Inventergy LBS LLC v. Meitrack America Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Inventergy LBS, LLC (Delaware)
  • Defendant: Meitrack America Corporation (California)
  • Plaintiff’s Counsel: Law Office of Ryan E. Hatch, PC; RABICOFF LAW LLC
• Case Identification: 2:19-cv-06802, C.D. Cal., 08/06/2019
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is incorporated in the state, maintains an established place of business in the District, and has committed acts of patent infringement within the District.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle tracking products infringe five patents related to systems and methods for remotely communicating with and configuring tracking devices.
• Technical Context: The technology at issue involves remote management of location-aware devices to enhance functionality and conserve resources like battery power and network bandwidth, which are significant considerations in the fleet management and asset tracking industries.
• Key Procedural History: All five patents-in-suit claim priority from the same 2008 provisional patent application, indicating they are part of a single, focused patent family. The complaint does not mention any prior litigation or post-grant proceedings involving these patents.

Case Timeline

Date	Event
2008-02-08	Earliest Priority Date for all Patents-in-Suit
2012-04-10	U.S. Patent No. 8,154,401 Issued
2014-06-24	U.S. Patent No. 8,760,286 Issued
2015-12-22	U.S. Patent No. 9,219,978 Issued
2017-10-03	U.S. Patent No. 9,781,558 Issued
2018-11-13	U.S. Patent No. 10,129,695 Issued
2019-08-06	Complaint Filed

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

U.S. Patent No. 8,760,286 - “System and method for communication with a tracking device”

The Invention Explained

• Problem Addressed: The patent’s background section identifies limitations in prior art tracking systems, including high power consumption which limits operational time, and the cost of network access (i.e., mobile air time) for transmitting data (’286 Patent, col. 1:47-57).
• The Patented Solution: The invention is a tracking device that can be remotely reconfigured by a central system. A remote system sends “configuration data” to the device, which modifies its functionality (’286 Patent, Abstract). This allows for dynamic control over operations such as the interval for buffering location data when the device is out of communication range, thereby managing power and network usage more efficiently (’286 Patent, col. 2:26-37). The overall method is depicted in the patent’s Figure 5, which shows a remote system providing configuration data to the device and receiving processed data in return.
• Technical Importance: This approach allows for more flexible and efficient operation of tracking devices compared to earlier systems that often had static, power-intensive reporting behaviors.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶14).
• Claim 1 of the ’286 Patent requires:
  • A tracking device comprising a location detector, a communication device, memory, and a processor.
  • The memory stores location data and "configuration data."
  • A "configuration routine" modifies the configuration data in response to communication from a remote system.
  • The modifiable configuration data determines an "interval for buffering" location data when communication is lost.
  • This interval "controls how frequently newly acquired location data will be stored in said memory."
• The complaint reserves the right to assert additional claims (Compl. ¶13).

U.S. Patent No. 8,154,401 - “System and method for communication with a tracking device”

The Invention Explained

• Problem Addressed: The patent addresses the same technical challenges as its family member, the ’286 Patent: the high cost of network access and significant power consumption in personal tracking devices, which limit their utility and endurance (’401 Patent, col. 1:29-44).
• The Patented Solution: The invention provides "functional access" to the tracking device from a remote system, allowing for modification of its "configuration data" (’401 Patent, Abstract). One specific solution described is using this configuration data to set a "threshold distance" the device must move before it stores a new location point. This prevents the device from needlessly recording and storing data points when it is stationary, thereby conserving memory and, by extension, power and network resources (’401 Patent, col. 2:36-43).
• Technical Importance: By enabling remote control over data storage logic based on movement, the invention provides a method to reduce redundant data collection and transmission.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶29).
• Claim 1 of the ’401 Patent requires:
  • A tracking device comprising a location detector, communication device, memory, and processor.
  • A "configuration routine" that modifies the device’s "configuration data" based on communications from a remote system.
  • The modifiable configuration data determines a "threshold distance between one of said locations and subsequent ones of said locations for storing said subsequent ones of said locations."
• The complaint reserves the right to assert additional claims (Compl. ¶29).

U.S. Patent No. 10,129,695 - “System and method for communication with a tracking device”

• Technology Synopsis: This patent addresses the problem of data loss when a tracking device moves out of its communication network's range. The solution involves a device that can be remotely configured to buffer location data when communication is lost and then transmit the stored data once communication is restored, ensuring a more complete location history is available to the remote system (’695 Patent, col. 2:16-25, col. 42:57-65).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶39).
• Accused Features: The accused features are the general functionalities of the Meitrack products that permit remote configuration of data reporting and buffering behavior (Compl. ¶39, ¶45).

U.S. Patent No. 9,219,978 - “System and method for communication with a tracking device”

• Technology Synopsis: This patent discloses a remotely configurable tracking device where the configuration data is used to define a "monitored condition" based on the device's location, such as a "geofence" (’978 Patent, col. 2:44-51). The device is configured to transmit location data and information about the monitored condition (e.g., a geofence breach), and to buffer this data if communication with the remote system is lost (’978 Patent, col. 43:23-43).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶49).
• Accused Features: The accused features are the geofencing, alert, and data buffering capabilities of the Meitrack products, which are allegedly configured and managed remotely (Compl. ¶49, ¶55).

