DCT

2:25-cv-04890

Fleet Connect Solutions LLC v. CalAmp Corp

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Fleet Connect Solutions LLC (Texas)
- Defendant: CalAmp Corp. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
Case Identification: 2:25-cv-04890, C.D. Cal., 10/03/2025
Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts substantial business in the district, has committed alleged acts of infringement in the district, and has not contested venue in this district in previous litigation.
Core Dispute: Plaintiff alleges that Defendant’s fleet management platforms, telematic devices, and related software infringe nine U.S. patents related to wireless communications, mobile asset management, and vehicle tracking technologies.
Technical Context: The dispute spans several key technologies in telematics and wireless communications, including methods for reducing radio frequency interference, improving data rates in multi-antenna systems, and managing vehicle data.
Key Procedural History: The complaint notes that a related case, originally filed in the Eastern District of Texas, was consolidated into this action, suggesting a multi-front litigation strategy or a prior attempt to secure a different forum.

Case Timeline

Date	Event
1999-09-10	U.S. Patent No. 7,450,955 Priority Date
2000-09-18	U.S. Patent Nos. 8,494,581 & 8,862,184 Priority Date
2001-02-21	U.S. Patent Nos. 6,549,583 & 6,633,616 Priority Date
2001-09-21	U.S. Patent No. 8,005,053 Priority Date
2002-01-10	U.S. Patent No. 6,941,223 Priority Date
2002-10-11	U.S. Patent No. 7,092,723 Priority Date
2003-04-15	U.S. Patent No. 6,549,583 Issued
2003-04-28	U.S. Patent No. 7,260,153 Priority Date
2003-10-14	U.S. Patent No. 6,633,616 Issued
2005-09-06	U.S. Patent No. 6,941,223 Issued
2006-08-15	U.S. Patent No. 7,092,723 Issued
2007-08-21	U.S. Patent No. 7,260,153 Issued
2008-11-11	U.S. Patent No. 7,450,955 Issued
2011-08-23	U.S. Patent No. 8,005,053 Issued
2013-07-23	U.S. Patent No. 8,494,581 Issued
2014-10-14	U.S. Patent No. 8,862,184 Issued
2025-10-03	Complaint Filing Date

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

U.S. Patent No. 8,005,053 - "Channel Interference Reduction"

The Invention Explained

Problem Addressed: The patent addresses radio frequency (RF) interference that occurs when different wireless communication systems, such as Bluetooth and IEEE 802.11, operate in close proximity within the same unlicensed radio band (e.g., 2.4 GHz) (U.S. Patent 7,058,040, col. 1:11-26, parent to the reexamined '053 patent).
The Patented Solution: The invention proposes a method to mitigate interference by having the different systems share one or more Time Division Multiple Access (TDMA) time-slot channels. The system allocates specific time slots to each communication medium, thereby preventing them from transmitting simultaneously and causing interference (U.S. Patent 7,058,040, Abstract; col. 2:4-12). The method also includes dynamically adjusting the number of time slots assigned to each medium to maintain a desired level of service.
Technical Importance: This approach was designed to enable the coexistence of multiple, otherwise conflicting, wireless technologies in a shared, crowded radio spectrum, which is critical for devices incorporating multiple radios (U.S. Patent 7,058,040, col. 1:27-31).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶24).
Claim 1 is a method claim with the following essential elements:
- A base station allocating at least one of a plurality of data channels to a first medium for data transmission via a wireless device.
- The base station allocating at least one remaining data channel to a second medium.
- The base station dynamically adjusting a number of the data channels assigned to one of the media to remain within limits of a desired level of service.
The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range and Extended Rate Across Imperfectly Estimated Channels"

