DCT
9:22-cv-80388
Ollnova Tech Ltd v. Carrier Global Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ollnova Technologies Ltd. (Ireland)
- Defendant: Carrier Global Corp. (Delaware)
- Plaintiff’s Counsel: Johnson & Martin, P.A.; BC LAW GROUP, Group
- Case Identification: 9:22-cv-80388, S.D. Fla., 11/21/2022
- Venue Allegations: Venue is alleged to be proper in the Southern District of Florida because Defendant Carrier Global Corp.’s headquarters are located within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart thermostats and related HVAC control systems infringe patents related to power management and data reporting in wireless building automation systems.
- Technical Context: The dispute centers on technology designed to enhance the efficiency of wireless sensor networks in smart buildings, primarily by reducing power consumption and network traffic.
- Key Procedural History: The complaint notes that Defendant was served with the original complaint and a claim chart for the ’282 patent on March 14, 2022, which may be relevant to allegations of post-suit willfulness. Subsequent to the filing of this complaint, an Inter Partes Review (IPR) was instituted against the ’282 patent (IPR2023-00624), resulting in the cancellation of asserted claims 1-5, 7-11, 13-16, and 20-21, a development that will significantly impact the litigation of that patent.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-12 | ’887 Patent Priority Date |
| 2008-01-03 | ’371 Patent Priority Date |
| 2008-03-19 | ’282 Patent Priority Date |
| 2010-06-29 | ’887 Patent Issue Date |
| 2012-07-17 | ’282 Patent Issue Date |
| 2012-09-11 | ’371 Patent Issue Date |
| 2022-03-14 | Original Complaint Served on Defendant |
| 2022-11-21 | Second Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,224,282 - "Method and device to manage power of wireless multi-sensor devices," issued July 17, 2012
The Invention Explained
- Problem Addressed: Wireless devices used in building automation systems, such as temperature sensors, must operate for extended periods on limited battery power, making power conservation critical ('282 Patent, col. 1:15-19). Constant communication from multi-sensor devices, which may track numerous variables (e.g., temperature, humidity, occupancy), can rapidly drain the battery.
- The Patented Solution: The invention proposes a power-saving method where a multi-sensor device receives "status information" from a second component (e.g., a central controller) indicating which specific sensor data is currently being used or is "in control" of the system. The device then only communicates that specific, relevant portion of its sensor data, avoiding the need to transmit all data from all its sensors, thereby conserving power ('282 Patent, Abstract; col. 9:8-24).
- Technical Importance: This selective data communication approach was designed to maximize the operating life of battery-powered wireless devices, a key factor in the feasibility and maintenance cost of large-scale smart building networks ('282 Patent, col. 1:15-19).
Key Claims at a Glance
- The complaint asserts independent claims 1, 7, 13, and 20, as well as several dependent claims (Compl. ¶10). However, a subsequent IPR proceeding cancelled all of these asserted claims.
- Independent Claim 1, prior to cancellation, recited:
- An automation component for wireless communication, comprising:
- a multi-sensor package to detect and generate data for a plurality of variables;
- a wireless communications component;
- a processor and a memory;
- the memory containing instructions programmed to:
- receive sensor control information related to sensor data in control at a second automation component; and
- communicate a portion of the stored sensor data corresponding to the received sensor control information to the second automation component.
U.S. Patent No. 7,746,887 - "Dynamic value reporting for wireless automated systems," issued June 29, 2010
The Invention Explained
- Problem Addressed: Wireless automation systems with many devices can create a "noisy environment" and be constrained by available bandwidth. The continuous transmission of sensor data consumes significant power and processing resources, shortening the life of battery-powered devices ('887 Patent, col. 1:36-44).
- The Patented Solution: The patent describes a device that monitors a condition but only transmits data wirelessly in response to detecting a "change" in that condition—for example, when a value crosses a predetermined threshold or differs significantly from a prior reading. This "change-of-value" reporting avoids continuous, redundant data transmission ('887 Patent, Abstract; col. 10:60-65). The system can also dynamically vary the polling interval and the thresholds that define a "change" ('887 Patent, col. 11:23-43).
