DCT

2:21-cv-00115

Vivint v. ADT LLC Of Delaware

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:21-cv-00115, D. Utah, 03/08/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Utah because Defendant ADT maintains a regular and established physical place of business in West Valley City, Utah, and sells the accused smart home security systems to residents within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s smart home security systems, including ADT Pulse, ADT Control, and Blue by ADT, infringe five patents related to entity detection, localized security alerts, presence services for monitoring systems, and configurable security platforms that integrate disparate devices.
  • Technical Context: The dispute is in the competitive smart home security and automation market, where companies vie to offer integrated, intelligent, and user-friendly systems for monitoring and controlling homes.
  • Key Procedural History: The complaint notes that during the prosecution of a parent to the ’159 patent, the applicant amended claims to recite a camera and controller to overcome a patent-eligibility rejection. Additionally, an Inter Partes Review (IPR) certificate provided with the ’159 patent documents indicates that asserted claim 9, among others, was subsequently cancelled. A separate IPR certificate provided for the ’739 patent indicates that all claims of that patent, including asserted claim 8, were cancelled. These post-issuance proceedings may raise threshold questions regarding the viability of the infringement counts for the ’159 and ’739 patents.

Case Timeline

Date Event
2001-04-03 Priority Date for ’552 and ’769 Patents
2006-09-13 Priority Date for ’739 Patent
2011-06-07 ’739 Patent Issued
2013-03-05 ’552 Patent Issued
2013-03-15 Priority Date for ’262 Patent
2013-12-06 Priority Date for ’159 Patent
2014-04-15 ’769 Patent Issued
2016-05-24 ’262 Patent Issued
2019-06-18 ’159 Patent Issued
2021-02-25 Date of Alleged Knowledge (Initial Complaint Filing Date)
2022-03-08 Second Amended Complaint Filed

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

U.S. Patent No. 10,325,159 - "Entity detection"

  • Issued: June 18, 2019

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of conventional security systems, which could detect entry into an area (e.g., via an infrared beam) but could not discriminate between different types of entrants, such as a human versus an animal, or identify specific individuals (Compl. ¶21).
  • The Patented Solution: The invention uses camera data to implement a multi-step process. First, it detects an entity (human or animal) entering a predefined area. It then detects a specific feature of that entity (e.g., facial features) and compares that feature against a database of predefined features to recognize a specific, known individual or animal, subsequently generating a specific notification (Compl. ¶20, ¶22; ’159 Patent, Abstract). The system is designed to distinguish a known person from a stranger or a pet from an intruder, providing more intelligent alerts (’159 Patent, col. 10:45-56).
  • Technical Importance: This approach represents a shift from simple motion detection to specific entity recognition, enabling more sophisticated and less error-prone security monitoring.

Key Claims at a Glance

  • The complaint asserts at least independent claim 9 (Compl. ¶71).
  • Essential elements of Claim 9 (Apparatus) include:
    • A processor and memory with instructions to cause the apparatus to:
    • Detect an entity entering a predefined area based on camera data, where the entity is a human or an animal;
    • Detect a feature of the entity based on the camera data;
    • Compare the detected feature to predefined features in a database;
    • Match the detected feature to one of the predefined features;
    • Recognize the entity based on an image and the detected feature;
    • Determine an identifier assigned to the entity at a previous time based on the match; and
    • Generate a notification indicating the entity based on determining the identifier.
  • The complaint reserves the right to assert additional claims (Compl. ¶71).

U.S. Patent No. 9,349,262 - "Security system providing a localized humanly-perceivable alert for identifying a facility to emergency personnel"

  • Issued: May 24, 2016

The Invention Explained

  • Problem Addressed: Emergency responders often struggle to quickly locate the specific facility that generated an alarm, particularly at night or in multi-unit buildings where addresses may be poorly marked, losing critical time (’262 Patent, col. 1:45-56).
  • The Patented Solution: The invention provides a system where, upon an alarm, a message is sent to a remote monitoring service. After verifying the alarm and dispatching emergency personnel, the service sends a command back to the facility to activate a specific, humanly-perceivable indicator (e.g., flashing an exterior light) at or near the alarm's location, thereby guiding responders directly to the correct site (’262 Patent, Abstract; col. 2:1-12).
  • Technical Importance: This system aims to reduce emergency response times by creating an unambiguous visual beacon at the scene of an incident.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶83).
  • Essential elements of Claim 1 (System) include:
    • A sensor that generates an alarm condition message;
    • A control unit configured to:
      • Receive the alarm message and determine a location;
      • Send the message to a remote monitoring service that filters false alarms;
      • Receive a command from the remote service that identifies a specific light and includes an instruction to turn it on;
      • Execute the command to turn on the specified light; and
      • Receive a dispatch notification from the service indicating emergency personnel have been dispatched.
  • The complaint reserves the right to assert additional claims (Compl. ¶83).

