Fleet Connect Solutions LLC v. Schneider National Carriers Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fleet Connect Solutions LLC (Texas)
  • Defendant: Schneider National Carriers Inc. (Nevada)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC; Insight, PLLC
• Case Identification: 2:24-cv-10435, C.D. Cal., 12/04/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business in the Central District of California, including facilities in South El Monte and San Bernardino, and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management and tracking solutions infringe seven patents related to dynamic vehicle routing, handheld data management for field operations, intelligent trip status notification, group navigation tracking, and wireless packet generation methods.
• Technical Context: The technology at issue falls within the domain of fleet telematics and logistics management, a field focused on using telecommunications and information technology to optimize the efficiency, safety, and management of commercial vehicle fleets.
• Key Procedural History: The complaint does not mention any prior litigation involving the asserted patents, any Inter Partes Review (IPR) proceedings, or specific licensing history relevant to the dispute.

Case Timeline

Date	Event
2000-09-18	Earliest Priority Date for ’586, ’751, and ’184 Patents
2002-01-10	Earliest Priority Date for ’223 Patent
2002-11-04	Earliest Priority Date for ’837 Patent
2004-07-20	Earliest Priority Date for ’388 Patent
2005-09-06	U.S. Patent No. 6,941,223 Issues
2005-11-01	U.S. Patent No. 6,961,586 Issues
2007-04-17	U.S. Patent No. 7,206,837 Issues
2008-06-20	Earliest Priority Date for ’968 Patent
2009-09-29	U.S. Patent No. 7,593,751 Issues
2010-06-22	U.S. Patent No. 7,741,968 Issues
2010-06-22	U.S. Patent No. 7,742,388 Issues
2014-10-14	U.S. Patent No. 8,862,184 Issues
2024-12-04	Complaint Filed

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

U.S. Patent No. 6,941,223 - “Method And System For Dynamic Destination Routing”

The Invention Explained

• Problem Addressed: The patent describes the inadequacy of vehicle navigation systems that compute a static route without considering real-time information, such as traffic, which can render the initial route suboptimal during a trip (Compl. ¶25; ’223 Patent, col. 1:12-24). Existing dynamic systems were also noted to have limitations, such as relying on single sources of information, which could affect reliability and driver acceptance (’223 Patent, col. 1:40-54).
• The Patented Solution: The invention proposes a two-part system: a component fixedly installed in the vehicle for basic navigation and a portable component (e.g., a PDA) that connects to it. This portable unit is responsible for receiving and analyzing "additional information" from multiple sources (e.g., internet services, traffic message channels) to compute a "dynamically optimal route." A key aspect is the system’s ability to perform a "self-diagnosis" during the drive by comparing actual travel progress against the parameters of the computed optimal route to check if it remains optimal, triggering a new route computation if a deviation occurs (’223 Patent, Abstract; col. 2:59-col. 3:5; col. 5:58-62).
• Technical Importance: This functional division allows the dynamic routing logic, which is subject to constant change as new data services emerge, to be updated easily via the portable unit without altering the vehicle’s integrated hardware (’223 Patent, col. 3:25-41).

Key Claims at a Glance

• The complaint asserts at least independent claim 19 (Compl. ¶28).
• Essential elements of independent method claim 19 include:
  • determining, based on static information, an optimal route;
  • receiving additional information;
  • determining, based on a comparison of real travel parameters of the vehicle with travel parameters associated with the optimal route, whether the optimal route remains optimal; and
  • determining a new optimal route when the optimal route does not remain optimal, using the additional information, where travel parameters include at least travel time or traveled distance.
• The complaint’s use of "one or more claims" suggests the right to assert additional dependent claims is preserved (Compl. ¶27).

