Honeywell Intl Inc v. EPS Ehrhardt + Partner Solutions Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiffs: Vocollect, Inc. (Pennsylvania) and Hand Held Products, Inc. (Delaware)
  • Defendant: EPS - Ehrhardt + Partner Solutions Inc. (Delaware)
  • Plaintiff's Counsel: Womble Bond Dickinson (US) LLP
• Case Identification: 2:25-cv-00918, E.D. Tex., 07/14/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant EPS has its principal place of business within the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiffs allege that Defendant's voice-directed warehouse logistics products infringe fifteen patents related to voice-directed work technology, speech recognition systems, and associated hardware.
• Technical Context: The technology at issue involves voice-directed systems used in industrial and supply chain environments, a market where such technology can significantly improve operational efficiency, safety, and accuracy for mobile workers.
• Key Procedural History: The complaint details extensive pre-suit communications between the parties, beginning in January 2022, which included multiple notice letters from Plaintiffs asserting infringement with detailed claim charts. It also notes that Defendant EPS previously filed a declaratory judgment action in the Western District of North Carolina, which was subsequently transferred to the Eastern District of Texas and consolidated with the present case. This history suggests a well-documented period of pre-suit knowledge, which may be significant for Plaintiffs' willfulness allegations.

Case Timeline

Date	Event
2005-02-14	U.S. Patent No. 7,609,669 Priority Date
2006-02-06	U.S. Patent No. 7,885,419 Priority Date
2006-10-06	U.S. Patent No. 7,827,032 Priority Date
2007-03-21	U.S. Patent No. 7,949,533 Priority Date
2008-05-06	U.S. Patent No. 9,361,882 Priority Date
2008-11-14	U.S. Patent Nos. 11,158,336, 12,057,139, & 12,400,678 Priority Date
2009-10-27	U.S. Patent No. 7,609,669 Issue Date
2009-11-12	U.S. Patent No. 8,386,261 Priority Date
2010-02-16	U.S. Patent Nos. 8,700,405 & 9,642,184 Priority Date
2010-11-02	U.S. Patent No. 7,827,032 Issue Date
2011-02-08	U.S. Patent No. 7,885,419 Issue Date
2011-02-17	U.S. Patent No. 8,550,354 Priority Date
2011-03-09	U.S. Patent No. 8,255,219 Priority Date
2011-05-20	U.S. Patent Nos. 8,914,290 & 11,817,078 Priority Date
2011-05-24	U.S. Patent No. 7,949,533 Issue Date
2012-08-28	U.S. Patent No. 8,255,219 Issue Date
2013-02-26	U.S. Patent No. 8,386,261 Issue Date
2013-10-08	U.S. Patent No. 8,550,354 Issue Date
2014-04-15	U.S. Patent No. 8,700,405 Issue Date
2014-12-16	U.S. Patent No. 8,914,290 Issue Date
2016-06-07	U.S. Patent No. 9,361,882 Issue Date
2017-05-02	U.S. Patent No. 9,642,184 Issue Date
2021-10-26	U.S. Patent No. 11,158,336 Issue Date
2022-01-18	Plaintiffs send notice letter regarding '669, '405, and '184 Patents
2023-05-02	Plaintiffs send notice letter regarding '419 and '219 Patents
2023-09-08	Plaintiffs send notice letter regarding '882, '354, and '290 Patents
2023-11-14	U.S. Patent No. 11,817,078 Issue Date
2024-06-23	Plaintiffs send notice letter regarding '032, '261, and '078 Patents
2024-08-06	U.S. Patent No. 12,057,139 Issue Date
2025-07-09	EPS files declaratory judgment action in W.D.N.C.
2025-08-26	U.S. Patent No. 12,400,678 Issue Date
2025-08-29	Plaintiffs file original complaint in E.D. Tex.
2026-06-04	W.D.N.C. action transferred to E.D. Tex.
2026-07-14	First Amended Complaint filed; cases consolidated

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

U.S. Patent No. 11,158,336 - "Distinguishing user speech from background speech in speech-dense environments"

