DCT

1:25-cv-13450

Security People Incdba Digilock v. Triteq Lock & Security LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Security People, Inc. d/b/a DIGILOCK (Texas)
    • Defendant: TriTeq Lock & Security, LLC (Illinois)
    • Plaintiff’s Counsel: Venable LLP
  • Case Identification: 1:25-cv-13450, N.D. Ill., 11/03/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant maintains an office with employees in the district and has committed the alleged acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s electronic cam lock products and associated management systems infringe a family of patents related to electronic and network-connected locks designed to retrofit conventional mechanical locks.
  • Technical Context: The technology at issue involves electronic locking systems for furniture such as cabinets, drawers, and lockers, a market segment transitioning from traditional key-operated mechanical locks to digitally-accessed electronic solutions.
  • Key Procedural History: The complaint notes that pre-suit settlement negotiations between the parties were unsuccessful. It also alleges that Defendant had knowledge of Plaintiff's patent family as early as July 2017, when a Digilock patent publication was cited during the prosecution of a patent application owned by Defendant, a fact which may be central to the allegations of willful infringement.

Case Timeline

Date Event
2006-05-31 Earliest Patent Priority Date ('898, '443, '492, '789, '099, '522 Patents)
2013-07-23 U.S. Patent No. 8,490,443 Issues
2013-07-30 U.S. Patent No. 8,495,898 Issues
2016-03-01 U.S. Patent No. 9,273,492 Issues
2017-07-17 Alleged Actual Notice of '898 Patent to Defendant
2017-07-21 Alleged First Knowledge of Patent Family by Defendant
2021-02-02 U.S. Patent No. 10,909,789 Issues
2021-02-23 U.S. Patent No. 10,930,099 Issues
2024-06-25 U.S. Patent No. 12,020,522 Issues
2025-04-07 Alleged Actual Notice of '789, '099, '898, '443, '492, '522 Patents
2025-11-03 Complaint Filing Date

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

U.S. Patent No. 10,909,789 - "Electronic Cam Lock for Cabinet Doors, Drawers and Other Applications"

The Invention Explained

  • Problem Addressed: The patent's background section identifies a need for a "relatively simple, easily used, reliable and compact electronic lock" capable of being installed in the "standard opening or bore" of conventional mechanical cam locks used in furniture like cabinets and lockers (Compl. ¶12; ’789 Patent, col. 1:62-2:6). This addresses the difficulty and expense of upgrading existing furniture to electronic access control.
  • The Patented Solution: The invention is a self-contained, battery-powered electronic lock designed to directly replace a mechanical lock assembly. As shown in Figures 4 and 5, it features a housing (14) with a keypad (15) and a rotatable knob (12) on the exterior, and a cam lock cylinder unit (26) that extends through the standard opening in a panel (40). Upon entry of a correct code, the electronics release the knob, allowing a user to manually rotate a cam (30) on the interior to lock or unlock the cabinet or drawer (’789 Patent, Abstract; col. 7:1-12).
  • Technical Importance: The technology provided a "retrofit" solution, enabling the upgrade of legacy mechanical locks to electronic keypad access without requiring significant modifications to the existing furniture (Compl. ¶14-15; ’789 Patent, col. 3:9-16).

Key Claims at a Glance

  • The complaint asserts independent claim 1, among others (Compl. ¶53).
  • The essential elements of independent claim 1 include:
    • A compact housing with electronics and a terminal for code entry.
    • A cam lock plug unit extending from the housing, adapted to fit into a standard cam lock cylinder shell already present on a door or panel.
    • A knob or handle on the housing for manual operation of the cam lock plug unit.
    • A battery compartment within the housing.
    • The housing being a "self-contained, single housing comprising the sole housing and sole electronics of the cam lock device."
  • The complaint also asserts claims 35, 43-44, 52, and 57-58 (Compl. ¶52).

