EPS Ehrhardt + Partner Solutions Inc v. Honeywell Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: EPS - Ehrhardt + Partner Solutions Inc. (Delaware)
  • Defendant: Honeywell International Inc., Vocollect, Inc., Hand Held Products, Inc., and Intelligrated Headquarters LLC (Delaware/Pennsylvania)
  • Plaintiff's Counsel: Moore & Van Allen PLLC
• Case Identification: 3:25-cv-00494, W.D.N.C., 10/09/2025
• Venue Allegations: Venue is asserted on the basis that the Defendants regularly and intentionally conduct business in the Western District of North Carolina and are subject to personal jurisdiction there.
• Core Dispute: Plaintiff seeks a declaratory judgment that its products, primarily the Lydia Voice software suite and associated hardware, do not infringe eighteen U.S. patents owned by Defendants related to voice-directed warehouse management, speech recognition, and associated technologies.
• Technical Context: The technology at issue involves voice-controlled systems for logistics and warehouse management, a market where voice direction enhances worker productivity and accuracy by enabling hands-free and eyes-free operation.
• Key Procedural History: The complaint details a multi-year history of pre-suit correspondence, initiated by Honeywell on January 18, 2022, accusing Plaintiff's "Lydia Voice Software solution" of infringing a progressively expanding list of patents. Despite licensing discussions, the parties did not reach an agreement. Subsequently, Honeywell filed a patent infringement complaint against EPS in the Eastern District of Texas ("EDTX Complaint"). This declaratory judgment action appears to be a response to Honeywell's continued accusations and litigation threats.

Case Timeline

Date	Event
1999-05-18	Priority Date for '669 Patent
2002-12-05	Priority Date for '533 Patent
2003-03-24	Priority Date for '032 Patent
2003-09-02	Priority Date for '261 Patent
2005-02-14	Filing Date of Complaint (Original)
2005-05-20	Priority Date for '419 Patent
2008-05-06	Priority Date for '882 Patent
2009-10-27	Issue Date for '669 Patent
2011-02-17	Priority Date for '354 Patent
2011-05-20	Priority Date for '290 Patent
2011-06-20	Priority Date for '219 Patent
2011-07-29	Priority Date for '405 Patent
2011-07-29	Priority Date for '184 Patent
2011-02-10	Issue Date for '419 Patent
2012-08-28	Issue Date for '219 Patent
2013-03-05	Issue Date for '261 Patent
2013-05-21	Issue Date for '032 Patent
2013-05-21	Issue Date for '533 Patent
2013-08-27	Priority Date for '940 Patent
2013-10-08	Issue Date for '354 Patent
2014-02-25	Issue Date for '405 Patent
2014-08-26	Priority Date for '504 Patent
2014-08-26	Priority Date for '863 Patent
2014-12-16	Issue Date for '290 Patent
2015-09-01	Issue Date for '940 Patent
2016-06-07	Issue Date for '882 Patent
2016-07-27	Priority Date for '336 Patent
2017-04-18	Issue Date for '184 Patent
2017-05-09	Priority Date for '078 Patent
2018-08-14	Issue Date for '504 Patent
2020-09-08	Issue Date for '863 Patent
2021-10-26	Issue Date for '336 Patent
2022-01-18	Honeywell sends first letter accusing infringement of '669, '405, '184 Patents
2022-02-16	EPS sends letter denying infringement
2023-05-02	Honeywell sends letter accusing infringement of '419, '219 Patents
2023-08-18	Priority Date for '678 Patent
2023-09-08	Honeywell sends letter accusing infringement of '882, '354, '290 Patents
2023-09-27	EPS sends letter reiterating denial
2023-10-17	Priority Date for '139 Patent
2023-11-14	Issue Date for '078 Patent
2023-12-05	Honeywell sends letter with claim charts for '882, '354, '290 Patents
2024-03-05	EPS sends response denying all allegations
2024-06-23	Honeywell sends letter accusing infringement of '261, '032, '533, '078 Patents
2024-08-06	Issue Date for '139 Patent
2024-08-14	Parties participate in an in-person meeting
2025-08-26	Issue Date for '678 Patent
2025-10-09	Complaint for Declaratory Judgment Filed

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

This analysis focuses on two of the eighteen patents identified in the complaint for which exemplary claim charts were provided as exhibits (Compl. Ex. F).