- Technical Importance: By transmitting data only when necessary, this approach aimed to reduce both power consumption and network traffic, enabling more robust and scalable wireless sensor networks in automated buildings ('887 Patent, col. 2:56-62).
Key Claims at a Glance
- The complaint asserts independent claim 1 and several dependent claims (Compl. ¶19).
- The essential elements of Independent Claim 1 include:
- A wireless automation device with a transceiver, a sensor, a controller, and a memory.
- The controller polls the sensor at a polling interval to read an indicator of a sensed condition.
- The controller stores current and prior readings in memory.
- The transceiver is configured to transmit the most recent reading "in response to detecting a change in the sensed condition outside a predetermined range."
U.S. Patent No. 8,264,371 - "Method and device for communicating change-of-value information in a building automation system," issued September 11, 2012
- Technology Synopsis: This patent discloses methods for managing the communication of "change-of-value" (COV) data within a building automation system. The technology allows devices to either "push" notifications of changed values as they occur or respond to "pull" requests (polls) from other system components, thereby providing a structured way to handle event-driven data updates ('371 Patent, Abstract).
- Asserted Claims: Independent claims 1 and 13, among others (Compl. ¶25).
- Accused Features: The complaint accuses Carrier's smart thermostats and the "MyInfinity server" of infringing by implementing methods of communicating change-of-value information within an automation system (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
The complaint identifies the Carrier Infinity System Control, Cor Thermostat, Connect Wi-Fi Thermostat, Connect BACnet Thermostat, and Carrier Connect 43 FX Thermostat, along with their associated sensors and the MyInfinity server, as the "Accused Products" (Compl. ¶9, ¶18, ¶24).
Functionality and Market Context
The Accused Products are described as smart HVAC control systems that manage temperature, humidity, and airflow across multiple zones (Compl. p. 4). They are "Wi-Fi® enabled" for remote access and are promoted as the "brains" of a complete communicating system that integrates data from a plurality of sensors, including built-in motion sensors, to optimize comfort and energy savings (Compl. p. 4, p. 6). The complaint references an image of the Infinity System Control's menu, which shows icons for managing wireless settings, heat sources, and multiple sensors, illustrating its role as a central hub (Compl. p. 5). The products are also alleged to generate alerts based on sensor data crossing certain thresholds, such as for high temperature or high humidity (Compl. p. 6).
IV. Analysis of Infringement Allegations
’282 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a multi-sensor package configured to detect a plurality of variables | The Accused Products are promoted as managing temperature, humidity, and occupancy, using built-in and external sensors like the "on-board PIR motion sensor" and "Indoor Air Quality" sensors. | ¶9; p. 6 | col. 9:11-14 |
| receive sensor control information related to sensor data in control at a second automation component | The system allows users to select "comfort profiles" (e.g., Home, Away, Sleep), which dynamically adjust temperature setpoints. This selection is alleged to be the "sensor control information" that determines which data is "in control." An image in the complaint shows the user interface for setting these profiles. | ¶11; p. 7 | col. 9:40-44 |
| communicate a portion of the stored sensor data corresponding to the received sensor control information | By operating under a specific profile (e.g., "Away"), the system allegedly prioritizes and communicates data relevant to that state, rather than communicating all possible data, thereby sending only a "portion" of the total stored data. | ¶11; p. 7 | col. 9:45-49 |
’887 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sensor operable to generate a indicator for a sensed condition | The Accused Products contain temperature and humidity sensors that generate data for an HVAC alert system. | ¶9; p. 6 | col. 7:44-50 |
| a controller storing a reading of the indicator... where the memory stores at least one prior reading | The system's ability to trigger alerts based on conditions existing for a specific duration (e.g., "for at least 10 minutes") implies storage and comparison of readings over time. | p. 6 | col. 9:58-61 |
| wherein the transceiver is configured to transmit a most recent reading... in response to detecting a change in the sensed condition outside a predetermined range | The complaint alleges the products generate alerts, such as a "High Room Temp Alert, when 100°F exists," which constitutes transmitting information only when a sensed value crosses a threshold, or "changes" outside a range. | p. 6 | col. 12:56-63 |
- Identified Points of Contention:
- ’282 Patent: A primary question, now likely moot due to the IPR, would have been whether a user-selected "comfort profile" qualifies as "sensor control information" received from a "second automation component" as required by the claim. A court would have to decide if this term requires a technical, machine-to-machine instruction or if a user mode selection on the device itself suffices.
