DCT

6:19-cv-02557

Golden v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Larry Golden (South Carolina)
    • Defendant: See Attached List
    • Plaintiff’s Counsel: Pro Se
  • Case Identification: 6:19-cv-02557, D.S.C., 10/15/2019
  • Venue Allegations: Plaintiff alleges venue is proper under 28 U.S.C. §§ 1391(c) and 1400(b).
  • Core Dispute: Plaintiff alleges patent infringement under Title 35 of the U.S. Code related to multi-sensor detection, security, and lock disabling systems.
  • Technical Context: The technology concerns systems for monitoring products, such as shipping containers or vehicles, using various sensors (e.g., chemical, biological, radiological) that can trigger remote locking, disabling, or vehicle-stopping functions.
  • Key Procedural History: The patents-in-suit belong to a large, interrelated family with a lengthy prosecution history involving numerous continuation applications. Notably, U.S. Reissue Patent No. RE43,990 E, one of the patents in the family, was the subject of an Inter Partes Review (IPR) proceeding (IPR2014-00714), which resulted in the cancellation of claims 11, 74, and 81 as confirmed by a certificate issued on July 24, 2018.

Case Timeline

Date Event
2006-04-05 Earliest Priority Date Asserted ('497, '189, '439, '287, '891, '990 Patents)
2008-06-10 U.S. Patent No. 7,385,497 Issues
2013-01-01 U.S. Reissue Patent No. RE43,891 E Issues
2013-02-12 U.S. Reissue Patent No. RE43,990 E Issues
2015-08-04 U.S. Patent No. 9,096,189 B2 Issues
2017-03-07 U.S. Patent No. 9,589,439 B2 Issues
2018-07-24 Inter Partes Review Certificate Cancels Claims of '990 Reissue Patent
2018-12-25 U.S. Patent No. 10,163,287 B2 Issues
2019-10-15 Complaint Filed

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

U.S. Patent No. 10,163,287

  • Patent Identification: U.S. Patent No. 10,163,287, titled "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued December 25, 2018 (’287 Patent).

The Invention Explained

  • Problem Addressed: The patent describes the ongoing threat of terrorist activity and the need for proactive security measures that can be implemented without causing excessive disruption to commerce and daily routines (’287 Patent, col. 2:1-12). The background notes a need for systems that can detect hazards and control access to assets like shipping containers (’287 Patent, col. 2:13-21).
  • The Patented Solution: The invention is a security system that uses a "detector case" containing interchangeable sensors to sample for chemical, biological, or radiological agents (’287 Patent, Abstract). When a harmful agent is detected, the system transmits information to a remote monitoring terminal and sends a signal to a "lock disabler" to secure the product, thereby preventing unauthorized access and further contamination (’287 Patent, col. 4:25-35). The system is depicted as a modular framework adaptable to various products, including shipping containers as shown in Figure 1 (’287 Patent, Fig. 1).
  • Technical Importance: The technology aims to provide an automated, networked security solution for monitoring goods during transport or storage, addressing a critical vulnerability in global supply chains (’287 Patent, col. 4:25-35).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted. Claim 1, the first independent claim, is directed to "Monitoring equipment."
  • Its essential elements include:
    • Monitoring equipment comprising a computer terminal, PC, laptop, handheld, cell phone, PDA, or smart phone interconnected to a lock.
    • A central processing unit (CPU) for communication.
    • A transmitter for sending signals to a remote lock.
    • A receiver for receiving signals from the remote lock.
    • A "lock disabling mechanism" that can engage, disengage, or disable the monitoring equipment itself after a specific number of tries.
    • At least one communication connection (e.g., satellite, Bluetooth, WiFi, cellular).
    • At least one biometric recognition system (e.g., fingerprint, voice, face).
    • The capability of sending signals to control a remote lock, whereupon the lock sends back location or status data.