U.S. Patent No. 6,961,586 - “Field Assessments Using Handheld Data Management Devices”

The Invention Explained

• Problem Addressed: The patent identifies a problem in industries requiring field assessments (e.g., construction, appraisals) where less-experienced personnel may lack access to critical information or expert guidance, potentially leading to inaccurate or inefficient work (’586 Patent, col. 1:19-33).
• The Patented Solution: The invention describes a system using a handheld computing device (e.g., a PDA) loaded with an "industry-specific field assessment program module." This software guides the field user through a structured process, such as a checklist or a series of prompts. The system enables two-way communication, allowing the handheld device to synchronize data with a remote server or computer, facilitating real-time analysis, assistance from remote experts, and access to centralized information (’586 Patent, Abstract; col. 3:19-44; Fig. 7).
• Technical Importance: The technology aims to improve the accuracy and professionalism of field operations by providing personnel with structured, computer-guided workflows and real-time access to remote data and expertise (’586 Patent, col. 1:50-57).

Key Claims at a Glance

• The complaint asserts at least independent claim 9 (Compl. ¶37).
• Essential elements of independent method claim 9 include:
  • providing a handheld device user, acting as a field assessor, access to an industry-specific field assessment program module for executing various assessment types;
  • executing the program module to conduct the field assessment;
  • providing field-specific information required by the program module to render data supporting the assessment; and
  • retrieving data through the handheld device in support of the assessment.
• The complaint’s language suggests the right to assert additional claims is preserved (Compl. ¶36).

U.S. Patent No. 7,206,837 - “Intelligent Trip Status Notification”

• Technology Synopsis: The patent describes methods for providing periodic trip status information, such as time-of-arrival estimates, to a user in transit. The system calculates these metrics based on a plurality of data inputs, including the user's current location, calendrical time (time and date), mode of travel, historical travel data, and current/forecasted weather and traffic conditions (’837 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶46).
• Accused Features: Defendant's fleet management and tracking solutions that provide real-time vehicle tracking and status notifications, including estimated times of arrival (Compl. ¶¶ 16, 19).

U.S. Patent No. 7,593,751 - “Conducting Field Operations Using Handheld Data Management Devices”

• Technology Synopsis: The patent covers methods for conducting field operations using a portable device. The method includes providing instructions to an operator via the device, establishing communication with a remote resource for support, and providing collected data back to a remote server. This technology appears related to the subject matter of the ’586 patent (’751 Patent, Abstract).
• Asserted Claims: At least claim 6 (Compl. ¶55).
• Accused Features: Defendant's use of in-cab tablets and connected devices for functions such as PS Workflow, PS Messages, and PS DVIR, which involve guided processes and data transmission to a central system (Compl. ¶¶ 16, 19).

U.S. Patent No. 7,741,968 - “System and Method For Navigation Tracking of Individuals In a Group”

• Technology Synopsis: The invention discloses a system where a "master" portable device can be grouped with a plurality of other portable devices. The master device is able to maintain and display the geographic positions of all other devices in the group, facilitating group tracking and coordination (’968 Patent, Abstract).
• Asserted Claims: At least claim 4 (Compl. ¶64).
• Accused Features: Defendant's fleet management solutions, such as PS Fleets and PS Asset Tracking, which track and manage the locations of multiple vehicles within a fleet (Compl. ¶16).

U.S. Patent No. 7,742,388 - “Packet Generation Systems And Methods”

• Technology Synopsis: The patent describes a method for increasing the data rate in a digital communication system, such as a wireless local area network. The technique involves adding subcarriers to a standard-sized data packet to create an "extended data signal," thereby increasing bandwidth and data throughput (’388 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶79).
• Accused Features: The Accused Products' implementation of wireless communications pursuant to various standards, including IEEE 802.11 protocols, which allegedly involve the generation of data packets (Compl. ¶¶ 17-18).

U.S. Patent No. 8,862,184 - “System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices”

• Technology Synopsis: This invention relates to systems for managing mobile field assets (personnel, equipment) using wireless handheld devices. The system architecture involves enterprise servers providing dispatch, data synchronization, and logistics information to field devices, which in turn report data back to enable real-time management of field operations. This technology is in the same family as the ’586 and ’751 patents (’184 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶94).
• Accused Features: Defendant's comprehensive fleet management platform, which uses in-cab devices to communicate with a central system for managing vehicle assets, workflows, and logistics (Compl. ¶¶ 16, 19).

