Zest Labs Inc v. Carrier Global Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Zest Labs, Inc. f/k/a Intelleflex Corporation (Nevada)
  • Defendant: Carrier Global Corporation (Delaware)
  • Plaintiff's Counsel: Potter Anderson & Corroon LLP
• Case Identification: 1:26-cv-00787, D. Del., 07/02/2026
• Venue Allegations: Venue is asserted in the District of Delaware based on Defendant Carrier Global Corporation being incorporated in the State of Delaware.
• Core Dispute: Plaintiff alleges that Defendant's Lynx Fleet telematics platform and associated refrigeration control systems infringe six patents related to actively managed cold-chain logistics.
• Technical Context: The technology involves cloud-connected systems for real-time monitoring of perishable goods in transit, comparing environmental conditions to product-specific profiles, and issuing corrective commands to prevent spoilage.
• Key Procedural History: The complaint alleges that Defendant had knowledge of the patent family since at least April 2020, when Defendant cited a publication that issued as the lead patent-in-suit in an Information Disclosure Statement (IDS) during the prosecution of its own patent. This allegation forms the primary basis for the claim of willful infringement.

Case Timeline

Date	Event
2015-03-30	Earliest Priority Date for all Patents-in-Suit
2019-09-24	U.S. Patent No. 10,423,918 Issued
2019-10-15	U.S. Patent No. 10,445,684 Issued
2020-04-03	Carrier files IDS citing Zest's patent publication
2021-06-15	U.S. Patent No. 11,037,092 Issued
2021-06-15	U.S. Patent No. 11,037,093 Issued
2021-06-15	U.S. Patent No. 11,037,094 Issued
2023-01-01	Alleged start of infringing deployment across Carrier's manufacturing line
2024-06-11	U.S. Patent No. 12,008,509 Issued
2026-07-02	Complaint Filed

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

U.S. Patent No. 10,445,684 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 10,445,684 ("the '684 Patent"), titled "Actively managed food delivery," issued on October 15, 2019.

The Invention Explained

• Problem Addressed: The patent's background section describes the challenge of shipping perishable products, where mishandling is often not visually apparent and data collected during transit is typically unusable until after delivery, by which time spoilage may have already occurred (Compl. ¶12; Compl. ¶13, Compl. ¶¶col. 5:35-60).
• The Patented Solution: The invention proposes a centralized system that solves this problem by associating a product container with a product-specific profile, monitoring its environmental conditions in real-time, and sending a command to initiate corrective action if conditions deviate from a preferred range Compl. ¶14 '684 Patent, abstract '684 Patent, col. 5:61-6:11 This allows for intervention before spoilage occurs.
• Technical Importance: This technology represented a shift from passive refrigeration, which maintained fixed temperature setpoints, to an active, dynamically managed system that responds to the specific needs of the cargo in real-time Compl. ¶1

Key Claims at a Glance

• The complaint asserts infringement of at least exemplary claim 1 of the '684 Patent Compl. ¶27
• Independent claim 1 of the '684 Patent is a method claim with the following essential elements:
  • Receiving status information from one or more product containers, including conditions of each.
  • Determining preferred ranges for the conditions based on a product stored in each container.
  • Determining whether the received conditions are within the preferred ranges.
  • Sending a command in response to determining a condition is outside the preferred range.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringing "one or more claims" Compl. ¶42

U.S. Patent No. 10,423,918 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 10,423,918 ("the '918 Patent"), titled "Actively managed food delivery," issued on September 24, 2019.

The Invention Explained

• Problem Addressed: Similar to the '684 Patent, the '918 Patent addresses the problem of product spoilage in complex supply chains where real-time condition monitoring and control are lacking, making it difficult to know if a product has surpassed its tolerance until after delivery is complete Compl. ¶13 '918 Patent, col. 1:26-45
• The Patented Solution: The '918 Patent describes a computer-implemented method where a central system determines preferred environmental ranges for products, which notably "change over time by a predefined amount per unit time." The system compares real-time conditions against these dynamic ranges and sends commands to correct deviations. It further claims using food product history to create prioritized delivery schemes '918 Patent, abstract '918 Patent, col. 1:46-2:16
• Technical Importance: This patent adds a layer of sophistication by introducing dynamic, time-varying profiles and logistics prioritization, allowing for more precise control and efficient routing based on product freshness Compl. ¶1

