DCT
2:24-cv-00125
Liberty Access Tech Licensing LLC v. Wyndham Hotel Group LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Liberty Access Technologies Licensing LLC (Texas)
- Defendant: Wyndham Hotels & Resorts, Inc. and Wyndham Hotel Group, LLC (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough, PLLC
- Case Identification: 2:24-cv-00125, E.D. Tex., 02/22/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain regular and established places of business within the Eastern District of Texas, listing numerous specific hotel locations, and have committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s mobile application, which includes a "digital key" feature for hotel room access, infringes four patents related to access control systems that use a portable device to present a digital reservation certificate to a lock.
- Technical Context: The technology involves using smartphones as secure, time-limited keys for physical access, a growing feature in the hospitality industry aimed at improving guest convenience and operational efficiency.
- Key Procedural History: The complaint notes that U.S. Patent No. 9,373,205 was the subject of a supplemental examination, resulting in the issuance of a Reexamination Certificate. Allegations of willful infringement are based on knowledge dating from "at least the time of receiving the original Complaint in this matter," suggesting this action may be a re-filing or an amended complaint.
Case Timeline
| Date | Event |
|---|---|
| 2010-03-02 | Earliest Priority Date for all Asserted Patents |
| 2016-06-21 | U.S. Patent No. 9,373,205 Issued |
| 2020-05-19 | U.S. Patent No. 10,657,747 Issued |
| 2022-01-04 | U.S. Patent No. 11,217,053 Issued |
| 2022-02-25 | Reexamination Certificate Issued for U.S. Patent No. 9,373,205 |
| 2022-09-13 | U.S. Patent No. 11,443,579 Issued |
| 2024-02-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,373,205 - Access Control System And Method For Use By An Access Device
- Issued: June 21, 2016
The Invention Explained
- Problem Addressed: The patent describes the inconvenience faced by users of services like electric vehicle charging stations or hotel rooms, who may not know where to find an available access point or have a convenient way to reserve and pay for access (’205 Patent, col. 1:36-42).
- The Patented Solution: The invention proposes an access device (e.g., a door lock) with a processor and communication module. The device is configured to receive a digital "reservation certificate" from a user's portable terminal (e.g., a smartphone). The processor then validates the certificate by comparing the reservation time interval specified in the certificate to the current time, and if valid, activates the lock (’205 Patent, Abstract; col. 2:62-67). This automates and secures access based on a pre-arranged reservation.
- Technical Importance: This approach sought to centralize the reservation and authorization process for distributed access points, replacing physical keys or simple keycards with a more dynamic, network-enabled system tied to a specific user and time window (’205 Patent, col. 1:43-56).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶27).
- The essential elements of independent claim 1 are:
- An access device comprising a processor controlling a door lock and a communication module.
- The processor is configured to receive a "reservation certificate" from a portable terminal.
- When a certificate with a reservation interval is presented, the processor is configured to:
- Compare the reservation interval to the current time.
- Determine if the current time is within that interval.
- Activate the door lock to allow access during that interval.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,657,747 - Access Control System And Method For Use By An Access Device
- Issued: May 19, 2020
The Invention Explained
- Problem Addressed: The patent addresses the same general problem of providing convenient, reservable access to resources like hotel rooms or vehicle chargers (’747 Patent, col. 1:36-42).
- The Patented Solution: This patent claims a broader, multi-component system. It describes an architecture that includes not just the access device (lock) and portable terminal (smartphone), but also a "secure reservation interface" (e.g., a website or app screens) for making a booking and a back-end "reservation server" that issues and transmits the reservation certificate to the user's device (’747 Patent, Abstract; col. 10:1-33). This solution covers the end-to-end process from booking to unlocking.
- Technical Importance: By claiming the entire ecosystem, the invention covers the interaction between the user-facing booking interface, the central server, the user's mobile device, and the physical lock, defining a complete architecture for mobile-based access control (’747 Patent, Fig. 7).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶43).
- The essential elements of independent claim 1 are:
- An access control system comprising:
- a) an access device (e.g., door lock).
- b) a secure reservation interface with screens for selecting a location and reservation interval.
- c) a reservation server that receives the request, issues a reservation certificate, and transmits it to a second device.
- d) an application on the second device that receives the certificate and wirelessly transmits it to the access device.