• Patent Identification: US11158336B2, "Distinguishing user speech from background speech in speech-dense environments," issued October 26, 2021 Compl. ¶37

The Invention Explained

• Problem Addressed: The patent's background describes the difficulty voice-driven systems face in noisy environments, where extraneous sounds like public address (PA) system announcements or conversations from other people can interfere with the system's ability to recognize the intended user's speech U.S. Patent No. 11,158,336, col. 2:30-44
• The Patented Solution: The invention provides a system and method to distinguish a user's speech from background sounds by preparing a voice-data model in advance in a training environment that exhibits both desired user speech and unwanted background sounds. This pre-trained model, or "audio characterization model," is then used in the field to identify and reject audio that matches the characteristics of background speech, thereby improving recognition of the user's intended speech U.S. Patent No. 11,158,336, abstract U.S. Patent No. 11,158,336, FIG. 4
• Technical Importance: This approach allows for more robust speech recognition in "speech-dense" industrial settings, which is critical for the reliability and efficiency of voice-directed workflow systems U.S. Patent No. 11,158,336, col. 2:45-55

Key Claims at a Glance

• The complaint asserts at least independent claim 17 Compl. ¶216
• Claim 17 recites a method for speech recognition, with essential elements including:
  • receiving an audio input at a microphone of a speech recognition device (SRD);
  • identifying a vocalization of a human language;
  • categorizing the vocalization as either a first vocalization from a user or a second vocalization from a background, based on a model stored in memory;
  • filtering the audio input to remove the second vocalization; and
  • processing the first vocalization in the filtered vocalization to generate words and phrases.
• The complaint reserves the right to assert additional claims (Compl. ¶217).

U.S. Patent No. 11,817,078 - "Systems and methods for dynamically improving user intelligibility of synthesized speech in a work environment"

• Patent Identification: US11817078B2, "Systems and methods for dynamically improving user intelligibility of synthesized speech in a work environment," issued November 14, 2023 Compl. ¶39

The Invention Explained

• Problem Addressed: The patent identifies that in speech-directed work environments, the intelligibility of synthesized speech from a text-to-speech (TTS) engine can be hindered by factors like high ambient noise or a user's unfamiliarity with a particular prompt, and manually adjusting TTS settings is time-consuming and frustrating U.S. Patent No. 11,817,078, col. 2:54-3:18
• The Patented Solution: The invention proposes a system that automatically and dynamically modifies adjustable operational parameters of the TTS engine (such as speed, pitch, or volume) in response to monitored "environmental conditions." These conditions can include ambient noise levels, the user speaking a command like "Say Again," or the system issuing an unfamiliar or important message U.S. Patent No. 11,817,078, abstract U.S. Patent No. 11,817,078, FIGS. 3-5
• Technical Importance: This solution improves user experience and efficiency by automatically enhancing speech clarity when needed, while maintaining a user's preferred settings under normal conditions, thereby reducing errors and frustration U.S. Patent No. 11,817,078, col. 4:59-68

Key Claims at a Glance

• The complaint asserts at least independent claim 10 Compl. ¶229
• Claim 10 recites a communication system with essential elements including:
  • a speech recognition system to gather speech inputs;
  • a text-to-speech engine to provide audible output;
  • processing circuitry configured to monitor an environmental condition (ambient noise level);
  • modify an operational parameter of the TTS or speech recognition system based on the monitored condition; and
  • cause a task to be audibly output.
• The complaint reserves the right to assert additional claims (Compl. ¶230).

