DCT

3:25-cv-00494

Eps Ehrhardt + Partner Solutions Inc v. Honeywell Intl Inc

Key Events

Amended Complaint

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: EPS - Ehrhardt + Partner Solutions Inc. (Delaware)
- Defendant: Honeywell International Inc., Vocollect, Inc., Hand Held Products, Inc., and Intelligrated Headquarters LLC (collectively, "Honeywell") (Various, with principal places of business in North Carolina)
- Plaintiff’s Counsel: Moore & van Allen PLLC
Case Identification: 3:25-cv-00494, W.D.N.C., 10/09/2025
Venue Allegations: Venue is alleged as proper in the Western District of North Carolina, where several Honeywell defendant entities maintain their principal place of business.
Core Dispute: Plaintiff seeks a declaratory judgment that its Lydia Voice Software solution does not infringe eighteen U.S. patents owned by Defendant related to warehouse management, speech recognition, and logistics technology.
Technical Context: The dispute centers on voice-directed software solutions used for supply chain and warehouse optimization, a key technology for improving efficiency in modern logistics.
Key Procedural History: The complaint details extensive pre-suit correspondence initiated by Honeywell in January 2022, which included multiple letters accusing Plaintiff of infringement and progressively expanding the number of patents-in-suit from three to eighteen. Honeywell subsequently filed its own patent infringement complaint against EPS in the Eastern District of Texas.

Case Timeline

Date	Event
2011-05-20	U.S. Patent No. 11,817,078 Priority Date
2014-08-26	U.S. Patent Nos. 10,049,504 & 10,769,863 Priority Date
2016-07-27	U.S. Patent No. 11,158,336 Priority Date
2018-08-14	U.S. Patent No. 10,049,504 Issued
2019-10-01	U.S. Patent Nos. 12,057,139 & 12,400,678 Priority Date
2020-09-08	U.S. Patent No. 10,769,863 Issued
2021-10-26	U.S. Patent No. 11,158,336 Issued
2022-01-18	Honeywell sends first letter accusing EPS of infringement
2022-02-16	EPS sends letter to Honeywell denying infringement
2023-05-02	Honeywell sends letter asserting additional patents
2023-09-08	Honeywell sends letter asserting additional patents
2023-11-14	U.S. Patent No. 11,817,078 Issued
2023-12-05	Honeywell sends letter with claim charts
2024-06-23	Honeywell sends letter asserting additional patents
2024-08-06	U.S. Patent No. 12,057,139 Issued
2025-08-26	U.S. Patent No. 12,400,678 Issued
2025-10-09	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 10,049,504 - "Annotating Three-Dimensional Displays"

Issued: August 14, 2018.

The Invention Explained

Problem Addressed: The patent's background section describes the problem of text annotations in three-dimensional (3D) models of facilities becoming unreadable, obscured, or overlapping when a user rotates, pans, or zooms the 3D view (’504 Patent, col. 1:36-49).
The Patented Solution: The invention proposes a method for providing "context-driven annotations" that adapt to the user's focus (’504 Patent, col. 2:50-54). The system determines a "context" (e.g., a user selecting a specific building system like "HVAC Network" from a menu, or an automated alarm from a building management system) and then displays only the subset of annotations relevant to that context, hiding or dimming others to reduce clutter (’504 Patent, Abstract; col. 2:40-52). The invention also describes methods for automatically offsetting or dimming annotations to prevent them from occluding each other (’504 Patent, col. 2:55-66).
Technical Importance: This approach sought to improve the usability of complex Building Information Models (BIMs) by preventing information overload and maintaining visual clarity during user interaction (’504 Patent, col. 2:50-54).

Key Claims at a Glance

The complaint does not identify specific asserted claims. Claim 1, an independent method claim, is representative of the patent's core teachings.
The essential elements of Claim 1 are:
- Displaying a particular view of a 3D model of a facility, the model including a plurality of objects, each with a respective annotation.
- Determining a context associated with the 3D model.
- Displaying a subset of the annotations associated with a subset of the objects based on the determined context.

U.S. Patent No. 10,769,863 - "Annotating Three-Dimensional Displays of a Particular View of a 3D Model"

Issued: September 8, 2020.

