7:25-cv-00447
Ivani LLC v. Legrand SA
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ivani, LLC (Delaware)
- Defendant: Legrand S.A. (France); Legrand North America, LLC (Delaware); The Watt Stopper, Inc. (California)
- Plaintiff’s Counsel: Hecht Partners LLP
- Case Identification: 7:25-cv-00447, W.D. Tex., 10/02/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant The Watt Stopper, Inc. has a regular and established place of business in the district, and because Defendants have committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s smart electrical switches, remotes, and controllers infringe patents related to configurable wireless mesh networks for electrical switching systems.
- Technical Context: The technology enables the retrofitting of traditional electrical wiring with smart switches that communicate wirelessly, allowing for advanced control (e.g., multi-way switching) without requiring new physical wiring in a building.
- Key Procedural History: The complaint alleges a multi-year history of business development discussions between the parties, beginning in June 2015. This history includes Plaintiff allegedly providing Defendant with the patent application for the ’194 Patent and conducting multiple in-person meetings and technology demonstrations prior to and after the patent's issuance.
Case Timeline
| Date | Event |
|---|---|
| 2014-01-27 | Earliest Priority Date for ’194 and ’824 Patents |
| 2015-06-04 | Plaintiff's CMO allegedly emails Defendant's VP to begin discussions |
| 2015-06-12 | Plaintiff allegedly sends the ’194 Patent application to Defendant |
| 2016-11-10 | Plaintiff allegedly attends Defendant's "Eliot Event" in New York |
| 2017-07-25 | Plaintiff and Defendant allegedly meet at Defendant's Connecticut office |
| 2017-10-12 | Plaintiff and Defendant allegedly meet at Defendant's headquarters in France |
| 2017-12-12 | U.S. Patent No. 9,843,194 issues |
| 2018-01-09 | Plaintiff and Defendant allegedly meet at the Consumer Electronics Show |
| 2018-03-13 | Plaintiff and Defendant allegedly meet again at Defendant's Connecticut office |
| 2018-10-15 | Plaintiff allegedly drops off demonstration kits at Defendant's headquarters |
| 2019-09-17 | U.S. Patent No. 10,418,824 issues |
| 2025-10-02 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,843,194 - Configurable Mesh Network for an Electrical Switching System
The Invention Explained
- Problem Addressed: The patent’s background section describes the technical problem of creating multi-way control for electrical fixtures (e.g., a light controlled by switches at opposite ends of a room) using traditional electrical systems, which requires complex, costly, and inflexible hard-wiring (’194 Patent, col. 4:26-53). Retrofitting such functionality into existing structures is particularly difficult and expensive (’194 Patent, col. 5:17-34).
- The Patented Solution: The invention proposes a power control system comprising a "master switch" and one or more "remote switches" (’194 Patent, Abstract). The master switch physically replaces a traditional switch, connecting to the building's power source and the electrical load (e.g., a light fixture) and contains a physical relay and a computer (’194 Patent, col. 13:6-20). The remote switch is not physically wired to the load; instead, it wirelessly transmits a command to the master switch, instructing the master's onboard computer to operate the physical relay, thereby controlling power to the load (’194 Patent, col. 6:11-22). This architecture allows for flexible multi-way control without new wiring.
- Technical Importance: This approach allows for the creation of sophisticated and reconfigurable home automation systems within the constraints of existing building infrastructure, avoiding the high cost and disruption of physical rewiring (’194 Patent, col. 6:58-67).
Key Claims at a Glance
The complaint asserts infringement of at least Claim 1 (Compl. ¶56).
Independent Claim 1 is a system claim requiring:
- A master switch comprising a first activation object, a physical switch to connect/disconnect an outlet from a power source, a first computer to control the physical switch, and a first network communication system.
- A remote switch comprising a second activation object and a second network communication system, but explicitly "not comprising a physical switch configured to connect and disconnect an outlet to a power source."
- An operational relationship where the remote switch provides an instruction to the network upon activation, and this instruction directs the master switch's computer to control its physical switch.
U.S. Patent No. 10,418,824 - Configurable Mesh Network for an Electrical Switching System
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’194 Patent, the ’824 Patent addresses the same technical problem of implementing flexible and retrofittable multi-way electrical control in buildings with existing wiring (’824 Patent, col. 4:26-53).
