Lockfob LLC v. Iloq Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lockfob, LLC (California)
  • Defendant: iLOQ LTD. (Finland)
  • Plaintiff’s Counsel: Global IP Law Group, LLC
• Case Identification: 2:25-cv-00672, E.D. Tex., 10/10/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant, a Finnish company, maintains its only North American distribution center in the district, constituting a regular and established place of business, and has committed acts of infringement there. As a foreign resident, Defendant may also be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s battery-free smart lock products infringe four patents related to contactless electronic access control systems that are powered wirelessly by an electronic key.
• Technical Context: The technology domain concerns battery-free electronic locks that harvest power from an external device, such as a smartphone using near-field communication (NFC), to actuate the lock mechanism, a significant feature for reducing maintenance and environmental impact.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement in January 2025 and offered a license, which Defendant declined in February 2025. Plaintiff filed an original complaint on July 1, 2025, before filing the current amended complaint.

Case Timeline

Date	Event
2013-09-10	Earliest Priority Date for all Patents-in-Suit
2016-XX-XX	Defendant iLOQ announces its first NFC-powered lock
2017-07-11	U.S. Patent 9,704,316 Issues
2021-08-03	U.S. Patent 11,080,951 Issues
2023-10-31	U.S. Patent 11,804,084 Issues
2025-01-10	Plaintiff provides pre-suit notice of infringement to Defendant
2025-01-28	U.S. Patent 12,211,328 Issues
2025-02-24	Defendant declines license offer
2025-07-01	Plaintiff files Original Complaint
2025-10-10	Plaintiff files Amended Complaint

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

U.S. Patent No. 9,704,316 - Contactless electronic access control system

The Invention Explained

• Problem Addressed: The patent’s background section identifies a key drawback of existing electronic locks: they can be rendered inoperable if their internal or external power source is disconnected or fails, making it impossible to operate the lock without dismantling it (Compl. ¶24; ’316 Patent, col. 1:40-47).
• The Patented Solution: The invention describes a system where an electronic access apparatus (e.g., a key or smartphone) transmits both a wireless power signal and a wireless data signal to an electronic lock. The lock, which lacks its own battery, harvests energy from the power signal, stores it in a capacitor, and then uses that energy to power its microcontroller and actuate the lock mechanism based on the authenticated data signal (’316 Patent, Abstract; col. 4:53-65). This allows the lock to operate solely on the power provided wirelessly by the key during the access event.
• Technical Importance: This technology enables the creation of fully electronic, programmable access control systems that do not require batteries in the lock component, thereby reducing long-term maintenance costs and environmental waste (Compl. ¶¶ 5-7).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 6, 7, 9, and 10 (Compl. ¶77).
• Independent Claim 1 is a method claim with the following essential elements:
  • Receiving, at an electronic lock's receiver, a wireless power signal from a handheld electronic apparatus.
  • Booting the lock’s microcontroller after an energy level threshold is met.
  • Receiving a wireless digital data signal from the apparatus.
  • Charging at least one capacitor in the lock using energy from the power signal.
  • Receiving, by power management circuitry, electric power from the capacitor based on a lock actuation instruction.
  • Supplying, by the power management circuitry, power to the lock mechanism at a second voltage that is higher than the capacitor's first voltage.
  • Actuating the lock mechanism using only the electric power received from the wireless power signal during its transmission.