U.S. Patent No. 7,385,497

  • Patent Identification: U.S. Patent No. 7,385,497, titled "Multi Sensor Detection and Lock Disabling System," issued June 10, 2008 (’497 Patent).

The Invention Explained

  • Problem Addressed: The patent identifies a need for a system to protect various types of products, grouped by common characteristics (e.g., shipping containers, lockers, mail boxes), from terrorist activity, unauthorized entry, and contamination (’497 Patent, col. 1:5-12).
  • The Patented Solution: The invention describes a system comprising detector cases with interchangeable sensors that sample for chemical, biological, and radiological agents (’497 Patent, Abstract). Upon detection, externally visible, color-coded light alarm indicators are activated, and the system transmits information to a monitoring terminal and sends a signal to a "lock disabler" to secure the product's lock (’497 Patent, col. 3:6-23). The system can be interconnected with surveillance towers that scan detector cases on containers at facilities like seaports, as illustrated in Figure 5 (’497 Patent, Fig. 5).
  • Technical Importance: This patent outlines an early version of a networked security architecture for automated, continuous monitoring of static or in-transit assets, a key concern for logistics and homeland security (’497 Patent, col. 3:37-46).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted. Claim 1, the first independent claim, is directed to "A multi sensor detection and lock disabling system."
  • Its essential elements include:
    • A detector case with a power source and a CPU.
    • A plurality of indicator lights on the case's front side corresponding to specific chemical, biological, or radiological agents.
    • A plurality of interchangeable detectors disposable within the detector case.
    • Each detector having a sound alarm, readings panel, light alarm, and sensor.
    • An automatic/mechanical lock disabler interconnected to the CPU and mounted to a product's lock, which receives a transmission from the CPU to lock or disable it.

Multi-Patent Capsules

  • U.S. Patent No. 9,096,189

    • Patent Identification: U.S. Patent No. 9,096,189, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued August 4, 2015 (’189 Patent).
    • Technology Synopsis: This patent describes a security system that integrates multi-sensor detection with vehicle control capabilities. Upon detection of a threat (e.g., an explosive) or receipt of a remote command, the system can communicate via satellite or cellular tower to activate a "stall-to-stop" mechanism that disables the vehicle's engine and/or locks its doors (’189 Patent, col. 11:1-14).
    • Asserted Claims: The complaint does not specify claims. Claim 1 is a representative independent claim directed to a "communication device."
    • Accused Features: The complaint does not provide sufficient detail to identify accused features for this patent.

  • U.S. Patent No. 9,589,439

    • Patent Identification: U.S. Patent No. 9,589,439, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued March 7, 2017 (’439 Patent).
    • Technology Synopsis: This patent focuses on a security system with a network of watchtowers and communication devices for monitoring critical areas like borders. It describes a system where sensors (including infrared human detection) and communication devices (e.g., mobile phones, laptops) are integrated to detect, track, and identify threats, and can be used to stop or slow a vehicle remotely (’439 Patent, col. 15:46-64).
    • Asserted Claims: The complaint does not specify claims. Claim 1 is a representative independent claim directed to a "multi sensor detection system."
    • Accused Features: The complaint does not provide sufficient detail to identify accused features for this patent.

  • U.S. Reissue Patent No. RE43,891 E

    • Patent Identification: U.S. Reissue Patent No. RE43,891 E, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued January 1, 2013 (’891 Reissue Patent).
    • Technology Synopsis: This is a reissue of U.S. Patent No. 7,636,033. The invention covers a vehicle slowdown and lock disabling system where a remote monitoring station can communicate via satellite or cell tower with a vehicle's transceiver to activate a "stall-to-stop" or "slow-down" command in response to a distress signal, such as one indicating unauthorized use (’891 Reissue Patent, col. 14:1-19).
    • Asserted Claims: The complaint does not specify claims. Claim 1 is a representative independent claim directed to a "stall-to-stop or vehicle slow-down system."
    • Accused Features: The complaint does not provide sufficient detail to identify accused features for this patent.

