Cedar Lane Tech Inc v. Johnson Controls Intl

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Johnson Controls International plc (Ireland)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00815, E.D. Tex., 08/19/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s ventilation products and systems infringe a patent related to controlling ventilation blowers using air quality sensors.
• Technical Context: The technology at issue involves integrating multiple environmental sensors into building ventilation systems to automatically respond to contaminants like carbon monoxide, smoke, or other noxious fumes by increasing air exchange.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or inter partes review proceedings related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 7,632,178 - Ventilation blower controls employing air quality sensors

The Invention Explained

• Problem Addressed: The patent describes a problem with existing building ventilation systems, which are often controlled manually, by timers, or by simple humidistats. These methods are inefficient and may fail to activate ventilation when needed to remove harmful contaminants (e.g., carbon monoxide, smoke) or may run unnecessarily when air quality is good (’178 Patent, col. 2:6-28). The patent notes that retrofitting existing systems with advanced sensors can be complex (’178 Patent, col. 2:32-41).
• The Patented Solution: The invention proposes a method for retrofitting an existing ventilation system that has a "Remote Switch" terminal, which is designed to force the system into a continuous, high-speed mode (’178 Patent, col. 2:36-39). The solution involves adding one or more air quality sensors (e.g., for CO, smoke, fuel gas) and connecting them in a parallel network to a relay. When any sensor detects an "abnormal air quality condition," the relay is activated, which in turn connects to the remote switch terminal to set the ventilation fans to high speed, thereby evacuating the contaminated air (’178 Patent, col. 2:54-58; col. 5:20-34). Figure 3 illustrates this retrofit concept, showing various sensors (26, 27, 28) connected via diodes (31) to a relay (32) that simulates the operation of a manual wall switch (20).
• Technical Importance: The claimed method provides a simplified way to upgrade existing ventilation infrastructure with automated, multi-sensor safety features without requiring a complete system overhaul or a complex central controller (’178 Patent, col. 2:32-37).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead incorporating by reference a claim chart (Exhibit 2) that was not attached to the filed complaint (Compl. ¶11, ¶16). The patent contains one independent claim, Claim 1, which is a method claim.
• Essential elements of independent Claim 1 include:
  • Providing an existing ventilation system having fans for exhausting stale air and bringing in fresh air, and having at least one remote switch terminal for setting a high speed mode.
  • Adding a relay to the system.
  • Inserting at least one air quality sensor in a specific location.
  • Connecting the relay's contacts to the remote switch terminal to enable setting the high speed mode.
  • Connecting the air quality sensor(s) in a parallel network to the relay.
  • Whereby the relay is activated to set the high speed fan operation when a sensor detects an "abnormal air quality condition."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Defendant products identified in the charts" attached as Exhibit 2, which are termed the "Exemplary Defendant Products" (Compl. ¶11). Exhibit 2 was not provided with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. The infringement allegations are premised entirely on the contents of the unprovided Exhibit 2 (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '178 Patent" and that they "satisfy all elements of the Exemplary '178 Patent Claims" (Compl. ¶16). The complaint states that detailed infringement comparisons are provided in claim charts in Exhibit 2, which was not included with the public filing (Compl. ¶17). As such, a claim chart summary cannot be constructed. The narrative theory relies on the assertion that Defendant's products directly infringe by their nature and that Defendant also induces infringement by distributing "product literature and website materials" that instruct end users on infringing uses (Compl. ¶14).

No probative visual evidence provided in complaint.

Identified Points of Contention

Lacking specific allegations, any analysis is speculative. However, based on the asserted patent, future disputes may revolve around several key technical and legal questions:

• Scope Questions: Do the accused ventilation systems possess a "remote switch terminal" as that term is used in the patent, or do they use more modern digital or networked control protocols that may not map onto the claimed architecture?
• Technical Questions: What specific functionality in the accused products constitutes a "parallel network" for connecting sensors to a control relay? The complaint provides no evidence on how Defendant's products are architected. A central question will be whether the accused systems operate by activating a relay connected to a high-speed terminal, as required by the claim, or through a different control logic.

V. Key Claim Terms for Construction

• The Term: "remote switch terminal" (Claim 1)

• Context and Importance: This term appears central to the claimed method of retrofitting. The patent's solution is built around interfacing with this specific pre-existing component (’178 Patent, col. 2:36-39). The viability of the infringement case may depend on whether Defendant's products, which may use modern integrated controllers, contain an analogous physical or logical input that can be fairly characterized as a "remote switch terminal."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification refers to the terminal's function: "setting the system controller for continuous high speed operation" (’178 Patent, col. 2:36-39). A party might argue that any input, physical or logical, that achieves this specific function falls within the term's scope.
  • Evidence for a Narrower Interpretation: The patent consistently describes this as a feature of existing, prior art systems that can be retrofitted (’178 Patent, col. 2:32-37). Figure 3 depicts the terminals (19) as distinct physical connection points for a wall switch (20). A party could argue the term is limited to the physical, two-wire switch interface common at the time of invention, not modern bus-based or software-defined control inputs.

• The Term: "abnormal air quality condition" (Claim 1)

• Context and Importance: This term defines the trigger for the claimed method. Its scope will determine what types of sensor detections constitute infringement. Practitioners may focus on this term because its breadth is not explicitly defined, raising potential indefiniteness or scope questions.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of contaminants, including "carbon monoxide, fuel gasses, or smoke" (’178 Patent, col. 2:39-41), as well as byproducts of urination and defecation (’178 Patent, col. 2:18-19). This suggests the term should be read broadly to cover any air quality issue detectable by a sensor.
  • Evidence for a Narrower Interpretation: A party might argue that the term is tied to specific hazard levels that trigger an alarm or high-speed ventilation for safety reasons, as opposed to mere comfort or odor control. The specification distinguishes between high-priority dangers like CO and lower-priority conditions that might warrant a delayed or different response (’178 Patent, col. 6:20-24; col. 3:40-45).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells its products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14-15).
• Willful Infringement: The complaint bases its willfulness allegation on post-suit knowledge. It asserts that filing the complaint provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14). No pre-suit knowledge is alleged.

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

1. Evidentiary Sufficiency: The central immediate issue is the complaint's reliance on an external, unprovided exhibit for all substantive allegations regarding the accused products and the mechanism of infringement. A primary question will be whether the complaint, as filed, provides sufficient notice of the infringement claims to survive a motion to dismiss.
2. Technological Equivalence: Assuming the case proceeds, a core technical question will be one of architectural correspondence: do Defendant’s potentially modern, integrated HVAC control systems contain a "remote switch terminal" and a "parallel network" of sensors as understood in the context of the '178 patent, or do they operate on a fundamentally different control logic that falls outside the claim scope?
3. Definitional Scope: The dispute may also turn on the interpretation of "abnormal air quality condition." The question will be whether this term is limited to specific life-safety events (e.g., high CO levels) or if it can be construed more broadly to cover any environmental condition that a sensor is configured to detect and respond to.