The Invention Explained

Problem Addressed: As a continuation of the ’504 Patent, this patent addresses the same technical challenge: annotations in 3D facility models becoming unreadable or collapsing on one another when the user manipulates the view, leading to a loss of context awareness (’863 Patent, col. 1:40-49).
The Patented Solution: The patented solution is again a system of context-driven annotations that displays only relevant information based on the user's task or system-generated events (’863 Patent, Abstract). This patent further details methods for managing visual clarity, such as enclosing annotations in rectangles to better handle occlusion and linking offset annotations to their corresponding objects with lines to maintain their association (’863 Patent, col. 6:35-54; Fig. 3).
Technical Importance: The invention aims to make complex 3D digital representations of buildings more manageable for tasks like facility management and auditing by ensuring that critical information remains visible and intelligible regardless of the viewing angle or zoom level (’863 Patent, col. 2:55-60).

Key Claims at a Glance

The complaint does not identify specific asserted claims. Claim 1, an independent method claim, is representative.
The essential elements of Claim 1 are:
- Displaying a particular view of a 3D model of at least a portion of a building, the model including objects each with a respective annotation.
- Determining a context associated with the 3D model.
- Displaying a subset of annotations associated with a subset of objects based on the context.

U.S. Patent No. 7,609,669 - "Voice Directed System and Method Configured for Assured Messaging to Multiple Recipients"

Technology Synopsis: The patent describes a method for warehouse logistics where "selected operators performing logistical operations" use a wireless network to execute a logistical application. The technology focuses on coordinating personnel within a warehouse environment (Compl. ¶46(a)).
Asserted Claims: The complaint does not specify claims but references Claims 1 and 33 as examples (Compl. ¶46(a)).
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution of infringement, suggesting the accused features relate to voice-directed warehouse operations (Compl. ¶¶ 23, 46(a)).

U.S. Patent No. 7,827,032 - "Methods and Systems for Adapting a Model for a Speech Recognition System"

Technology Synopsis: The patent discusses inventory management and warehouse operations as background art to an invention related to adapting speech recognition models (Compl. ¶46(b)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its speech recognition technology used in warehouse management (Compl. ¶¶ 23, 46(b)).

U.S. Patent No. 7,949,533 - "Methods and Systems for Assessing and Improving the Performance of a Speech Recognition System"

Technology Synopsis: The patent discusses warehouse inventory management related to its invention for assessing and improving the performance of speech recognition systems (Compl. ¶46(c)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its speech recognition and performance assessment capabilities in a warehouse context (Compl. ¶¶ 23, 46(c)).

U.S. Patent No. 8,255,219 - "Method and Apparatus for Determining a Corrective Action for a Speech Recognition System Based on the Performance of the System"

Technology Synopsis: The patent discusses warehouse inventory management as it relates to its invention for determining corrective actions for a speech recognition system based on its performance (Compl. ¶46(d)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, suggesting the accused features relate to its speech recognition and performance-based adaptation capabilities (Compl. ¶¶ 23, 46(d)).

U.S. Patent No. 7,885,419 - "Headset Terminal With Speech Functionality"

Technology Synopsis: The patent purports to include technology for a product management system that can be used in a manufacturing or warehouse facility (Compl. ¶46(e)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, suggesting the accused features relate to its integration with hardware in a warehouse setting (Compl. ¶¶ 23, 46(e)).

U.S. Patent No. 8,550,354 - "Indicia Reader System With Wireless Communication With a Headset"

Technology Synopsis: The patent is associated with warehouse management technology and discloses embodiments that include an indicia scanner for use in a store or warehouse (Compl. ¶46(f)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, suggesting an infringement theory related to integration with scanning hardware in a warehouse (Compl. ¶¶ 23, 46(f)).

U.S. Patent No. 8,700,405 - "Audio System and Method for Coordinating Tasks"

Technology Synopsis: The patent discusses a communication device and method with applications in managing and operating an industrial plant (Compl. ¶46(g)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its functionality for coordinating tasks in an industrial or warehouse environment (Compl. ¶¶ 23, 46(g)).

U.S. Patent No. 9,642,184 - "Audio System and Method for Coordinating Tasks"

Technology Synopsis: The patent discusses a communication device and method with applications in managing and operating an industrial plant, similar to the '405 patent (Compl. ¶46(h)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its functionality for coordinating tasks in an industrial or warehouse environment (Compl. ¶¶ 23, 46(h)).

