DCT
2:17-cv-00213
Clean Energy Management Solutions LLC v. Lowes Companies Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Clean Energy Management Solutions, LLC (Texas)
- Defendant: Lowe's Companies, Inc. (North Carolina)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Van Cleef Law Office
- Case Identification: 2:17-cv-00213, E.D. Tex., 03/20/2017
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant conducts substantial business in the district, and a portion of the alleged infringements occurred there.
- Core Dispute: Plaintiff alleges that Defendant’s Iris home security and automation system infringes a patent related to operating door locks using a mesh network.
- Technical Context: The lawsuit concerns the smart home technology sector, specifically systems that use low-power wireless mesh networks (such as ZigBee or Z-Wave) for remote access control.
- Key Procedural History: The complaint asserts infringement of at least claim 15. Subsequent to the filing of this complaint, an Inter Partes Review (IPR) proceeding was initiated (IPR2019-00476). The resulting IPR certificate, issued June 25, 2021, states that claims 1, 2, 6, 9, 10, 15, and 16 have been cancelled. The cancellation of claim 15, the only claim explicitly asserted in the complaint, is a dispositive event for this specific allegation.
Case Timeline
| Date | Event |
|---|---|
| 2006-06-12 | ’479 Patent Priority Date |
| 2011-10-11 | U.S. Patent No. 8,035,479 Issued |
| 2017-03-20 | Complaint Filed |
| 2018-12-28 | IPR2019-00476 Filed |
| 2021-06-25 | IPR Certificate Issued Cancelling Asserted Claim 15 |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,035,479 - "Mesh Network Door Lock"
- Patent Identification: U.S. Patent No. 8,035,479, "Mesh Network Door Lock", issued October 11, 2011.
The Invention Explained
- Problem Addressed: The patent describes prior art electronic locks as often being complicated, high-power, or incompatible with the mechanisms of conventional key-operated door locks, while conventional locks themselves lacked flexible, electronic key control (U.S. Patent No. 8,035,479, col. 2:10-14; col. 5:60-63).
- The Patented Solution: The invention discloses a system for controlling a door lock using a low-power wireless mesh network, such as ZigBee. A user employs a "mesh network key" to wirelessly send an authenticated code through the network to a "mesh network lock controller," which then operates an electromechanical device to lock or unlock a secured area (U.S. Patent No. 8,035,479, Abstract; Fig. 2). This solution aims to provide a "simple, 'pick-proof' low power lock configuration" that is compatible with existing door latch structures (U.S. Patent No. 8,035,479, col. 5:46-52).
- Technical Importance: The technology sought to merge the robustness of traditional mechanical locks with the advanced, flexible, and low-power capabilities of emerging mesh networking protocols for home and office automation (U.S. Patent No. 8,035,479, col. 5:42-46).
Key Claims at a Glance
- The complaint asserts independent method claim 15 (Compl. ¶13).
- Claim 15 requires:
- Sending a code from a mesh network key.
- Wirelessly communicating the code over a mesh network comprising a full function device, a coordinator node, a router node, and an end node.
- The end node is a mesh network key usable by a user to remotely access the secured area.
- The coordinator node establishes the network and defines its main parameters.
- The end node is a reduced function device that communicates with the network but does not participate in routing.
- Receiving the code at a mesh network lock controller.
- Providing access to the secured area upon authenticating the code.
- The complaint states Defendant infringed "one or more claims," suggesting a reservation of rights to assert additional claims (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- Defendant's "Iris home security and automation system" ("Iris") (Compl. ¶13).
Functionality and Market Context
- The complaint alleges that Iris is a home control system that integrates door locks using mesh network connectivity (Compl. ¶15). The system allegedly uses a "Z-wave mesh network" where an "Iris hub" acts as a "full function device" that communicates with various nodes, including smart locks (Compl. ¶15). A smartphone running the "Iris App" is alleged to function as an "end node" used to send an unlock code through the hub to a compatible electronic deadbolt, such as a Schlage-branded lock (Compl. ¶15). A screenshot of the accused "Iris App" is referenced as evidence of the user interface for controlling the system. (Compl. ¶15, referencing "Iris App").
