Causam Enters. v. Ecobee Techs. ULC

Authored by: Jeremy J. Gustrowsky

In a recent decision, the U.S. Court of Appeals for the Federal Circuit upheld a ruling that key claims in a patent for managing electricity use on power grids are unpatentable due to obviousness. The patent, owned by Causam Enterprises, describes a system for utilities to reduce customer power consumption during peak times—known as demand response—by sending control messages to devices like smart appliances. Ecobee Technologies challenged the patent through an inter partes review (IPR) at the Patent Trial and Appeal Board (PTAB), arguing the ideas were already known in prior patents. The PTAB agreed, finding the claims obvious, and Causam appealed to the Federal Circuit.

A major point of contention was whether Causam even had the right to appeal because of questions about patent ownership. Ecobee had raised ownership doubts in a separate trade commission proceeding, but not in the IPR itself. Causam argued the PTAB should have investigated this to ensure due process for any potential true owner. The court rejected this, noting Causam is the recorded owner with no evidence to the contrary, giving it clear standing to challenge the unpatentability decision. Importantly, Causam couldn’t claim rights on behalf of a supposed third-party owner, especially since it insists it’s the sole owner.

On the merits, the dispute centered on how to interpret a key part of the patent claims: generating data to measure and verify reductions in power use. Causam wanted a strict reading requiring real-time measurements during the power cut, but the court sided with the PTAB’s broader view. The patent’s own description includes examples using estimates from pre-event device measurements or averages from past data, so a narrow interpretation would exclude those valid embodiments. With this construction, the prior art fully covered the claims, making them obvious.

The Federal Circuit affirmed the PTAB’s decision, leaving most of Causam’s patent claims canceled. This case highlights how courts prioritize the patent’s full description in interpreting claims and underscores the importance of clear ownership records in patent challenges.