U.S. Patent No. 8,914,290 - "Systems and Methods for Dynamically Improving User Intelligibility of Synthesized Speech in a Work Environment"

Technology Synopsis: The patent discusses using text-to-speech-based devices for inventory management and warehouse operations (Compl. ¶46(i)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its text-to-speech capabilities within a warehouse environment (Compl. ¶¶ 23, 46(i)).

U.S. Patent No. 11,817,078 - "Systems and Methods for Dynamically Improving User Intelligibility of Synthesized Speech in a Work Environment"

Technology Synopsis: The patent discusses using speech-based devices for inventory management and warehouse operations (Compl. ¶46(j)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its speech-based functionalities in a warehouse context (Compl. ¶¶ 23, 46(j)).

U.S. Patent No. 9,361,882 - "Supervisor Training Terminal and Monitor for Voice-Driven Applications"

Technology Synopsis: The patent purports to discuss a system for supervising an operator in a speech-based task management system, with embodiments where the system is used in inventory management and warehouse operations (Compl. ¶46(k)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, suggesting the accused features relate to supervisor or training modes within the software (Compl. ¶¶ 23, 46(k)).

U.S. Patent No. 9,152,940 - "Method and Apparatus for Optimized Shipping Strategies Accounting for Endpoint Requirements"

Technology Synopsis: The patent discusses warehouse control software, loading products from a distribution center, and incorporates speech-directed technology (Compl. ¶46(m)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint alleges Honeywell has accused EPS's Lydia Voice Software solution, indicating the accused features relate to its warehouse control and speech-directed functionalities (Compl. ¶¶ 23, 46(m)).

U.S. Patent No. 11,158,336 - "Distinguishing User Speech From Background Speech in Speech-Dense Environments"

Technology Synopsis: The technology addresses distinguishing user speech from background speech in warehouse environments and claims methods that include speech recognition (Compl. ¶46(n)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint states Honeywell has asserted that EPS's Lydia Voice software solution infringes this patent (Compl. ¶46(n)).

U.S. Patent No. 12,057,139 - "Distinguishing User Speech From Background Speech in Speech-Dense Environments"

Technology Synopsis: The patent discusses applications for distinguishing user speech from background speech in warehouse environments, particularly in warehouse picking operations, and claims methods of speech recognition (Compl. ¶46(o)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint states Honeywell has asserted that EPS's Lydia Voice software solution infringes this patent (Compl. ¶46(o)).

U.S. Patent No. 12,400,678 - "Distinguishing User Speech From Background Speech in Speech-Dense Environments"

Technology Synopsis: The patent discloses applications for distinguishing user speech from background speech in warehouse environments and purports to claim methods of speech recognition in warehouse picking operations (Compl. ¶46(p)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint states Honeywell has asserted that EPS's Lydia Voice software solution infringes this patent (Compl. ¶46(p)).

U.S. Patent No. 8,386,261 - "Training/Coaching System for a Voice-Enabled Work Environment"

Technology Synopsis: The patent discusses speech-recognition and text-to-speech technology and allegedly encompasses warehouse management systems (Compl. ¶46(q)).
Asserted Claims: Not specified in the complaint.
Accused Features: The complaint states Honeywell has asserted that EPS's Lydia Voice software solution infringes this patent (Compl. ¶46(q)).

III. The Accused Instrumentality

Product Identification: The accused instrumentality is Plaintiff's "Lydia Voice Software solution" (Compl. ¶23).
Functionality and Market Context: The Lydia Voice Software is described as a "voice solution to optimize logistics processes" as part of a suite of products for supply chain optimization, including warehouse management systems ("WMS") and warehouse control systems ("WCS") (Compl. ¶14). The complaint notes Honeywell's accusations suggest the software includes functionality related to displaying "three-dimensional models of facilities" (Compl. ¶46(l)) and features for distinguishing user speech from background noise in warehouse environments (Compl. ¶46(n), (o), (p)). Plaintiff EPS describes itself as a "global leader in the supply chain optimization software industry" (Compl. ¶14).

IV. Analysis of Infringement Allegations

As this is a complaint for declaratory judgment of non-infringement, it does not contain affirmative infringement allegations or claim charts. Instead, it describes accusations made by Honeywell in pre-suit correspondence (Compl. ¶¶ 23, 26, 28, 30, 39). The complaint does not provide specific claim charts that Honeywell may have presented.

