Earlier this year, Eastern District of Texas Judge Rodney Gilstrap denied a motion filed by Marriott challenging the claims of the patents that Liberty Access Technologies Licensing LLC asserted against it in an August 2022 complaint. The court indicated that claim construction “could be of benefit in addressing” whether those claims are directed to the putative abstract idea of “allowing access based on receiving reservation information”, allowing Marriott to refile its Alice motion, if appropriate, after claim construction. Meanwhile, December 2022 defendant ASSA ABLOY has responded to the East Texas complaint filed against it by suing—via subsidiary ASSA ABLOY Global Solutions, Inc.—Liberty Access in a new Northern District of Illinois declaratory judgment action (1:23-cv-00756).

Earlier this year, Liberty Access Technologies Licensing LLC revived litigation over a portfolio of patents generally related to an “access device” for activating a door lock when a “current reservation certificate has been presented”. In 2018, the Empire IP LLC plaintiff, as exclusive licensee, had sued Hilton over its Digital Key, a tool for opening a hotel room door with a mobile device. That case ended within months of filing, the campaign going silent until earlier this year when Liberty Access sued Marriott in the Eastern District of Texas. Now, the plaintiff has added a second active case, hitting ASSA ABLOY (2:22-cv-00507) in the same district over the same three patents.