Ollnova Tech Ltd v. Resideo Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ollnova Technologies Ltd. (Ireland)
  • Defendant: Resideo Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Russ August & Kabat
• Case Identification: 6:22-cv-00390, W.D. Tex., 04/15/2022
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant Resideo Technologies, Inc. has a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s smart thermostat products infringe four patents related to wireless communication, power management, and control architectures for building automation systems.
• Technical Context: The technology at issue involves methods for optimizing communication and power consumption in smart home devices, such as HVAC thermostats that interact with remote sensors and networks.
• Key Procedural History: Post-filing, U.S. Patent No. 8,224,282, one of the four asserted patents, was subject to an Inter Partes Review (IPR2023-00624). The review concluded with the cancellation of all claims asserted in this litigation (including independent claim 13), as reflected in a certificate issued January 27, 2025. This event substantially impacts the viability of the infringement count related to the ’282 Patent.

Case Timeline

Date	Event
2004-08-09	’495 Patent Priority Date
2006-04-12	’887 Patent Priority Date
2008-01-03	’371 Patent Priority Date
2008-03-19	’282 Patent Priority Date
2010-06-29	’887 Patent Issued
2010-12-28	’495 Patent Issued
2012-07-17	’282 Patent Issued
2012-09-11	’371 Patent Issued
2022-04-15	Complaint Filed
2025-01-27	’282 Patent Inter Partes Review Certificate Issued (Claims Cancelled)

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

U.S. Patent No. 8,224,282 - “Method and device to manage power of wireless multi-sensor devices,” issued July 17, 2012

The Invention Explained

• Problem Addressed: The patent addresses the problem of limited battery life in wireless devices used in building automation systems (BAS), particularly those with multiple sensors that must communicate information over a network (’282 Patent, col. 2:14-19).
• The Patented Solution: The invention proposes a power-saving method where a first automation component (e.g., a multi-sensor device) receives "status information" from a second component (e.g., a controller). This status information indicates which specific sensor data the controller is currently using. The multi-sensor device then communicates only that "portion of the stored sensor data," rather than all available data, thereby conserving power by reducing unnecessary transmissions (’282 Patent, Abstract; col. 2:36-44).
• Technical Importance: This approach sought to make battery-powered, multi-function wireless sensors more viable for long-term deployment in building automation by intelligently reducing their communication load based on the immediate needs of the control system (’282 Patent, col. 2:14-19).

Key Claims at a Glance

• The complaint asserts independent claim 13 (Compl. ¶10).
• Essential elements of claim 13 include:
  • An automation component for a BAS comprising a multi-sensor package, a wireless communications component, a processor, and a memory.
  • The memory stores sensor data and computer-readable instructions.
  • The instructions are programmed to: receive a wake-up command from a second automation component; communicate stored sensor data related to the sensor data in control at the second component; and receive a power-down command from the second component.
• Note: As noted in Section I, claim 13 was cancelled in a subsequent Inter Partes Review proceeding.

U.S. Patent No. 7,746,887 - “Dynamic value reporting for wireless automated systems,” issued June 29, 2010

The Invention Explained

• Problem Addressed: The patent identifies the problem that continuous monitoring and broadcasting of information by wireless devices in an automation system consumes large amounts of power and network bandwidth, and can create redundant or unnecessary data traffic (’887 Patent, col. 1:40-49).
• The Patented Solution: The invention describes a system for "dynamic value reporting" where a wireless device monitors a condition at a "variable periodic interval." It only reports an event over the network in response to detecting a change in the condition, such as a value moving outside a predefined range or differing from a prior value. This prevents the device from constantly transmitting data when the monitored condition is stable, thus saving power and bandwidth (’887 Patent, Abstract; col. 2:1-8).
• Technical Importance: This method provided a more efficient communication protocol for wireless sensor networks by shifting from a constant-reporting model to an exception-based reporting model, which is critical for scaling up the number of devices in a BAS without overwhelming the network (’887 Patent, col. 2:56-62).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶18).
• Essential elements of claim 1 include:
  • A wireless automation device with a transceiver, a sensor, a controller, and a memory.
  • The controller polls the sensor at a "polling interval" to read an indicator of a sensed condition.
  • The memory stores current and prior readings of the indicator.
  • The transceiver transmits a reading in response to "detecting a change in the sensed condition outside a predetermined range."
  • Transmission is suspended when detecting a "change" within the predetermined range.