For the '504 and '863 patents, the complaint states that Honeywell's accusations relate to EPS's "warehouse control systems" and involve "technology that relates to three-dimensional models of facilities" (Compl. ¶46(l)). This suggests a narrative infringement theory wherein Honeywell alleges that the Lydia Voice Software includes a feature for displaying a 3D model of a warehouse or similar facility, and that this feature displays annotations (e.g., for equipment or inventory) in a manner that is "context-driven" as claimed by the patents. The specific operational details of the accused software that would map to the claim elements are not provided in the complaint.

No probative visual evidence provided in complaint.

Identified Points of Contention:
- Scope Questions: A primary question may be whether the accused software's graphical interface, if any, qualifies as a "3D model of a facility" or "building" as those terms are used in the patents. The patents' specifications repeatedly reference complex "Building Information Models (BIMs)," which may suggest a narrower scope than a typical warehouse logistics map (’504 Patent, col. 1:15-20).
- Technical Questions: A key technical question will be whether the filtering or display management functions in the accused Lydia software perform the function of "determining a context" and "displaying a subset of the plurality of annotations...based on the context" as required by the independent claims. The complaint does not provide sufficient detail to analyze how the accused software's display functions operate, raising the question of what evidence supports Honeywell's allegation that it meets this claim limitation.

V. Key Claim Terms for Construction

The Term: "context associated with the 3D model" (Claim 1, ’504 Patent; Claim 1, ’863 Patent).
- Context and Importance: This term is central to the claimed invention of both the ’504 and ’863 patents. The definition of "context" will be critical to determining whether standard user-interface filtering functions fall within the claim scope, or if a more dynamic or automated system response is required. Practitioners may focus on this term because its interpretation could distinguish the patented invention from conventional methods of managing display layers.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification discloses that "context can be determined based on user interaction with the 3D model," including a user "clicking on, or hovering over, an object" (’504 Patent, col. 2:45-48). The specification also provides an example where context is derived from a user selecting "HVAC Network" from a menu to cause the display of associated annotations (’504 Patent, col. 4:50-66). This language may support a construction covering user-initiated filtering.
  - Evidence for a Narrower Interpretation: The specification also provides examples where context is determined from external, automated events, such as "information received from a subsystem of a building management system" where "if an alarm is present... some embodiments can allow the display... of annotations associated with portions of the 3D model corresponding to the alarm" (’504 Patent, col. 2:40-45). This may support a narrower construction requiring a response to system-level events rather than just direct user commands.
The Term: "3D model of a facility" (Claim 1, ’504 Patent).
- Context and Importance: The applicability of the patent to the accused software hinges on whether the software includes this feature. The construction of this term will determine whether a schematic or simplified graphical representation of a warehouse constitutes a "3D model of a facility." Practitioners may focus on this term because the patents frequently associate the invention with a "Building Information Model (BIM)," a term of art for a specific type of data-rich 3D model (’504 Patent, col. 1:15-20).
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification describes a BIM as "a digital representation of the physical and/or functional characteristics of the facility," a broad definition which could be argued to cover various types of digital representations, not just formal BIMs (’504 Patent, col. 4:11-13).
  - Evidence for a Narrower Interpretation: The background section consistently frames the invention in the context of complex structures, referring to "a facility (e.g., a building, plant, refinery, etc.)" (’504 Patent, col. 1:14-15). This, combined with the repeated references to BIMs, may support a construction limited to more complex and data-rich models than what might be found in a typical logistics application.

VI. Other Allegations

Indirect Infringement: The complaint does not contain facts or allegations regarding indirect infringement claims by Honeywell.
Willful Infringement: The complaint does not allege that Honeywell has accused EPS of willful infringement. The extensive pre-suit correspondence detailed in the complaint establishes that EPS was aware of the patents prior to the filing of the lawsuit (Compl. ¶¶ 23-36).

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

A central factual question will be one of feature existence: does the accused "Lydia Voice Software" actually incorporate a feature for displaying a "3D model of a facility" with annotations, as Honeywell's accusations appear to allege, or is there a fundamental mismatch between the asserted patent technology and the accused product's functionality?
A core legal issue will be one of definitional scope: can the term "context," which the asserted 3D modeling patents describe in relation to both user menu selections and automated building system alarms, be construed to cover the specific filtering and display mechanisms, if any, within EPS's warehouse control software?
A key procedural issue will be the manageability of the dispute, which involves eighteen patents spanning disparate technologies from 3D model annotation to speech recognition in noisy environments. The court will need to determine how to efficiently adjudicate claims across such a broad and varied patent portfolio asserted against a single software suite.