U.S. Patent No. 7,609,669 - "Voice directed system and method configured for assured messaging to multiple recipients"

• Patent Identification: US7609669B2, "Voice directed system and method configured for assured messaging to multiple recipients," issued October 27, 2009 Compl. ¶15
• Technology Synopsis: The patent describes a system for sending messages to multiple users in a wireless network, such as a warehouse. The system ensures message delivery by requiring acknowledgements from the user's terminal and can track the status of messages for each recipient, providing an "assured messaging" capability without using a disruptive public address system U.S. Patent No. 7,609,669, abstract
• Asserted Claims: At least claim 19 is asserted Compl. ¶73
• Accused Features: The Lydia Voice software is accused of embodying the patented inventions Compl. ¶73

U.S. Patent No. 7,827,032 - "Methods and systems for adapting a model for a speech recognition system"

• Patent Identification: US7827032B2, "Methods and systems for adapting a model for a speech recognition system," issued November 2, 2010 Compl. ¶17
• Technology Synopsis: This patent discloses a method for adapting a speech recognition model by determining an error rate without using a transcript of the words input to the system. The model for a word or various words is then adjusted based on this determined error rate, allowing for more efficient, automated improvement of the recognition system's performance U.S. Patent No. 7,827,032, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶86
• Accused Features: The Lydia Voice software is accused of embodying the patented inventions Compl. ¶86

U.S. Patent No. 7,885,419 - "Headset terminal with speech functionality"

• Patent Identification: US7885419B2, "Headset terminal with speech functionality," issued February 8, 2011 Compl. ¶19
• Technology Synopsis: The patent describes a headset terminal that integrates processing circuitry for speech recognition and synthesis. The invention focuses on the physical design and ergonomic features of the headset, including a rotatable microphone boom with consistently oriented controls and a modular architecture that separates personal components from electronics for hygiene and cost-efficiency U.S. Patent No. 7,885,419, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶99
• Accused Features: The Lydia Headset is accused of infringing Compl. ¶99

U.S. Patent No. 7,949,533 - "Methods and systems for assessing and improving the performance of a speech recognition system"

• Patent Identification: US7949533B2, "Methods and systems for assessing and improving the performance of a speech recognition system," issued May 24, 2011 Compl. ¶21
• Technology Synopsis: This patent discloses a method for assessing the performance of a speech recognition system by determining a grade based on a recognition rate and at least one other recognition factor. Based on this grade, the system can generate corrective action suggestions, allowing for systematic performance monitoring and improvement without requiring manual transcription analysis U.S. Patent No. 7,949,533, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶112
• Accused Features: The Lydia Voice software is accused of infringing Compl. ¶112

U.S. Patent No. 8,255,219 - "Method and apparatus for determining a corrective action for a speech recognition system based on the performance of the system"

• Patent Identification: US8255219B2, "Method and apparatus for determining a corrective action for a speech recognition system based on the performance of the system," issued August 28, 2012 Compl. ¶23
• Technology Synopsis: This patent is related to the '533 patent and similarly describes assessing the performance of a speech recognition system by determining a grade. The system then determines a corrective action based on this performance grade, providing a systematic way to improve system accuracy U.S. Patent No. 8,255,219, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶125
• Accused Features: The Lydia Voice software is accused of infringing Compl. ¶125

U.S. Patent No. 8,386,261 - "Training/coaching system for a voice-enabled work environment"

• Patent Identification: US8386261B2, "Training/coaching system for a voice-enabled work environment," issued February 26, 2013 Compl. ¶25
• Technology Synopsis: The patent discloses a system where a trainer or "coach" can wirelessly listen to the voice prompts being delivered to another user (the "coached" user). This allows the coach to hear exactly what the user hears in real-time, facilitating more effective training and supervision in a voice-enabled work environment without needing extra hardware U.S. Patent No. 8,386,261, abstract
• Asserted Claims: At least claim 6 is asserted Compl. ¶138
• Accused Features: The Lydia Voice software on hardware products such as the EPS Voxter is accused of infringing Compl. ¶138

U.S. Patent No. 8,550,354 - "Indicia reader system with wireless communication with a headset"

• Patent Identification: US8550354B2, "Indicia reader system with wireless communication with a headset," issued October 8, 2013 Compl. ¶27
• Technology Synopsis: This patent describes an indicia reader (barcode scanner) system that communicates wirelessly with a headphone worn by an operator. This allows the operator to receive audio feedback (e.g., a beep for a successful scan) directly in the headphone, which is particularly useful in noisy environments where the scanner's own beeper might be inaudible U.S. Patent No. 8,550,354, abstract
• Asserted Claims: At least claim 10 is asserted Compl. ¶151
• Accused Features: The Lydia VoiceWear product that includes the Voxter computer is accused of infringing Compl. ¶151

