DCT
2:22-cv-00428
SmarterHome v. Designer Furniture Warehouse
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hall Labs, LLC, and SmarterHome, Inc. (Utah)
- Defendant: Hunter Douglas N.V. (Curaçao), Hunter Douglas Industries B.V. (Netherlands), Hunter Douglas Inc. (Delaware), and numerous other related entities.
- Plaintiff’s Counsel: Wasatch-IP, A Professional Corp.
- Case Identification: 2:22-cv-00428, D. Utah, 06/27/2022
- Venue Allegations: Venue is alleged based on the U.S. and Utah-based defendants committing acts of infringement and having regular and established places of business within the District of Utah. For foreign defendants, venue is based on their non-residency in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s tool-free window covering installation systems and wireless hub-based control systems infringe patents related to lever-actuated compression mounting and low-power wireless network architectures for smart blinds.
- Technical Context: The lawsuit concerns the smart home market, specifically automated window coverings, where ease of installation and efficient power management for wireless control are significant areas of technical development.
- Key Procedural History: The complaint alleges that certain defendants received a cease-and-desist letter regarding the ’722 patent on September 21, 2021, a fact which may be relevant to the claim of willful infringement for that patent. For the remaining patents, notice is alleged as of the filing of the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2016-03-17 | ’722 Patent Priority Date |
| 2017-05-10 | ’449 Patent Priority Date |
| 2017-06-06 | ’722 Patent Issue Date |
| 2017-10-20 | ’668 Patent Priority Date |
| 2019-10-29 | ’449 Patent Issue Date |
| 2020-04-21 | ’668 Patent Issue Date |
| 2021-09-21 | Cease-and-desist letter regarding ’722 Patent sent |
| 2022-06-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,670,722 - "Lever Arm Assembly for a Window Covering"
- Patent Identification: U.S. Patent No. 9,670,722, entitled "Lever Arm Assembly for a Window Covering," issued on June 6, 2017.
The Invention Explained
- Problem Addressed: The patent seeks to solve problems with conventional window covering installation, which can require tools, precise measurements, and may leave unsightly holes or damage to the window casing. Existing spring-loaded alternatives may generate insufficient force to securely hold heavy window coverings (US 9,670,722, col. 1:12-39).
- The Patented Solution: The invention is an extensible end cap for a window covering's headrail that uses a lever-actuated crankshaft mechanism. When a user rotates the lever, the crankshaft translates a moveable portion of the end cap outward, creating a strong and secure compression fit against the inside of the window casing without the need for tools, screws, or other fasteners (US 9,670,722, Abstract; col. 2:50-67).
- Technical Importance: This approach provides a robust, tool-free installation method that aims to be more secure than spring-based systems while avoiding the permanent modifications associated with traditional screw-in brackets (US 9,670,722, col. 1:40-47).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶54). The right to assert additional claims is reserved (Compl. ¶57).
- Essential elements of independent claim 1 include:
- A headrail.
- A stationary portion that attaches to an end of the headrail.
- A moveable portion that contacts an inside of a window casing.
- A first crankshaft member that, upon rotation, translates the moveable portion.
- A second crankshaft member that also translates the moveable portion, with its rotational axis being offset from the first crankshaft member's axis.
- A lever arm attached to the first crankshaft member to enable rotation.
U.S. Patent No. 10,458,449 - "Compression Adjustment Mechanism for Headrail"
- Patent Identification: U.S. Patent No. 10,458,449, entitled "Compression Adjustment Mechanism for Headrail," issued on October 29, 2019.
The Invention Explained
- Problem Addressed: The patent addresses the difficulty of achieving an optimal compression fit for tool-less window coverings, as window casing dimensions can vary. Insufficient compression can cause the covering to fall, while excessive compression can make installation difficult or damage the window frame ('449 Patent, col. 1:29-46).
- The Patented Solution: The invention provides an end cap assembly with a rotational cam mechanism that includes adjustable "nesting spacers" (or shims) to modify the headrail's effective length. Critically, it includes a system of alignment indicators that provide visual feedback to the user, signaling whether the compression level is too low ("increase shim"), acceptable ("good"), or too high ("reduce shim") ('449 Patent, Abstract; col. 2:11-25; Fig. 3B).
- Technical Importance: This invention introduces a user-friendly feedback system to the tool-free installation process, allowing a user to precisely adjust and confirm the correct amount of compression for a secure and safe fit without guesswork ('449 Patent, col. 1:41-55).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶60). The right to assert additional claims is reserved (Compl. ¶63).
