Thermo Dynamic Solutions LLC v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Thermo Dynamic Solutions LLC (Texas)
  • Defendant: Honeywell International Inc. (Delaware)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 2:17-cv-00047, E.D. Tex., 01/13/2017
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendant's substantial business in the state, including the sale of accused products and commission of infringing acts within the district.
• Core Dispute: Plaintiff alleges that Defendant’s Lyric Round smart thermostat system infringes a patent related to using occupant feedback gathered over a communications network to determine and adjust an HVAC thermal setpoint.
• Technical Context: The lawsuit involves smart home technology, specifically internet-connected thermostats that allow users to provide input remotely via software applications to control heating and cooling systems.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,145,751 - "Method and Apparatus for Determining a Thermal Setpoint in a HVAC System"

• Patent Identification: U.S. Patent No. 6,145,751, “Method and Apparatus for Determining a Thermal Setpoint in a HVAC System,” issued November 14, 2000.

The Invention Explained

• Problem Addressed: The patent identifies that conventional HVAC systems typically rely on a single, centralized thermostat for feedback, which may not accurately reflect the thermal comfort of all occupants in a space (Compl. ¶11; ’751 Patent, col. 1:18-21). Furthermore, this single sensor can be influenced by local micro-climates, and occupants often have limited or no ability to provide direct feedback to the control system (Compl. ¶¶ 11-12; ’751 Patent, col. 1:22-27, 43-46).
• The Patented Solution: The invention proposes a system where multiple occupants can provide subjective feedback on their thermal comfort (e.g., "cool," "warm") through individual interfaces connected to a communications network like the Internet or an Intranet (’751 Patent, col. 2:9-16). This "fuzzy" feedback is then processed, or "defuzzified," by a central controller to calculate a single "crisp" temperature setpoint that better reflects the collective comfort of the occupants, as illustrated in the process diagram of Figure 7A (’751 Patent, col. 4:54-66).
• Technical Importance: The technology provided a method for aggregating subjective user comfort data from multiple, distributed sources over a network to enable a more responsive and democratic climate control system (’751 Patent, col. 2:9-16).

Key Claims at a Glance

• The complaint asserts independent claim 9 and dependent claim 10 (’751 Patent, col. 14:8-25; Compl. ¶¶ 13, 18).
• Independent Claim 9 recites the following essential elements for a control system:
  • A software interface for entering occupant feedback
  • Means for transmitting the occupant feedback
  • A CPU for receiving the feedback information from the transmitting means
  • The CPU calculates an adjusted thermostat setpoint using a previous thermostat setpoint and the occupant feedback information

III. The Accused Instrumentality

Product Identification

• The complaint identifies "Defendant's Lyric Round thermostat and system" as the "Accused Instrumentality" (Compl. ¶13).

Functionality and Market Context

• The Accused Instrumentality is a smart thermostat system that includes a mobile software application, the "Lyric app," allowing users to control the thermostat and provide feedback (Compl. ¶14). The system is alleged to use a Wi-Fi chip to connect to the Internet and transmit this user feedback to a CPU, which then "calculates an adjusted thermostat setpoint" (Compl. ¶¶ 15-17). A screenshot provided in the complaint shows the mobile app interface, which displays the current temperature and allows for adjustment (Compl. p. 5). The complaint also alleges the system uses geofencing technology to automatically adjust temperature based on the user's location (Compl. p. 5).

IV. Analysis of Infringement Allegations

'751 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The claim recites "means for transmitting the occupant feedback." As a means-plus-function element, its scope is limited to the corresponding structure in the specification—an "Internet and/or Intranet communications network 70"—and its equivalents (’751 Patent, col. 5:7-9). A question for the court will be whether the accused system's combination of a Wi-Fi chip, the public internet, and remote servers is structurally equivalent to the network disclosed in the patent.
  • Technical Questions: A primary technical question will be whether the accused Lyric system's method of using feedback aligns with the method required by the claim. The complaint alleges the system "calculates an adjusted thermostat setpoint using...occupant feedback," but provides no evidence on the specific algorithm used (Compl. ¶17). The patent specification heavily details a "defuzzification" process for converting subjective inputs into a "crisp" numerical setpoint (’751 Patent, col. 3:19-25). What evidence does the complaint provide that the accused product's algorithm performs the specific function of calculating an adjusted setpoint based on feedback, rather than simply accepting a direct temperature setting from the user?

V. Key Claim Terms for Construction

• The Term: "calculates an adjusted thermostat setpoint using a previous thermostat setpoint and the occupant feedback information"
• Context and Importance: This phrase is the functional core of the asserted independent claim. The outcome of the infringement analysis will depend heavily on whether the accused product's operation falls within the court's construction of this term. Practitioners may focus on this term because the complaint's allegations regarding this function are conclusory, lacking specific detail on the accused algorithm.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Proponents of a broader view may argue that the claim language itself does not explicitly require "fuzzy logic" or "defuzzification," and should therefore encompass any algorithm that uses the recited inputs (previous setpoint, occupant feedback) to determine a new setpoint.
  • Evidence for a Narrower Interpretation: Proponents of a narrower view may argue that the patent specification repeatedly and almost exclusively describes the invention in the context of fuzzy logic, including detailed explanations of "defuzzification," "center of area," and "centroid" methods (’751 Patent, col. 2:17-23, col. 4:54-66, FIG. 7A). This may suggest that the "calculation" is not just any computation, but one tied to the specific methodologies disclosed as the invention's solution to the prior art's problems.

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

• A key evidentiary question will be one of functional operation: Does the accused Honeywell Lyric system's software actually perform the specific "calculation" required by Claim 9? The case may turn on evidence from the accused product's source code and technical documentation to determine if it uses occupant feedback to mathematically derive an adjusted setpoint, as described in the patent, or if it simply implements direct user commands in a manner that falls outside the claim's scope.
• The central legal issue will be one of claim construction: How will the court define the scope of the term "calculates an adjusted thermostat setpoint"? Whether this term is construed broadly to cover any algorithm using the recited inputs, or narrowly to the fuzzy logic-based "defuzzification" methods that form the bulk of the patent's disclosure, will likely be a dispositive factor in the infringement analysis.