DCT
2:25-cv-00394
L4T Innovations LLC v. ecobee Tech ULC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: L4T Innovations LLC (Michigan)
- Defendant: ecobee Technologies ULC d/b/a ecobee (Canada)
- Plaintiff’s Counsel: L4T Innovations LLC
- Case Identification: 2:25-cv-00394, E.D. Tex., 04/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, which may be sued in any judicial district. The complaint further alleges that Defendant conducts substantial business and has committed acts of infringement in the Eastern District of Texas through authorized sellers.
- Core Dispute: Plaintiff alleges that Defendant’s SmartCamera products and associated security system infringe a patent related to methods and devices for marking notable events in time for subsequent retrieval from media recordings.
- Technical Context: The technology addresses the challenge of locating specific moments within long video or audio recordings by using a trigger mechanism to create a timestamp that flags an event of interest.
- Key Procedural History: The complaint does not mention prior litigation, IPR proceedings, or licensing history related to the patent-in-suit. The willfulness allegation is based on notice via the complaint itself.
Case Timeline
| Date | Event |
|---|---|
| 2017-10-02 | ’321 Patent Priority Date (Provisional App. 62/567,054) |
| 2021-11-30 | ’321 Patent Issue Date |
| 2025-04-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,189,321 - "Retrospective Capture Trigger," issued November 30, 2021
The Invention Explained
- Problem Addressed: When continuously recording media, such as with a body camera or sports camera, it can be "tedious and time-consuming to peruse the entirety of the captured media" to locate specific "noteworthy events" after the fact (’321 Patent, col. 3:5-13).
- The Patented Solution: The patent describes an "event marking device" that contains a trigger, a real-time clock, and a microcontroller (’321 Patent, Fig. 1). When a user activates the trigger (e.g., by pressing a button), the device captures the precise time and stores it as "trigger event data" (’321 Patent, col. 4:5-12). This data is then outputted to a separate "external device," such as a video camera, which uses the timestamp to flag or preserve the segment of the recording corresponding to the notable event, thus enabling a user to easily find it later (’321 Patent, col. 2:1-5; Fig. 3).
- Technical Importance: The invention aims to decouple the action of marking an event from the operation of the primary recording device, allowing a user to conveniently flag important moments without interrupting an activity or directly handling the camera (’321 Patent, col. 2:54-59).
Key Claims at a Glance
- The complaint asserts independent claims 1 (device), 8 (method), and 15 (device), as well as dependent claims 9, 10, 14 (Compl. ¶21).
- Independent Claim 1 (Device): An event marking device comprising a housing, microcontroller, memory, real-time clock, communication interface, and a trigger circuit, where the microcontroller outputs real-time data via the interface, which "causes the external device to preserve a recording captured at the time of the enablement of the trigger circuit."
- Independent Claim 8 (Method): A method comprising generating clock data, generating a trigger signal with a trigger circuit, identifying a corresponding real time with a microcontroller, writing trigger data to memory, and outputting the data to an external device, which "causes the external device to preserve a recording captured at the time of the enablement of the trigger circuit."
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s "smart camera platform and systems," including "ecobee's Smart Cameras (including but not limited to the ecobee SmartCamera with voice control), the ecobee mobile application for Android and iOS devices ('ecobee app'), and their associated hardware and software" (Compl. ¶16).
Functionality and Market Context
- The complaint identifies the accused products as part of ecobee's "Smart Security system" (Compl. ¶16). The complaint includes a screenshot from Defendant's website describing the "SmartCamera with voice control" as an "indoor security camera that gives you more insight into your home" (Compl. ¶16, Fig. 4). The complaint also provides evidence of the products being offered for sale in the district through major retailers like Home Depot and Best Buy (Compl. ¶13, Fig. 1; ¶14, Fig. 3). Figure 1 from the complaint shows the ecobee Smart Camera available for "Free Ship to Store" at a Home Depot location in Longview, Texas (Compl. p. 4, Fig. 1).
IV. Analysis of Infringement Allegations
The complaint alleges infringement of at least claim 8 and provides a narrative mapping of the accused product's functions to the claim elements (Compl. ¶22).