III. The Accused Instrumentality

Product Identification

• The complaint identifies a suite of fleet management and tracking solutions, collectively termed the "Accused Products." Specific named components include, but are not limited to, PS Navigation, PS Analytics, PS Telematics, PS Workflow, PS Messages, PS DVIR, PS Fleets, PS HOS, and PS Asset Tracking, as well as associated hardware such as In-Cab Tablets and Connected Vehicle Devices (Compl. ¶16). These products are allegedly manufactured by Platform Science, Inc., in which Defendant's corporate parent is an investor (Compl. ¶¶14-15).

Functionality and Market Context

• The Accused Products allegedly constitute a comprehensive fleet management platform that performs functions including vehicle tracking, dynamic navigation, data analysis, driver-administrator communication, and workflow management (Compl. ¶¶16, 19). These products are said to utilize various wireless communication standards, including Bluetooth, IEEE 802.11, and LTE, to transmit data and connect in-vehicle hardware with a central system (Compl. ¶17). The complaint alleges Defendant, a national carrier, uses and distributes these products in its fleet operations (Compl. ¶¶4, 16).
  No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,941,223 Infringement Allegations

Claim Element (from Independent Claim 19)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
determining, based on static information, an optimal route	The "PS Navigation" component of the Accused Products allegedly computes vehicle routes (Compl. ¶16).	¶16	col. 6:52-57
receiving additional information	The Accused Products' telematics and wireless communication capabilities (e.g., via LTE) are alleged to receive dynamic data such as real-time traffic information (Compl. ¶¶16-17).	¶¶16-17	col. 6:45-51
determining, based on a comparison of real travel parameters of the vehicle with travel parameters associated with the optimal route, whether the optimal route remains optimal	The platform allegedly analyzes vehicle progress and communications to dynamically manage routing, which suggests a re-evaluation of the current route's optimality (Compl. ¶¶16, 19).	¶¶16, 19	col. 7:33-38
and determining a new optimal route when the optimal route does not remain optimal...	The "PS Navigation" functionality is alleged to provide dynamic routing, which implies the calculation of new routes in response to updated information (Compl. ¶16).	¶16	col. 7:59-62

• Identified Points of Contention:
  • Scope Questions: A potential point of contention may be whether the Accused Products' method for re-routing meets the specific limitation of "a comparison of real travel parameters of the vehicle with travel parameters associated with the optimal route." The question for the court will be whether simply reacting to new external traffic data satisfies this element, or if the claim requires a more specific internal comparison of actual versus predicted progress along the originally computed route.
  • Technical Questions: The complaint does not specify the precise algorithm or data points used by the PS Navigation system for dynamic routing. The factual question will be what evidence demonstrates that the accused system performs the specific comparison required by the claim, rather than a more generic form of dynamic re-routing.

U.S. Patent No. 6,961,586 Infringement Allegations

Claim Element (from Independent Claim 9)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing a hand held data management device user performing as a field assessor access to a industry-specific field assessment program module for enabling the field assessor to execute at least one of the following field assessments...	Defendant allegedly provides drivers with "In-Cab Tablets" that run software applications such as "PS Workflow," "PS Messages," and "PS DVIR," which guide field operations (Compl. ¶16).	¶16	col. 3:45-56
executing said program module to conduct the field assessment	Drivers and other field personnel allegedly operate these software modules on the in-cab devices as part of their duties (Compl. ¶16).	¶16	col. 12:5-11
providing field-specific information required by said program module for said program module to render data in support of said field assessment	The accused software modules, such as those for vehicle inspection reports ("PS DVIR") or custom forms ("PS Form Messages"), allegedly prompt users for specific data input (Compl. ¶16).	¶16	col. 14:50-55
and retrieving data through said handheld data management device in support of said field assessment	Data entered by users into the in-cab devices is allegedly transmitted wirelessly back to a central system for tracking, analysis, and management (Compl. ¶¶16, 19).	¶¶16, 19	col. 12:11-14

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the definition of a "field assessment program module." The question for the court will be whether routine logistical tasks performed via the accused software (e.g., filling out a vehicle inspection report, confirming a delivery) fall within the scope of an "assessment," a term the patent specification often illustrates with more complex examples like construction project estimation.
  • Technical Questions: The complaint does not detail the user interface or workflow of the accused software. A key factual question will be the degree to which these modules actively guide the user through a structured analytical process, as opposed to simply serving as electronic data entry forms.