U.S. Patent No. 11,080,951 - Contactless electronic access control system

The Invention Explained

• Problem Addressed: Similar to the ’316 Patent, this patent addresses the unreliability of electronic locks that depend on a dedicated power source (’951 Patent, col. 1:40-47).
• The Patented Solution: The invention claims the electronic lock apparatus itself, which is capable of being powered wirelessly. The lock comprises a receiver for power and data, a capacitor to store the harvested energy, and specialized power management circuitry. This circuitry is configured to receive power from the capacitor at a first voltage and output power to the lock mechanism at a second voltage, which "varies over the actuation time period," ensuring the lock can be actuated using only the transient power supplied by the key (’951 Patent, Abstract; col. 4:4-24). The focus is on the specific power management technique within the lock.
• Technical Importance: The claimed solution provides a concrete architecture for the lock-side electronics, particularly the power management, required to operate a mechanism using harvested wireless energy, a non-trivial engineering challenge (Compl. ¶29).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 6, 7, 9, and 10 (Compl. ¶83).
• Independent Claim 1 is an apparatus claim for an electronic lock with the following essential elements:
  • A lock mechanism connected to a lock microcontroller.
  • An electromagnetic radiation receiver configured to receive wireless data and power signals, and to output electric power at a first voltage.
  • A lock microcontroller configured to control the lock mechanism.
  • At least one capacitor connected to receive power from the receiver.
  • Power management circuitry configured to (1) receive power from the capacitor at the first voltage and output it at a second voltage that "varies over the actuation time period," and (2) supply that power to the lock mechanism.
  • The lock mechanism is capable of actuating using only the power supplied by the wireless power signal.

U.S. Patent No. 11,804,084 - Contactless electronic access control system

Technology Synopsis

This patent claims an "electronic lock module" that embodies the core battery-free technology. It describes a module with a receiver for wireless power and data, at least one capacitor, and power management circuitry that supplies a varying voltage over an actuation period to a lock mechanism, using only the wirelessly supplied power (Compl. ¶88).

Asserted Claims

Independent claim 1 and dependent claims 2, 4, 5, 6, 11, and 14 (Compl. ¶95).

Accused Features

The complaint alleges that the Accused iLOQ Products, which are battery-free and NFC-powered, infringe the ’084 Patent (Compl. ¶95).

U.S. Patent No. 12,211,328 - Contactless electronic access control system

Technology Synopsis

This patent claims both a "handheld electronic apparatus" (the key) and an "electronic lock" (the lock). The key claim recites a battery-powered handheld device with a processor and radiation source configured to transmit both data and power to a lock. The claims add specific operational parameters, including a "lock access time period of less than or equal to six seconds" and an operating distance of "less than 10 cm" (Compl. ¶¶ 100-101).

Asserted Claims

Independent claims 1 (handheld apparatus), 10 (electronic lock), and 24 (method) (Compl. ¶103).

Accused Features

The complaint alleges that the Accused iLOQ Products, used in combination, infringe the ’328 Patent (Compl. ¶103).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Accused iLOQ Products," which are iLOQ-branded products featuring "NFC-enabled smart access control capabilities" (Compl. ¶53). Specific product categories listed include battery-free programmable lock cylinders, padlocks, leversets, cam locks, key tube locks, and a rechargeable digital key (Compl. ¶53).

Functionality and Market Context

The complaint alleges that the accused products operate without internal batteries by harvesting power from a key, typically a smartphone, via NFC induction (Compl. ¶¶ 42-45). Defendant’s own 2016 marketing materials, cited in the complaint, describe this as an "invention that turns a phone also into a power source" and a "ground-breaking technology" (Compl. ¶¶ 42-43). The complaint positions these products as direct competitors that use the patented technology to achieve a battery-free design (Compl. ¶52).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference external claim chart exhibits that were not filed with the complaint; therefore, a claim chart summary table is not possible. The narrative infringement theory is summarized below.

The complaint alleges that Defendant’s Accused iLOQ Products practice the inventions claimed in the Patents-in-Suit (Compl. ¶52). The central theory of infringement is that Defendant’s NFC-powered locks operate without an internal battery by receiving both power and data wirelessly from a key (such as a smartphone), which is the core concept disclosed and claimed in the patents (Compl. ¶¶ 42-45, 53). Figure 3 of the complaint provides a block diagram illustrating the interaction between an electronic access apparatus (key) and an electronic lock, showing components for transmitting and receiving power and data wirelessly (Compl. p. 6, Fig. 3). The complaint alleges that the physical iLOQ locks embody the apparatus claims (e.g., in the ’951 and ’084 Patents), while the use of an iLOQ key with an iLOQ lock constitutes practice of the method claims (e.g., in the ’316 Patent) (Compl. ¶¶ 78, 83, 95, 103).