Key Claims at a Glance

• The complaint asserts infringement of at least exemplary claim 1 of the '918 Patent Compl. ¶27
• Independent claim 1 of the '918 Patent is a method claim with the following essential elements:
  • Receiving status information about product containers.
  • Determining preferred ranges for conditions, where the ranges "change over time by a predefined amount per unit time" specified in a product profile.
  • Determining if received conditions are within the preferred ranges.
  • Sending a first command to adjust an environmental control unit if conditions are outside the range.
  • Analyzing food product history.
  • Using the history to determine a "prioritized delivery scheme" (e.g., prioritizing delivery of the product with the longest time since preparation).
  • Sending the prioritized delivery scheme to an individual or system.
  • Evaluating the product history to determine if products are unsafe and sending a second command to not deliver them if they are.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringing "one or more claims" Compl. ¶61

U.S. Patent No. 11,037,092 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 11,037,092 ("the '092 Patent"), titled "Actively managed food delivery," issued on June 15, 2021 Compl. ¶17
• Technology Synopsis: The patent describes a method for actively managing food delivery where a product container is pre-loaded with a profile (e.g., for pre-heating/cooling) and autonomously maintains environmental parameters based on that profile. The system is capable of modifying a prioritized delivery scheme based on real-time conditions and food product history '092 Patent, abstract '092 Patent, claim 1
• Asserted Claims: At least exemplary claim 1 Compl. ¶81
• Accused Features: The complaint alleges that Carrier's Accused Instrumentalities, as a whole, perform the patented methods Compl. ¶80

U.S. Patent No. 11,037,093 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 11,037,093 ("the '093 Patent"), titled "Actively managed food delivery," issued on June 15, 2021 Compl. ¶18
• Technology Synopsis: The patent describes a method for managing food delivery by receiving a food product history for products in multiple containers, using that history to determine a prioritized delivery scheme, and sending that scheme to a dispatcher or transporter. The history includes data such as expiration date, storage time, and temperature history, and is used to evaluate a freshness metric '093 Patent, abstract '093 Patent, claim 1
• Asserted Claims: At least exemplary claim 1 Compl. ¶100
• Accused Features: The complaint alleges that Carrier's Accused Instrumentalities, as a whole, perform the patented methods Compl. ¶99

U.S. Patent No. 11,037,094 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 11,037,094 ("the '094 Patent"), titled "Actively managed food delivery," issued on June 15, 2021 Compl. ¶19
• Technology Synopsis: The patent describes a method for generating an analytical report on a food delivery process. It involves receiving and storing sensor-derived status information from a product container as it travels, analyzing the performance of entities involved in the delivery against ideal conditions, and outputting a report, such as a food safety report '094 Patent, abstract '094 Patent, claim 1
• Asserted Claims: At least exemplary claim 1 Compl. ¶119
• Accused Features: The complaint alleges that Carrier's Accused Instrumentalities, as a whole, operate as the claimed systems and perform the patented methods Compl. ¶118

U.S. Patent No. 12,008,509 - "Actively managed food delivery"

• Patent Identification: U.S. Patent No. 12,008,509 ("the '509 Patent"), titled "Actively managed food delivery," issued on June 11, 2024 Compl. ¶20
• Technology Synopsis: The patent describes a method for managing a food delivery process that includes obtaining ideal delivery conditions, accumulating sensor data during transit, and generating a food product history. This history is compared to the ideal conditions to analyze performance, and a report of the analysis is generated and outputted '509 Patent, abstract '509 Patent, claim 1
• Asserted Claims: At least exemplary claim 1 Compl. ¶138
• Accused Features: The complaint alleges that Carrier's Accused Instrumentalities, as a whole, operate as the claimed systems and perform the patented methods Compl. ¶137

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are identified as Carrier's Lynx Fleet telematics solution, including its integration with the APX™ Control System, IntelliSet™ product profiles, EverFRESH® Active Controlled Atmosphere System, Lynx Logix container telematics, and the Sensitech monitoring platform Compl. ¶21