U.S. Patent No. 8,550,354 - Indicia Reader System with Wireless Communication with a Headset (Issued Oct. 8, 2013)

The Invention Explained

• Problem Addressed: The patent does not contain a background section describing a specific problem. However, the claims and abstract suggest the invention addresses the need for efficient, hands-free data capture and operator feedback in work environments, such as logistics, where operators handle physical items while interacting with a data management system Compl. Ex. F, p. 7
• The Patented Solution: The invention is a system that combines an indicia reader (e.g., a barcode scanner) with a wireless headphone worn by an operator Compl. Ex. F, p. 7, abstract The indicia reader is used to capture data, and the system then wirelessly sends audio data to the headphone to provide audio feedback to the operator Compl. Ex. F, p. 7, abstract This creates a closed loop where a worker can scan an item and receive an audible confirmation or instruction without needing to look at a screen. The specification also contemplates a noise-cancelling headphone to improve performance in noisy environments Compl. Ex. F, p. 17
• Technical Importance: The technology integrates barcode scanning with voice-directed work, streamlining warehouse operations by allowing workers to remain "hands-free" and "eyes-free" while performing tasks like order picking or inventory management.

Key Claims at a Glance

• The complaint references Honeywell's assertion of at least independent claim 10 Compl. Ex. F, p. 8
• Essential elements of Independent Claim 10 include:
  • A method of operating an indicia reader system.
  • Providing an indicia reader to read information bearing indicia (IBI).
  • Activating the indicia reader.
  • Wirelessly sending audio data with a first device.
  • Wirelessly receiving the audio data with a second device, disposed in a headphone worn on an operator's head.
  • Broadcasting audio information to the operator using a speaker within the headphone.
  • Wherein the headphone is noise-cancelling.

U.S. Patent No. 8,914,290 - Systems and Methods for Dynamically Improving User Intelligibility of Synthesized Speech in a Work Environment (Issued Dec. 16, 2014)

The Invention Explained

• Problem Addressed: The patent's abstract notes that environmental conditions can degrade the intelligibility of synthesized speech from a text-to-speech (TTS) engine in a speech-based system Compl. Ex. F, p. 19, abstract This is a common issue in noisy industrial settings like warehouses, where audible instructions can be difficult for workers to understand.
• The Patented Solution: The invention provides a method and system that dynamically adjust the operational parameters of a TTS engine-such as volume or speed-in response to one or more monitored environmental conditions Compl. Ex. F, p. 19, abstract By adapting to the environment, the system aims to increase the intelligibility of the synthesized speech for the user Compl. Ex. F, p. 19, abstract Figure 4 of the patent illustrates a process flow where an "ADVERSE ENVIRONMENT" is detected, leading to a modification of the TTS engine's settings Compl. Ex. F, p. 19, FIG. 4
• Technical Importance: This technology makes voice-directed systems more robust and effective in real-world industrial environments by actively compensating for factors like background noise, which improves worker accuracy and efficiency.

Key Claims at a Glance

• The complaint references Honeywell's assertion of at least independent claim 12 Compl. Ex. F, p. 20
• Essential elements of Independent Claim 12 include:
  • A method of communicating in a speech-based environment using a text-to-speech engine.
  • Monitoring at least one environmental condition associated with a user that is related to intelligibility of an audible output of the text-to-speech engine.
  • Modifying at least one adjustable operational parameter of the text-to-speech engine in response to the monitored condition to improve the intelligibility of the output.

Multi-Patent Capsule Analysis

The complaint identifies sixteen additional patents asserted by Honeywell Compl. ¶41 These patents are generally directed to related technologies in warehouse management, speech recognition, and logistics automation Compl. ¶¶45-46

• U.S. Patent No. 7,609,669: "Voice Directed System and Method Configured for Assured Messaging to Multiple Recipients." This patent describes methods for facilitating logistical operations in a warehouse environment using a wireless network Compl. ¶46(a) Asserted claims include 1 and 33, and the accused product is the Lydia Voice Software solution.
• U.S. Patent No. 8,700,405 & 9,642,184: These patents concern a communication device and method for applications in managing and operating an industrial plant Compl. ¶46(g) Compl. ¶46(h) The accused product is the Lydia Voice Software solution.
• U.S. Patent No. 9,361,882: "Supervisor Training Terminal and Monitor for Voice-Driven Applications." This patent describes a system for supervising an operator in a speech-based task management system Compl. ¶46(k) The accused product is the Lydia Voice Co-Pilot tool, which enables supervisors to monitor operators Compl. Ex. F, p. 29
• Other patents cover areas such as inventory management systems ('419, '032, '533, '219, '261 Patents) Compl. ¶46(b)-(e) Compl. ¶46(q), text-to-speech and speech-based devices ('290, '078 Patents) Compl. ¶46(i) Compl. ¶46(j), three-dimensional facility modeling ('504, '863 Patents) Compl. ¶46(l), warehouse control software ('940 Patent) Compl. ¶46(m), and distinguishing user speech from background noise in warehouses ('336, '139, '678 Patents) Compl. ¶46(n)-(p)