U.S. Patent No. 8,700,405 - "Audio system and method for coordinating tasks"

• Patent Identification: US8700405B2, "Audio system and method for coordinating tasks," issued April 15, 2014 Compl. ¶29
• Technology Synopsis: This patent discloses a system where a hands-free mobile communication device provides audible instructions to a field operator. The system receives and processes oral communications from the operator to provide further instructions, and can also route comments to appropriate recipients based on context, thereby coordinating tasks in an industrial environment U.S. Patent No. 8,700,405, abstract
• Asserted Claims: At least claim 11 is asserted Compl. ¶164
• Accused Features: The Lydia Voice software as used on Lydia VoiceWear is accused of infringing Compl. ¶164

U.S. Patent No. 8,914,290 - "Systems and methods for dynamically improving user intelligibility of synthesized speech in a work environment"

• Patent Identification: US8914290B2, "Systems and methods for dynamically improving user intelligibility of synthesized speech in a work environment," issued December 16, 2014 Compl. ¶31
• Technology Synopsis: This patent is an earlier version in the same family as the '078 patent. It similarly describes a system that dynamically adjusts parameters of a text-to-speech engine, like speed or volume, in response to monitored environmental conditions or user commands to improve the intelligibility of synthesized speech in a work environment U.S. Patent No. 8,914,290, abstract
• Asserted Claims: At least claim 12 is asserted Compl. ¶177
• Accused Features: The Lydia Voice software is accused of infringing Compl. ¶177

U.S. Patent No. 9,361,882 - "Supervisor training terminal and monitor for voice-driven applications"

• Patent Identification: US9361882B2, "Supervisor training terminal and monitor for voice-driven applications," issued June 7, 2016 Compl. ¶33
• Technology Synopsis: The patent discloses a system where a supervisor's terminal can run a speech task in parallel with an operator's terminal, but in a different language. The supervisor's terminal synchronizes its progress with the operator's, allowing the supervisor to monitor and train an operator who speaks a different language without needing real-time translation U.S. Patent No. 9,361,882, abstract
• Asserted Claims: At least claim 12 is asserted Compl. ¶190
• Accused Features: The Lydia Voice Software is accused of infringing Compl. ¶190

U.S. Patent No. 9,642,184 - "Audio system and method for coordinating tasks"

• Patent Identification: US9642184B2, "Audio system and method for coordinating tasks," issued May 2, 2017 Compl. ¶35
• Technology Synopsis: This patent is a later version in the same family as the '405 patent. It also describes a hands-free audio system for coordinating tasks in an industrial setting, where oral communications from an operator are processed to provide further audible instructions U.S. Patent No. 9,642,184, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶203
• Accused Features: The Lydia Voice software, EPS Voxter, and Lydia VoiceWear are accused of infringing Compl. ¶203

U.S. Patent No. 12,057,139 - "Distinguishing user speech from background speech in speech-dense environments"

• Patent Identification: US12057139B2, "Distinguishing user speech from background speech in speech-dense environments," issued August 6, 2024 Compl. ¶41
• Technology Synopsis: This patent is in the same family as the '336 patent. It describes a method for distinguishing user speech from background sounds by using a pre-trained voice-data model created in an environment with both user speech and background noise, allowing the system to better identify and filter unwanted sounds during field use U.S. Patent No. 12,057,139, abstract
• Asserted Claims: At least claim 28 is asserted Compl. ¶242
• Accused Features: The EPS Lydia Voice software, EPS Voxter, and Lydia VoiceWear product are accused of infringing Compl. ¶242

U.S. Patent No. 12,400,678 - "Distinguishing user speech from background speech in speech-dense environments"