U.S. Patent No. 10,930,099 - "Electronic Cam Lock for Cabinet Doors, Drawers and Other Applications"

The Invention Explained

  • Problem Addressed: The patent addresses a manufacturing and inventory challenge where electronic locks with fixed-length plugs require manufacturers to "manufacture and stock cam locks of differing plug lengths" to accommodate cabinets and doors of various thicknesses (Compl. ¶28; ’099 Patent, col. 10:26-29).
  • The Patented Solution: The patent discloses a modular "adapter plug" system. As illustrated in Figures 13 and 14, the electronic lock assembly (74a) has a standardized "drive shaft" (102). A separate, interchangeable "plug" (108) of a specific length connects this drive shaft to the internal locking mechanism of a cylinder (104). This allows a single electronic unit to be paired with different length plugs to fit various installation depths (’099 Patent, col. 10:30-51).
  • Technical Importance: This approach simplifies the manufacturing supply chain by allowing one common electronic lock assembly to be adapted to various furniture dimensions using simple, interchangeable plugs of different lengths (Compl. ¶30).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶58).
  • The essential elements of independent claim 1 include:
    • A housing with electronics and a terminal for code entry.
    • A rotatable knob or handle.
    • A "drive shaft" extending from the rear of the housing and coupled to the knob.
    • A "rotatable plug unit" configured to be front-loaded into a cam lock cylinder shell.
    • The plug unit is configured to operatively couple to the drive shaft on one end and to a locking element on the other.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 8,495,898, "Cam Lock with Retractable Bolt," issued July 30, 2013.

  • Technology Synopsis: This patent discloses a foundational compact electronic cam lock designed to retrofit standard mechanical lock openings. It describes the core functionality of a keypad-operated, battery-powered, self-contained unit with a rotatable knob that, when electronically released, operates a cam or bolt on the interior of a cabinet or drawer (Compl. ¶14-22).

  • Asserted Claims: Claims 1 and 19 (Compl. ¶63).

  • Accused Features: The complaint alleges that the general structure and retrofit functionality of the "MicroIQ locks" infringe the '898 Patent (Compl. ¶63-64).

  • Patent Identification: U.S. Patent No. 8,490,443, "Electronic Lock for Cabinet Doors, Drawers and Other Applications," issued July 23, 2013.

  • Technology Synopsis: Similar to the '898 patent, this patent covers a compact electronic lock for retrofitting mechanical locks. It includes embodiments for both fixed-plug installations and removable-plug retrofits, where an electronic plug unit is inserted into an existing mechanical lock cylinder shell (Compl. ¶22, 27).

  • Asserted Claims: Claims 1 and 19 (Compl. ¶71).

  • Accused Features: The complaint alleges that the general hardware configuration and retrofit capabilities of the "MicroIQ locks" infringe the '443 Patent (Compl. ¶71-72).

  • Patent Identification: U.S. Patent No. 9,273,492, "Electronic Cam Lock for Cabinet Doors, Drawers and Other Applications," issued March 1, 2016.

  • Technology Synopsis: This patent expands on the core electronic cam lock technology by describing embodiments that include network connectivity for remote access and control. It discloses locks equipped with wireless antennas (e.g., Bluetooth) or wired network receptacles, allowing administrators to manage access codes and audit lock usage from a central system (Compl. ¶32-36).

  • Asserted Claims: Claims 1 and 4-6 (Compl. ¶79).

  • Accused Features: The MicroIQ locks' alleged wireless communication capability (e.g., Bluetooth) and their management through the cloud-based "ProxTraq" system are accused of infringing the '492 Patent (Compl. ¶47-48, 79).

  • Patent Identification: U.S. Patent No. 12,020,522, "Electronic Cam Lock for Cabinet Doors, Drawers and Other Applications," issued June 25, 2024.

  • Technology Synopsis: This patent appears to be part of the same family, covering compact electronic cam locks for retrofitting furniture. The specific claims asserted in the complaint are not identified beyond "at least claim 1" (Compl. ¶87).

  • Asserted Claims: At least Claim 1 (Compl. ¶87).