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Plaintiff EPS's "Lydia Voice Software solution," also referred to as the "Lydia Voice Suite," and associated hardware including the "Lydia Voxter Scan/Scan+ scanner" and the "HS01 BT Headset" Compl. ¶23 Compl. Ex. F, p. 6

Functionality and Market Context

• The Lydia Voice suite is a system for "voice-guided picking processes in warehouse, intralogistics, production and maintenance" Compl. Ex. F, p. 13 It is designed to optimize logistics by enabling workers to perform tasks using voice commands, keeping their hands and eyes free Compl. Ex. F, p. 16 The image from an EPS product brochure shows a worker in a warehouse using a wearable scanner and headset Compl. Ex. F, p. 17
• The Voxter Scan+ is a wearable barcode scanner that captures 1D and 2D barcodes and features an "auto-trigger function" allowing for hands-free activation Compl. Ex. F, p. 9 Compl. Ex. F, p. 11
• The HS01 BT is a wireless Bluetooth headset featuring "integrated advanced noise cancelling technology" Compl. Ex. F, p. 17
• The Lydia Voice Suite also includes a "Noise Controlled Volume (NCV)" feature that "automatically adjusts to the environmental background noise and adapts the sound volume of Lydia's speech output accordingly for each individual user" Compl. Ex. F, p. 23 This functionality is aimed at improving voice recognition in challenging industrial environments Compl. Ex. F, p. 23

IV. Analysis of Infringement Allegations

The following summary is based on the exemplary claim charts provided by Honeywell's counsel and attached as Exhibit F to the complaint.

'354 Patent Infringement Allegations

Claim Element (from Independent Claim 10)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of operating an indicia reader system comprising:	The Lydia Voxter Scan+ is alleged to perform a method of operating an indicia reader system.	¶28; Ex. F, p. 9	col. 4:3-4
providing an indicia reader to read information bearing indicia (IBI);	The Lydia VOXTER Scan+ is a barcode scanner used to read 1D and 2D barcodes.	¶28; Ex. F, p. 9	col. 4:3-5
activating the indicia reader;	The Voxter Scan+ has an "auto-trigger function" that automatically triggers the scanning process when brought close to a barcode.	¶28; Ex. F, p. 11	col. 4:5-6
wirelessly sending audio data with a first device;	The Voxter Scan+ connects via Bluetooth to other devices and is used in combination with the Lydia Voice Suite for "voice guidance."	¶28; Ex. F, p. 12	col. 4:6-7
wirelessly receiving the audio data with a second device, the second device being disposed in a headphone worn on an operator's head;	The Lydia HS01 BT is a Bluetooth-enabled headset worn on a user's head for voice picking and other voice operations.	¶28; Ex. F, p. 14	col. 4:8-11
broadcasting audio information to the operator using a speaker disposed within the headphone; and	The Lydia Voice solutions deliver WMS instructions (e.g., bin location, quantity) to a picker via the headset as audio information.	¶28; Ex. F, p. 15	col. 4:12-14
wherein the headphone is noise-cancelling.	The Lydia HS01 BT headphone is described as including "integrated advanced noise cancelling technology."	¶28; Ex. F, p. 17	col. 4:14-15

'290 Patent Infringement Allegations

Claim Element (from Independent Claim 12)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of communicating in a speech-based environment using a text-to-speech engine, the method comprising:	The Lydia Voice Suite is alleged to be a method of communicating in a speech-based environment where commands are converted into "voice-directed instructions."	¶28; Ex. F, p. 21	col. 4:59-62
monitoring at least one environmental condition associated with a user that is related to intelligibility of an audible output of the text-to-speech engine by the user; and	The Lydia Voice system is alleged to work in "challenging work environments" and "adjusts to the environmental background noise," addressing sounds like forklift beeps and pallet drops.	¶28; Ex. F, p. 22	col. 5:1-5
modifying at least one adjustable operational parameter of the text-to-speech engine in response to the monitored at least one environmental condition to improve the intelligibility of an audible output of the text-to-speech engine.	The Lydia Voice Suite is alleged to use "Noise Controlled Volume (NCV)" which "automatically adapts the sound volume of Lydia's speech output for each individual user in accordance with the monitored environmental background noise."	¶28; Ex. F, p. 23	col. 5:6-11

Identified Points of Contention

• Scope Questions:

  • For the '354 Patent, a potential issue is whether the combination of EPS's separate products-the Voxter Scan+ scanner and the HS01 BT headset-constitutes a single "indicia reader system" as required by the preamble of the asserted method claim. The patent's abstract describes the system as "including" these separate components, which may support a broader, multi-component interpretation Compl. Ex. F, p. 7, abstract
  • For the '290 Patent, a question may arise regarding the scope of "environmental condition." Honeywell alleges this term reads on ambient background noise in a warehouse Compl. Ex. F, p. 22 The court may need to determine if the patent's teachings limit this term to other types of conditions, such as user-initiated feedback (e.g., a "say again" command).

