DCT
2:25-cv-00966
Liberty Access Tech Licensing LLC v. Schlage Lock Co LLC
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-00966, E.D. Tex., 09/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established and regular place of business in Plano, Texas, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart lock products and associated mobile application infringe five patents related to access control systems that use a portable device to present a time-limited "reservation certificate" to a lock.
- Technical Context: The technology enables temporary, credentialed access to secure points, such as door locks, via a digital token on a mobile device, a central feature in the smart home, property management, and hospitality industries.
- Key Procedural History: The complaint notes that U.S. Patent No. 9,373,205 and U.S. Patent No. 11,373,474 were the subject of supplemental examination proceedings that resulted in the issuance of Reexamination Certificates. The survival of claims through such proceedings may be presented by the Plaintiff to suggest the patents' robustness against 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 |
| 2017-07-13 | Defendant registered to do business in Texas |
| 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 for ’205 Patent Issued |
| 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 for ’474 Patent Issued |
| 2025-09-19 | 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 family addresses the inconvenience of finding, reserving, and securely accessing resources like electric vehicle charging stations or hotel room locks, where access is needed for a specific period. (’747 Patent, col. 1:36-44).
- The Patented Solution: The invention proposes a system where a user receives a digital "reservation certificate" on a portable terminal (e.g., a smartphone). This certificate contains a valid time interval. The user presents the certificate to an access device (e.g., a door lock), whose processor then compares the interval in the certificate to its internal clock to determine if the current time falls within the valid period, granting access if it does. (’205 Patent, Abstract; ’205 Patent, col. 5:4-14).
- Technical Importance: This approach allows for secure, time-limited access control without requiring the access device itself to have a persistent connection to a central network, using the portable terminal as the carrier of the authorization token. (’205 Patent, col. 2:53-61).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶32).
- Essential elements of Claim 1 include:
- An access device with a processor controlling a door lock and a communication module.
- The processor is configured to receive a reservation certificate from a portable terminal via the communication module.
- When a certificate with a reservation interval is presented, the processor is configured to compare that interval to a current time.
- The processor determines if the current time is within the interval.
- The processor activates the door lock to allow unlocking 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
The Invention Explained
- Problem Addressed: As with the parent ’205 Patent, the technology seeks to streamline the process of reserving and gaining temporary access to controlled resources. (’747 Patent, col. 1:36-44).
- The Patented Solution: The ’747 Patent claims a more detailed, multi-component system. It describes a "secure reservation interface" (like a website or app screen) used on a first device to make a request. A "reservation server" receives this request, issues a reservation certificate, and transmits it along with a "communication setting" to a second device (like a smartphone). An application on the second device then uses this information to wirelessly transmit the certificate to the access device to activate the lock. (’747 Patent, col. 14:1-33).
- Technical Importance: The claimed invention formally structures the entire ecosystem, from the user interface for booking to the server-side logic and the multi-device workflow, reflecting a common architecture for modern application-based services. (’747 Patent, col. 13:13-31).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶48).
- Essential elements of Claim 1 include:
- An access device (with a processor controlling a door lock).
- A secure reservation interface to receive a reservation request from a first device.
- A reservation server that receives the request, issues a reservation certificate, and transmits the certificate and a communication setting to a second device.
- An application on the second device that receives the certificate and setting and wirelessly transmits the certificate to the access device upon a command.
- The access device receives the certificate and the 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
- Technology Synopsis: Describes an access control system comprising an access device, an application on a portable terminal, and a server. The server provides a communication setting and a reservation certificate to the application, which then presents the certificate to the access device's processor to compare the reservation interval and activate the lock. (Compl. ¶66).
- Asserted Claims: At least Claim 8 is asserted. (Compl. ¶65).
- Accused Features: The integrated system of Schlage's smart locks, the Schlage Home app, and backend servers is alleged to provide the claimed access control system. (Compl. ¶66).