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,035,479 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| sending a code from a mesh network key and wirelessly communicating the code with one or more mesh network appliances over a mesh network | The Iris system sends a code to unlock a door using a Z-wave mesh network; the smartphone running the Iris App allegedly functions as the mesh network key. | ¶15 | col. 20:16-20 |
| wherein the mesh network comprises a full function device that communicates with a coordinator node, a router node, and an end node, the end node being a mesh network key usable by a user to remotely access said secured area... wherein the coordinator node establishes the network and define main parameters... | The Iris hub is alleged to be a "full function device that communicates with an end node, router node and integrated coordinator node." Iris allegedly "uses the coordinator node integrated in the full-function device to establish the network." | ¶15 | col. 20:20-33 |
| wherein the end node includes a reduced function device, the reduce function device capable of communicating with the network and does not participate in routing | The smartphone is alleged to be the "end node" and is described as a "reduced function device which is capable of communicating with the mesh network and does not participate in the routing of the command to lock or unlock the door." | ¶15 | col. 20:33-36 |
| receiving the code at a mesh network lock controller through the mesh network | The unlock code is allegedly received at the lock controller, such as a "Schlage-Connect... Electronic-Entry-Door-Deadbolt." | ¶15 | col. 20:37-38 |
| providing access to the secured area upon authenticating the code. | The Iris system "will unlock the door upon authentication of the code." | ¶15 | col. 20:39-40 |
- Identified Points of Contention:
- Scope Questions: A primary issue is whether the term "mesh network key", which the patent illustrates as a dedicated fob or wristwatch (U.S. Patent No. 8,035,479, Figs. 2, 3A), can be construed to read on a general-purpose smartphone running an application, as alleged in the complaint (Compl. ¶15).
- Technical Questions: The complaint alleges the accused Z-Wave network meets the specific architectural limitations of claim 15, such as the distinct roles of "coordinator node", "router node", and "end node" (Compl. ¶15). A key technical question is whether the architecture of the accused Z-Wave-based Iris system maps onto these specific device roles, which the patent describes in the context of the ZigBee protocol (U.S. Patent No. 8,035,479, col. 5:26-40). The complaint references a diagram to support its allegation about the coordinator node's function (Compl. ¶15, referencing Referenced Diagram).
V. Key Claim Terms for Construction
The Term: "mesh network key"
- Context and Importance: The definition of this term is central to the dispute, as the complaint’s theory relies on a smartphone being a "key." Practitioners may focus on this term because its construction will determine whether a general-purpose computing device running software falls within the scope of what the patent may describe as a more specialized hardware component.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not explicitly limit the "key" to a specific form factor. Claim 15 describes it functionally as being "usable by a user to remotely access said secured area," which could arguably encompass a smartphone app (U.S. Patent No. 8,035,479, col. 20:25-26).
- Evidence for a Narrower Interpretation: The specification’s embodiments consistently depict the key as a dedicated physical object, such as the fob-like device "400" in Figure 2 or the wristwatch in Figure 3A (U.S. Patent No. 8,035,479, Figs. 2, 3A). This could support an argument that the term implies a dedicated piece of hardware, not a general-purpose device.
The Term: "coordinator node"
- Context and Importance: This term, along with "router node" and "end node", defines the specific network topology required by the claim. The infringement analysis depends on whether the accused Iris hub and connected devices perform the functions of these specific nodes as defined by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim provides a functional definition: "the coordinator node establishes the network and define main parameters for the mesh network" (U.S. Patent No. 8,035,479, col. 20:30-32). A party might argue that any device performing this function in any mesh network meets the limitation.
- Evidence for a Narrower Interpretation: The specification introduces these terms in the context of the IEEE 802.15.4 (ZigBee) standard, stating, "In a ZigBee network a node can have three roles: ZigBee Coordinator, ZigBee Router, and ZigBee End Device" (U.S. Patent No. 8,035,479, col. 5:29-31). This linkage may support a narrower construction limiting the term to its meaning within the ZigBee standard or a demonstrably equivalent architecture.
VI. Other Allegations
The complaint does not contain specific counts for indirect infringement or willful infringement. The sole count is for direct infringement under 35 U.S.C. § 271(a) (Compl. ¶¶ 12-17).
VII. Analyst’s Conclusion: Key Questions for the Case
- Viability of the Lawsuit: The most critical issue is the post-filing cancellation of claim 15, the only claim specifically asserted in the complaint, during an Inter Partes Review. A threshold question is whether the Plaintiff can amend its complaint to assert any of the surviving claims of the ’479 patent against the accused Iris system.
- Definitional Scope: Assuming the case proceeds on other claims, a core issue will be one of claim construction: can the term "mesh network key", illustrated in the patent as a dedicated hardware device, be interpreted broadly enough to cover a general-purpose smartphone running a software application?
- Technical Equivalence: A central evidentiary question will be one of technical mapping: does the architecture of Defendant’s accused Z-Wave-based system contain components that perform the specific functions of the "coordinator node", "router node", and "end node" as defined in the patent’s ZigBee-centric claims, or is there a fundamental mismatch in network topology and operation?