U.S. Patent No. 7,956,739 - "Monitoring and entry system presence service"

  • Issued: June 7, 2011
  • Technology Synopsis: The patent describes repurposing a "presence service"—a software model conventionally used in applications like instant messaging to show user status (e.g., "online")—for use in a security context. The invention applies this model to a monitoring device (a "presentity," such as a doorbell camera) to notify a remote user (a "watcher") of an event and provide the user with interactive response options (Compl. ¶32-37).
  • Asserted Claims: At least independent claim 8 (Compl. ¶97).
  • Accused Features: The ADT Control video doorbell system, which sends a notification to a user's mobile device upon detecting motion or a button push, determines the user's location to filter notifications, and allows the user to activate the mobile application in response (Compl. ¶99, ¶100, ¶102).

U.S. Patent No. 8,700,769 - "System and method for providing configurable security monitoring utilizing an integrated information system"

  • Issued: April 15, 2014
  • Technology Synopsis: The patent addresses the challenge of integrating security monitoring devices from different manufacturers and of different types. It describes a system with a central server and a database of rules that can process a combination of inputs from disparate devices and execute an "integrated system response," thereby improving on conventional systems that relied on human interpretation of standalone devices (Compl. ¶42-43, ¶49-50).
  • Asserted Claims: At least independent claim 13 (Compl. ¶111).
  • Accused Features: The accused ADT systems are configurable by users to define rules (allegedly corresponding to asset, resource, and device rules) that are based on data from specified device sources and trigger automated actions (Compl. ¶115, ¶117).

U.S. Patent No. 8,392,552 - "System and method for providing configurable security monitoring utilizing an integrated information system"

  • Issued: March 5, 2013
  • Technology Synopsis: This patent is a parent to the ’769 patent and shares the same specification (Compl. ¶41). It is likewise directed to an improved security network architecture that uses a rules-based system to integrate various types of monitoring devices, reduce dependency on human control, and enable flexible, automated responses to complex events based on combined inputs (Compl. ¶47-50).
  • Asserted Claims: At least independent claim 11 (Compl. ¶128).
  • Accused Features: The accused ADT systems' ability for users to define rules based on categorized data from various device sources (e.g., locks, sensors, cameras) to automate system functions (Compl. ¶130, ¶132-133).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are ADT’s "Pulse," "Control," and "Blue by ADT" smart home security systems (collectively, the "Accused Systems") (Compl. ¶12).

Functionality and Market Context

The Accused Systems are platforms sold with a suite of smart home devices, including cameras, video doorbells, thermostats, lights, door locks, and various sensors (Compl. ¶61). These systems allow customers, via a website or smartphone application, to manage their devices and configure automation and notification rules (Compl. ¶61). The complaint highlights specific functionalities, including facial recognition features in the Blue system, the ability to automate lights in response to alarm events in the Control system, and the use of geo-fencing to filter notifications from video doorbells (Compl. ¶73, ¶88, ¶100). The complaint includes a screenshot from the ADT Blue website showing its compatibility with various smart home automation standards like Z-Wave, Amazon Alexa, and IFTTT (Compl. ¶62).

IV. Analysis of Infringement Allegations

’159 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
detect an entity entering a predefined area based at least in part on camera data, wherein the entity includes a human or an animal The complaint does not provide sufficient detail for analysis of this specific element. — col. 10:45-50
detect a feature of the entity based at least in part on the camera data ADT’s Blue system cameras and video doorbells detect facial features of humans from the camera data they capture (Compl. ¶74). ¶74 col. 10:51-53
compare the detected feature to one or more predefined features stored in a database The ADT Blue system includes a "Facial Recognition Library" that stores photos of users, which serves as the database of predefined features (Compl. ¶75). ¶75 col. 10:54-56
match the detected feature to one or more of the predefined features The Blue system, with its cameras, compares and matches the detected facial features to the features of users stored in its database (Compl. ¶76). ¶76 col. 10:57-59
recognize the entity based at least in part on an image of the entity captured by a camera and the detected feature Upon recognizing a user's face, the Blue system performs the next step of generating a notification (Compl. ¶77). The screenshot of the "Facial Recognition Library" UI confirms the system's recognition capability (Compl. ¶75). ¶77 col. 10:60-63
determine an identifier assigned to the entity based at least in part on matching... wherein the identifier was assigned... at a previous time The system generates a notification that a specific user has been recognized, implying it uses an identifier associated with the matched facial features from a previous enrollment (Compl. ¶77). ¶77 col. 10:64-67
generate a notification indicating the entity based at least in part on determining the identifier Upon recognition, the Blue system generates and delivers a notification to a user's device, such as a smartphone, indicating that a specific user has been recognized (Compl. ¶77). ¶77 col. 11:1-3

Identified Points of Contention (’159 Patent)

  • Scope Questions: A central question may be the interpretation of the sequence of operations. The claim recites detecting entry into a "predefined area" before detecting and matching a feature. It is unclear from the complaint whether the accused system uses a predefined area as a trigger for facial recognition, or if it performs facial recognition on any entity within its general field of view.
  • Technical Questions: What evidence does the complaint provide that the accused system's facial recognition process is initiated by an entity crossing a specific, predefined boundary, as distinct from general motion detection?

