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Honeywell v. Nest Labs: Complaint for Patent Infringement

Interesting Quotes from Honeywell's Complaint

  1. Paragraph 3:
    "Upon information and belief, Nest Labs was founded by Tony Fadell and Matt Rogers, and is backed by significant investment from Kleiner Perkins Caufield & Byers, Google Ventures, Lightspeed Venture Partners, Intertrust, Shasta Ventures and Generation Investment Management."
  2. Paragraph 11:
    "Honeywell commercialized the first adjustable thermostat that allowed people to sleep through the night without having to manually turn their furnaces on and off to maintain a comfortable temperature."
  3. Paragraph 11:
    "Honeywell’s iconic “round” thermostat is featured in the Smithsonian."
  4. Paragraph 43:
    "Media coverage of the Nest Thermostat includes pictures taken at Nest Labs that show that Nest Labs examined numerous Honeywell thermostats. See Indeed, each of the thermostats circled in red appears to be a different Honeywell thermostat model –ranging from Honeywell’s digital round thermostats, model numbers T8775C 1005 and T8775A 1009, to Honeywell’s Prestige® thermostats that embody and are marked with the ‘504 Patent."
  5. Paragraph 44:
    "The Nest Thermostat also includes a notice that it is subject to Patents Pending."
  6. Paragraph G:
    "To declare this case to be “exceptional” under 35 U.S.C. § 285 and to award Honeywell its attorneys’ fees, expenses, and costs incurred in this action[.]"

Docket & History

  1. Complaint
  2. Complaint Exhibit 1
  3. Complaint Exhibit 2
  4. Complaint Exhibit 3
  5. Complaint Exhibit 4
  6. Complaint Exhibit 5
  7. Complaint Exhibit 6
  8. Complaint Exhibit 7
  9. Complaint Exhibit 8

Honeywell v. Nest: Court & Judge Information

Court Case Number: 0:12-cv-00299-SRN-JSM
File Date: Monday, February 06, 2012
Plaintiff: Honeywell International, Inc.
Plaintiff Counsel: Andrew F. Johnson, Kenneth A. Liebman, Joel D. Sayres, Nina Y. Wang, Randall E. Kahnke of Faegre Baker Daniels LLP
Defendant: Nest Labs, Inc. and Best Buy Co., Inc.
Court: Minnesota District Court
Judge: Judge Susan Richard Nelson
Referred To: Magistrate Judge Janie S. Mayeron

Honeywell's Patents in PDF Format

  1. United States Patent No. 7,634,504 US7634504.pdf
  2. United States Patent No. 7,142,948
  3. United States Patent No. 6,975,958
  4. United States Patent No. 7,584,899
  5. United States Patent No. 7,159,789
  6. United States Patent No. 7,159,790
  7. United States Patent No. 7,476,988

How is a trademark for trash removal confused with equipment rental?

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