The Invention Explained

Problem Addressed: In Multiple-Input Multiple-Output (MIMO) wireless systems, which use multiple antennas to increase data rates and range, performance is often degraded by "cross-talk interference" between data sub-streams. This problem is exacerbated when the communication channel characteristics are imperfectly estimated, which is typical in real-world scenarios (’153 Patent, col. 3:11-23).
The Patented Solution: The patent describes a method for evaluating the quality of a MIMO channel using a "Channel Matrix Metric" based on the channel's singular values. If a channel is deemed "Bad" (i.e., likely to cause high cross-talk), a "Pre-Equalizer" operator is calculated and applied at the transmitter to transform the channel into a "Good" one, thereby making the communication more robust and predictable before the signal is even sent (’153 Patent, Abstract; col. 4:45-61).
Technical Importance: This invention provides a method to achieve the theoretical performance gains of MIMO systems (higher data rates and extended range) under practical, non-ideal conditions where perfect knowledge of the communication channel is unavailable (’153 Patent, col. 4:31-38).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶33).
Claim 1 is a method claim for evaluating a MIMO channel with the following essential elements:
- Defining a channel matrix metric comprising a predefined function of channel matrix singular values that provides a measure of cross-talk signal-to-noise ratio (SNR).
- Obtaining an estimated channel matrix.
- Performing a singular value decomposition (SVD) of the estimated channel matrix to obtain estimated channel singular values.
- Calculating a respective crosstalk measure for each data sub-stream from the channel matrix metric and the estimated channel singular values.
The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,494,581 - "System and methods for management of mobile field assets via wireless handheld devices"

Technology Synopsis: This patent describes a system where handheld wireless devices are used to manage field operations. It enables functions like data synchronization, logistics, and personnel management by facilitating bi-directional data delivery between enterprise-based servers and the handheld devices in the field (’581 Patent, Abstract).
Asserted Claims: At least claims 21 and 22 (Compl. ¶42).
Accused Features: The complaint alleges that Defendant's fleet management platforms infringe by providing systems for managing mobile assets via wireless handheld devices (Compl. ¶¶15, 41-42).

U.S. Patent No. 7,092,723 - "System and method for communicating between mobile units"

Technology Synopsis: This patent discloses a system for communication between mobile units (e.g., vehicles). The system involves a broadband RF transceiver, a GPS receiver, and a microprocessor in each unit to create communication packets containing information such as the vehicle's position, speed, and direction, enabling vehicle-to-vehicle communication (’723 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶51).
Accused Features: The accused products are alleged to infringe by providing systems and methods for communication between mobile units (Compl. ¶¶15, 50-51).

U.S. Patent No. 6,549,583 - "Optimum phase error metric for OFDM pilot tone tracking in wireless LAN"

Technology Synopsis: The patent describes a method for improving signal tracking in Orthogonal Frequency Division Multiplexed (OFDM) receivers, such as those used in Wi-Fi. It uses pilot tones within the OFDM signal to estimate and compensate for phase errors, particularly those caused by imperfect local oscillators, thereby improving performance especially under poor signal-to-noise conditions (’583 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶60).
Accused Features: The accused products, which utilize wireless LAN technologies, are alleged to infringe by using methods for OFDM pilot tone tracking (Compl. ¶¶15, 59-60; Exhibit H, Exhibit I).

U.S. Patent No. 6,633,616 - "OFDM pilot tone tracking for wireless LAN"

Technology Synopsis: Related to the ’583 patent, this invention also focuses on pilot tone tracking in an OFDM receiver. It describes a pilot phase tracking loop that includes a discrete Fourier transform portion separate from the main FFT, allowing it to determine a phase error estimate more quickly and thereby reduce phase noise introduced by the radio portion of the receiver (’616 Patent, Abstract).
Asserted Claims: At least claim 12 (Compl. ¶69).
Accused Features: Defendant's products employing wireless LAN communications are accused of infringing through their use of OFDM pilot tone tracking methods (Compl. ¶¶15, 68-69; Exhibit J, Exhibit K).

U.S. Patent No. 6,941,223 - "Method and system for dynamic destination routing"

Technology Synopsis: This patent discloses a vehicle navigation system that determines an optimal route based on vehicle position, destination, and additional information (e.g., traffic). The system continuously checks during the drive whether the recommended route remains optimal and can trigger a new route determination if conditions change (’223 Patent, Abstract).
Asserted Claims: At least claim 19 (Compl. ¶78).
Accused Features: Defendant's routing and navigation applications, such as MobileNAV, are accused of infringing by providing dynamic destination routing (Compl. ¶¶15, 77-78).

U.S. Patent No. 7,450,955 - "System and method for tracking vehicle maintenance information"

Technology Synopsis: The patent describes systems and methods for tracking vehicle maintenance information using wireless communication. The system allows a system administrator to identify a vehicle, determine its maintenance status, and send a warning to the vehicle's mobile unit if maintenance is needed (’955 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶87).
Accused Features: The accused fleet management products are alleged to infringe by providing systems for tracking vehicle maintenance information (Compl. ¶¶15, 86-87).

