DCT

0:25-cv-60483

IoT Innovations LLC v. Lutron Electronics Co Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:25-cv-60483, S.D. Fla., 06/02/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Southern District of Florida.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home systems and related products infringe seven U.S. patents related to network data classification, automatic device registration, wireless communication protocols, signal modulation, and user interface controls.
  • Technical Context: The dispute is centered on the underlying technologies that enable modern Internet of Things (IoT) and smart home ecosystems, focusing on network management, device onboarding, and wireless communication efficiency.
  • Key Procedural History: This First Amended Complaint follows an original complaint, which Plaintiff cites to establish the date of Defendant's alleged knowledge for claims of indirect and willful infringement. The asserted portfolio includes one reissue patent (RE44,742), which re-examined claims of a previously issued patent.

Case Timeline

Date Event
2001-04-16 Priority Date for ’173 and ’266 Patents
2001-07-09 Priority Date for ’872 Patent
2001-09-10 Priority Date for ’260 Patent
2002-11-05 Priority Date for ’571 Patent
2004-06-02 Priority Date for ’830 Patent
2005-05-02 Priority Date for ’724 Patent
2007-07-17 Issue Date for U.S. Patent No. 7,246,173
2007-10-09 Issue Date for U.S. Patent No. 7,280,830
2008-08-05 Issue Date for U.S. Patent No. 7,408,872
2011-07-05 Issue Date for U.S. Patent No. 7,974,266
2011-07-05 Issue Date for U.S. Patent No. 7,974,260
2013-03-19 Issue Date for U.S. Patent No. 8,401,571
2014-02-04 Issue Date for U.S. Patent No. RE44,742
2025-06-02 Complaint Filing Date

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

U.S. Patent No. 7,246,173 - Method And Apparatus For Classifying IP Data (Issued July 17, 2007)

The Invention Explained

  • Problem Addressed: In early packet-switched networks using IPv4 and IPv6, implementing Quality of Service (QoS) was challenging when "source routing" was employed. Source routing allows a sending device to specify a path of intermediate routers for a packet. During this transit, the primary "destination address" field in the IP packet header points to the next intermediate router, not the final destination (Compl. ¶41; ’173 Patent, col. 2:63-67). This could cause intermediate routers, which classify packets for QoS based on their final destination, to misclassify the packet and fail to provide the required service level (Compl. ¶¶45-46; ’173 Patent, col. 4:28-43).
  • The Patented Solution: The invention provides a method and apparatus (e.g., a router) that classifies an IP data packet by looking for the final destination address within the source routing information contained in the packet's header, rather than relying solely on the main destination address field, which may be pointing to an intermediate hop (Compl. ¶48; ’173 Patent, col. 4:51-56). The patent describes specific classification algorithms for both IPv4 and IPv6 that involve examining fields like the "last destination address field" in an IPv6 routing header or the end of the route data field in an IPv4 LSRR/SSRR option to identify the true destination for QoS purposes (Compl. ¶50; ’173 Patent, col. 4:57-5:15). A diagram in the complaint shows an IPv6 packet header with distinct source and destination address fields. (Compl. p. 14, FIG. 3).
  • Technical Importance: This technology provided a more robust method for applying QoS policies in complex networks, ensuring that time-sensitive or critical data streams received appropriate priority even when traversing a pre-defined path of multiple routers (Compl. ¶27).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 13, and 17, focusing on Claim 1 (Compl. ¶¶51, 62).
  • Independent Claim 1 (Method) requires:
    • receiving said data at a first node, the data comprising a header comprising a list of at least one intermediate node to be visited on a way to the destination apparatus; and
    • classifying said data at said first node based on an entry in said header.
  • The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶51).

U.S. Patent No. 7,280,830 - Automatic Registration Services Provided Through A Home Relationship Established Between A Device And A Local Area Network (Issued October 9, 2007)

The Invention Explained

  • Problem Addressed: The patent's background describes the process of registering a new electronic device on a network (as of 2004) as "often cumbersome," involving manual software installation, filling out warranty forms, and complex user configuration. This friction was identified as a factor that "limits the penetration of the marketplace for high technology products" (Compl. ¶72; ’830 Patent, col. 1:15-32).
  • The Patented Solution: The patent discloses a method to automate device registration by first establishing a trusted "home" relationship between a new wireless device and a local "network server" (e.g., a hub or processor). This relationship allows the device to join the network without manual configuration by the user (Compl. ¶75; ’830 Patent, col. 3:5-11). Once connected, the network server determines the device is an "owned device," automatically obtains its registration information (e.g., model, serial number), establishes a secure connection with a remote "registration server" (e.g., the manufacturer's server), and transmits the information to complete registration, all with minimal user input (Compl. ¶¶78-82; ’830 Patent, col. 3:12-45). A system diagram in the complaint illustrates the relationship between a new device, a home network server, and a remote registration server. (Compl. p. 27, FIG. 1).
  • Technical Importance: The invention describes a streamlined "plug-and-play" user experience for adding devices to a home network, a foundational concept for the usability and growth of modern smart home and IoT ecosystems (Compl. ¶74).

