CAFC: Patent owner failed to show Amazon and Ring infringed smoke alarm patent claims
Judge Lourie authored the opinion. Judge Lourie authored the opinion.
Massoud Heidary sued Amazon, which owns home security company Ring, for infringement of his U.S. Patent 10,380,862, titled “Fire Protection System with Fan Shut Off, Including a Camera and a Display Unit,” in the United States District Court for the District of Maryland. Heidary claimed that Ring’s X-SENSE Wi-Fi Smoke Alarms and Aegislink Wi-Fi Smoke Alarms met “each and all limitations of claim 1 of ‘862 Patent”. Ring argued that Heidary had failed to prove that Ring had a place of business in Maryland, and Amazon and Ring argued that Heidary “did not plead sufficient facts to show that either accused product plausibly contained each and every limitation” of claim 1 of ‘862 Patent, and therefore there could be no direct infringement. The district court agreed and dismissed the complaint without prejudice.
Heidary first appealed to the U.S. Court of Appeals for the Fourth Circuit and the Fourth Circuit transferred the appeal to the Federal Circuit. The Federal Circuit first outright affirmed the district court’s dismissal for improper venue as “Heidary pleaded no facts and otherwise made no showing that Ring has a physical place of business in the District of Maryland,” which was required to prove that venue was proper.
Turning to infringement, the CAFC explained that a showing of direct patent infringement requires that one or more claims read on the accused device and that “each and every limitation set forth in a claim appear
in an accused product.” Here, said the opinion, “Heidary’s complaint does nothing more than list what Heidary contends are the limitations of his claim 1 and assert that Amazon ‘make
, sell
, use[s], offer[s] to sell, or import[s] in the United States products . . . that meet each and every limitation of claim 1.” Without factual allegations to prove why the claim is infringed, “[s]his is insufficient to state a plausible claim of patent infringement,” wrote the CAFC.[s]Additionally, the opinion quoted the district court’s finding that “there is a facially apparent disconnect between the ‘862 patent and the [s].” While Amazon/ Ring’s products consisted of only smoke detectors, Heidary’s patent covers a complete “fire protection system.” Since “a patent on a combination is a patent on the assembled or functioning whole, not on the separate parts,” the district court was correct to conclude that Amazon/ Ring’s products did not “plausibly consist of the complete invention of the asserted claims of the ‘862 patent.” The opinion further explained that Heidary’s submission of a screenshot of one of the accused products without any detailed reason the product infringes the claim failed to plead a claim for infringement:[t]”Although Heidary is not required to attach claim charts or allege how each limitation of a claim is infringed, Heidary must still ‘articulate why it is plausible that the accused product infringes the patent claim.’… In fact, the screenshot merely appears to show that one of the accused products is a standalone smoke detector device, which accounts for just one of the 13 limitations recited by claim 1 of the ‘862 patent.”
The CAFC thus ultimately affirmed the district court’s dismissal.[accused products]Image Source: Deposit Photos
Author: aa-w
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Eileen McDermott
Eileen McDermott, Editor-in Chief of IPWatchdog.com is a veteran IP and legal journalist. Eileen McDermott is a veteran IP journalist and has held editorial and management positions at