V. Key Claim Terms for Construction

U.S. Patent No. 6,941,223

• The Term: "a comparison of real travel parameters... with travel parameters associated with the optimal route" (Claim 19)
• Context and Importance: This phrase defines the core of the dynamic "self-diagnosis" feature. The viability of the infringement allegation depends on whether the accused system performs this specific type of comparison. Practitioners may focus on this term because it distinguishes the claimed invention from generic systems that simply re-route based on new external alerts without referencing the original route's predicted parameters.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes "actual driving progress" broadly as "the actually covered path and/or the time which has passed since the start of the drive" (’223 Patent, col. 2:2-4), which could support construing the comparison element flexibly.
  • Evidence for a Narrower Interpretation: The specification frames the check as determining if "the actual parameters deviate from the determined parameters of the optimal route" (’223 Patent, col. 1:63-66), suggesting a direct comparison against a pre-calculated set of data points (e.g., expected time at waypoints) rather than a general re-evaluation in light of new, unrelated information.

U.S. Patent No. 6,961,586

• The Term: "field assessment program module" (Claim 9)
• Context and Importance: The definition of this term is critical for determining whether the accused products, which are used for fleet logistics, fall within the scope of the patent. Practitioners may focus on this term because the patent's specification provides detailed examples primarily from the construction and HVAC industries, raising the question of its applicability to the different context of transportation logistics.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 8 of the patent, which depends from an independent claim similar to claim 9, explicitly lists a wide range of applications, including "project management," "equipment readiness," "inventory tracking," and "multi-users remote function coordination," suggesting the term is not limited to construction or HVAC (’586 Patent, claim 8).
  • Evidence for a Narrower Interpretation: The detailed description repeatedly uses examples of complex, guided assessments, such as troubleshooting HVAC equipment or preparing a detailed construction estimate, where the program provides significant guidance to an "inexperienced" user (’586 Patent, col. 9:15-34, 9:46-54). This context may support a narrower construction limited to programs that provide substantive, quasi-expert guidance rather than simple data collection.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement and contributory infringement for the ’968 and ’388 patents. The inducement theory is based on allegations that Defendant provides the Accused Products to end-users (e.g., drivers, contractors) and provides instructions and technical support that guide them to use the products in an infringing manner (Compl. ¶¶65, 80). The contributory infringement allegation asserts that the Accused Products have "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶¶66, 81).
• Willful Infringement: Willfulness is alleged for the ’968 and ’388 patents. The allegations are based on knowledge of the patents "at least as of the date when it was notified of the filing of this action" (Compl. ¶¶67, 82). The complaint further alleges that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness (Compl. ¶¶68, 83).

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

1. Definitional Scope: A core issue will be one of definitional scope: can terms like "field assessment," rooted in the patent specifications' examples of complex construction and technical evaluations, be construed to cover the more routine logistical and compliance tasks (e.g., vehicle inspections, delivery status updates) performed by the accused fleet management software?
2. Functional Specificity: A key evidentiary question will be one of functional specificity: do the accused products perform the precise technical steps recited in the claims? For example, does the accused navigation system perform the specific "comparison of real travel parameters... with travel parameters associated with the optimal route" as required by the ’223 patent, or does it employ a technically different method of dynamic re-routing?
3. Patent Eligibility: Given the subject matter involves processing information, managing data, and coordinating activities, a central challenge for the plaintiff may be defending the patents under 35 U.S.C. § 101. The case may turn on whether the asserted claims are found to be directed to patent-ineligible abstract ideas or, as the plaintiff will argue, recite specific, non-conventional improvements to computer functionality and network operations.