• Patent Identification: US12400678B2, "Distinguishing user speech from background speech in speech-dense environments," issued August 26, 2025 Compl. ¶43
• Technology Synopsis: This patent is also in the same family as the '336 and '139 patents. It discloses a method for filtering background speech in noisy environments by training a speech recognition system to identify wanted user speech that occurs concurrently with unwanted background sounds, using a pre-established voice-data model U.S. Patent No. 12,400,678, abstract
• Asserted Claims: At least claim 1 is asserted Compl. ¶255
• Accused Features: The EPS Lydia Voice software, the EPS Voxter, and the Lydia VoiceWear are accused of infringing Compl. ¶255

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant EPS's Lydia Voice software, Lydia CoPilot, Voxter computers (including the Voxter Vantage VT5), and Lydia headsets and wearables (including Lydia VoiceWear, Lydia Headset HS11, and Lydia Headset HS22) Compl. ¶66

Functionality and Market Context

• The accused products collectively form a voice-picking solution for logistics and industrial applications Compl. ¶65 The core of the system is the "Lydia Voice" software, which is used with purpose-built hardware such as the "Voxter Vantage" mobile voice computer and wearable accessories like the "Lydia VoiceWear" vests and various headsets Compl. ¶¶67-69 The complaint includes an image of the Voxter Vantage, described as a "mobile voice computer" developed for use with Lydia Voice Compl. ¶67, p. 14 Further visual evidence includes images of the "Lydia VoiceWear" vests, which integrate speakers and microphones for hands-free picking processes Compl. ¶68, p. 14 Images of the Lydia Headset HS11 and HS22 are also provided, described as being optimized for speech recognition with LYDIA Voice Compl. ¶69, p. 15
• The complaint alleges that EPS markets Lydia Voice as "the leading voice picking solution for logistics and industry" Compl. ¶65 The system is designed to provide voice-guided workflows for mobile workers, enabling them to perform tasks hands-free in environments such as warehouses Compl. ¶¶4-5 Compl. ¶12

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that were not provided in the supplied documents Compl. ¶¶217; Compl. ¶230 The infringement analysis is therefore summarized based on the narrative allegations in the complaint.

'336 Patent Infringement Allegations

• The complaint alleges that EPS's products, including the Lydia Voice software, EPS Voxter, and Lydia VoiceWear, directly infringe at least claim 17 of the '336 Patent Compl. ¶216 The infringement theory is that the accused products embody the patented method for distinguishing a user's speech from background noise in speech-dense environments Compl. ¶¶37; Compl. ¶216 This suggests the accused system uses a trained model to analyze incoming audio and filter out sounds that are characteristic of background noise, thereby mapping to the elements of claim 17 (Compl. ¶217).
• Identified Points of Contention: A primary point of contention may be whether the accused Lydia Voice system's noise filtering technology practices every step of the claimed method. A technical question will be whether the accused system employs an "audio characterization model" and a "rejection threshold" as those terms are understood in the context of the '336 patent. The dispute could center on the specific algorithms and data structures used by the accused products for noise cancellation versus those described and claimed in the patent.

'078 Patent Infringement Allegations

• The complaint alleges that the Lydia Voice software directly infringes at least claim 10 of the '078 Patent Compl. ¶229 The infringement theory is that the accused software embodies the patented system for dynamically improving the intelligibility of synthesized speech by monitoring an "environmental condition" (specifically ambient noise level, as recited in claim 10) and modifying an operational parameter of the text-to-speech engine in response Compl. ¶¶39; Compl. ¶229-230
• Identified Points of Contention: A key legal and technical question will be one of functional causality: does the accused Lydia Voice system actually modify a TTS parameter in response to a monitored ambient noise level, as required by the claim? The analysis will likely focus on whether any adjustments to speech output in the accused product are directly and automatically triggered by changes in ambient noise, or if they result from general user settings or other mechanisms that fall outside the specific cause-and-effect relationship recited in the claim.

