DCT
7:25-cv-00406
Liberty Access Tech Licensing LLC v. Verkada Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Liberty Access Technologies Licensing LLC (Texas)
- Defendant: Verkada Inc. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 7:25-cv-00406, W.D. Tex., 09/04/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district, specifically citing an office in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s cloud-based access control systems, which use smartphones as mobile credentials, infringe five patents related to methods for controlling access to a lock using a time-limited "reservation certificate" transmitted to a portable device.
- Technical Context: The technology at issue falls within the modern physical security sector, where traditional keycards are being supplemented or replaced by digital credentials stored on mobile devices for building access.
- Key Procedural History: The complaint notes that two of the asserted patents, U.S. Patent Nos. 9,373,205 and 11,373,474, have survived post-grant reexamination proceedings at the USPTO. Such proceedings, where the patent office re-evaluates patentability in light of new prior art, may be presented by the Plaintiff to argue for the strengthened validity of the reexamined claims.
Case Timeline
| Date | Event |
|---|---|
| 2010-03-02 | Earliest Priority Date for Asserted Patents |
| 2015-01-23 | ’205 Patent Application Filed |
| 2016-06-21 | ’205 Patent Issued |
| 2018-07-12 | ’747 Patent Application Filed |
| 2020-04-14 | ’053 Patent Application Filed |
| 2020-05-19 | ’747 Patent Issued |
| 2022-01-03 | ’474 Patent Application Filed |
| 2022-01-04 | ’053 Patent Issued |
| 2022-02-25 | ’205 Patent Reexamination Certificate Issued |
| 2022-04-02 | ’579 Patent Application Filed |
| 2022-06-28 | ’474 Patent Issued |
| 2022-09-13 | ’579 Patent Issued |
| 2024-05-13 | ’474 Patent Reexamination Certificate Issued |
| 2025-09-04 | Complaint Filing Date |
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 difficulty of conveniently reserving and gaining access to resources like electric vehicle chargers or hotel rooms, where a user needs to ensure access for a specific time without a complex on-site payment or authentication process (’747 Patent, col. 1:36-44).
- The Patented Solution: The invention describes an access device (e.g., a door lock) that can operate without a constant internet connection. A user makes a reservation remotely, and a server sends a digital "reservation certificate" to the user's portable device, such as a smartphone. The certificate contains an approved time interval for access. The user presents this certificate wirelessly to the access device, which checks the certificate's interval against its own internal clock and grants access if the current time is within the approved window (’205 Patent, col. 6:5-28; Abstract). This architecture uses the smartphone as a secure, temporary key carrier.
- Technical Importance: This method allows access control devices to be managed centrally while enabling them to make access decisions locally, increasing reliability in environments where internet connectivity may be unstable (’747 Patent, col. 2:54-61).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶31). The right to assert additional claims is reserved (Compl. ¶33).
- 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.
- The certificate comprises an "interval of a reservation."
- The processor is configured to compare the certificate's interval to a current time accessible to the processor.
- The processor determines if the current time is within the interval and, if so, activates the door lock.
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 as the ’205 Patent: coordinating remote reservation with local access for time-limited resources (’747 Patent, col. 1:36-44).
- The Patented Solution: The ’747 Patent claims the entire end-to-end system. The system includes: (1) an access device (e.g., lock); (2) a secure reservation interface (e.g., a website or app screen) for making a reservation from a first device; (3) a server that issues a reservation certificate and sends it to a second, distinct device (e.g., a smartphone); and (4) an application on the second device that wirelessly transmits the certificate to the access device to activate the lock (’747 Patent, col. 9:1-33; Abstract). Figure 7 illustrates a potential user flow for such an application, from making a new reservation to enabling the access device (’747 Patent, Fig. 7).
- Technical Importance: This patent purports to cover the complete ecosystem for mobile-based, reservation-style access control, linking the user-facing booking interface with the back-end server logic and the final hardware interaction.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶47). The right to assert additional claims is reserved (Compl. ¶49).
- Essential elements of Claim 1 include:
- An access control system comprising an access device, a secure reservation interface, a reservation server, and an application on a second device.
- The interface receives a reservation request from a first device.
- The server receives the request, issues a "reservation certificate" and a "communication setting," and transmits them to a second device.
- The application on the second device receives the certificate and setting.