Functionality and Market Context

• The complaint describes the Lynx Fleet solution as an "overarching IoT, machine learning, and analytics platform" that monitors and controls connected refrigeration units Compl. ¶8(i) It allegedly receives real-time data (e.g., temperature, location), compares this data to pre-configured "IntelliSet™ product profiles" for specific commodities, and enables two-way remote control to make adjustments Compl. ¶8(i) Compl. ¶8(iii) Compl. ¶26 For example, an operator can select a profile like "APPLES," and the system automatically programs the settings for temperature control Compl. ¶24 The system also allegedly generates alarms and can trigger shutdown actions if the temperature drifts outside a defined range Compl. ¶¶25-26
• The complaint alleges these systems have been deployed across Carrier's entire trailer refrigeration unit manufacturing line since at least 2023, providing Carrier with a significant market advantage Compl. ¶3 Compl. ¶22 A marketing graphic from Carrier included in the complaint depicts a cloud-based architecture connecting various points in the cold chain, from "Growers & Manufacturers" to a "Distribution Center," all managed by AWS-powered analytics Compl. ¶23

IV. Analysis of Infringement Allegations

'684 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving status information from one or more product containers, wherein the status information includes conditions of each of the one or more product containers	The Lynx Fleet platform receives real-time data, including temperature and unit status, from connected refrigeration units through a centralized data stream Compl. ¶8(i)	¶8	col. 6:47-54
determining preferred ranges for the conditions of each of the one or more product containers based on a product stored in each of the one or more product containers	The system uses IntelliSet™ product profiles, which are pre-configured templates specifying ideal temperature setpoints and tolerances for specific commodities like "apples" or "cheese" Compl. ¶8(iii) Compl. ¶24	¶8; ¶24	col. 7:7-22
determining whether the received conditions from the one or more product containers are within the preferred ranges	The system continuously monitors sensor temperatures and compares them against setpoint data plus a tolerance to determine if conditions are "Out-Of-Range" Compl. ¶25	¶25	col. 7:46-53
sending a command in response to determining that at least one of the received conditions is outside the determined preferred range	When a temperature drifts beyond a specified range, the system triggers an alarm that can lead to a "configured alarm or alarm and shutdown action," which is a command sent to the refrigeration unit Compl. ¶26	¶26	col. 8:6-15

'918 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
determining, by the computer, preferred ranges for the conditions... wherein the preferred ranges change over time by a predefined amount per unit time, wherein the predefined amount and the unit time are specified in a profile...	The complaint alleges that the IntelliSet™ product profiles "operationalize the concept of 'preferred ranges that change over time by predefined amounts per unit time' at the core of the patent claim" Compl. ¶8(iii)	¶8	col. 7:32-45
sending, by the computer, a first command in response to determining that at least one of the received conditions is outside the determined preferred range, wherein the first command is sent to... adjust an environmental parameter...	The system sends commands via the Lynx Fleet two-way command interface to the APX Control System, which translates them into physical adjustments to the refrigeration unit's operation, such as a "shutdown action" Compl. ¶8(ii) Compl. ¶26	¶8; ¶26	col. 8:16-29
using, by the computer, the food product history to determine a prioritized delivery scheme of the one or more product containers, wherein the food product with the longest time since preparation is prioritized for delivery ahead of another...	The Lynx Logix™ container telematics layer allegedly applies AI and machine learning to determine prioritized delivery schemes based on food product history, such as which shipment has been in transit the longest Compl. ¶9(v)	¶9	col. 9:8-22
sending, by the computer, a second command to not deliver certain food products in response to determining that they are unsafe and/or undesirable.	The Sensitech platform allegedly supports the "issuance of hold or stop-delivery commands when they are not" safe or desirable for delivery Compl. ¶9(vi)	¶9	col. 9:66-10:15

Identified Points of Contention

• Scope Questions: The patents often use the term "food delivery," with some embodiments described in the context of "delivery bag[s]" '918 Patent, col. 5:54-55 A potential point of contention may be whether the scope of the claims, when read in light of the specification, can be interpreted to cover large-scale commercial refrigeration units for truck-trailers and shipping containers as alleged in the complaint.
• Technical Questions: For the '918 Patent, a central question will be whether Carrier's "IntelliSet™ product profiles" truly implement the claimed feature of "preferred ranges [that] change over time by a predefined amount per unit time" '918 Patent, claim 1 The dispute may focus on whether the accused profiles constitute a dynamic, time-varying function as claimed, or merely a selection of static, pre-set operational modes.