’262 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a sensor... configured to generate an alarm condition message in response to an alarm condition The ADT Control system includes sensors that, when the panel is armed, detect an alarm event and generate an alarm condition message (Compl. ¶84-85). ¶84, ¶85 col. 12:4-6
a control unit configured to... receive the alarm condition message... determine a location... and send the alarm condition message to a remote monitoring service, wherein the remote monitoring service filters out false alarms Upon detection of an alarm event, the system's panel sends a message with the alarm condition to a remote server or backend (Compl. ¶86). The user is then provided a notification to cancel or verify the alarm, which serves to filter false alarms (Compl. ¶87). ¶86, ¶87 col. 12:12-25
receive a command from the remote monitoring service, the command identifying a specific light... and including an instruction to turn on the specified light The user can set up a rule to turn on a specific light upon an alarm (Compl. ¶88). Upon detection of the alarm, the backend sends a command to the panel to execute that rule. A provided screenshot shows the UI for creating this rule-based command (Compl. ¶88). ¶88 col. 13:26-32
execute the command from the remote monitoring service to turn on the specified light Upon receiving the command from the backend, the panel executes the specific rule to turn on the light (Compl. ¶88). ¶88 col. 13:33-35
receive, from the remote monitoring service, a dispatch notification indicating that emergency personnel are dispatched to the premises On information and belief, the Control system may receive a notification indicating the dispatch of emergency personnel from the backend (Compl. ¶89). ¶89 col. 12:26-28

Identified Points of Contention (’262 Patent)

  • Scope Questions: Does the combination of ADT's automated "backend" server and a user-preconfigured "rule" meet the claim limitation of "receiving a command from the remote monitoring service"? The defense may argue this is a pre-programmed, local action rather than a dynamic command received from a remote service post-alarm.
  • Technical Questions: What is the nature of the "remote monitoring service"? The complaint alleges a "remote server or backend" (Compl. ¶86), but the patent specification discusses the service being staffed by human "security representatives" (’262 Patent, col. 12:29-32). Whether a fully automated system meets this definition may be a key point of dispute.

V. Key Claim Terms for Construction

’159 Patent (Claim 9)

  • The Term: "predefined area"
  • Context and Importance: The claim requires the system to first "detect an entity entering a predefined area." The viability of the infringement theory may depend on whether this requires a geographically defined zone that acts as a trigger for the subsequent recognition steps, or if it can be interpreted more broadly as the camera's general field of view.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides broad examples of what a predefined area could be, including "a parking lot," "a shop," or "a home" (’159 Patent, col. 12:60-65), which could suggest a general location rather than a precise boundary.
    • Evidence for a Narrower Interpretation: The figures and associated description depict an entity crossing a distinct perimeter or boundary, suggesting a specific, delineated zone is contemplated (’159 Patent, Fig. 3-4, col. 11:7-13). The term itself implies some level of prior definition or boundary setting.

’262 Patent (Claim 1)

  • The Term: "remote monitoring service"
  • Context and Importance: This term is central as it is the entity required to filter alarms, dispatch personnel, and issue the command to activate the light. The dispute will likely focus on whether ADT's automated backend, potentially combined with user interaction via an app, constitutes this "service."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines the "remote monitoring service" functionally by what it does (e.g., "filters out false alarms") without explicitly requiring human operators (’262 Patent, col. 14:14-15). Plaintiff may argue that any system, automated or not, that performs these functions meets the claim definition.
    • Evidence for a Narrower Interpretation: The detailed description states that in the described embodiments, "human beings continue to play a role because that service is staffed by human beings, referred to as 'security representatives'" (’262 Patent, col. 12:29-32). Defendant may argue this language limits the scope of the term to a human-staffed call center.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges ADT induces infringement by advertising and instructing users on how to configure and use the accused features. For the ’159 patent, it cites ADT’s website advertising "Facial recognition" (Compl. ¶80). For the ’262 patent, it provides a screenshot of the user interface that allows users to create a rule to turn on a light in response to an alarm (Compl. ¶88). Similar allegations supported by screenshots of user interfaces are made for the other asserted patents (Compl. ¶106, ¶123, ¶140).
  • Willful Infringement: The complaint alleges willful infringement based on ADT’s knowledge of the Asserted Patents since at least February 25, 2021, the filing date of the original complaint in the case (Compl. ¶65, ¶67). The willfulness claim is therefore based on alleged post-suit conduct.

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

This case presents several critical questions for the court, spanning procedural viability, claim scope, and technical operation.

  • A primary issue will be one of procedural viability: Given that the provided patent documents include IPR certificates indicating that the specifically asserted claim of the ’159 patent and all claims of the ’739 patent have been cancelled, a threshold question will be whether the infringement counts related to these two patents can proceed.
  • A second core issue will be one of definitional scope: Can the term "remote monitoring service" from the ’262 patent, which the specification describes as being staffed by humans, be construed to cover ADT's largely automated backend servers that execute user-preconfigured rules?
  • Finally, a key evidentiary question will be one of functional operation: For the ’552 and ’769 patents, does ADT’s system for creating user-defined rules for individual devices meet the claimed requirements for a system that processes combined inputs from different types of devices according to distinct types of rules (asset, resource, and device), or is there a fundamental mismatch in the level of integration and logic claimed versus that which is practiced?