U.S. Patent No. 11,217,053 - Access Control System and Method for Use by an Access Device
- Technology Synopsis: Claims an access control system with an access device having a short-range wireless communication module. A reservation server transmits a reservation certificate and a short-range wireless communication setting to a smartphone application, which then wirelessly transmits the certificate to the access device when it is within transmission distance. (Compl. ¶83).
- Asserted Claims: At least Claim 1 is asserted. (Compl. ¶82).
- Accused Features: The Schlage system, which uses short-range wireless protocols like Wi-Fi or Bluetooth for communication between the app and the lock, is accused of infringing. (Compl. ¶83).
U.S. Patent No. 11,373,474 - Access Control System And Method For Use By An Access Device
- Technology Synopsis: Claims an access control system where a server provides a communication setting and reservation certificate to an application. A key asserted element is that the access device's processor receives the reservation certificate solely from the application based on the application's use of the communication setting. (Compl. ¶101).
- Asserted Claims: At least Claim 8 is asserted. (Compl. ¶99).
- Accused Features: The complaint alleges the Schlage system architecture operates such that the lock receives its authorization token directly and solely from the mobile app, rather than from a central server. (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 Accused Products constitute a smart home access system. The hardware (locks) is installed on doors, and the software (Schlage Home mobile application) is used by end-users to manage access. The complaint alleges these products implement "Access Codes" features that enable time-based access to entry points. (Compl. ¶23). This functionality allows owners to grant temporary access to guests, contractors, or renters without providing a physical key, a significant feature in the consumer smart home and short-term rental markets.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint. The complaint references Exhibits A-E, which are described as containing evidence of infringement, but these exhibits were not filed as part of the complaint document itself. (Compl. p. 29). The following analysis is based on the narrative infringement summaries provided in the body of the complaint.
U.S. Patent No. 9,373,205 - Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a processor having control of a door lock; and a communication module connected to the processor | The Accused Products include a smart lock with a processor and a communication module for interacting with a user's device. | ¶33 | col. 6:12-19 |
| the processor is configured to receive a reservation certificate presented by a portable terminal through the communication module | The Schlage lock processor allegedly receives an access credential (the "reservation certificate") from a user's portable terminal (e.g., a smartphone running the Schlage app). | ¶33 | col. 5:4-6 |
| when a current reservation certificate that comprises an interval of a reservation is presented...the processor is configured to compare the interval of the reservation...to a current time accessible to the processor | The Schlage lock processor allegedly compares the time validity interval associated with the received access credential to the lock's current time. | ¶33 | col. 5:9-12 |
| determine the current time is within the interval of the reservation, and activate the door lock to allow the portable terminal to unlock the door lock during the interval | The Schlage lock processor allegedly determines the credential is valid for the current time and activates the lock mechanism, allowing it to be opened. | ¶33 | col. 5:12-14 |
U.S. Patent No. 10,657,747 - Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an access device comprising a communication module connected to a processor having control of a door lock | The Schlage smart lock serves as the access device. | ¶49 | col. 10:9-11 |
| a secure reservation interface to receive a reservation request from a first device... the reservation interface comprising one or more screens for receiving a selection of a location... and an interval | The Schlage Home app and/or website allegedly provides screens for a user on a first device to request and define access permissions for a specific lock ("location") and time period ("interval"). | ¶49 | col. 13:42-49 |
| a reservation server... to: receive the reservation request... issue a reservation certificate... and... transmit, via the network, from the reservation server to a second device... the reservation certificate and a communication setting | Schlage's backend servers allegedly receive the access request, generate a digital credential ("reservation certificate") and necessary connection data ("communication setting"), and transmit them to a second device (e.g., a smartphone). | ¶49 | col. 11:15-21 |
| an application installed on the second device to receive the reservation certificate and the communication setting... wherein the application wirelessly transmits the reservation certificate to the access device | The Schlage Home app on a user's smartphone receives the credential and connection data and wirelessly transmits the credential to the Schlage lock. | ¶49 | col. 11:54-65 |
| wherein the access device receives the reservation certificate... and the processor activates the door lock | The Schlage lock receives the credential from the app, and its processor activates the lock mechanism. | ¶49 | col. 12:20-24 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over whether the "Access Codes" feature of the Schlage system is equivalent to the "reservation certificate" claimed in the patents. The defense may argue that the patents describe a system for reserving a resource for a time slot (originating in the EV charging context), whereas the accused system is a credentialing system that grants access during a time window, suggesting a potential mismatch in purpose and function.