V. Key Claim Terms for Construction

The Term: "preferred ranges change over time by a predefined amount per unit time" (['918 Patent, claim 1](https://ex:cit:44))

• Context and Importance: This limitation is a key technical feature differentiating the '918 Patent from earlier patents like the '684 Patent. The infringement case for the '918 Patent likely hinges on whether the functionality of Carrier's IntelliSet™ profiles falls within the scope of this term. Practitioners may focus on this term because the complaint alleges the accused profiles "operationalize" this concept, suggesting this will be a contested point of interpretation Compl. ¶8(iii)
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims and specification do not limit the "change over time" to a purely linear or continuous function. The language "change over time" could be argued to encompass any programmed variation, including stepped changes or mode shifts that occur at predefined intervals.
  • Evidence for a Narrower Interpretation: The specification provides a specific example that could support a narrower reading: "a preferred temperature range may reduce about 5 degrees Fahrenheit each hour, thereby preventing the food from being cooked while in transport" '918 Patent, col. 8:1-3 A defendant may argue this example limits the claim to a more defined, periodic rate of change.

The Term: "command" ('684 Patent, claim 1; ['918 Patent, claim 1](https://ex:cit:44))

• Context and Importance: The patents require sending a "command" to take corrective action when conditions are out of range. The definition of this term is critical because it determines whether a simple alert to a human operator is sufficient to infringe, or if a direct, automated instruction to the control unit is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests a command can be directed to a person, stating it may "instruct an individual transporting the one or more product containers to perform a corrective (e.g., preventative) action" '918 Patent, col. 8:8-11 This may support an interpretation that includes alerts and notifications intended for human intervention.
  • Evidence for a Narrower Interpretation: The specification also describes a more automated system, where a "controller may be able to automatically turn on an air conditioning unit" or "adjust settings of an environmental control unit" '918 Patent, col. 8:16-29 This may support an interpretation requiring a machine-to-machine instruction that directly alters the unit's operation without human input.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Carrier provides product documentation, user manuals, mobile apps, and technical support that instruct and encourage end-users to operate the Accused Instrumentalities in a manner that directly infringes the patents Compl. ¶¶45-46 The complaint also alleges contributory infringement under 35 U.S.C. § 271(c), stating that Carrier supplies software components for the Lynx Fleet platform that are a material part of the invention, are not staple articles of commerce, and are especially made for infringing use Compl. ¶49

Willful Infringement

• The complaint alleges willful infringement based on pre-suit knowledge. The primary factual basis is that Carrier cited a Zest patent publication, which issued as the '684 Patent, in an IDS filed on April 3, 2020, during the prosecution of its own patent Compl. ¶¶28, 47, 53 The complaint further alleges that Carrier has known of its infringement and has made no attempt to design around the patents Compl. ¶¶54-55

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

• A core issue will be one of claim construction: Can the phrase "preferred ranges change over time by a predefined amount per unit time" be construed to read on Carrier's "IntelliSet" system, which uses pre-configured commodity profiles? The outcome of this definitional dispute will be critical to determining infringement of the '918 patent and its relatives.
• A central question for damages will be one of willfulness: Do Carrier's alleged "patent monitoring activities," particularly its citation of a Zest patent publication in a 2020 IDS, establish the requisite knowledge and "egregious" conduct to support a finding of willful infringement and potential for enhanced damages, especially in light of the allegation that Carrier made no effort to design around the technology?
• A key evidentiary question will be one of functional operation: Does the accused Lynx Fleet system and its sub-components (e.g., Lynx Logix, Sensitech) actually perform the advanced analytical functions claimed in the later patents, such as creating a "prioritized delivery scheme" based on food history or issuing "hold or stop-delivery commands"? The case may turn on whether the evidence shows the accused system operates with the level of autonomy and intelligence described in the patent claims, versus merely providing data and alerts for human decision-making.