Pinek IP LLC v. Creston Electronics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pinek IP LLC (Texas)
  • Defendant: Crestron Electronics, Inc. (New Jersey)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt, LLC; Rabicoff Law LLC
• Case Identification: 2:19-cv-11386, D.N.J., 04/25/2019
• Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant is incorporated in New Jersey, maintains its principal place of business in the district, and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s wireless occupancy sensor infringes a patent related to a system for remotely activating electronic circuits using a pyroelectric element.
• Technical Context: The technology concerns low-power methods for "waking up" battery-operated electronic devices, a critical function for extending battery life in sensors and other intermittently used wireless products.
• Key Procedural History: The asserted patent is a U.S. national stage entry of an international PCT application. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history.

Case Timeline

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

U.S. Patent No. 7,233,256 - SYSTEM AND METHOD FOR RECEIVING A SIGNAL TO TRIGGER A PYROELECTRIC ACTIVATION SYSTEM

The Invention Explained

• Problem Addressed: The patent describes a problem with battery-powered devices that must remain in a low-power state until activated by a remote signal. Conventional methods that use direct rectification of a radio signal to provide activation power are inefficient, which limits activation range and drains batteries. These systems can also be triggered by unwanted interference signals. (’256 Patent, col. 1:11-30).
• The Patented Solution: The invention proposes converting a received high-frequency activation signal into heat via a heating element. This heat is then transferred to a pyroelectric element, which generates a voltage in response to the temperature change. This voltage, in turn, actuates an activation circuit to "wake up" the main electronics. This thermal conversion pathway is presented as a more efficient and signal-sensitive alternative to direct signal rectification. (’256 Patent, Abstract; col. 1:56-65; Fig. 1).
• Technical Importance: This approach provided a method for activating dormant electronic circuits that was designed to be both highly energy-efficient and less susceptible to interference than prior art radio-frequency-based activation systems. (’256 Patent, col. 1:50-53).

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶12).
• Claim 1 Elements:
  • An activation system, comprising:
  • 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 does not explicitly reserve the right to assert other claims but makes general allegations of infringement of "one or more claims" (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

The "Crestron Zum Wireless Battery-Powered Occupancy Sensor" is identified as an exemplary accused product (Compl. ¶12).

Functionality and Market Context

The complaint alleges that the accused product is made, used, sold, and imported by the Defendant (Compl. ¶12). It provides no specific details regarding the technical operation or internal components of the sensor. The complaint alleges that Crestron distributes "product literature and website materials" related to the product but does not include this material as an exhibit (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references "charts comparing the Exemplary ’256 Patent Claim to the Exemplary Crestron Products" in an Exhibit B (Compl. ¶17). However, this exhibit was not attached to the publicly filed complaint. The infringement theory is therefore based on the complaint's narrative allegations.

The complaint alleges that the Accused Instrumentality directly infringes at least Claim 1 of the ’256 Patent because it "practices the technology claimed" and "satisfy all elements" of the asserted claim (Compl. ¶¶12, 17). The complaint does not explain how the accused occupancy sensor allegedly meets each limitation of Claim 1.

• Identified Points of Contention:
  • Technical Questions: A primary question will be evidentiary: what is the actual mechanism of operation of the accused occupancy sensor? Occupancy sensors typically use passive infrared (PIR) detectors, which themselves can be pyroelectric elements, to detect ambient body heat. The complaint provides no facts to support its theory that the accused product operates according to the patent's specific architecture, which involves receiving an "activation signal," actively heating a pyroelectric element in response, and using the resulting voltage to trigger a separate "activation circuit."
  • Scope Questions: The infringement analysis raises a question of claim scope: does the phrase "heated by the activation signal from said receiving device" read on the function of a standard PIR occupancy sensor? The court may need to determine if passively detecting ambient infrared radiation is equivalent to the patent's described process of actively converting a received radio signal into heat to stimulate the pyroelectric element.

V. Key Claim Terms for Construction

• The Term: "heated by the activation signal from said receiving device"
• Context and Importance: This phrase is the functional core of the asserted claim, defining the causal link between the received signal and the voltage generation. The viability of the infringement case hinges on whether the accused product's operation can be characterized as performing this specific heating step. Practitioners may focus on this term because its construction will likely resolve whether the patent covers passive environmental sensing or is limited to systems that actively convert a transmitted signal to heat.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is general and does not specify the nature of the "activation signal" (e.g., radio, infrared) or the mechanism of heating. An argument could be made that any signal received by the device that results in a temperature change in the pyroelectric element falls within the plain meaning of the claim.
  • Evidence for a Narrower Interpretation: The specification repeatedly frames the invention in the context of receiving a "radio signal" or "high-frequency-activation signal" and converting it to heat using a "special heating element, in particular... an ohmic resistance" connected to the receiving device. (’256 Patent, col. 1:62-63; col. 3:55-60; Fig. 1). This suggests a specific, multi-step process where the received signal is not the heat itself, but rather the energy source for a separate heater, potentially narrowing the term's scope to exclude passive thermal detection.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced and contributory infringement, stating that Crestron sells the accused products to customers and provides "product literature and website materials" that instruct them to use the products in an infringing manner (Compl. ¶¶13-14, 16). The complaint does not provide specific factual support, such as excerpts from user manuals.
• Willful Infringement: The complaint does not use the term "willful." It does allege, however, that the filing of the complaint constitutes notice to the Defendant and that infringement has continued post-filing (Compl. ¶¶15-16). This provides a basis for alleging post-suit knowledge to support a potential future claim for enhanced damages.

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

This case appears to present two fundamental questions for the court:

1. A core issue will be one of technical mechanism versus claim scope: Can the claim limitation "heated by the activation signal," which the patent specification describes in the context of actively converting a transmitted radio wave into thermal energy, be construed to cover the function of a passive infrared (PIR) occupancy sensor that detects ambient body heat?

2. A key evidentiary question will be one of operative reality: Given the lack of technical detail in the complaint, the case will depend on whether discovery reveals that the accused sensor actually contains the specific components (a receiving device, a distinct heater, a pyroelectric element, and an activation circuit) that operate in the precise sequence described and claimed in the ’256 Patent.