- e) wherein the access device receives the certificate and its processor activates the door lock.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 11,443,579 - Access Control System And Method For Use By An Access Device
- Issued: September 13, 2022
- Technology Synopsis: This patent claims a system architecture similar to the ’747 patent, comprising an access device, a server, and an application on a portable terminal. A key distinction in its asserted claim is that the time-validation step is performed by the application on the portable terminal, which "compares the interval of the reservation to a current time accessible to the application" before communicating with the lock to activate it (’579 Patent, col. 9:10-23).
- Asserted Claims: Independent claim 1 (Compl. ¶60).
- Accused Features: The complaint alleges that in the Wyndham system, the mobile application performs the comparison of the reservation interval to the current time to determine if the digital key is current before activating the lock (Compl. ¶61).
U.S. Patent No. 11,217,053 - Access Control System and Method for Use by an Access Device
- Issued: January 4, 2022
- Technology Synopsis: This patent claims an access control system with increased technical specificity regarding the communication link. The asserted claim requires the server to transmit not just the reservation certificate but also a "short-range wireless communication setting" to the smartphone. The smartphone application then uses this setting to establish a wireless connection with the access device when it is within transmission distance (’053 Patent, col. 9:11-26).
- Asserted Claims: Independent claim 1 (Compl. ¶77).
- Accused Features: The complaint alleges the Wyndham system uses a server to provide the mobile app with a reservation certificate and a short-range wireless setting, which the app then uses to transmit the certificate to the door lock (Compl. ¶78).
III. The Accused Instrumentality
Product Identification
- The accused products are the Wyndham Hotels & Resorts website, the associated Wyndham Resort & Hotels mobile application, and related hardware and software, which collectively provide a "digital key" feature (Compl. ¶18).
Functionality and Market Context
- The system allows a hotel guest to use their mobile device, running the Wyndham app, as a key to unlock their hotel room door. The complaint alleges this functionality involves a user making a reservation, receiving a digital key (or "reservation certificate") on their app, and the app communicating with the door lock to grant access for the duration of the stay (Compl. ¶18, ¶28, ¶44). The complaint provides a screenshot from the Wyndham mobile app showing an interface with a large lock icon and the confirmation message "Room Unlocked You're In!" (Compl. p. 5, Figure 1). Another screenshot shows the app prompting the user to "press the key while the phone is near the door" (Compl. p. 6, Figure 3). The complaint portrays this "seamless contactless technology" as a key feature advertised to guests (Compl. p. 6).
IV. Analysis of Infringement Allegations
’205 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an access device for use in an access control system, the access device comprising: a processor having control of a door lock; and a communication module connected to the processor... | The Accused Products include an access device (e.g., hotel door lock) with a processor and a communication module. | ¶28 | col. 6:15-18 |
| the processor is configured to receive a reservation certificate presented by a portable terminal through the communication module; | The processor in the lock is configured to receive a "reservation certificate" (i.e., the digital key) from a guest's portable terminal (smartphone). | ¶28 | col. 6:31-36 |
| wherein, when a current reservation certificate that comprises an interval of a reservation is presented..., the processor is configured to compare the interval... to a current time..., determine the current time is within the interval... | The processor in the lock compares the reservation interval of the digital key to the current time to determine if the guest's stay is current. | ¶28 | col. 5:8-12 |
| and activate the door lock to allow the portable terminal to unlock the door lock during the interval of the reservation. | The processor activates the lock, allowing the guest to unlock the door during their reserved stay. | ¶28 | col. 6:23-26 |
- Identified Points of Contention:
- Technical Questions: A key evidentiary question will be whether the time-comparison logic resides in the lock's processor as required by this claim, or elsewhere in the system (e.g., on the smartphone or a server). The complaint's allegations for the '579 patent suggest the comparison may happen on the application, which could create a factual dispute for infringement of this specific claim.
- Scope Questions: The case may explore the precise definition of a "reservation certificate." Defendant may argue that the data packet used in its system does not meet the specific structure or content of the "certificate" described and enabled in the patent specification.
