Cedar Lane Tech Inc v. Ventilation Systems Prjsc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedar Lane Technologies Inc. (Canada)
  • Defendant: Ventilation Systems PrJSC (Ukraine)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01149, E.D. Tex., 11/24/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign corporation, and further asserts that Defendant has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s ventilation products infringe a patent related to retrofitting ventilation systems with air quality sensors that can automatically trigger high-speed operation.
• Technical Context: The technology at issue concerns automated control systems for building ventilation, a field focused on improving indoor air quality and energy efficiency by responding dynamically to environmental conditions.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or specific licensing history 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 patent-in-suit is U.S. Patent No. 7,632,178, issued December 15, 2009 (the “’178 Patent”).

The Invention Explained

• Problem Addressed: The patent describes a problem with existing building ventilation systems, which are often controlled manually, by a simple timer, or by a humidistat. These methods are not ideal, as occupants may forget to activate a blower when needed, or automated systems may run unnecessarily (e.g., an occupancy sensor turning on a fan when someone only enters a bathroom to wash hands) (’178 Patent, col. 2:7-17). This results in either a failure to remove contaminants or inefficient operation.
• The Patented Solution: The invention proposes a method for retrofitting existing ventilation systems with one or more air quality sensors (e.g., for carbon monoxide, smoke, or ammonia) (’178 Patent, col. 2:31-41). When a sensor detects a contaminant above a certain threshold, it activates a relay that is wired to the ventilation system's "Remote Switch" or equivalent high-speed-mode terminal, forcing the system into a continuous high-speed mode to evacuate the contaminated air (’178 Patent, col. 2:41-46; Fig. 3). The patent describes connecting multiple sensors in parallel, allowing any one of them to trigger the high-speed operation (’178 Patent, col. 5:26-31).
• Technical Importance: This approach provides a way to upgrade existing, non-intelligent ventilation systems into automated, responsive systems that can react to specific air quality threats without requiring a complete system replacement.

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" of the ’178 Patent, with specific claims identified in an attached but unprovided exhibit (Compl. ¶11). Claim 1 is the first independent claim.
• The essential elements of independent claim 1 include:
  • Providing an existing ventilation system having fans and a remote switch terminal for setting a high-speed mode.
  • Adding a relay to the system.
  • Inserting at least one air quality sensor.
  • Connecting the relay's contacts to the remote switch terminal.
  • Connecting the air quality sensor to the relay in a parallel network, such that the sensor's detection of an "abnormal air quality condition" activates the relay and sets the fans to high-speed operation.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies certain "Exemplary Defendant Products" in charts incorporated by reference as Exhibit 2, which was not provided with the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’178 Patent (Compl. ¶16). It states that these products have been made, used, sold, imported, and offered for sale by the Defendant (Compl. ¶11). The complaint does not provide sufficient detail for analysis of the specific technical functionality or market positioning of the accused products.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2; however, this exhibit was not included with the filed document (Compl. ¶16-17). The complaint asserts that these charts compare the "Exemplary '178 Patent Claims" to the "Exemplary Defendant Products" and demonstrate that the products "satisfy all elements" of the asserted claims (Compl. ¶16). Without the charts, a detailed element-by-element analysis is not possible based on the provided documents. The infringement theory appears to be that Defendant's products, when used as intended, perform the patented method of using air quality sensors to trigger a high-speed ventilation mode.

• Identified Points of Contention:
  • Scope Questions: A potential issue may be whether modern, integrated ventilation control units, which may use microprocessors and digital signals, can be said to include a "relay" connected to a "remote switch terminal" as recited in the claim. The defense may argue that its architecture is fundamentally different from the electromechanical retrofitting method described.
  • Technical Questions: A factual question may arise regarding how the accused products are installed and configured. Because the claim is a method of "retrofitting an existing ventilation system," infringement analysis may depend on whether the accused products are used to modify pre-existing systems in the manner claimed, or if they are sold as fully integrated new systems.

V. Key Claim Terms for Construction

• The Term: "remote switch terminal"
• Context and Importance: This term appears central to defining the type of ventilation system the patented method is designed to retrofit. The claim requires connecting a relay to this specific interface. The construction of this term may determine whether the patent applies only to older systems with a specific type of physical, high-speed override connection, or if it can read on more modern digital or bus-based control inputs.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to the Honeywell HR150 and HR200 systems, which have a "Remote Switch connection which sets the system controller for continuous high speed operation," suggesting the term refers to a functional input rather than a specific physical structure (’178 Patent, col. 2:36-39). This may support an interpretation covering any input that achieves the same high-speed override function.
  • Evidence for a Narrower Interpretation: The figures and description consistently depict a direct electrical connection for a physical switch, such as "wall switch 20" (’178 Patent, Fig. 3; col. 5:9-12). This context may support an interpretation limited to the specific electromechanical interfaces common at the time of the invention, as distinct from modern, software-controlled systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products to customers for use in a manner that infringes and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing way (Compl. ¶14-15).
• Willful Infringement: The complaint does not allege pre-suit knowledge. It asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14).

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

1. A central issue will be one of technological evolution: Does the claim language, rooted in the concept of retrofitting systems via a "remote switch terminal" and a "relay," encompass modern ventilation systems that may achieve the same result through integrated digital controllers and software logic?
2. A key evidentiary question will concern the specific nature of the infringement evidence presented in the unprovided claim charts: What specific "Exemplary Defendant Products" are accused, and what technical documentation or analysis does the plaintiff provide to show that these products perform each step of the claimed retrofitting method?
3. The analysis of indirect infringement may hinge on the content of Defendant’s instructional materials. The case may turn on whether these materials direct customers to install and use the accused products to modify an "existing ventilation system" in the manner specifically recited by the claims.