Key Claims at a Glance

  • The complaint focuses on independent claim 1 (Compl. ¶¶84, 96).

  • Independent Claim 1 (Method) requires:

    • establishing a home relationship between the new wireless device and a network server, such that no additional configuration is required by a user;
    • wherein establishing a home relationship includes, determining at the network server, that the wireless device is an owned device, wherein the owned device is previously known to the network server;
    • automatically obtaining registration information for the new device;
    • establishing a connection between a registration server and the network server; and
    • sending the registration information from the network server to the registration server.

  • The complaint notes that similar arguments apply to the patent's other 51 claims (Compl. ¶84).
    The complaint asserts five additional patents. They are summarized below.

  • U.S. Patent No. 7,974,266: Titled “Method And Apparatus For Classifying IP Data,” issued July 5, 2011. This patent is related to the ’173 Patent and addresses a similar technical problem. It discloses a method for classifying IP data at a network node based on the "last destination address entry" from a plurality of destination address entries in the packet header, and then forwarding the data to a second node where it is classified again based on that same last destination address (Compl. ¶¶114, 132, 147). Independent claims 1 and 16 are asserted (Compl. ¶136). The accused features involve data classification within Defendant's network.

  • U.S. Patent No. 7,974,260: Titled “Method Of Transmitting Time-Critical Scheduling Information Between Single Network Devices In A Wireless Network Using Slotted Point-To-Point Links,” issued July 5, 2011. The technology relates to wireless communication scheduling. The invention involves a device defining a data sequence with a header portion (containing an address code) and a payload portion (containing timing control information) and transmitting it in a "time defined contact slot" (Compl. ¶¶151, 157). Independent claim 1 is asserted (Compl. ¶156). The accused features relate to how Defendant's wireless devices schedule and transmit data packets.

  • U.S. Patent No. 7,408,872: Titled “Modulation Of Signals For Transmission In Packets Via An Air Interface,” issued August 5, 2008. This patent concerns signal modulation techniques for wireless communication. The technology involves receiving pluralities of bits, creating a pair of bits by adding a "set bit" with a fixed value to another bit, and mapping the resulting bit pair to a value according to a modulation scheme (Compl. ¶¶170, 176). Independent claim 1 is asserted (Compl. ¶175). The accused features are the signal modulation methods used by Defendant's wireless products.

  • U.S. Patent No. 8,401,571: Titled “Mobile Electronic System,” issued March 19, 2013. The technology involves using a device's physical orientation, or "posture," to control the user interface. The invention claims an apparatus with a processing component that processes data "indicative of the current posture of said apparatus" to select one of at least two different modes of presentation (Compl. ¶¶180, 186). Independent claim 1 is asserted (Compl. ¶185). The accused features likely relate to Defendant's mobile applications that may change display modes based on device orientation (e.g., portrait to landscape).

  • U.S. Patent No. RE44,742: Titled “Dynamic Message Templates And Messaging Macros,” issued February 4, 2014. This reissue patent addresses methods for reducing manual data entry. The technology involves automatically populating a "dynamic field" of a message template with "message context data" in response to determining that a message is to be generated (Compl. ¶¶197, 233). Independent claims 11 and 22 are the focus (Compl. ¶221). The accused features may relate to how Defendant's software generates automated status messages or alerts using contextual information.

III. The Accused Instrumentality

Product Identification

The complaint collectively identifies the accused instrumentalities as "Lutron Smart Home Systems" or the "Accused Products" (Compl. ¶19). This includes a broad ecosystem of hardware and software, such as RadioRA 3 and Homeworks QSX processors, the Lutron App and Lutron Vive App, and various smart devices like dimmers, sensors, shades, and hubs (Compl. ¶19).

Functionality and Market Context

The Accused Products constitute an integrated platform for controlling lighting, shades, and other environmental systems in residential and commercial buildings (Compl. ¶19). The system's functionality involves numerous devices communicating wirelessly and via wired networks, coordinated by central processors or hubs. Users interact with the system through dedicated keypads, sensors, and mobile software applications. The complaint alleges these systems perform the patented methods of network data classification, device registration, and wireless communication as part of their core operation (Compl. ¶63, 97).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided. The following summaries are based on the narrative infringement theories presented in the complaint body.