  • Accused Features: The complaint alleges that the general hardware and functionality of the "MicroIQ locks" infringe the '522 Patent (Compl. ¶87-88).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendant's "MicroIQ UT Cam/Utility Electronic Lock," "MicroIQ CT Electronic Lock for Haworth," and the associated "MicroIQ ProxTraq" cloud-based management system (collectively, "Accused Products") (Compl. ¶42).

Functionality and Market Context

  • The complaint describes the MicroIQ UT and CT locks as electronic, battery-powered keypad locks designed to "directly replace" existing mechanical cam locks on furniture and office cabinets (Compl. ¶43, 45). The UT model is presented as a "Fixed Plug" version, while the CT model is described as a "Removable/Adapter Plug" version designed to replace specific existing lock cores, such as a "Haworth key" (Compl. ¶43-46). An image provided in the complaint depicts the MicroIQ UT Cam/Utility electronic lock as a compact unit with a five-button keypad and a rotary knob (Compl. p. 15).
  • The MicroIQ ProxTraq system is alleged to be a cloud-based web portal and mobile application that enables "enterprise-wide access management" of the locks (Compl. ¶47). This system allegedly allows administrators to remotely control access credentials, set permissions, and receive audit trail information via the locks' wireless communication capabilities (e.g., Bluetooth) (Compl. ¶48). A screenshot in the complaint shows a web interface for managing multiple locks across an organization (Compl. p. 17).

IV. Analysis of Infringement Allegations

10,909,789 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a compact housing containing electronics and having a terminal enabling entry of a code by a user... The MicroIQ UT lock allegedly has a "compact housing containing electronics and having a keypad or other terminal" for a user to input an access code. ¶44 col. 6:1-6
a cam lock plug unit extending from a back side of the housing, adapted to fit into a standard cam lock cylinder shell... The lock is allegedly "adapted to fit through a standard cam lock opening" and includes a "threaded cam cylinder unit extending from a back side of the housing with a rotatable core". ¶44 col. 3:7-16
...said cam lock plug unit extending into and fitted into the standard cam lock cylinder shell... The UT lock is alleged to be an electronic cam lock that "directly replace[s] the cam locks found on desks, furniture, and office cabinets," implying it fits into existing hardware. ¶43-44 col. 9:6-12
...a knob or handle on the housing for operating the cam lock device manually without a mechanical key to rotate the cam lock plug unit... A correct access code allegedly activates the electronics to "permit turning of the knob," which in turn causes the rotatable core to rotate. ¶44 col. 6:7-10
...the housing including a battery compartment containing one or more batteries... and the housing being a self-contained, single housing comprising the sole housing and sole electronics... The lock is allegedly "powered by a concealed and secured low profile coin-cell battery." The complaint describes a single physical unit. ¶43-44 col. 6:45-48

10,930,099 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a housing containing electronics and having a terminal for receipt of an access code... The MicroIQ CT lock allegedly has a keypad or other terminal for a user to input an access code. An image of the lock shows a keypad and knob on a housing (Compl. p. 16). ¶46 col. 10:30-35
a drive shaft extending from a rear side of the housing and operatively coupled to the knob or handle; The complaint does not explicitly mention a "drive shaft," but alleges the CT lock has a "plug extending from the back side of the housing." ¶46 col. 10:35-37
a rotatable plug unit configured to be selectively front loaded in the cam lock cylinder shell... The CT lock's plug allegedly "matches the size and shape of the cam lock shell already mounted on the door," replacing a conventional key and core. ¶46 col. 10:38-41
...the rotatable plug unit configured to operatively couple on a first end to the drive shaft... The complaint alleges the CT lock "includes a plug extending from the back side of the housing," which replaces the conventional lock and key, implying a coupling that allows operation. ¶46 col. 10:41-43
wherein the electronics are configured to permit rotation of the knob or handle upon receipt of a predetermined access code. Entering a correct access code allegedly "will activate the electronics stored in the housing to permit turning of the knob." ¶46 col. 10:50-53
  • Identified Points of Contention:
    • A potential scope question for the ’789 Patent is whether the Accused Products meet the limitation "sole housing and sole electronics." Defendant may argue that because the locks are designed to be managed by the separate ProxTraq cloud system, the electronics are distributed and not "solely" within the device housing.
    • For the ’099 Patent, a key technical question will concern the "drive shaft" and "rotatable plug unit" elements. The complaint describes the accused CT lock as having a single "plug extending from the back side." The analysis may focus on whether this single component can be shown to embody both the claimed "drive shaft" and the separate "rotatable plug unit" to which it couples, or if there is a technical mismatch.