U.S. Patent No. 9,781,558 - “System and method for communication with a tracking device”

• Technology Synopsis: This patent focuses on power management. The invention is a tracking device whose "power state" can be controlled by remotely modifiable configuration data (’558 Patent, Abstract; col. 2:40-43). The device also includes a "reporting routine" to communicate operational data, such as battery status or signal strength, back to the remote system, allowing for comprehensive remote diagnostics and management (’558 Patent, col. 42:46-51).
• Asserted Claims: Independent claim 31 is asserted (Compl. ¶59).
• Accused Features: The accused features relate to the power management modes and diagnostic reporting functionalities of the Meitrack products (Compl. ¶59, ¶65).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Meitrack's MVT380" as an "Exemplary Meitrack Product" and makes allegations against a broader category of "Exemplary Meitrack Products" (Compl. ¶12).

Functionality and Market Context

The accused products are described as vehicle tracking devices. Based on the allegations, these devices determine their geographic location and communicate that information to a remote system (Compl. ¶19, ¶25). The complaint alleges that these products include functionality that allows them to be remotely configured by users to control how and when location data is buffered, stored, and reported (Compl. ¶25, ¶35, ¶45, ¶55, ¶65). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent (Exhibits 6-10), but these exhibits were not filed with the complaint itself (Compl. ¶25, ¶35, ¶45, ¶55, ¶65). The infringement theories are therefore summarized below in prose based on the complaint's narrative allegations.

’286 Patent Infringement Allegations

The complaint alleges that the accused Meitrack products directly infringe at least claim 1 of the ’286 Patent (Compl. ¶19). The infringement theory posits that the products possess the claimed hardware elements (processor, memory, location detector, etc.) and that their software allows a remote system to set an "interval for buffering" location data (Compl. ¶25). This allegedly satisfies the claim requirement that remotely modifiable configuration data controls the frequency with which location data is stored when the device cannot communicate with the remote system (Compl. ¶25).

’401 Patent Infringement Allegations

The infringement theory for the ’401 Patent is that the accused products infringe at least claim 1 by implementing a feature where a remote user can set a "threshold distance" (Compl. ¶35). The complaint alleges that this feature dictates that subsequent location data points are only stored after the device has moved by that threshold distance, which Plaintiff contends meets the final limitation of claim 1 (Compl. ¶35).

Identified Points of Contention

• Scope Questions: A potential point of contention for the ’401 Patent is whether the term "for storing," as used in the claim, requires the distance threshold to be a direct logical input to the data storage decision. The question may arise as to whether a distance threshold used for triggering data transmission (a common feature in tracking devices) falls within the scope of a claim that specifies the threshold is "for storing." The complaint's allegations do not draw a distinction between these potentially separate functions.
• Technical Questions: For the ’286 Patent, a key technical question is whether the accused products' "interval for buffering" functionality operates to control the frequency of data storage during a communication outage, as the claim language requires (i.e., "controls how frequently"). The complaint does not provide detail on whether the accused feature is a rate-setting mechanism or a simple condition that enables or disables buffering altogether.

V. Key Claim Terms for Construction

"interval for buffering" (’286 Patent, claim 1)

• Context and Importance: This term is central to the infringement analysis for the ’286 Patent. Its construction will determine whether a simple setting to enable or disable buffering when out of range is sufficient for infringement, or if the claim requires a more specific, configurable time or distance period that dictates the rate of data storage.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses that the interval can be a "time interval (e.g., every 30 minutes) or a distance interval (e.g., whenever the tracking device moves 50 yards)" (’286 Patent, col. 2:34-37). This language may support an interpretation that covers various types of conditions, not just a strict frequency.
  • Evidence for a Narrower Interpretation: The claim states this interval "controls how frequently newly acquired location data will be stored." Defendant may argue this requires a rate-setting function (e.g., store one location point every five minutes while offline), which may be narrower than a simple trigger condition (e.g., store all data points once communication is lost).

"threshold distance ... for storing said subsequent ones of said locations" (’401 Patent, claim 1)

• Context and Importance: The viability of the infringement claim for the ’401 Patent may depend on this term. The dispute will likely focus on whether the thresholding feature in the accused products is used for the purpose of storing data, as the claim recites, or for the more common purpose of transmitting data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides an example of configuration data that "determines a threshold distance between one of the locations and subsequent ones of the locations for storing the subsequent ones... (e.g., only buffer location data if the tracking device has moved at least the threshold distance)" (’401 Patent, col. 2:36-43). Plaintiff may argue this language directly supports its theory that a threshold for buffering/storing is what was patented.
  • Evidence for a Narrower Interpretation: Defendant may argue that the phrase "for storing" imparts a functional and purposeful limitation. If the accused devices store all location data points by default and only use a distance threshold to decide when to transmit a batch of already-stored data, it may be argued that the threshold is not "for storing" and therefore does not meet this limitation.

VI. Other Allegations

Indirect Infringement

For all asserted patents, the complaint alleges induced and contributory infringement. The basis for these claims is Defendant's alleged sale of the accused products to customers along with the distribution of "product literature and website materials" that instruct or encourage end-users to operate the products in an infringing manner (e.g., Compl. ¶23-24, ¶33-34).

Willful Infringement

The complaint alleges that Defendant's infringement will be willful from the date of service of the complaint. The allegations are based on continued infringement despite having "actual knowledge" of the patents-in-suit from this litigation (e.g., Compl. ¶21-22, ¶31-32).

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

• A core issue will be one of functional specificity: do the accused products’ remote configuration features for data buffering and thresholding operate in the precise manner claimed? The case may turn on evidence distinguishing between common industry practices, such as using distance thresholds for triggering data transmission, and the specific claim language requiring these configurations to control the conditions and frequency of data storage.
• A key evidentiary question will be one of technical proof: given that the complaint makes conclusory allegations without providing supporting technical documents or evidence, the case will likely depend on what Plaintiff can obtain through discovery to demonstrate that the internal software logic of the Meitrack devices performs the specific functions recited in the patent claims, rather than similar but technically distinct operations.