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| generating real-time clock data with a real-time clock of an event marking device; | The Accused Products perform a method that includes generating real-time clock data with a real-time clock. | ¶22 | col. 3:31-44 |
| generating, with a trigger circuit of the event marking device, a trigger signal; | The Accused Products generate a trigger signal with a trigger circuit. | ¶22 | col. 4:45-56 |
| identifying, from the real-time clock data with a microcontroller of the event marking device, a real time corresponding to a receipt of the trigger signal; | The Accused Products identify, from the real-time clock data with a microcontroller, a real time corresponding to the trigger signal's receipt. | ¶22 | col. 4:5-10 |
| writing, with the microcontroller, trigger signal data to a memory of the event marking device indicating the real time associated with receipt of the trigger signal; and | The Accused Products write, with the microcontroller, trigger signal data to memory indicating the real time associated with the trigger signal. | ¶22 | col. 4:10-12 |
| outputting, with a communication interface of the event marking device, the trigger event data...to an external device; whereby outputting the trigger event data causes the external device to preserve a recording captured at the time of the enablement of the trigger circuit. | The Accused Products output, with a communication interface, the trigger event data to an external device, which causes the external device to preserve a recording from the time of the trigger circuit's enablement. | ¶22 | col. 14:19-24 |
- Identified Points of Contention:
- Scope Questions: The complaint appears to allege that the ecobee SmartCamera itself is the "event marking device." However, the patent specification consistently illustrates the "event marking device" (102) and the "external device" (350, e.g., a camera) as two distinct, communicating components (’321 Patent, Fig. 3, Fig. 5). This raises the question of whether a single, integrated product like the ecobee camera can meet the claim limitations for both the "event marking device" and the "external device."
- Technical Questions: The complaint asserts that the accused products perform each step of the claimed method but does not provide specific technical details about how they do so (Compl. ¶22). For example, it does not specify what constitutes the "trigger circuit" in the ecobee camera (e.g., motion detection, audio detection) or the mechanism by which outputting data "causes" the preservation of a recording as required by the final "whereby" clause of the claim.
V. Key Claim Terms for Construction
- The Term: "event marking device"
- Context and Importance: This term defines the central apparatus of claims 1 and 15 and is a key component in method claim 8. Its construction is critical because the infringement theory appears to collapse the patent's "event marking device" and "external device" into a single accused product. Practitioners may focus on this term to determine if the claims require two separate physical devices or if they can read on functional modules within a single, integrated system.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Summary of the Invention states the real-time clock and memory "may be disposed in an external device to which the communication interface is operatively coupled," which suggests some components of the "event marking device" could reside elsewhere, potentially allowing for a more integrated system architecture (’321 Patent, col. 2:49-54).
- Evidence for a Narrower Interpretation: The detailed description and figures consistently depict the "event marking device" 102 as physically separate from the "external device" 350, which is often a camera (’321 Patent, Fig. 3, Fig. 5). Embodiments show the event marking device as a wrist-worn unit communicating with a head-mounted camera or a device coupled to bicycle handlebars, reinforcing the concept of two distinct physical entities (’321 Patent, Fig. 4B, Fig. 5).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating Defendant provides the Accused Products and "distributing instructions that guide users to use the Accused Products in an infringing manner" (Compl. ¶23). It alleges contributory infringement on the basis that the products contain "special features" that are material to the invention and have no substantial non-infringing use (Compl. ¶24).
- Willful Infringement: The complaint alleges knowledge of the ’321 Patent "at least as of the date when it was notified of the filing of the original complaint in this action" (Compl. ¶25). Willfulness is also alleged on the basis that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness (Compl. ¶26).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "event marking device" be construed to read on a component or function within a single, integrated security camera, or does the patent’s language and specification, which consistently depict it as separate from the "external device" (the camera), require two distinct physical apparatuses?
- A key evidentiary question will be one of causation and functionality: what evidence will be presented to demonstrate that the ecobee SmartCamera system performs the specific steps of the asserted method claim, particularly how its internal data handling "causes" the preservation of a recording in the manner required by the claim's "whereby" clause?
- A third question will relate to indirect infringement: what specific "instructions" does Plaintiff allege lead users to infringe, and can Defendant show that the accused features have substantial non-infringing uses that would defeat the claim of contributory infringement?