V. Key Claim Terms for Construction

  • The Term: "self-contained, single housing comprising the sole housing and sole electronics of the cam lock device" (’789 Patent, Claim 1)

    • Context and Importance: This term is central because the Accused Products are marketed with an associated cloud-based management system (ProxTraq). Practitioners may focus on this term because Defendant could argue that the lock is not "self-contained" and its electronics are not the "sole electronics" when it is part of a larger, networked ecosystem.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification emphasizes that the physical hardware is a single unit installed on the cabinet, stating an "important feature" is that the device "includes no housing or electronic components at the inside of a door or drawer or panel" (’789 Patent, col. 8:33-38). This may support an interpretation where "sole electronics" refers to the hardware necessary for local operation, irrespective of optional network connectivity.
      • Evidence for a Narrower Interpretation: The specification also describes network-connected embodiments where a "central control system" can manage the locks (’789 Patent, col. 16:7-13). This could support an argument that once networked, the electronics are distributed, and the lock is no longer operating with its "sole electronics."

  • The Term: "drive shaft" and "rotatable plug unit" (’099 Patent, Claim 1)

    • Context and Importance: The claim requires two distinct components: a "drive shaft" extending from the housing and a "rotatable plug unit" that couples to it. Infringement depends on whether the accused CT lock, which the complaint describes as having "a plug extending from the back side" (Compl. ¶46), embodies this two-part structure.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the invention as an "adapter plug system" that replaces a single, fixed-length plug (Compl. ¶28-29). This purpose could support construing the terms broadly to cover any two-part assembly that achieves this modularity, even if the parts are sold together.
      • Evidence for a Narrower Interpretation: Figure 14 explicitly depicts the "drive shaft" (102) as a male-like keyed post extending from the housing (74a) and the "plug" (108) as a separate, female component that receives the shaft (’099 Patent, Fig. 14; col. 10:35-46). This could support a narrower construction requiring two physically separate and distinct components with a keyed interface.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for the '898, '443, '492, and '522 patents. The allegations are based on Defendant providing "step-by-step instructions for installation, setup, and use" via user manuals and its website, which allegedly instruct customers on how to use the Accused Products in an infringing manner (Compl. ¶64, 72, 80, 88). The complaint further alleges the products have no substantial non-infringing use (Compl. ¶65, 73, 81, 89).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The claims are based on constructive notice from each patent's issuance date and alleged actual notice from Plaintiff's contact with Defendant on or around April 7, 2025 (Compl. ¶56, 61, 68, 76, 84, 92). Critically, for the '898 patent and the broader patent family, the complaint alleges pre-suit knowledge dating to at least July 21, 2017, when a Digilock patent publication was allegedly cited as prior art during the prosecution of Defendant's own patent application (Compl. ¶51, 68).

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

  • A core issue will be one of definitional scope: can the modular claim language of the '099 Patent, requiring a distinct "drive shaft" and "rotatable plug unit," be construed to read on the accused product's allegedly integrated plug mechanism? Similarly, can the "sole housing and sole electronics" language of the '789 Patent encompass a device designed to operate within a networked, cloud-based management system?
  • A second central issue will be willful infringement, particularly the weight of the allegation that Defendant was on notice of Plaintiff's patented technology as early as 2017 due to events in its own patent prosecution history. The factual evidence surrounding this alleged notice will likely be a focal point for determining intent and potential for enhanced damages.