• Technical Questions:

  • The infringement allegation for the '354 Patent relies on combining functionalities from at least two separate EPS products. A factual question for the court will be whether these products are sold and used together in a manner that performs the complete sequence of steps recited in method claim 10.
  • For the '290 Patent, the allegation centers on the "Noise Controlled Volume" feature. A technical question will be whether the evidence shows this feature actually "monitors" an environmental condition and "modifies" a TTS parameter in response, as required by the claim, or if it operates in a technically distinct manner.

V. Key Claim Terms for Construction

Term from '354 Patent: "indicia reader system"

• The Term: "indicia reader system" (from the preamble of claim 10)
• Context and Importance: The construction of this term is critical because Honeywell's infringement theory appears to be based on the combined operation of at least two separate EPS products (the Voxter scanner and the HS01 headset). Whether this combination constitutes a single "system" under the patent's definition will be a central point of dispute. Practitioners may focus on this term to determine if the claim requires a single, integrated apparatus or if it can encompass a collection of communicating components.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's abstract describes an "indicia reader system including: an indicia reader...; a first device...; [and] a headphone..." Compl. Ex. F, p. 7, abstract This language suggests the "system" is inherently composed of multiple, distinct components working together, which may support an interpretation that covers the combination of accused EPS products.
  • Evidence for a Narrower Interpretation: The detailed drawings in the patent, such as Figure 1, depict the "indicia reader 112" as a single handheld device Compl. Ex. F, p. 7, FIG. 1 Parties arguing for a narrower scope may contend that the figures illustrate a unitary device and that the term "system" should be interpreted in light of this specific embodiment.

Term from '290 Patent: "environmental condition... related to intelligibility"

• The Term: "environmental condition... related to intelligibility of an audible output" (from claim 12)
• Context and Importance: This term's definition is key to determining the scope of the patented method. Honeywell alleges this term covers ambient background noise in a warehouse Compl. Ex. F, p. 22 The dispute may turn on whether the patent limits "environmental condition" to specific types of events (e.g., only user feedback) or if it broadly covers ambient conditions like noise.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's abstract states the invention adjusts parameters "In response to one or more environmental conditions" to increase intelligibility Compl. Ex. F, p. 19, abstract The use of the plural and general term "conditions" may support a broad interpretation that is not limited to any single type of event and could include ambient noise.
  • Evidence for a Narrower Interpretation: Figure 4 of the patent depicts a process box labeled "ADVERSE ENVIRONMENT DETECTED?" which is followed by an increase in the TTS engine's volume Compl. Ex. F, p. 19, FIG. 4 A party could argue that the specific examples or embodiments described in the specification define the metes and bounds of "environmental condition," potentially limiting it to only those conditions explicitly disclosed.

VI. Other Allegations

The complaint is for declaratory judgment and does not itself make allegations of infringement against the Defendants. It does, however, incorporate Honeywell's allegations by reference.

• Indirect Infringement: The claim chart for the '354 patent alleges that EPS "directly and/or indirectly infringes" the patent Compl. Ex. F, p. 8 The factual basis appears to be that EPS provides the component parts (the Voxter scanner and HS01 headset) that, when combined by a user, allegedly perform the patented method.
• Willful Infringement: The complaint documents a long series of letters and communications from Honeywell to EPS, beginning January 18, 2022, providing notice of the asserted patents and alleging infringement Compl. ¶¶23-36 This extensive pre-suit notice could form the basis for a claim of willful infringement by Honeywell against EPS in the parallel EDTX litigation.

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

• A core issue will be one of system definition: can the term "indicia reader system," as used in the '354 patent, be construed to cover the combination of EPS's separate scanner and headset products, or does the claim require a single, integrated device?
• A second central question will be one of technical scope: does the term "environmental condition" in the '290 patent broadly encompass ambient background noise, as alleged by Honeywell, or is its meaning limited by the specific examples disclosed in the patent's specification, potentially creating a non-infringement argument for EPS?
• Finally, a significant procedural question looms over the case: given that Honeywell filed an infringement action in the Eastern District of Texas prior to this declaratory judgment action, the court will need to address whether the first-to-file rule mandates a stay, dismissal, or transfer of this case in favor of the Texas litigation.