V. Key Claim Terms for Construction

Term from the '336 Patent: "audio characterization model"

• Context and Importance: This term appears in asserted independent claim 17 and is central to the patented method of distinguishing user speech. The definition of this term will be critical to determining whether the specific algorithms and data structures used by the accused Lydia Voice system for noise filtering fall within the scope of the claims. Practitioners may focus on this term because the infringement analysis will likely depend on comparing the technical implementation of the accused product's noise model with the specific structure and function of the "audio characterization model" as described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification refers to the model as a "stored audio template" derived from a "collection of voice training samples," which could support an argument that the term covers any pre-established data set used for comparing and classifying sounds U.S. Patent No. 11,158,336, col. 10:1-10
  • Evidence for a Narrower Interpretation: The patent provides a detailed, multi-step method for creating the model, involving collecting user speech, mixing it with background speech, running it through characterization algorithms, and using a learning algorithm to determine the final model U.S. Patent No. 11,158,336, FIG. 4 This detailed process could support a narrower construction that requires the model to be created in this specific manner.

Term from the '078 Patent: "environmental condition related to intelligibility"

• Context and Importance: This term, found in asserted independent claim 10, defines the trigger for the claimed dynamic adjustment of the TTS engine. The outcome of the case may hinge on whether the triggers used by the accused Lydia Voice system (if any) to adjust audio output are considered "environmental condition[s] related to intelligibility" under the patent's definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad definition, stating that environmental conditions "are understood to include any operating/work environment conditions or variables which are associated with the user" and lists examples like "ambient noise level," "user tasks," and "system events" U.S. Patent No. 11,817,078, col. 4:32-44
  • Evidence for a Narrower Interpretation: The patent also provides very specific examples of such conditions, such as a user speaking the phrase "Say Again" or the system detecting a "non-native" word in a prompt U.S. Patent No. 11,817,078, col. 7:55-59 U.S. Patent No. 11,817,078, col. 9:11-15 A defendant might argue these specific embodiments limit the term's scope to discrete, predefined events rather than general, continuous states like ambient noise.

VI. Other Allegations

Indirect Infringement

• The complaint pleads both induced and contributory infringement for all asserted patents. Inducement is based on allegations that EPS provides marketing materials, product guides, instructional materials, and YouTube videos that instruct and encourage customers to use the accused products in an infringing manner Compl. ¶¶77; Compl. ¶90; Compl. ¶103 Contributory infringement is based on allegations that the accused products, such as the Lydia VoiceWear, are especially made for infringing use and are not staple articles of commerce suitable for substantial non-infringing use Compl. ¶¶78; Compl. ¶91; Compl. ¶104

Willful Infringement

• The complaint alleges willful infringement for all asserted patents, based on extensive pre-suit knowledge Compl. ¶63 The basis for knowledge varies by patent but is supported by a series of specific notice letters sent by Plaintiffs to EPS, some including detailed claim charts, with the earliest notice date alleged as January 18, 2022 Compl. ¶¶47-58; Compl. ¶79 For some patents, knowledge is alleged to have occurred at a later date based on subsequent letters or upon the filing of the action itself Compl. ¶¶92; Compl. ¶114; Compl. ¶218

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

• A central issue will be one of algorithmic scope: does the accused Lydia Voice system's method for filtering background noise employ an "audio characterization model" and a corresponding "rejection threshold" as those terms are defined by the '336 patent and its prosecution history, or is there a fundamental difference in the underlying filtering technology that places it outside the claims?
• A key evidentiary question will be one of functional causality: for patents like the '078 patent, does the accused system's method of adjusting synthesized speech meet the claim requirement of modifying a parameter in response to a "monitored environmental condition related to intelligibility," or are the adjustments performed based on general user settings or other triggers that fall outside the specific cause-and-effect relationship recited in the claims?
• A significant question for damages will be the extent of willfulness, which will likely hinge on the extensive pre-suit notice alleged by Plaintiffs. The court will need to examine the content and timing of the alleged notice letters and claim charts, dating back several years, to determine whether Defendant's continued alleged infringement was objectively reckless.