DCT
2:25-cv-00745
Liberty Access Tech Licensing LLC v. Avigilon Corp
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Liberty Access Technologies Licensing LLC (Texas)
- Defendant: Schlage Lock Company LLC (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00745, E.D. Tex., 12/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established and regular place of business in the Eastern District of Texas and has committed acts of patent infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart lock products and associated mobile applications infringe five patents related to remote access control systems that use time-limited digital credentials, described as "reservation certificates."
- Technical Context: The technology at issue involves using a portable device, such as a smartphone, to receive and present a temporary digital credential to an access device, such as a door lock, to gain entry for a specified period.
- Key Procedural History: The complaint notes that two of the asserted patents have undergone reexamination proceedings. U.S. Patent No. 9,373,205 had a Reexamination Certificate issued on February 25, 2022, and U.S. Patent No. 11,373,474 had a Reexamination Certificate issued on May 13, 2024. The survival of claims through reexamination may be presented by the Plaintiff to suggest the patents' resilience to validity challenges.
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 |
| 2022-06-28 | U.S. Patent No. 11,373,474 Issued |
| 2022-09-13 | U.S. Patent No. 11,443,579 Issued |
| 2024-05-13 | Reexamination Certificate Issued for U.S. Patent No. 11,373,474 |
| 2025-12-10 | 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
The Invention Explained
- Problem Addressed: The patent describes the difficulty of managing access to electronic devices like electric vehicle chargers or hotel room locks, including finding an available device and conveniently reserving and paying for its use (’205 Patent, col. 1:25-44).
- The Patented Solution: The invention is an access device (e.g., a door lock) with a processor and a communication module. The device is configured to receive a digital "reservation certificate" from a user's portable terminal (like a smartphone). This certificate contains a valid time "interval." The device's processor compares this interval to the current time and, if the current time falls within the interval, activates the lock to grant access (’205 Patent, Abstract; col. 2:7-22). This allows for temporary access control using the user's device as a key.
- Technical Importance: This approach enables remotely managed, time-limited access control without requiring the access device itself to maintain a constant connection to a central network, as the portable terminal acts as the secure data carrier (’205 Patent, col. 2:51-66).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶32). The essential elements are:
- An access device for use in an access control system.
- A processor having control of a door lock.
- A communication module connected to the processor.
- The processor is configured to receive a reservation certificate presented by a portable terminal through the communication module.
- When a current reservation certificate comprising an interval of a reservation is presented, the processor is configured to:
- compare the interval to a current time accessible to the processor,
- determine the current time is within the interval, and
- activate the door lock to allow the portable terminal to unlock the door during the interval.
U.S. Patent No. 10,657,747 - Access Control System And Method For Use By An Access Device
The Invention Explained
- Problem Addressed: The patent addresses the same general problem of managing temporary access to electronic devices (’747 Patent, col. 1:25-44).
- The Patented Solution: This patent claims the entire end-to-end access control system. The system includes the access device, a "secure reservation interface" (e.g., a website or app screen) used on a first device to make a request, and a "reservation server." The server receives the request, issues the reservation certificate, and transmits it to a second device (e.g., a user's smartphone). An application on the second device then wirelessly transmits the certificate to the access device to activate the lock (’747 Patent, Abstract; col. 2:7-22).
- Technical Importance: The claimed invention captures the complete system architecture, from the user's initial reservation action on one device to the server's processing and the final secure, local communication between the user's mobile device and the lock itself (’747 Patent, Claim 1).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶48). The essential elements are:
- An access control system comprising:
- An access device with a processor controlling a door lock.
- A secure reservation interface on a first device to receive a reservation request.
- A reservation server that receives the request, issues a reservation certificate, and transmits it to a second, distinct device.
- An application on the second device that receives the certificate and wirelessly transmits it to the access device upon a command to activate the lock.
- The access device receives the certificate from the application and the processor activates the door lock based on its receipt.
U.S. Patent No. 11,443,579 - Access Control System And Method For Use By An Access Device
- Technology Synopsis: This patent claims an access control system comprising an access device, an application on a portable terminal, and a server. The server provides both a communication setting and a reservation certificate to the application, which then uses that information to communicate with the access device and present the certificate to activate the lock based on a time-interval comparison (Compl. ¶66).
