United States District Court, D. Delaware
ALARM.COM, INC. and ICN ACQUISITION, LLC, Plaintiffs;
SECURENET TECHNOLOGIES, LLC, Defendant.
Kenneth Dorsney, MORRIS JAMES LLP, Wilmington, DE; Ian R.
Liston, WILSON SONSINI GOODRICH & ROSATI, P.C.,
Wilmington, DE; James C. Yoon, Ryan R. Smith, Christopher D.
Mays, and Mary A. Procaccio-Flowers, WILSON SONSINI GOODRICH
& ROSATI, P.C., Palo Alto, CA, attorneys for Plaintiffs.
B. Blumenfeld and Stephen J. Kraftschik, MORRIS, NICHOLS,
ARSHT & TUNNEL LLP, Wilmington, DE; Erik B. Milch, Frank
Pietrantonio, and Dustin Knight, COOLEY LLP, Reston, VA; Rose
Whelan, Lisa Fuller Schweir, and Naina Soni, COOLEY LLP,
Washington, D.C., attorneys for Defendant.
ANDREWS, U.S. DISTRICT JUDGE
pending before the Court is Plaintiffs' Motion for New
Trial and Renewed Judgment as a Matter of Law. (D.I. 283).
The Parties' have fully briefed the issues. (D.I. 284,
287, 291). For the following reasons, I deny Plaintiffs'
Alarm.com, Inc. and ICN Acquisition LLC brought suit against
Defendant SecureNet Technologies LLC alleging infringement of
U.S. Patent Nos. 7, 855, 635 ("the '635
patent"), 8, 473, 619 ("the '619 patent"),
8, 478, 844 ("the '844 patent"), and 8, 073,
931 ("the '931 patent"). Before trial,
Plaintiffs narrowed their infringement contentions to allege
infringement (both direct and indirect) of claims 1 and 9 of
the '931 patent, claims 1 and 55 of the '619 patent,
and claim 48 of the '844 patent ("the asserted
patents"). Defendant asserted invalidity based on
obviousness for claims 1 and 9 of the '931 patent.
trial, I granted JMOL of no infringement for any asserted
claim under the Doctrine of Equivalents. (D.I. 277). At
trial, the jury found the following: 1) Plaintiffs did not
prove direct, induced or contributory infringement for any of
the asserted claims, and 2) Defendant did not prove
invalidity of the '931 patent claims. (D.I. 270).
now move for a new trial or JMOL of infringement on the
asserted claims of the '619 and '931 patent.
Plaintiffs do not challenge the jury's finding on the
'844 patent. Plaintiffs' motion asserts that the jury
was exposed to numerous erroneous claim constructions. I have
included the relevant claim language below, with the disputed
claim language italicized.
asserted claims of the '619 patent read as follows:
a gateway located at a first location;
a connection management component coupled to the
gateway and automatically establishing a wireless
coupling with a security system installed at the first
location, the security system including security system
components, wherein the connection management
component forms a security network by automatically
discovering the security system components and
integrating communications and functions of the security
system components into the security network; and
a security server at a second location different from the
first location, wherein the security server is coupled to the
gateway, wherein the gateway receives security data from the
security system components, device data of a plurality of
network devices coupled to a local network of the first
location that is independent of the security network, and
remote data from the security server, wherein the gateway
generates processed data by processing at the gateway the
security data, the device data, and the remote data, wherein
the gateway determines a state change of the security system
using the processed data and maintains objects at the
security server using the processed data, wherein the objects
correspond to the security system components and the
plurality of network devices.
55. The system of claim 1, wherein the security server
generates and transfers notifications to remote client
devices, the notifications comprising event data.
('619 patent, els. 1, 55) (disputed claim terms
italicized). The asserted claims of the '931 patent read
a touchscreen at a first location, wherein the
touchscreen includes a processor coupled to a local
area network (LAN) and a security system at the first
a plurality of interfaces presented by at least one
application executing on the processor of the
touchscreen and presented to a user via the
touchscreen, wherein the plurality of interfaces
include a security interface and a network interface, wherein
the security interface provides the user with control of
functions of the security system and access to data collected
by the security system, wherein the network interface allows
the user to transfer content to and from a wide area network
(WAN) coupled to the LAN; and
a remote server at a second location, wherein the remote
server is coupled to the touchscreen, the remote
server managing at least one of the touchscreen and
the security system, wherein objects are maintained on the
remote server that correspond to at least one of at least one
security system component of the security system and at least
one network device of the LAN.
9. The device of claim 7, wherein the camera is managed by
the remote server.
('931 patent, els. 1, 9) (disputed claim term
Rule of Civil Procedure 59(a)(1)(A) provides, in pertinent
part: "The court may, on motion, grant a new trial on
all or some of the issues-and to any party- .. . after a jury
trial, for any reason for which a new trial has heretofore
been granted in an action at law in federal court . . .
." Among the most common reasons for granting a new
trial are: (1) the jury's verdict is against the clear
weight of the evidence, and a new trial must be granted to
prevent a miscarriage of justice; (2) newly discovered
evidence exists that would likely alter the outcome of the
trial; (3) improper conduct by an attorney or the court
unfairly influenced the verdict; or (4) the jury's
verdict was facially inconsistent. See Zarow-Smith v.
N.J. Transit Rail Operations, Inc., 953 F.Supp. 581,
584-85 (D.N.J. 1997).
decision to grant or deny a new trial is committed to the
sound discretion of the district court. See Allied Chem.
Corp. v. Daiflon, Inc.,449 U.S. 33, 36 (1980);
Olefins Trading, Inc. v. Han Yang Chem. Corp., 9
F.3d 282, 289 (3d Cir. 1993) (reviewing district court's
grant or denial of new trial motion under the "abuse of
discretion" standard). Although the standard for
granting a new trial is less rigorous than the standard for
granting judgment as a matter of law-in that the Court need
not view the evidence in the light most favorable to the
verdict winner-a new trial should only be granted where
"a miscarriage of justice would result if the verdict