- Technical Questions: The complaint's allegations are described at a high level. A key technical question will be how the Schlage lock validates an "Access Code." Does its processor perform the specific function of "compar[ing] the interval... to a current time" as required by claim 1 of the ’205 Patent, or does it use a different technical method, such as validating a cryptographic signature that has an embedded expiration time?
V. Key Claim Terms for Construction
"reservation certificate"
- Context and Importance: This term is the central object of the asserted claims. The outcome of the case may depend on whether Schlage's "Access Codes" or other digital credentials fall within the scope of this term. Practitioners may focus on this term because its construction will determine whether the patents apply to consumer smart lock systems generally or are limited to systems for making explicit "reservations" for resources.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification uses the terms "digital token or certificate" interchangeably, suggesting the form is not limited. (’747 Patent, col. 2:17). The claims focus on the certificate's technical content—primarily an "interval of a reservation"—rather than the commercial context of the transaction.
- Evidence for a Narrower Interpretation: The detailed description and figures heavily frame the invention in the context of making "reservations" for access to EV chargers or hotel rooms, which implies a booking or scheduling function that may not be present in all temporary access credentialing systems. (’747 Patent, col. 1:25-44; Fig. 7).
"communication setting"
- Context and Importance: This term, appearing in the ’747, ’579, ’053, and ’474 patents, is critical for defining the system architecture. Infringement requires showing that Schlage's servers transmit not just a credential, but also a separate "setting" used by the app to connect to the lock. The dispute will likely focus on whether the data transmitted by Schlage's servers to its app contains a distinct element that meets this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides examples such as "network SSID, passcodes, IP addresses, Bluetooth ID, etc.," suggesting it can be any information needed to establish communication. (’747 Patent, col. 11:63-65). This could potentially cover a wide range of connection parameters.
- Evidence for a Narrower Interpretation: The term implies a setting provided by the server for a specific transaction. The defense might argue that in the accused system, the communication parameters (e.g., Bluetooth ID) are established during an initial pairing process and are not transmitted from the server with each new access code, suggesting a mismatch with the claimed process.
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement by claiming Defendant provides instructions, advertising, and promotional materials that guide end-users to operate the Accused Products in an infringing manner. (Compl. ¶¶34, 50, 67, 84, 102). It also alleges contributory infringement, asserting that the Accused Products have special features specifically designed to be used in an infringing way and are not staple articles of commerce with substantial non-infringing uses. (Compl. ¶¶35, 51, 68, 85, 103).
Willful Infringement
The complaint alleges willfulness based on Defendant's knowledge of the Asserted Patents since at least the time of receiving the complaint. (Compl. ¶¶38, 55, 72, 89, 107). It further alleges willful blindness, claiming on information and belief that Defendant has a "policy or practice of not reviewing the patents of others." (Compl. ¶¶36, 53, 70, 87, 105).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: can the term "reservation certificate," rooted in the patent family's description of reserving time-limited resources like EV chargers, be construed to cover the "Access Codes" and digital keys used in Defendant's consumer-facing smart lock system? The answer will likely define the applicability of the patent portfolio to the broader smart lock market.
The case will also present a key question of technical operation: does the accused Schlage system's method for validating a temporary access credential function in the same way as the claimed method, which requires the lock's processor to actively "compare the interval of the reservation... to a current time"? The evidentiary record on the specific software and hardware operations of the accused locks will be dispositive.
Finally, for the system claims, the dispute may focus on architectural mapping: does the data flow between the Schlage servers, the Schlage Home app, and the Schlage smart lock meet the specific claim elements requiring a server to transmit both a "reservation certificate" and a corresponding "communication setting" to an application for subsequent use?