- The Patented Solution: The patented solution is structurally and functionally identical to that described in the ’194 Patent, involving a system of a hard-wired "master switch" containing a physical power relay controlled by an onboard computer, and a separate, wireless "remote switch" that instructs the master switch to operate its relay (’824 Patent, col. 6:1-22). Figure 3 illustrates the master switch's internal components, including the computer (121) and physical relay (111), while Figure 4 shows the remote switch's wireless communication pathway (’824 Patent, Figs. 3, 4).
- Technical Importance: The technology provides a pathway for modernizing electrical control systems by overlaying a wireless command network onto existing physical power infrastructure, thereby enabling smart home features without rewiring (’824 Patent, col. 5:58-6:4).
Key Claims at a Glance
The complaint asserts infringement of at least Claim 1 (Compl. ¶70).
Independent Claim 1, similar to the ’194 Patent, is a system claim requiring:
- A master switch with a first activation object, a physical switch, a first computer, and a first network communication system.
- A remote switch with a second activation object and a second network communication system, which does not contain a physical switch for controlling power to an outlet.
- An operational relationship wherein the remote switch instructs the master switch's computer via the network to control the physical switch.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are various Legrand master switches (e.g., WNRL50), remote switches (e.g., WNRL23), and "kits" that package a master and remote switch together (e.g., WNRH10KIT) (Compl. ¶¶20, 28, 32).
Functionality and Market Context
The complaint alleges that the accused products are designed to be used as a system to create wireless multi-way lighting control (Compl. ¶48). The WNRL50 master switch allegedly includes a physical paddle, an internal physical switch (relay), and an Atmel SAM R21 microcontroller with an integrated 2.4GHz transceiver that acts as a computer and network communication system (Compl. ¶¶21-24). A photograph in the complaint shows the circuit board of the WNRL50, identifying the Atmel microcontroller that allegedly serves as the claimed "computer" (Compl. p. 8). The WNRL23 remote switch is described as a battery-operated, wireless device with its own activation object and network communication system (Compl. ¶¶29-30). The system allegedly functions by the remote switch sending a wireless instruction to the master switch, causing the master's microcontroller to adjust the physical switch and control power to a connected light fixture (Compl. ¶¶25, 30). The complaint includes a side-by-side photographic sequence demonstrating a user activating a remote switch, which results in the lights controlled by the master switch turning off (Compl. p. 9).
IV. Analysis of Infringement Allegations
’194 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a master switch configured to replace a traditional light-switch, the master switch comprising: a first activation object; | The Legrand WNRL50 master switch, which includes a paddle for user interaction. | ¶¶20-21, 47 | col. 14:35-37 |
| a physical switch configured to connect and disconnect an outlet to a power source; | The WNRL50 allegedly includes an internal physical switch, depicted in a teardown photograph. | ¶¶22, 47 | col. 14:50-55 |
| a first computer configured to control said physical switch; | The WNRL50 allegedly contains an Atmel SAM R21 microcontroller configured to control the physical switch. | ¶¶23, 47 | col. 14:55-60 |
| a first network communication system configured to receive instructions from a network and provide them to said computer; | The microcontroller allegedly has an integrated transceiver that receives instructions from a network. | ¶¶24, 47 | col. 14:55-60 |
| a remote switch, the remote switch comprising: a second activation object; and not comprising a physical switch... | The Legrand WNRL23, a battery-operated wireless remote switch with a paddle, which allegedly lacks a physical switch to control a power outlet. | ¶¶28-29, 51 | col. 15:15-24 |
| a second network communication system configured to provide instructions to said network; wherein said second network communication system will provide an instruction...instructing said first computer to control said physical switch... | The WNRL23 allegedly has a network communication system that sends instructions to the master switch upon activation, causing the master's computer to control the physical switch. | ¶¶30, 51 | col. 15:15-24 |
’824 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a master switch configured to replace a traditional light-switch, the master switch comprising: a first activation object; | The same Legrand WNRL50 master switch products are accused, which include a paddle. | ¶¶20-21, 61 | col. 14:35-37 |
| a physical switch; | The WNRL50 allegedly contains an internal physical switch to control power. | ¶¶22, 61 | col. 14:50-55 |
| a first computer configured to control said physical switch; | The accused master switches allegedly include an Atmel microcontroller that controls the physical switch. | ¶¶23, 61 | col. 14:55-60 |
| a first network communication system configured to receive instructions from a network and provide them to said first computer; | The microcontroller allegedly includes an integrated transceiver for receiving instructions. | ¶¶24, 61 | col. 14:55-60 |
| a remote switch, the remote switch comprising: a second activation object; and not comprising a physical switch... | The Legrand WNRL23 and similar wireless remote switches, which are alleged to be battery-operated and lack a physical power-controlling switch. | ¶¶28-29, 65 | col. 15:15-24 |
| a second network communication system configured to provide instructions to said network...instructing said first computer to control said physical switch... | The accused remote switches allegedly send wireless instructions to the master switch to control its physical relay. | ¶¶30, 65 | col. 15:15-24 |
Identified Points of Contention
- Scope Questions: The case may raise questions about the scope of the term "computer." Does the functionality of the accused Atmel microcontroller, operating with its specific firmware, meet the requirements of a "computer configured to control said physical switch" as contemplated by the patents?