U.S. Patent No. 7,860,495 - “Wireless building control architecture,” issued December 28, 2010

Technology Synopsis

The ’495 Patent describes a two-tier wireless control architecture for building automation. The architecture uses two different wireless communications protocols: a first, lower-bandwidth protocol for a "first wireless network" of local devices (e.g., sensors and actuators), and a second, higher-bandwidth protocol for a "second wireless network" of controllers. A key feature is that the first network can operate to control building components "free of communications with the second wireless network," allowing for direct, peer-to-peer control at the local level for improved reliability (’495 Patent, Abstract; col. 5:55-6:3).

Asserted Claims

The complaint asserts independent claim 1 (Compl. ¶26).

Accused Features

The complaint alleges infringement by products like the T10 Pro Smart Thermostat, which allegedly operates using two different wireless protocols (e.g., WiFi and RedLINK) to form distinct communication networks with different devices (Compl. ¶27; p. 9).

U.S. Patent No. 8,264,371 - “Method and device for communicating change-of-value information in a building automation system,” issued September 11, 2012

Technology Synopsis

The ’371 Patent discloses methods for managing "change-of-value" (COV) communications in a BAS to optimize network traffic. It describes both a "polled" (pull) system, where a central device requests updates, and a "pushed" system, where a remote device independently sends an update when a change occurs. The invention allows a device to generate and communicate a COV update that can include messages from a plurality of other devices (’371 Patent, Abstract; col. 2:25-38).

Asserted Claims

The complaint asserts independent claim 13 (Compl. ¶34).

Accused Features

The complaint alleges that the Accused Products, through their scheduling and other control features, infringe by implementing methods for communicating change-of-value information (Compl. ¶35).

III. The Accused Instrumentality

Product Identification

The complaint identifies a range of Resideo smart thermostats, including the T10 Pro Smart Thermostat, T9 Smart Thermostat, Round Smart Thermostat, T6 Pro Thermostat, and others, collectively termed the "Accused Products" (Compl. ¶9).

Functionality and Market Context

• The complaint describes the Accused Products as smart thermostats that can connect to a home's Wi-Fi network and communicate with other devices, such as the RedLINK Room Sensor, to manage a home's climate (Compl. ¶11, ¶27). A marketing screenshot for the T10 Pro Smart Thermostat highlights its "Advanced connectivity and reliability," noting it "Connects directly to the home's Wi-Fi network" and "Communicates to RedLINK™ Room Sensors" (Compl. p. 10).
• A key functionality alleged as infringing is "location-based temperature control" or "geofencing," where the thermostat uses a smartphone's location to adjust temperature settings automatically, for example, by entering an energy-saving mode when the user leaves home (Compl. ¶11; p. 4). Another screenshot describes this feature, stating the "T10 Pro Smart thermostat will automatically use your smartphone's location" to save energy (Compl. p. 4).
• The complaint also highlights the use of multiple wireless protocols, alleging that products like the T10 Pro use both WiFi and RedLINK (900MHz) to communicate with different parts of the smart home system (Compl. ¶27; p. 9).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 2, 4, 6, 8) that were not provided with the filed document. Therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

• ’282 Patent Infringement Allegations
  The complaint alleges that the Accused Products infringe claim 13 by implementing a power management scheme that corresponds to the claimed method (Compl. ¶10). The theory appears to be that the Resideo thermostats (as the "first automation component") receive commands or status information from a controller or app (the "second automation component") that effectively function as "wake-up" and "power-down" commands, and in response, the thermostats communicate relevant sensor data. However, the subsequent cancellation of claim 13 by the USPTO raises the question of whether this infringement count remains viable.

• ’887 Patent Infringement Allegations
  The complaint alleges that the Accused Products infringe claim 1 by employing "dynamic value reporting" (Compl. ¶18). The infringement theory centers on features like "location-based temperature control (geofence technology)" and time-based scheduling (Compl. ¶11; p. 4, ¶19). The complaint suggests that when a user's smartphone location crosses a geofence boundary (e.g., leaving home), this constitutes a "change in the sensed condition" that triggers the thermostat to transmit a new state or setting, which maps to the claim requirement of reporting only upon a detected change. The periods when the user is stationary (either at home or away) would correspond to the claimed "suspension" of transmission.

