic Evidence for Interpretation:
- Function: "wirelessly informing a remote user of the amount of biocide" (’778 Patent, col. 5:27-28).
- Disclosed Structure: The specification identifies the corresponding structure as a "control unit 12 having a microprocessor 13 with wireless-transmission capabilities to allow communication with remote electronic devices via a Wi-Fi connection 14." (’778 Patent, col. 4:1-6).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement based on Defendants’ sales of the iFLO device to retailers, who in turn sell the products to consumers that operate them in an infringing manner (Compl. ¶26, ¶35).
- Willful Infringement: Willfulness is alleged based on both pre- and post-suit knowledge. The complaint asserts pre-suit knowledge by pointing to Defendant McDonnell’s own patent applications for "identical subject matter," which were filed three years after the ’778 Patent issued and allegedly did not cite the ’778 Patent as prior art (Compl. ¶¶21-22, 24). Post-suit knowledge is established by the filing of the complaint itself (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of technical proof: can Plaintiffs produce evidence that the accused iFLO device contains a "load cell," an "infrared thermometer," a "means for disabling" the A/C unit, and a "camera interface"? The complaint's allegations are silent or non-specific on these claim elements, which will likely be a focus of early discovery and dispositive motions.
- A key legal issue will be one of claim scope: does the accused product's alleged function of accessing "environmental data" satisfy the specific and distinct claim requirements for both a "humidity sensor" and an "infrared thermometer," or does this represent a mismatch between the general nature of the accused functionality and the specificity of the patent claims?
- The case may also feature a significant dispute over willfulness: do the circumstances surrounding Defendant McDonnell’s prosecution of his own patents, particularly the failure to cite the patent-in-suit, constitute the "egregious" conduct often required for an award of enhanced damages?