- Essential elements of independent claim 1 include:
- One or more end cap assemblies attached to a headrail.
- One or more rotational members that extend one or more pistons upon rotation.
- One or more nesting spacers to adjust the headrail length.
- A first alignment indicator for a "low compression state."
- A second alignment indicator for a "medium compression range."
- A third alignment indicator for a "high compression state."
U.S. Patent No. 10,626,668 - "Low Power Hub Wireless Control of Motorized Window Coverings"
- Patent Identification: U.S. Patent No. 10,626,668, entitled "Low Power Hub Wireless Control of Motorized Window Coverings," issued on April 21, 2020.
- Technology Synopsis: This patent describes a system architecture for wirelessly controlling motorized window coverings designed to conserve power. It utilizes a hub that acts as a gateway, receiving commands from a user's mobile device over a higher-power local area network (LAN), such as Wi-Fi, and then relaying those commands to the window coverings using a lower-power personal area network (PAN), such as Bluetooth. This division of communication protocols aims to reduce the power load on the battery-operated window coverings ('668 Patent, Abstract; col. 2:14-35).
- Asserted Claims: The complaint asserts "one or more claims" of the ’668 patent without specifying any particular claims (Compl. ¶65).
- Accused Features: The infringement allegations target the "Hunter Douglas PowerView® Hub" (Gen 2 and Gen 3) and "Otto Wi-Fi Bridge" systems, which are alleged to function as gateways for wirelessly controlling motorized window coverings (Compl. ¶¶ 49, 50, 65).
III. The Accused Instrumentality
Product Identification
The complaint identifies two categories of accused instrumentalities:
- The "Select Blinds No-Tools Headrail" system (the "Headrail Products") (Compl. ¶¶ 47, 53).
- The "Hunter Douglas PowerView® Hub" (Gen 2 and Gen 3) and the "Otto Wi-Fi Bridge" systems (the "Hub Products") (Compl. ¶¶ 49, 50, 65).
Functionality and Market Context
- The complaint alleges the Headrail Products are window coverings designed to be installed without the use of tools, leveraging a compression-fit mechanism (Compl. ¶¶ 34, 47). These products are marketed toward the do-it-yourself (DIY) and direct-to-consumer (DTC) markets (Compl. ¶47).
- The Hub Products are alleged to be systems for wirelessly controlling motorized window coverings (Compl. ¶¶ 49-50). The complaint asserts these systems use a hub device that connects to a local area network (LAN) and a personal area network (PAN) to manage communication between a user's device and the window coverings (Compl. ¶42).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges infringement but does not provide the referenced claim chart exhibits. The following tables are constructed based on the narrative allegations in the complaint and the language of the asserted patents. The complaint does not provide specific details on the inner workings of the accused products; it makes general allegations that the products infringe.
U.S. Patent No. 9,670,722 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a headrail; a stationary portion that attaches to an end of the headrail...; a moveable portion that contacts an inside of a window casing | The complaint alleges that the Select Blinds No-Tools Headrail system is a window covering with a headrail that includes components for tool-free installation. | ¶53 | col. 2:50-54 |
| a first crankshaft member that, upon rotation, translates the moveable portion...; a second crankshaft member... wherein a rotational axis of the first crankshaft member is offset from a rotational axis of the second crankshaft member | The complaint alleges the No-Tools Headrail system infringes claim 1, which requires this specific offset dual crankshaft mechanism to create a compression fit. | ¶53, ¶54 | col. 2:59-67 |
| a lever arm attached to the first crankshaft member | The complaint alleges infringement of claims requiring a lever arm assembly for a window covering. | ¶33, ¶54 | col. 2:60-62 |
U.S. Patent No. 10,458,449 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| one or more end cap assemblies attached to one or more ends of the headrail...; one or more rotational members to, upon rotation, extend one or more pistons | The complaint alleges the Select Blinds No-Tools Headrail system infringes claim 1, which requires end cap assemblies with rotational members to extend pistons. | ¶59, ¶60 | col. 2:2-10 |
| one or more nesting spacers residing within the one or more end cap assemblies allowing adjustment of headrail length | The complaint's infringement allegation for claim 1 suggests the No-Tools Headrail system contains a mechanism for adjusting the compression fit. | ¶59, ¶60 | col. 2:11-15 |
| a first alignment indicator... low compression state; a second alignment indicator... medium compression range; and a third alignment indicator... high compression state | The complaint's infringement allegation for claim 1 suggests the No-Tools Headrail system provides feedback on the compression state. | ¶59, ¶60 | col. 2:16-29 |
- Identified Points of Contention:
- Factual Questions: A central point of contention for the ’722 and ’449 patents will be factual. The complaint does not describe the specific mechanics of the accused No-Tools Headrail. Discovery will be required to determine if its internal structure corresponds to the claimed offset crankshaft mechanism ('722 Patent) or the claimed system of adjustable spacers and multi-state alignment indicators ('449 Patent).