- ’887 Patent: The key technical question is whether the accused alert system, which appears to trigger when a sensor value crosses a static threshold (e.g., >100°F), meets the claim limitation of "detecting a change in the sensed condition." The patent specification often describes this "change" as a comparison between a current value and a prior value, raising the question of whether crossing a static boundary is equivalent to the patented method.
V. Key Claim Terms for Construction
For the ’282 Patent
- The Term: "sensor control information related to sensor data in control"
- Context and Importance: This term is central to the invention's power-saving mechanism. The viability of the infringement allegation hinges on whether the user-selectable "comfort profiles" of the accused thermostats can be construed as meeting this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract uses the general term "status information" without tightly defining its source or format, which could support an argument that any data influencing which sensor values are used (including a user setting) qualifies ('282 Patent, Abstract).
- Evidence for a Narrower Interpretation: The claim requires the information to be received from a "second automation component," which suggests a distinct piece of hardware in the automation network, not the user interface of the same device. The detailed description refers to components communicating with each other, reinforcing this interpretation ('282 Patent, col. 9:40-44).
For the ’887 Patent
- The Term: "detecting a change in the sensed condition"
- Context and Importance: Practitioners may focus on this term because the infringement theory relies on equating the accused product's threshold-crossing alerts with the patent's "change" detection.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract states the change may be determined by "detecting a value for the condition outside a variable range," which could be read to include crossing a static limit ('887 Patent, Abstract).
- Evidence for a Narrower Interpretation: The detailed description repeatedly explains the "change" by referencing a comparison of a current value (Vi) to one or more prior values (Vi-j), for example, by calculating a difference ('887 Patent, col. 10:19-29). This suggests the invention is directed at detecting a rate of change or a delta, not merely crossing a fixed point.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced and contributory infringement of the ’282 Patent. It claims Carrier provides product literature and online instructions that "actively encourage and instruct its customers and end users... to use the Accused Products in ways that directly infringe" (Compl. ¶11).
- Willful Infringement: Willfulness is alleged based on Carrier's purported knowledge of the ’282 Patent and its alleged infringement since at least March 14, 2022, the date the original complaint and a claim chart were served. The complaint asserts that Carrier's continued infringement after this date is willful (Compl. ¶11, ¶12).
VII. Analyst’s Conclusion: Key Questions for the Case
- Impact of IPR: A threshold issue for the case will be the effect of the IPR decision cancelling the asserted claims of the ’282 patent. This development fundamentally undermines Count I of the complaint and will likely reshape the scope and strategy of the entire litigation.
- Mechanism of Infringement: For the remaining patents, a key evidentiary question will be one of operational equivalence. Specifically for the ’887 patent, does the accused products' alert function, which triggers when a reading crosses a static threshold, operate in the same way as the patented method of "detecting a change," which the specification strongly suggests involves comparing current and prior sensor readings?
- Definitional Scope: Should the ’371 patent become the focus, a central question will be one of definitional scope. The court will need to determine if the routine data communications within the accused HVAC system, such as updating a central unit with a new temperature reading, constitute the specific "change-of-value message" and "change-of-value update" protocols as defined and claimed in the patent.