’747 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) an access device comprising a communication module connected to a processor having control of a door lock; | The Wyndham system includes an access device (the hotel room lock) with a processor and communication module. | ¶44 | col. 6:30-47 |
| b) a secure reservation interface to receive a reservation request... comprising one or more screens for receiving a selection of a location... and an interval of the reservation; | The Wyndham website and mobile app provide a reservation interface with screens for a user to select a hotel location and dates for their stay. | ¶44 | col. 7:13-18 |
| c) a reservation server, in communication with the reservation interface and a network, to: receive the reservation request... issue a reservation certificate... and transmit... to a second device... | Wyndham's reservation servers receive booking requests from the interface, issue a digital key ("reservation certificate") based on the selected location and interval, and transmit it over a network to the guest's smartphone (the second device). | ¶44 | col. 4:14-21 |
| d) an application installed on the second device to receive the reservation certificate... wherein the application wirelessly transmits the reservation certificate to the access device... | The Wyndham mobile app, installed on the guest's smartphone, receives the digital key. The app then wirelessly transmits the key to the hotel door lock when the guest initiates the unlock command. | ¶44 | col. 7:1-8 |
| e) wherein the access device receives the reservation certificate from the application... and the processor activates the door lock... | The door lock receives the digital key from the app, and its processor activates the lock based on the receipt of that certificate. | ¶44 | col. 5:4-12 |
- Identified Points of Contention:
- Scope Questions: As this is a system claim, a central question will be whether Wyndham "provides" or "controls" all recited components of the system for the purposes of direct infringement under 35 U.S.C. § 271(a), especially since the "second device" (the smartphone) and the "application" are on user-owned hardware. Plaintiff alleges Wyndham directs and controls its customers' use, which may be a point of dispute.
- Technical Questions: The functionality of the "reservation server" will be a focus. Discovery will be needed to determine if a single server or a distributed system performs all the recited functions of receiving the request, issuing the certificate, and transmitting it as claimed.
V. Key Claim Terms for Construction
"reservation certificate"
- Applicability: Asserted claims of all four patents.
- Context and Importance: This term is the core of the invention; it is the digital credential that enables access. Its construction will be critical to determining infringement. A narrow definition tied to specific data fields or encryption methods could allow the defendant to design around the claims, while a broad definition covering any form of digital token conveying reservation rights would make infringement easier to prove.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to the credential as a "digital token or certificate" and states it "may comprise a unique ID and/or a date/time stamp," suggesting flexibility in its form (’747 Patent, col. 2:18-21).
- Evidence for a Narrower Interpretation: The specification provides a specific embodiment in Figure 2, listing fields such as "CERTIFICATE ID," "DEVICE ID," "START TIME," and a "HASH (ENCRYPTED)" field (’747 Patent, Fig. 2; col. 5:21-40). A defendant may argue that a true "reservation certificate" must contain these specific, security-oriented elements.
"access control system"
- Applicability: Asserted claims of ’747, ’579, ’053 patents.
- Context and Importance: This term defines the scope of the claimed invention in the system claims. Practitioners may focus on this term because infringement requires the defendant to make, use, sell, or offer for sale the entire claimed system. How the court defines the boundaries of this "system"—and what level of control is required over its constituent parts (server, lock, user's phone)—will be pivotal.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves list the components that comprise the system (e.g., an access device, a reservation interface, a server, an application). A plaintiff would argue the definition is simply the combination of these enumerated parts working in concert.
- Evidence for a Narrower Interpretation: A defendant might argue that the term implies a single, integrated product offered by one entity. It could point to specification language discussing the "system of the present invention" as a cohesive whole, suggesting that a collection of components where one part (the user's smartphone) is outside the defendant's direct control does not constitute the claimed "system" (’747 Patent, col. 4:1-4).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendants took active steps with the specific intent to cause infringement by end-users. These steps allegedly include "advising or directing" users and "distributing instructions" that guide them to use the digital key feature in an infringing manner (Compl. ¶29, ¶45). The complaint also alleges contributory infringement, stating the accused products have "special features that are specially designed to be used in an infringing way" and have "no substantial non-infringing uses" (Compl. ¶30, ¶46).
- Willful Infringement: The complaint alleges willful infringement based on knowledge of the patents "since at least the time of receiving the original Complaint in this matter" (Compl. ¶33, ¶50). It further alleges objective recklessness and willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶31, ¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of claim construction and scope: Can the term "reservation certificate," which is described in the patent with specific security features like encrypted hashes, be construed to read on the digital key data packet used by the Wyndham system? The outcome of this definitional dispute will likely apply across all four asserted patents.
- A key evidentiary question will be one of technical implementation: For the '205 patent, does the time-validation logic for the digital key reside on the physical door lock's processor, or is it handled by the smartphone application? For the system claims ('747, '579, '053), can Plaintiff prove that Wyndham's distributed architecture of servers, apps, and locks practices each specific step and communication pathway as recited in the distinct claims?
- A central legal question will be one of divided infringement: For the system claims, can Plaintiff demonstrate that Wyndham directs or controls its guests' use of their own smartphones and the installed Wyndham app to a degree sufficient to be held liable for directly infringing the entire claimed system under 35 U.S.C. § 271(a)?