'173 Patent Infringement Allegations

The complaint alleges that the Accused Products perform a method of classifying IP data that meets the limitations of claim 1 (Compl. ¶63). The core theory appears to be that when Lutron devices communicate within the smart home network, they receive data packets that are routed through the system and must be classified for proper handling (e.g., prioritization). This classification is allegedly based on information within the packet headers, analogous to the claimed invention.

'830 Patent Infringement Allegations

The complaint alleges that the process of adding a new wireless device to a Lutron system infringes claim 1 (Compl. ¶97). The narrative theory tracks the claim elements: a new Lutron device allegedly establishes a "home relationship" with a Lutron network server (e.g., a hub) without requiring manual configuration. The hub then determines the device is an "owned device," automatically obtains its registration data, connects to a remote Lutron registration server, and sends the information to complete the process.

Identified Points of Contention:

  • Scope Questions: For the ’173 Patent, a central question may be whether the term "classifying Internet Protocol (IP) data", as used in a patent focused on public internet routing protocols like RSVP, can be construed to read on the proprietary data handling and prioritization that occurs within Defendant's closed smart home ecosystem. Similarly, for the ’830 Patent, the scope of "home relationship" and "owned device" will be critical.
  • Technical Questions: For the ’173 Patent, the analysis may turn on whether Lutron's network architecture uses a form of "source routing" where a packet's primary destination address points to an intermediate node, creating the technical problem the patent purports to solve. For the ’830 Patent, a key factual question may be how a brand-new device is "previously known to the network server" as required by claim 1 before the automated registration process begins.

V. Key Claim Terms for Construction

  • Term ('173 Patent, Claim 1): "classifying said data"
    • Context and Importance: This term is the central action of the method claim. Its definition will determine whether the claim is limited to the specific context of QoS protocols like RSVP described in the patent's specification, or if it can cover any form of data categorization for prioritization or routing within the accused proprietary network.
    • Intrinsic Evidence for a Broader Interpretation: The plain language of claim 1 does not limit "classifying" to any particular purpose or protocol; it only requires that the classification be "based on an entry in said header" ('173 Patent, col. 6:1-2).
    • Intrinsic Evidence for a Narrower Interpretation: The patent's specification heavily contextualizes the invention as a solution to problems with RSVP session classification in IPv4 and IPv6 networks ('173 Patent, col. 4:5-43). The "Summary of the Invention" also frames the invention in this context (Compl. ¶47). This may support an argument that "classifying" is implicitly limited to this technical field.
  • Term ('830 Patent, Claim 1): "owned device, wherein the owned device is previously known to the network server"
    • Context and Importance: This limitation appears in the step of "establishing a home relationship" and seems to require that the server have prior knowledge of the device. This is central to the infringement question, as the typical use case involves adding a device that is new to the system.
    • Intrinsic Evidence for a Broader Interpretation: The specification suggests the server attempts to recognize a new device by requesting its ID and checking it against an "'owned device' database or list" ('830 Patent, col. 2:58-61). This could mean the server "knows" of the device model or type, or that the user provides an identifier just prior to the automated process, which could satisfy the "previously known" requirement.
    • Intrinsic Evidence for a Narrower Interpretation: A narrow reading suggests the device's unique identifier must already be present in the server's database before the process begins. This could limit the claim to scenarios like re-registering a known device, rather than onboarding a new one, potentially creating a significant non-infringement argument.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for multiple asserted patents. Inducement is based on allegations that Lutron provides instructions, advertising, and user manuals that direct customers to use the Accused Products in an infringing manner (Compl. ¶98, 158). Contributory infringement is based on allegations that the products contain special features specifically designed for the infringing use that are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶100, 160).
  • Willful Infringement: Willfulness is alleged for multiple asserted patents. The complaint bases this on Defendant's alleged knowledge of the patents since at least the filing of the original complaint in the action, and on an alleged policy or practice of "willfully blind[ing]" itself to the patent rights of others (Compl. ¶¶102-103, 162-163).

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

  • A core issue will be one of definitional scope: can claim terms rooted in the context of early-2000s public internet protocols and networking challenges (e.g., "classifying IP data" for QoS) be construed to cover the analogous but distinct functions within a modern, proprietary smart home ecosystem?
  • A key evidentiary question will be one of procedural alignment: does the accused Lutron device onboarding process perform every step of the method claimed in the '830 patent in the specified order, particularly regarding the requirement that a new device is "previously known" to the network server?
  • A central strategic question will be one of case complexity: given the assertion of seven patents spanning a wide range of technologies from network packet routing and signal modulation to user interface design, the case will likely involve navigating multiple, distinct infringement theories and claim construction disputes, raising the question of which patents will ultimately become the primary focus of the litigation.