- The application wirelessly transmits the certificate to the access device, which receives it and activates the lock.
U.S. Patent No. 11,443,579 - "Access Control System And Method For Use By An Access Device"
Technology Synopsis
This patent describes a three-part access control system: an access device with a lock, an application on a portable terminal, and a server. The server provides a communication setting and a time-limited reservation certificate to the application, which then presents the certificate to the access device's processor to activate the lock (Compl. ¶65).
Asserted Claims
At least Claim 8 is asserted (Compl. ¶64).
Accused Features
The complaint alleges that the Verkada server, Verkada Pass mobile application, and Verkada Door Reader collectively practice the claimed system (Compl. ¶65).
U.S. Patent No. 11,217,053 - "Access Control System and Method for Use by an Access Device"
Technology Synopsis
This patent focuses on the use of short-range wireless communication. A server transmits a reservation certificate and a short-range wireless communication setting to a smartphone application. The application uses this setting to transmit the certificate to the access device only when the phone is within the required transmission distance (Compl. ¶82).
Asserted Claims
At least Claim 1 is asserted (Compl. ¶81).
Accused Features
The allegations target the Verkada system's use of Bluetooth communication between the Verkada Pass app and the Door Reader, which is triggered by proximity (Compl. ¶¶22, 82).
U.S. Patent No. 11,373,474 - "Access Control System And Method For Use By An Access Device"
Technology Synopsis
This patent claims an access control system where the processor of the access device receives the reservation certificate solely from the mobile application. This highlights the direct communication path between the user's device and the lock at the time of access, independent of a live server connection (Compl. ¶100).
Asserted Claims
At least Claim 8 is asserted (Compl. ¶98).
Accused Features
The complaint accuses the Verkada architecture where the Door Reader receives the mobile credential directly from the Verkada Pass app to make an access decision (Compl. ¶100).
III. The Accused Instrumentality
Product Identification
The accused products are collectively identified as the Verkada Access Control System, which includes its "Mobile Credential" feature, the Verkada Door Reader hardware, and the Verkada Pass mobile application for iOS and Android (Compl. ¶22).
Functionality and Market Context
The Verkada system is a "hybrid cloud access control" solution for enterprises (Compl. Figure 1). Administrators use a cloud-based platform to issue and manage access permissions for users. These permissions are delivered as a "Mobile Credential" to the user's smartphone via the Verkada Pass app. The app then uses Bluetooth to communicate with Verkada Door Readers to unlock doors (Compl. ¶22; Figure 3). The complaint presents a screenshot of the Verkada Pass app showing a list of "Nearby Doors," illustrating the application's proximity-based functionality (Compl. Figure 3). The system is marketed as a "modern and secure unlock experience" that can supplement or replace traditional keycards (Compl. Figure 2).
IV. Analysis of Infringement Allegations
’205 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an access device ... comprising: a processor having control of a door lock; and a communication module connected to the processor | The Verkada Door Reader is identified as the access device, containing a processor that controls an associated door lock and a communication module (e.g., Bluetooth). | ¶32 | col. 6:11-16 |
| the processor is configured to receive a reservation certificate presented by a portable terminal through the communication module | The Door Reader's processor is alleged to receive a "Mobile Credential" from the Verkada Pass mobile application (the portable terminal). | ¶32 | col. 6:16-19 |
| 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 | The Mobile Credential allegedly includes a valid time interval (e.g., 9:00 AM to 5:00 PM), which the Door Reader's processor compares against its current time to determine validity. | ¶32 | col. 6:20-25 |
| and activate the door lock to allow the portable terminal to unlock the door lock during the interval of the reservation | If the Mobile Credential is valid for the current time, the Door Reader's processor activates the door lock. | ¶32 | col. 6:25-28 |
’747 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an access control system comprising: a) an access device ... b) a secure reservation interface ... c) a reservation server ... d) an application installed on the second device | The complaint alleges the entire Verkada ecosystem infringes, with the Door Reader as the access device, the Verkada Command platform as the server/interface, and the Verkada Pass app as the application. | ¶48 | col. 9:2-23 |
| a secure reservation interface to receive a reservation request from a first device for a reservation at a given destination | The Verkada cloud platform allegedly functions as the interface for an administrator (on a first device) to create access rights for a user at a specific location. | ¶48 | col. 9:5-10 |
| 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 | The Verkada server receives the access request, creates a Mobile Credential (the alleged certificate), and transmits it over a network to the user's smartphone (the second device). | ¶48 | col. 9:11-23 |
| 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 Verkada Pass app receives the Mobile Credential and uses Bluetooth (a wireless communication setting) to transmit it to the Door Reader upon a user command to unlock. | ¶48 | col. 9:24-30 |
| wherein the access device receives the reservation certificate from the application ... and the processor activates the door lock | The Door Reader receives the credential from the app, and its processor activates the lock. | ¶48 | col. 9:30-33 |
Identified Points of Contention
- Scope Question: A central issue may be whether Verkada's "Mobile Credential," which appears to function as a persistent grant of access rights (e.g., employee access during business hours), falls within the scope of the patents' term "reservation certificate," which the patent specification often describes in the context of a discrete, time-limited booking for a resource like a hotel room or vehicle charger.