- Technical Questions: For the ’668 Patent, the dispute may focus on whether the accused Hub Products' network architecture (bridging a LAN and a PAN) operates in the same way and for the same power-saving purpose as the claimed invention, or if there are material differences in the protocol, gateway function, or overall system operation.
V. Key Claim Terms for Construction
- Term from ’722 Patent: "crankshaft member"
- Context and Importance: This term defines the core mechanical element of the invention. The infringement analysis will depend on whether the accused product's mechanism, if any, for extending the end cap qualifies as a "crankshaft member" with an offset rotational axis, which is a key limitation of claim 1.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue for the term's plain and ordinary meaning to a person of ordinary skill in the art of mechanical devices, as the specification does not provide an explicit definition.
- Evidence for a Narrower Interpretation: The specification consistently depicts the crankshaft as an eccentric cam-like structure with offset axes (e.g., '722 Patent, Fig. 7, elements 708, 710). A party may argue the term should be limited to the disclosed embodiments, where rotation directly translates a member via an offset pin.
- Term from ’449 Patent: "alignment indicator"
- Context and Importance: This term is central to the user-feedback aspect of the invention. The case may turn on whether any feedback provided by the accused product constitutes an "indicator" that signals three distinct compression states as required by claim 1.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification mentions that the indicators could be "unique audible indicator[s]" ('449 Patent, col. 2:58), suggesting the term is not limited to visual cues. A party could argue that any system providing distinct feedback (visual, audible, or tactile) for different compression levels meets the limitation.
- Evidence for a Narrower Interpretation: The primary embodiment shows a specific visual system where the edge of an end cap assembly progressively obscures words ("increase shim," "good," "reduce shim") to indicate the compression state ('449 Patent, col. 5:35-54; Figs. 3B-3C). A party may argue that "alignment indicator" requires this type of explicit, multi-state visual feedback system.
VI. Other Allegations
- Indirect Infringement:
- The complaint alleges induced infringement for all three patents, asserting that Defendants provide the accused products along with instructions, promotional literature, and technical support that encourage and facilitate infringing use by end-users and dealers (Compl. ¶¶ 55, 61, 67).
- The complaint also alleges contributory infringement for all three patents, based on Defendants allegedly providing designs for and facilitating the manufacture of components that are a material part of the inventions and not suitable for substantial non-infringing use (Compl. ¶¶ 56, 62, 68).
- Willful Infringement:
- For the ’722 patent, willfulness is alleged based on pre-suit knowledge stemming from a cease-and-desist letter sent on September 21, 2021 (Compl. ¶55).
- For the ’449 and ’668 patents, willfulness is alleged based on knowledge acquired "at least upon the receipt [of] this Complaint," which supports a claim for post-suit willfulness (Compl. ¶¶ 61, 67).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue for the ’722 and ’449 patents will be one of structural correspondence: does the accused "No-Tools Headrail" product, once examined in discovery, contain the specific lever-actuated, offset-crankshaft mechanism and/or the multi-state visual compression indicator system required by the respective claims, or does it achieve a tool-free installation via a distinct, non-infringing mechanical design?
- A key evidentiary question for the ’668 patent will be one of architectural equivalence: does the accused PowerView® and Otto hub-based system perform the same function (bridging a LAN and a PAN) in substantially the same way (as a power-saving gateway) to achieve the same result as the claimed system, or are there fundamental differences in its network topology and operation?
- A primary legal question regarding damages will be the effect of the alleged pre-suit notice for the ’722 patent. The court will have to determine if the September 2021 cease-and-desist letter was sufficient to make any continued infringement by the defendants an "egregious case of misconduct beyond typical infringement," potentially justifying enhanced damages.