DCT
1:23-cv-01300
Triteq Lock & Security LLC v. Minus Forty Tech Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Triteq Lock & Security, LLC (Illinois)
- Defendant: Minus Forty Technologies Corp., Minus Forty QBD Corp., and Due North (Canada)
- Plaintiff’s Counsel: Leinenweber Baroni & Daffada, LLC; Friedman, Suder & Cooke
- Case Identification: 1:23-cv-01300, N.D. Ill., 05/11/2023
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, has admitted to venue being proper and convenient in the district, maintains a regular place of business and a full-time employee in the district, and sells its products to customers in the district.
- Core Dispute: Plaintiff alleges that Defendant’s commercial refrigerators and freezers, equipped with the SmartLock II system, infringe patents related to electromechanical locks that automatically secure the units based on temperature and other conditions to prevent food spoilage.
- Technical Context: The technology involves intelligent locking systems for unattended commercial coolers, such as those in "micro-markets," to ensure food safety by preventing consumer access to products stored at unsafe temperatures.
- Key Procedural History: The complaint alleges a history between the parties, including concurrent patent litigation in Canada where applications for the Asserted Patents were produced in September 2019. Plaintiff also alleges sending a notice letter in February 2020, followed by discussions between the parties' CEOs.
Case Timeline
| Date | Event |
|---|---|
| 2013-01-18 | Priority Date for ’833 and ’262 Patents |
| 2017-12-20 | Effective Date of Defendant's TSB for Accused Gen2 Lock |
| 2019-09-01 | Defendant allegedly gained knowledge of patents via Canadian litigation |
| 2020-02-13 | Plaintiff sent actual notice letter to Defendant |
| 2020-04-07 | U.S. Patent No. 10,612,833 Issued |
| 2020-04-22 | Plaintiff issued press release on "Vending Market Watch" |
| 2021-09-07 | Defendant Minus Forty Technologies Corp. acquired by Ronin Equity Partners |
| 2021-09-27 | Defendant consolidated with QBD Cooling Systems Inc. |
| 2022-11-08 | U.S. Patent No. 11,493,262 Issued |
| 2023-05-11 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,612,833 - Cooler Lock, issued April 7, 2020
The Invention Explained
- Problem Addressed: In unattended retail environments like "micro-markets," perishable food in refrigerated coolers can spoil if the temperature rises due to a power failure, a cooling unit failure, or a door being left open. This creates a risk of consumers accessing and purchasing unsafe products (Compl. ¶13).
- The Patented Solution: The patent discloses an automated access control system for a cooler. It uses a controller, sensors, and an electromechanical lock to monitor conditions. If the controller detects a "fault event"—such as the internal temperature exceeding a preset threshold (e.g., 42°F) for a defined period—it automatically actuates the lock to prevent the door from being opened, thereby restricting access to potentially spoiled food (’833 Patent, Abstract; col. 7:35-52; Fig. 15). The system also contemplates a "service mode" to allow for restocking without triggering the lock (Compl. ¶18).
- Technical Importance: The invention provides an automated safety mechanism to maintain food integrity in the growing unattended retail and micro-market sectors (Compl. ¶12-13).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 14 (Compl. ¶46).
- Independent Claim 1 recites a lock for a food storage vending cooler, comprising:
- a locking element on the door;
- an electronic lock mechanism on the cabinet with an electronic actuator and an engaging member;
- lock controller circuitry to actuate the lock;
- at least one lock controller power source;
- a secured unlocking implement (external to the vending area) to unlock the mechanism;
- a non-secured unlocking implement (with at least a portion inside the vending area) to also unlock the mechanism.
- The complaint expressly reserves the right to assert additional claims (Compl. ¶50).
U.S. Patent No. 11,493,262 - Cooler Lock, issued November 8, 2022
The Invention Explained
- Problem Addressed: As with the ’833 Patent, the invention addresses the risk of food spoilage in commercial coolers used in unattended settings by preventing access when unsafe conditions are detected (Compl. ¶56).