Identified Points of Contention

• Scope Questions: A central dispute may concern whether the specific electrical components and power delivery profile of the Accused iLOQ Products fall within the scope of the claims. For instance, with respect to the ’951 Patent, a question for the court will be whether the power supplied to the iLOQ lock mechanism constitutes a "second voltage [that] varies over the actuation time period" as construed from the patent's specification and prosecution history.
• Technical Questions: The complaint relies on Defendant's high-level marketing descriptions of its technology. A key factual question will be whether the internal "power management circuitry" of the accused locks operates in the manner required by the claims, such as receiving power at a first voltage and outputting it at a second, potentially higher, voltage. The defense may argue a fundamental mismatch in the technical operation of its power harvesting and delivery circuits compared to the specific solutions claimed.

V. Key Claim Terms for Construction

For the ’951 Patent

"power management circuitry"

• Context and Importance: This term appears in independent claim 1 of the ’951 Patent and describes the core component on the lock side responsible for handling the harvested energy. The construction of this term will be critical, as it will determine whether the specific integrated circuits used in iLOQ's products for voltage regulation and power delivery meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a functional description, stating the circuitry is "configured to: receive the electric power... at the first voltage and output the electric power at a second voltage... and supply the electric power to the lock mechanism" (’951 Patent, col. 4:15-21). This language may support an interpretation covering any circuit that performs these functions.
  • Evidence for a Narrower Interpretation: The detailed description discloses specific embodiments for efficiency, such as a circuit that uses "switches and capacitors to double or triple the voltage" rather than a less efficient "switching regulator" (’951 Patent, col. 13:22-28). Defendant may argue that the term should be limited to such specific, highly efficient voltage-boosting circuits rather than any generic power conditioning circuit.

"wherein the second voltage varies over the actuation time period"

• Context and Importance: This limitation in independent claim 1 of the ’951 Patent describes the electrical behavior of the power supplied to the lock mechanism. Infringement will depend on whether the measured power profile in the accused locks exhibits this "varying" characteristic.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that during the actuation mode, "the voltage value is allowed to float or otherwise vary as the lock actuates" (’951 Patent, col. 20:53-54). This language, along with Figure 12 which depicts a non-flat voltage curve during actuation, may support a broad interpretation that includes any natural voltage drop from a discharging capacitor.
  • Evidence for a Narrower Interpretation: The context of the invention involves boosting a voltage to actuate a mechanism and ensuring it stays above a threshold during actuation. A defendant may argue that "varies" should be construed in this context and does not cover any incidental fluctuation, but rather describes the specific discharge profile of the claimed power management system after an initial voltage boost.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant encourages its customers to use the accused products in their intended (and allegedly infringing) manner, provides instructions for such use, and technically designed the products to infringe method claims (Compl. ¶¶ 56, 105).

Willful Infringement

Willfulness is alleged based on Defendant’s purported knowledge of the Patents-in-Suit following a January 10, 2025 notice letter. The complaint asserts that Defendant’s continued infringement after receiving notice, coupled with its refusal to take a license or provide any pre-suit basis for non-infringement or invalidity, constitutes willful and deliberate conduct (Compl. ¶¶ 107-108).

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

• A core issue will be one of definitional scope: how broadly will the court construe the term "power management circuitry" and its associated functional limitations? The outcome may depend on whether the term is interpreted to cover any circuit that conditions harvested power for actuation, or if it is limited to the specific efficient voltage-boosting embodiments detailed in the patent specification.
• A key evidentiary question will be one of technical implementation: does the actual circuitry and operational power profile of the accused iLOQ products align with the specific requirements of the asserted claims? While the complaint leverages Defendant's marketing statements, the case will likely turn on a detailed technical comparison between the patented system and the accused products' internal workings as revealed through discovery.