- Technical Question: For the device-centric claims of the ’205 Patent, the analysis may focus on whether the Verkada Door Reader's processor performs the time-comparison logic itself, or if it passes the credential to a separate controller or back to a server for validation. The complaint alleges the former, but the actual system architecture will be a key factual question.
- System Actors Question: For the system claims of the ’747 Patent, a potential point of dispute is whether an administrator provisioning long-term access rights via a dashboard constitutes making a "reservation request from a first device" that results in a certificate being sent to a "second device," as the claim requires.
V. Key Claim Terms for Construction
"reservation certificate"
- Context and Importance: This term is the central object of the asserted claims. Its construction will determine whether Verkada's "Mobile Credential" can be considered an infringing instrument. Practitioners may focus on this term because the patent's examples differ from the accused product's apparent function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patents refer to the object as a "digital token or certificate" that contains a "start time and duration (or end time), describing the interval" during which access is permitted (’747 Patent, col. 2:17-18, col. 2:28-30). This language could support an interpretation where any digital credential with a defined validity period qualifies.
- Evidence for a Narrower Interpretation: The specification's background and a detailed application flow-chart (Figure 7) frame the invention in the context of making a "New Reservation" for a specific time slot, akin to booking a hotel room or a charging station (’747 Patent, Fig. 7; col. 2:9-11). This may support a narrower construction limited to discrete, user-initiated bookings rather than ongoing administrative access rights.
"interval of a reservation"
- Context and Importance: This term defines the temporal limitation of the "reservation certificate." Whether a general grant of access (e.g., "Monday-Friday, 9 AM-5 PM") constitutes an "interval of a reservation" is critical to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is broad, requiring only an "interval" which could be any defined period, including recurring ones. The specification notes the certificate describes the "interval during which the final access device has been reserved" (’747 Patent, col. 2:28-30).
- Evidence for a Narrower Interpretation: The term is consistently linked with "reservation." The patent's user interface diagram shows a user explicitly selecting a "start time" and "end/duration" for a single reservation event, which may suggest the "interval" is tied to a specific, non-recurring booking (’747 Patent, Fig. 7).
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Defendant provides customers with instructions, documentation, and advertising that encourage and guide them to use the Accused Products in a manner that directly infringes the patents (e.g., by creating and using Mobile Credentials) (Compl. ¶¶33, 49).
Willful Infringement
Willfulness is alleged based on Defendant's knowledge of the patents obtained "at least the time of receiving the original Complaint in this matter," establishing a basis for potential post-filing willfulness (Compl. ¶¶37, 54). The complaint also alleges a "policy or practice of not reviewing the patents of others," which may be used to argue for willful blindness (Compl. ¶¶35, 52).
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's context of booking discrete time slots for resources like EV chargers, be construed to cover the "Mobile Credential" in the accused system, which functions as an ongoing grant of user access rights?
- A second key question will be one of system architecture and function: does the accused Verkada Door Reader operate as the self-contained decision-making "access device" claimed in the patents by performing the time-comparison logic on-device, or is this logic executed elsewhere in the system, potentially altering the infringement analysis?
- Finally, the case may turn on a question of user action: for the system claims, does an administrator provisioning employee access credentials via a dashboard constitute a "reservation request" as contemplated by the patent, or is the claim scope limited to an end-user actively booking a specific time for access?