- Asserted Claims: At least claim 8 (Compl. ¶65).
- Accused Features: The complaint alleges that the integrated Schlage system, including its smart locks, mobile application, and back-end servers, infringes this patent by providing time-based access codes and communication parameters to the Schlage Home app for use with Schlage locks (Compl. ¶66).
U.S. Patent No. 11,217,053 - Access Control system and Method for Use by an Access Device
- Technology Synopsis: This patent claims a system where a smartphone application is installed on a smartphone to receive the reservation certificate and communication setting. The application includes a transmission module that wirelessly transmits the certificate to the access device using a short-range wireless setting when the phone is within transmission distance of the lock (Compl. ¶83).
- Asserted Claims: At least claim 1 (Compl. ¶82).
- Accused Features: The infringement allegation targets the functionality of the Schlage Home mobile application in receiving access credentials and using short-range wireless communication (e.g., Bluetooth) to operate the Schlage smart locks when the user's phone is nearby (Compl. ¶83).
U.S. Patent No. 11,373,474 - Access Control System And Method For Use By An Access Device
- Technology Synopsis: This patent claims a system where the access device's processor receives the reservation certificate solely from the application on the portable terminal. After receiving the certificate, the processor performs the time-interval comparison to determine if the certificate is current and activates the lock accordingly (Compl. ¶101). The "solely" limitation suggests the lock does not receive the certificate from another source, such as directly from a network.
- Asserted Claims: At least claim 8 (Compl. ¶99).
- Accused Features: The complaint alleges the Schlage system infringes by having the Schlage Home app act as the exclusive conduit for presenting the temporary access credential to the lock for verification (Compl. ¶101).
III. The Accused Instrumentality
Product Identification
- The accused products are the "Schlage Smart Locks, Schlage Encode Plus Smart Wi-Fi Deadbolt, and Schlage Home mobile application," along with other substantially similar products (collectively, the "Accused Products") (Compl. ¶23).
Functionality and Market Context
- The complaint alleges that the Accused Products provide "features enabling access to entry points such as door locks" (Compl. ¶23). This functionality is allegedly implemented through features referred to as "Access Codes" (Compl. ¶23). While the complaint does not detail the technical operation of the Schlage system, it asserts that the system allows users to create and manage temporary, time-based access for guests via a mobile application that communicates with the smart locks. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
U.S. Patent No. 9,373,205 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 (Schlage Smart Locks) are alleged to be an access device with a processor that controls a door lock and a communication module. | ¶33 | col. 2:7-12 |
| the processor is configured to receive a reservation certificate presented by a portable terminal through the communication module... | The processor in the Schlage lock is alleged to be configured to receive a credential (characterized as a "reservation certificate") from a portable terminal (a smartphone running the Schlage Home app). | ¶33 | col. 2:12-15 |
| 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 accessible to the processor, determine the current time is within the interval... and activate the door lock... | The processor in the Schlage lock is alleged to compare the time validity period ("interval of a reservation") of the received credential to the current time to determine if access should be granted and, if so, activates the lock. | ¶33 | col. 2:15-22 |
U.S. Patent No. 10,657,747 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an access control system comprising an access device comprising a communication module connected to a processor having control of a door lock... | The Schlage system, including the smart lock, constitutes an access control system with an access device. | ¶49 | col. 9:1-4 |
| a secure reservation interface to receive a reservation request from a first device for a reservation at a given destination... | The Schlage Home app or website is alleged to provide a secure interface for creating a temporary access code for a specific lock ("destination"). | ¶49 | col. 9:5-10 |
| a reservation server... to receive the reservation request... issue a reservation certificate... and transmit... the reservation certificate and a communication setting corresponding to the access device... | Schlage's servers are alleged to receive the request, generate a credential ("reservation certificate"), and transmit it with necessary communication settings to the user's smartphone app. | ¶49 | col. 9:11-21 |
| 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 Schlage Home app on a user's smartphone allegedly receives the credential and wirelessly transmits it to the Schlage smart lock. | ¶49 | col. 9:22-29 |
| wherein the access device receives the reservation certificate from the application... and the processor activates the door lock based on at least the receipt of the reservation certificate. | The Schlage smart lock allegedly receives the credential from the app, and its processor activates the lock based on that receipt. | ¶49 | col. 9:30-34 |
Identified Points of Contention
- Scope Questions: A primary question will be whether the temporary "Access Codes" generated by the Schlage system meet the definition of a "reservation certificate" as contemplated by the patents. The patents’ specification often uses language of "reserving" a resource for a specific time, such as a hotel room or vehicle charger. The dispute may focus on whether creating a guest key with a set validity period (e.g., access from Tuesday to Friday) constitutes making a "reservation" for an "interval."
