On February 9, 2022, the Commission issued a notice of its final determination of a violation of section 337 and issuance of a limited exclusion order ("LEO") and cease-and-desist order ("CDO") in Certain Movable Barrier Operator Systems and Components Thereof (Inv. No. 337-TA-1209).
By way of background, this investigation was instituted on August 10, 2020 based on a complaint by Overhead Door Corporation of Lewisville, Texas and GMI Holdings Inc. of Mount Hope, Ohio (collectively, "Complainants") alleging violations of section 337 by Respondent The Chamberlain Group, Inc. of Oak Brook, Illinois ("Chamberlain") and seeking an LEO and CDO due to the infringement of U.S. Patent Nos. 8,970,345 ("the '345 patent"); 7,173,516 ("the '516 patent"); 7,180,260 ("the '260 patent"); U.S. Patent No. 9,483,935 ("the '935 patent"); U.S. Patent No. 7,956,718 ("the '718 patent"); and U.S. Patent No. 8,410,895 ("the '895 patent"). The asserted patents relate generally to remotely controlled barrier operator systems for opening and closing garage doors, gates, and other barriers. The accused products are the LiftMaster, Chamberlain, Raynor, and Craftsman brand garage door systems that include barrier operators, garage door operators, commercial barrier operators, and gate operators that include a transmitter and receiver. On October 13, 2021, ALJ David P. Shaw issued a final initial determination ("FID") finding that (1) the asserted claims of all five patents-in-suit are infringed by Chamberlain's accused products and redesigned products; (2) the domestic industry products practice the asserted patents; and (3) the asserted patents are not invalid under 35 U.S.C. §§ 101, 102, or 103. The ALJ also issued a recommended determination ("RD") recommending that the Commission issue an LEO and CDO. See our October 26, 2021 post for more details regarding the FID/RD.
According to the notice, the Commission (1) affirmed with modification the FID's infringement findings as to asserted claims of the '935 patent; (2) reversed the FID's infringement findings as to the asserted claims of the '345 patent; (3) affirmed with modification the FID's validity findings as to the asserted claims of the '935 and '345 patents over the prior art Keller reference; (4) reversed the FID's infringement findings as to the asserted claims of the '260 patent; (5) vacated and took no position as to the FID's finding that the asserted claims of the '260 patent are patent-eligible under § 101; (6) affirmed with modification the FID's infringement findings as to the asserted claims of the '718 and '895 patents; and (7) affirmed with modification the FID's finding that the asserted claims of the '718 and '895 patents are patent-eligible under § 101. The Commission also issued an LEO and CDO against Chamberlain.
We will post the public version of the Commission's opinion when it becomes available.
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