- The Patented Solution: The patent, which shares a common specification with the '833 Patent, describes a food storage vending cabinet access control system. A controller operates in a "normal operation mode" permitting access but transitions to a "fault condition" to restrict access when it detects an event risking spoilage, such as the temperature remaining above an elevated limit for a set time (’262 Patent, col. 10:1-12). The system includes unlocking implements and is designed to continue monitoring even during a power interruption using a backup power supply (Compl. ¶57).
- Technical Importance: This technology offers a robust, automated solution for food safety compliance in commercial vending and micro-market applications (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 9 (Compl. ¶58).
- Independent Claim 1 recites a food storage vending cabinet access control system for locking an unlocked cabinet, comprising:
- a locking element and a locking mechanism;
- a controller configured to operate in a "normal operation mode" and a "fault condition";
- the controller is configured to transition to the fault condition and actuate the lock when an event risking spoilage occurs (e.g., temperature exceeds a limit for a period of time);
- a first unlocking implement (independent from the controller) to unlock the mechanism and generate a signal to return the controller to normal operation;
- a second unlocking implement (independent from the controller) to unlock the mechanism while keeping the controller in the fault condition.
- The complaint expressly reserves the right to assert additional claims (Compl. ¶62).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant's "SmartLock II health timer controller" and its "Gen2 electromechanical lock," as implemented in numerous Minus Forty refrigerator and freezer merchandisers (Compl. ¶27).
Functionality and Market Context
- The SmartLock II is described as a "fully integrated, dual function food health and refrigeration controller" that "automatically locks to door preventing access to potentially hazardous food" (Compl. ¶28).
- It operates by using a controller and temperature sensors to continuously monitor the internal cabinet temperature. If the temperature exceeds a configurable threshold for a set duration (e.g., 41°F for 30 minutes in refrigerators, or 0°F for 30 minutes in freezers), the system activates a mechanical lock to secure the door (Compl. ¶30, ¶32). A specification sheet for an accused refrigerator shows an adjustable "Smartlock Trigger" set to ≥ 41°F (Compl. ¶31, p. 14).
- The complaint alleges Defendant manufactures and sells these merchandisers for use in vending machines and micro-markets, placing it in direct competition with Plaintiff (Compl. ¶26, ¶40). A technical bulletin excerpted in the complaint describes the purpose of the lock as preventing "public access to potentially hazardous food" in the event of a unit malfunction (Compl. ¶32, p. 15).
IV. Analysis of Infringement Allegations
’833 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a lock for a food storage vending cooler or freezer having a cabinet, a door on the cabinet... | Defendant’s Accused Products are freezer and refrigerator merchandisers comprising a cabinet, a door, and an internal food storage area (Compl. ¶26-27). | ¶26, ¶27 | col. 1:10-12 |
| an electronic lock mechanism mounted on the cabinet, the lock mechanism configured to selectively engage the locking element to lock and unlock the door... | The Accused Products include a "Gen2 electromechanical lock" mounted to the cabinet that engages a door-mounted element to selectively lock and unlock the door (Compl. ¶27, ¶31). | ¶27, ¶31 | col. 3:6-14 |
| lock controller circuitry associated with the lock mechanism to actuate the lock mechanism to lock the door... | The Accused Products include a "SmartLock II health timer controller" that "automatically locks" the door by activating the mechanical lock when triggering conditions are met (Compl. ¶28, ¶32). A flowchart illustrates this control logic (Compl. ¶17-18, p. 8). | ¶28, ¶32 | col. 7:35-52 |
| a secured unlocking implement independent from the cooler controller circuitry and external to the refrigerated vending area to selectively unlock the lock mechanism... | The Accused Products allegedly permit temporary access while electronically locked via an "external keyed lock operable to temporarily disengage the locking components" (Compl. ¶35). | ¶35 | col. 4:37-41 |
| a non-secured unlocking implement independent from the lock controller circuitry... wherein at least a portion of the non-secured unlocking implement is inside the refrigerated vending area... | The complaint alleges the Accused Products have an "internally disposed release is operable to temporarily disengage the locking components without resetting the locked state of the controller" (Compl. ¶35). | ¶35 | col. 4:56-64 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused "SmartLock II" controller meets all the functional requirements of the claimed "lock controller circuitry." The patent describes detailed logic flows (e.g., checking for service mode, probe faults) that may be argued to be required by the claims, potentially creating a mismatch with the accused system's alleged logic.