- Technical Questions: The complaint does not specify the exact data flow and architecture of the accused system. For the ’474 Patent, which requires the lock to receive the certificate "solely" from the application, a key factual question will be whether the accused Schlage locks also communicate directly with a server or other networked device to validate credentials, which could present a non-infringement argument.
V. Key Claim Terms for Construction
"reservation certificate"
- Context and Importance: This term is central to all asserted claims. The outcome of the case may depend on whether the digital credentials used by the Schlage system (e.g., "Access Codes") fall within the scope of this term. Practitioners may focus on this term because its construction will determine whether the patents read on a wide range of temporary digital key systems or are limited to more formal "reservation" systems.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patents interchangeably refer to a "digital token or certificate" (’747 Patent, col. 2:18-19). The specification describes the certificate as containing data fields like a "start time and duration (or end time)," which could plausibly describe any time-limited digital key (’747 Patent, col. 2:28-30).
- Evidence for a Narrower Interpretation: The patents consistently use the term "reservation" and provide examples like reserving an EV charger or a hotel room, suggesting a process of booking a specific, discrete time slot (’747 Patent, col. 1:10-12). The patent figures illustrate a user flow for making "New Reservations," which may imply a more structured booking process than simply creating a guest key (’747 Patent, Fig. 7).
"interval of a reservation"
- Context and Importance: This term defines the temporal limitation of the access grant. Its construction is linked to "reservation certificate" and is critical for determining whether the time-validity periods of Schlage's Access Codes meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification defines the interval by a "start time and duration (or end time)," which is a generic description of a time period that could cover any credential with an expiration date (’205 Patent, col. 2:28-31).
- Evidence for a Narrower Interpretation: The context of a "reservation" may imply that the "interval" is a formally booked and finite slot, as opposed to a longer, more open-ended period of validity that might be associated with a guest key. The specification notes that after the "reserved charging time," the certificate "will die automatically," suggesting a strict temporal boundary tied to a booked event (’205 Patent, col. 3:26-30).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant instructs its customers on how to use the Accused Products in an infringing manner through user manuals, advertising, and other promotional materials (Compl. ¶¶34, 50). It also alleges contributory infringement on the basis that the Accused Products contain special features designed for infringement and have no substantial non-infringing uses (Compl. ¶¶35, 51).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the patents since at least the time it received the original complaint in the matter (Compl. ¶¶38, 55). The complaint further alleges that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness to Plaintiff's patent rights (Compl. ¶¶36, 53).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: can the term "reservation certificate," which is described in the patents' context of reserving time-limited access to resources like EV chargers or hotel rooms, be construed to encompass the temporary "Access Codes" or digital guest keys used in the accused smart lock system?
- A key factual question will concern system architecture and data flow: does the accused Schlage system practice the claimed method of generating a credential on a central server, transmitting it to a user's portable terminal, and having that terminal then locally and wirelessly convey the credential to the lock, particularly with respect to patents that claim specific multi-device interactions or limitations like receiving the credential 'solely' from the application?
- An evidentiary question will relate to willfulness: what evidence supports the allegation that Defendant maintained a "policy or practice" of willful blindness toward the patent rights of others, and can Plaintiff establish that Defendant's conduct rose to the level of being "egregious" or "objectively reckless" following notice of the patents?