Causam Enterprises, Inc. v. International Trade Commission (ITC) & Resideo

22/12/2025

Causam Enterprises, Inc. (formerly Causam Energy, Inc.) owns U.S. Patent No. 10,394,268, related to demand-response technology for electrical utilities. Causam filed a complaint before the ITC alleging that Resideo Smart Homes Technology and its affiliate Ademco, Inc. were violating Section 337 of the Tariff Act of 1930 by importing and selling smart thermostats that infringed claim 1 of the '268 patent. The ITC instituted an investigation, and an Administrative Law Judge (ALJ) ruled that Causam did not own the patent and that Resideo's products did not infringe. The full Commission observed that there was no infringement with respect to the patent violation but did not address the ownership issue. Causam appealed the decision of no infringement.

 

1. Ownership: Whether Causam owns the '268 patent.

2. Infringement: Whether Resideo's smart thermostats infringe claim 1 of the '268 patent.

Ruling

• Ownership: The Federal Circuit concluded that Causam owns the '268 patent.

• Infringement: The court did not reach the infringement issue due to the ownership determination.

 

The Federal Circuit affirmed that Causam has Article III standing to bring the appeal, as it established ownership of the '268 patent. However, the court found that the appeal was moot because the Patent Trial and Appeal Board (PTAB) had previously ruled that claim 1 of the '268 patent was un-patentable. As a result, Causam had no right to an exclusion order under Section 337 of the Tariff Act. The court dismissed the appeal as moot and ordered that each party bear its own costs.

NANDINI KOHLI