• Identified Points of Contention:

  • Scope Questions (’887 Patent): A central question may be whether the Accused Products' geofencing and scheduling features meet the claim limitation of polling/sampling at a "variable periodic interval." The patent specification describes varying the interval based on a statistical analysis of prior sensor readings (’887 Patent, col. 12:22-34), which may present a different technical mechanism than a thermostat responding to an asynchronous event like a user crossing a geofence. The court may need to determine if an event-driven system (like geofencing) can be considered to operate on a "variable periodic interval" as described in the patent.
  • Technical Questions (’282 Patent): Even before considering the claim cancellation, a technical question would have been whether the normal operational communications of the accused thermostats (e.g., responding to app commands) constitute the specific claimed sequence of receiving a "wake-up command," communicating "sensor data in control," and receiving a "power-down command." The complaint does not provide sufficient detail for analysis of this specific sequence of operations.

V. Key Claim Terms for Construction

• Term: "suspended in response to detecting a change in the sensed condition within the predetermined range" (from '887 Patent, Claim 1)

  • Context and Importance: This term is critical because it defines the core power and bandwidth-saving feature of the '887 patent. The infringement case rests on whether the accused thermostats "suspend" transmissions when the system state is stable (e.g., user is at home and temperature is at setpoint) and only transmit when a change occurs (e.g., user leaves home).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify how the suspension occurs, only that it is the inverse of transmitting upon a change outside a range. This could support a reading that any period of non-transmission due to system stability meets the limitation.
    • Evidence for a Narrower Interpretation: The specification describes a system that actively polls a sensor and then makes a decision whether to transmit or not based on comparing the reading to a limit (’887 Patent, Fig. 3; col. 10:27-48). A defendant might argue that "suspended" requires this active decision-making process, not merely the absence of an external trigger like a geofence event.

• Term: "variable periodic interval" (from '887 Patent, specification, as context for "polling interval" in Claim 1)

  • Context and Importance: Practitioners may focus on this term because the infringement theory applies the patent to geofencing and scheduling, which may not operate on "periodic intervals" in the way a traditional polling system does. The definition will determine if these modern smart home features fall within the patent's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the interval "may be changed, varied, regulated, adjusted, extended and/or compressed" (’887 Patent, col. 3:41-44). This broad language could support an interpretation that covers any non-fixed interval, including those dictated by user schedules or location.
    • Evidence for a Narrower Interpretation: The specification provides specific examples where the interval is adjusted based on a "statistical analysis of the measurement" or the "dispersion of the values" (’887 Patent, col. 2:1-4, col. 13:12-16). This suggests the "variability" is a technical feedback mechanism based on the data itself, not an external input like a pre-set schedule or a user's physical location.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all four patents. The basis for inducement is that Resideo actively encourages and instructs customers on how to use the Accused Products in an infringing manner through materials such as online installation guides, user manuals, and product specifications (Compl. ¶¶ 11, 19, 27, 35). For example, the complaint cites Resideo's instructions on how to use "location-based temperature control" and how to install and set up the T10 Pro thermostat with its RedLINK sensors (Compl. ¶11, ¶27).
• Willful Infringement: The complaint alleges that Resideo has knowledge of the asserted patents and the infringing nature of the Accused Products "as of at least the filing and service of this complaint" (Compl. ¶¶ 11, 19, 27, 35). This allegation appears to be based on post-suit knowledge, as no facts suggesting pre-suit knowledge are pleaded.

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

1. Impact of IPR: A threshold issue for the case is the effect of the post-filing cancellation of all asserted claims of the ’282 Patent. This proceeding appears to render the infringement count on that patent moot, which may significantly narrow the scope and potential damages in the litigation.
2. Definitional Scope: A core issue for the remaining patents will be one of definitional scope: can claim terms rooted in the technical context of 2000s-era building automation systems be construed to cover modern consumer smart-home functionalities? For instance, with respect to the ’887 Patent, does the event-driven nature of "geofencing" technology fall within the scope of a system that reports changes based on polling at a "variable periodic interval"?
3. Functional Mismatch: A key evidentiary question will be one of functional operation, particularly for the ’495 Patent. Does Resideo’s use of two wireless standards (e.g., Wi-Fi and RedLINK) constitute the claimed "first" and "second" wireless networks with distinct protocols, and critically, does the alleged "first network" (e.g., thermostat-to-sensor) operate to control building components "free of communications with the second wireless network" as required by the claims?