DCT

1:19-cv-01487

Pinek IP LLC v. Lutron Electronics Co Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-01487, N.D. Ill., 03/01/2019
  • Venue Allegations: Venue is alleged to be proper based on Defendant Lutron maintaining a business office and having committed acts of patent infringement within the Northern District of Illinois.
  • Core Dispute: Plaintiff alleges that Defendant’s occupancy and vacancy sensor products infringe a patent related to systems for activating electronic circuits using pyroelectric elements.
  • Technical Context: The technology at issue involves using a pyroelectric element—a material that generates a voltage in response to a temperature change—to create a power-efficient and interference-resistant trigger for waking up low-power electronic devices.
  • Key Procedural History: The complaint notes that the asserted patent is a U.S. National Stage Entry of an international PCT application, which itself claimed priority to a German patent application. No other prior litigation, licensing history, or post-grant proceedings are mentioned.

Case Timeline

Date Event
2001-11-29 U.S. Patent No. 7,233,256 Priority Date (Germany)
2002-11-19 PCT Application Filing Date
2005-01-06 U.S. Patent No. 7,233,256 Application Filing Date
2007-06-19 U.S. Patent No. 7,233,256 Issue Date
2019-03-01 Complaint Filing Date

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

U.S. Patent No. 7,233,256 - A System and Method for Receiving a Signal to Trigger a Pyroelectric Activation System

Issued: June 19, 2007 (’256 Patent)

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of activating battery-powered electronic circuits, such as radio identity cards, in a power-efficient manner. Conventional methods that rectify a received radio signal to create an activation voltage are described as having an "inadequate range" and being susceptible to interference signals, which can lead to "unwanted activation of the circuit and therefore premature draining of the batteries." (’256 Patent, col. 1:22-31).
  • The Patented Solution: Rather than directly rectifying a received radio signal, the invention proposes converting the signal's energy into heat. As described, a received signal heats a resistor, which in turn heats a connected pyroelectric element. (’256 Patent, Fig. 1). This temperature change causes the pyroelectric element to generate a voltage, which is then used to trigger an "activation circuit" that powers on a main electronic system. (’256 Patent, col. 1:59-64; Abstract). This thermal conversion process is presented as a more robust and efficient alternative to direct electrical rectification.
  • Technical Importance: This approach provided a method for activating electronic circuits that could be both sensitive to specific signals and not susceptible to general interference. (Compl. ¶10; ’256 Patent, col. 1:50-53).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶12).
  • The essential elements of independent claim 1 are:
    • a receiving device (1) for receiving an activation signal (SIGA);
    • an activation circuit (4) for activating an electric circuit (5); and
    • at least one pyroelectric element (3) connected to the receiving device (1) and the activation circuit (4),
    • said at least one pyroelectric element producing a voltage that actuates said activation circuit (4) when heated by the activation signal from said receiving device.
  • The complaint alleges infringement of "one or more claims," suggesting the right to assert other claims, including dependent claims, may be reserved. (Compl. ¶12-14).

III. The Accused Instrumentality

Product Identification

The complaint names the "Lutron Radio Powr Savr Occupancy/Vacancy Sensor" as an exemplary accused product, along with other unspecified devices. (Compl. ¶12).

Functionality and Market Context

The complaint identifies the accused instrumentality as an occupancy and vacancy sensor but does not describe its specific technical operation. (Compl. ¶12). Allegations of infringement are supported by reference to claim charts in an "Exhibit B," which was not attached to the filed complaint. (Compl. ¶17-18). Therefore, the complaint itself does not provide sufficient detail for an analysis of the accused product's specific functionality or how it allegedly operates.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits to support its infringement allegations, but these exhibits were not provided with the filed document. (Compl. ¶17-18). The narrative allegations state that the accused products "satisfy all elements of the Exemplary '256 Patent Claim." (Compl. ¶17). Without the charts, a detailed, element-by-element comparison is not possible based on the complaint's text.

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Technical Questions: A primary technical question is whether the accused Lutron sensor, which likely functions as a passive infrared (PIR) detector, actually operates in the manner required by the claim. The claim requires that the pyroelectric element is "heated by the activation signal." Standard PIR sensors use a pyroelectric element to detect changes in ambient infrared radiation emitted by a person, not to be heated by a transmitted "activation signal" to generate a trigger voltage. The complaint does not provide evidence to clarify this operational point.
  • Scope Questions: A central dispute may arise over the meaning of "activation signal." The patent specification appears to contemplate a transmitted signal, such as a "radio signal" or "high-frequency activation signal" sent from a dedicated transmitter. (’256 Patent, col. 1:18, 1:65). The court may need to determine if this term can be interpreted to cover the ambient infrared energy passively detected by an occupancy sensor.

V. Key Claim Terms for Construction

1. "heated by the activation signal"

Context and Importance

This phrase is the mechanistic heart of the claim, defining how the pyroelectric element is triggered. The infringement analysis will turn on whether the accused sensor's operation meets this limitation. Practitioners may focus on whether "heated by" requires the signal's energy to be converted into heat (as the patent's embodiment shows) or if it can also mean detecting ambient heat which itself constitutes the signal.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to a specific heating mechanism (e.g., a resistor). Plaintiff may argue that any process where a signal's presence results in a temperature change in the pyroelectric element falls within the claim scope.
  • Evidence for a Narrower Interpretation: The specification's only detailed embodiment describes a process where a received radio signal powers a "heating element" (an ohmic resistor), which in turn heats the pyroelectric element. (’256 Patent, col. 4:56-62; Fig. 1). A defendant could argue this context limits the claim to an active heating process driven by the signal's power, not passive detection of ambient thermal energy.

2. "activation signal (SIGA)"

Context and Importance

The definition of the "signal" is critical. If it is limited to a transmitted signal from a source, it may not read on the functionality of a passive occupancy sensor.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The term itself is general. The claim does not specify the signal's source or nature (e.g., radio, acoustic, etc.). Plaintiff may argue that any energy pattern that triggers the claimed system qualifies.
  • Evidence for a Narrower Interpretation: The specification repeatedly refers to the signal as a "radio signal" and describes its transmission from a "transmitter ST1." (’256 Patent, col. 2:32-34; Fig. 3). The context consistently suggests an actively transmitted signal intended for the receiving device, rather than passive detection of ambient environmental conditions.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement, stating that Lutron sells the accused products to customers and provides "product literature and website materials" that instruct users to operate the products in an infringing manner. (Compl. ¶13, 14, 16).
  • Willful Infringement: The complaint does not use the term "willful," but it asserts that the filing of the complaint constitutes notice to Lutron and that Lutron continues to infringe despite this notice. (Compl. ¶15, 16). This provides a basis for alleging post-filing willful infringement. The prayer for relief also requests that the case be declared "exceptional," which can be predicated on a finding of willfulness. (Compl. p. 5, ¶D.i).

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

  • A core issue will be one of technical mechanism: Does the accused occupancy sensor function in the specific manner claimed by the ’256 Patent—where a received signal is used to actively heat a pyroelectric element to generate a trigger voltage—or is there a fundamental mismatch between the patented invention and the operation of a standard passive infrared sensor?
  • The case will also turn on a key question of claim construction: Can the term "activation signal," which the patent specification describes as a transmitted radio signal, be interpreted broadly enough to encompass the passive detection of ambient infrared energy from a person moving in a room? The answer will likely define the scope of the patent and the viability of the infringement claim.