- Technical Questions: A central technical question will be the nature of the communication between the accused remote and master switches. What evidence does the complaint provide that the remote switch provides an "instruction...instructing said first computer to control said physical switch," as required by the claims, versus broadcasting a more general status change that the master switch independently decides how to act upon?
V. Key Claim Terms for Construction
The Term: "computer"
Context and Importance: This term is recited in the master switch limitations of the asserted independent claims. The definition of "computer" will be critical to determining if the accused microcontroller, which the complaint alleges is an Atmel SAM R21, meets this limitation (Compl. ¶23). Practitioners may focus on this term because its construction could either broadly cover any microprocessor or be limited to a device with more substantial processing capabilities, potentially affecting the infringement analysis.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a very broad definition, stating the term is "not intended to be limited to any specific type of computing device" and includes "processing devices, microprocessors, personal computers...hardware appliances," and other devices (’194 Patent, col. 7:31-45).
- Evidence for a Narrower Interpretation: The patent describes the "computer (121)" as part of a "specialized computer" that will "generally serve to control power flow" and "detects that the activation object (151) has been activated" (’194 Patent, col. 14:52-62). This could suggest the term requires the specific combination of functions described in the embodiments.
The Term: "instruction instructing said first computer to control said physical switch"
Context and Importance: This phrase defines the functional link between the remote and master switches and is central to the infringement theory. Whether the wireless signal sent by the accused remote switch (e.g., WNRL23) constitutes such an "instruction" will be a key point of dispute.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the system generally, stating the remote switch "transmits a received indication of state change to a master switch" which then "appropriately alter[s] the mechanical switches" (’194 Patent, col. 12:15-24). This could support a view that any signal causing the intended result is an "instruction."
- Evidence for a Narrower Interpretation: The specification notes that a "transmitted message format may include addresses of the specific network and the specific master switch (101) as well as the command instruction" (’194 Patent, col. 14:45-49). This may support an argument that a mere broadcast of a status change is insufficient, and a more specific, directed "command instruction" is required.
VI. Other Allegations
Indirect Infringement
The complaint alleges both inducement and contributory infringement. The inducement theory is based on allegations that Defendant instructs end-users, via materials on its website, to combine the master and remote switches in an infringing manner (Compl. ¶58). The contributory infringement theory is based on allegations that the master and remote switches are not staple articles of commerce and have no substantial non-infringing use, pointing to Defendant's own marketing that they should be "pair[ed]" for "easy 3-way control" (Compl. ¶¶48, 50).
Willful Infringement
Willfulness is alleged based on Defendant’s purported knowledge of the asserted patent family since June 2015, when Plaintiff allegedly provided Defendant with the patent application that would become the ’194 Patent (Compl. ¶36). The complaint details a series of meetings and technology demonstrations that allegedly occurred both before and after the ’194 patent issued, suggesting Defendant had extensive pre-suit notice (Compl. ¶¶34-44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: how broadly will the court construe the term "computer," and what specific properties must a wireless signal possess to qualify as an "instruction instructing" that computer? The outcome of these definitional disputes may significantly shape the infringement analysis.
- A key evidentiary question will be one of technical operation: what does discovery reveal about the precise software and communication protocol running on the accused Legrand products? The case will likely depend on evidence showing whether the remote switch's transmission functions as a direct command to the master switch’s processor, as required by the claims, or if the interaction is less direct.
- A third central question will concern state of mind: given the detailed allegations of a multi-year pre-suit relationship and disclosure of the patent application, the inquiry into willfulness will be a critical component of the case. The focus will be on what Defendant knew about Plaintiff's technology and when, and whether its subsequent actions were consistent with the standards of commercial conduct.