  • U.S. Reissue Patent No. RE43,990 E

    • Patent Identification: U.S. Reissue Patent No. RE43,990 E, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued February 12, 2013 (’990 Reissue Patent).
    • Technology Synopsis: This is also a reissue of U.S. Patent No. 7,636,033. It describes a comprehensive communication and control system for monitoring products, involving communication devices (e.g., cell phones, PDAs) that can interact with remote sensors and locks via various communication methods (WiFi, cellular, satellite). The system incorporates biometrics and can be used to activate or deactivate security systems (’990 Reissue Patent, col. 15:11-37). Notably, claims 11, 74, and 81 of this patent were cancelled via Inter Partes Review.
    • Asserted Claims: The complaint does not specify claims. Claim 1 is a representative independent claim directed to a "communication device."
    • Accused Features: The complaint does not provide sufficient detail to identify accused features for this patent.

III. The Accused Instrumentality

The complaint does not provide sufficient detail to identify the accused product(s), method(s), or service(s).

IV. Analysis of Infringement Allegations

The complaint does not provide infringement allegations or claim charts for analysis.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a focused analysis of claim construction disputes. However, based on the representative independent claims of the lead patents, certain terms may become central to the case.

Term from the ’287 Patent: "lock disabling mechanism"

  • The Term: "lock disabling mechanism"
  • Context and Importance: This term appears in Claim 1 of the ’287 Patent and refers to a component that can disable the monitoring equipment itself after a certain number of failed access attempts. Its definition is critical because it relates to the security and functionality of the claimed monitoring terminal, not an external product lock. Practitioners may focus on this term because its operation—disabling the monitoring equipment rather than an external lock—is a specific feature that could be a key point of comparison with an accused product.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language states the mechanism is "able to engage (lock), or disengage (unlock), or disable (make unavailable) the monitoring equipment" (’287 Patent, col. 16:8-11). This disjunctive phrasing may support an interpretation where any of these functions meets the limitation.
    • Evidence for a Narrower Interpretation: The specification does not appear to provide a detailed embodiment of this specific feature, which may lead a court to construe it based on its plain and ordinary meaning in the context of securing electronic devices, potentially limiting its scope to conventional device-locking functions like software lockouts.

Term from the ’497 Patent: "automatic/mechanical lock disabler"

  • The Term: "automatic/mechanical lock disabler"
  • Context and Importance: This term from Claim 1 of the ’497 Patent is the component that acts upon an external product's lock. Its construction will be critical for determining infringement, as it defines the nature of the interaction between the patented system and the secured product. The question of whether this requires a physical, mechanical interaction or can be satisfied by a purely electronic signal to a smart lock may be a central point of contention.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the disabler is "interconnected to the cpu" and receives a "transmission," which could encompass wireless electronic signals sent to a modern electronic lock (’497 Patent, col. 11:11-15).
    • Evidence for a Narrower Interpretation: Figure 3a of the patent depicts the disabler (56) as a physical device mounted directly onto an existing mechanical lock (60) on a shipping container (’497 Patent, Fig. 3a). This specific embodiment may support a narrower construction requiring a device that physically engages or manipulates a mechanical lock.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

Given the absence of specific allegations in the provided documents, the case will likely depend on fundamental questions of claim scope and patent validity that are inherent to the technology and its extensive prosecution history.

  • A primary issue will be one of definitional scope: can terms rooted in the patents' descriptions of physical security hardware, such as "automatic/mechanical lock disabler" and "detector case," be construed to cover potentially software-driven or integrated electronic security features in modern products? The interpretation of these terms will be foundational to any infringement analysis.
  • A second critical question will concern patent validity and distinctiveness. Given the large number of related patents and continuation applications, and the successful IPR against the ’990 Reissue Patent, the court will likely face arguments regarding whether the asserted claims are patentably distinct from the prior art, subject to double patenting issues, or invalid for other reasons.