- Technical Questions: The infringement allegation for the "non-secured unlocking implement" relies on an "internally disposed release" (Compl. ¶35). A factual dispute may arise over whether this accused feature is located "inside the refrigerated vending area" as required by claim 1 of the ’833 Patent, and whether it functions to "selectively unlock the lock mechanism" in the manner claimed.
V. Key Claim Terms for Construction
The Term: "lock controller circuitry" (from ’833 Patent, Claim 1) and "controller" (from ’262 Patent, Claim 1)
Context and Importance: This is the "brain" of the patented system. The outcome of the case may depend on whether the specific operational logic of Defendant's "SmartLock II controller" falls within the scope of this term. Practitioners may focus on this term because the patents describe a multi-step decision process, while the Defendant's product literature describes a more direct "if temperature > X for Y minutes, then lock" function.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to the controller generally as a "microcomputer or microprocessor-based controller," which could support a construction not limited to a specific algorithm (’833 Patent, col. 8:41-43).
- Evidence for a Narrower Interpretation: The detailed description and Figure 15 describe a specific control logic sequence, including checks for service mode, power loss, and probe faults, which a defendant may argue confines the term to a controller that performs these specific steps (’833 Patent, col. 7:35-col. 8:10; Fig. 15).
The Term: "fault condition" (’262 Patent, Claim 1)
Context and Importance: The claims require the controller to transition between a "normal operation mode" and a "fault condition." The definition of this term is critical for determining when infringement occurs. The dispute may center on whether any high-temperature event constitutes a "fault condition," or if the term requires a specific type of malfunction as distinct from a normal, temporary temperature fluctuation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the fault event as one "requiring the cooler or freezer to be locked," which could encompass any condition that meets the programmed locking criteria, such as a prolonged over-temperature state (’262 Patent, col. 9:13-16).
- Evidence for a Narrower Interpretation: The specification discusses faults in the context of events like a "failed probe or an over temperature event" and a "malfunction of the cooler or the probe" (’833 Patent, col. 6:1-2; col. 8:21-23). This could support an argument that the term implies an actual equipment failure, not just a transient state.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. It alleges inducement by citing Defendant's user manuals, technical bulletins, and other instructions that allegedly direct end-users to operate the products in an infringing manner (Compl. ¶47-48, ¶59-60). It alleges contributory infringement on the basis that the Accused Products are "especially designed" for this use and have no substantial non-infringing use (Compl. ¶49, ¶61).
- Willful Infringement: The complaint alleges willfulness based on Defendant's alleged knowledge of the patents and infringement. The asserted grounds for knowledge include production of the patent applications in a prior Canadian litigation beginning in September 2019, a direct notice letter sent in February 2020, subsequent CEO-level discussions, and an industry press release (Compl. ¶37-39, ¶52, ¶64).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the term "lock controller circuitry," which the patent illustrates with a multi-step logic flow (including checks for service mode and probe faults), be construed broadly enough to read on the accused controller, which is alleged to operate on a more direct "if temperature exceeds X for Y minutes, then lock" basis?
- A second central question will be evidentiary and functional: does the Defendant's "internally disposed release" constitute a "non-secured unlocking implement" that is located "inside the refrigerated vending area" as strictly required by claim 1 of the ’833 Patent? The precise location and operation of this component in the accused products will be a critical factual determination.
- Finally, the case may turn on the definition of a triggering event: does the transition to a "fault condition" as claimed in the ’262 Patent require an actual equipment malfunction, or does it simply describe the state of the system after any pre-programmed, time-and-temperature-based threshold has been crossed?