U.S. Patent No. 8,862,184 - "System and methods for management of mobile field assets via wireless handheld devices"

Technology Synopsis: This patent, related to the ’581 patent, covers systems for managing mobile field assets using wireless handheld devices. It facilitates communication from enterprise servers to field devices to support functions like dispatch, data synchronization, and logistics for personnel and inventory (’184 Patent, Abstract).
Asserted Claims: At least claim 1 (Compl. ¶96).
Accused Features: Defendant's fleet management software is accused of infringing by enabling the management of mobile assets via wireless handheld devices (Compl. ¶¶15, 95-96).

III. The Accused Instrumentality

Product Identification

The complaint identifies a wide range of accused instrumentalities, including "fleet management platform and tracking solutions" (Compl. ¶15). These encompass hardware such as "Vehicle telematic devices and/or ELD solutions" (e.g., LMU series, TTU series) and various software platforms and applications (e.g., "CalAmp Fleet Telematics Application," "FleetOutlook," "MobileFind," "MobileNAV," "CalAmp ELD-app") (Compl. ¶15).

Functionality and Market Context

The complaint broadly characterizes the accused products as providing fleet management and tracking functionalities (Compl. ¶15). It does not provide specific technical details on how these products operate. The allegations suggest these products are commercially significant solutions for managing vehicle fleets, assets, and related logistics.
No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a narrative infringement theory or claim charts in the body of the complaint. For each asserted patent, the complaint states that infringement is "detailed in" a corresponding exhibit (e.g., Exhibits A-N) (Compl. ¶¶24, 33, 42, 51, 60, 69, 78, 87, 96). As these exhibits were not provided with the complaint document, a claim chart summary cannot be constructed.

Identified Points of Contention (U.S. Patent No. 8,005,053):
- Scope Questions: A potential dispute may arise over whether the accused products, which utilize modern standards like LTE and Wi-Fi, perform the specific "TDMA time-slot" allocation and "dynamically adjusting" recited in claim 1, or whether they use different, non-infringing methods for managing interference and quality of service.
- Technical Questions: The complaint provides no evidence that Defendant's systems employ a "base station" that performs the claimed allocation and adjustment steps for coordinating between different wireless media in the manner described by the patent.
Identified Points of Contention (U.S. Patent No. 7,260,153):
- Scope Questions: A central issue may be whether the channel estimation and correction techniques used in the accused products fall within the scope of the patent's specific "channel matrix metric," which is defined in relation to "singular values" and "predefined functions" for measuring cross-talk.
- Technical Questions: The infringement allegation raises the question of whether the accused products actually perform the claimed steps of "singular value decomposition" and "calculating a respective crosstalk measure" as part of their MIMO processing, or if they rely on alternative, standard-compliant algorithms that achieve a similar result through a different technical pathway.

V. Key Claim Terms for Construction

For U.S. Patent No. 8,005,053:
- The Term: "dynamically adjusting a number of the data channels... to remain within limits of a desired level of service" (Claim 1)
- Context and Importance: This term appears central to the inventive concept of actively managing shared resources. The dispute will likely focus on whether the quality-of-service (QoS) mechanisms in modern wireless standards (e.g., LTE, Wi-Fi) meet this "dynamically adjusting" limitation, or if the claim requires a specific, non-standard method of reallocation.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification may discuss the general goal of maintaining service quality in a shared spectrum, potentially supporting an interpretation that covers any active resource management.
  - Evidence for a Narrower Interpretation: The detailed description may disclose a specific algorithm where a base station controller monitors performance metrics and explicitly reallocates a specific number of TDMA time slots, suggesting a narrower, more rigid process than modern QoS protocols.
For U.S. Patent No. 7,260,153:
- The Term: "channel matrix metric" (Claim 1)
- Context and Importance: The definition of this term is critical because it forms the basis for the entire claimed evaluation method. Practitioners may focus on this term because the Defendant may argue its channel quality indicators, while functional, are not the specific "metric" defined by the patent, which is explicitly tied to singular values and predefined functions for measuring cross-talk.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The background may refer generally to the need for "channel information" or "channel quality estimation," which could be argued to support a broader meaning covering any form of channel evaluation.
  - Evidence for a Narrower Interpretation: The claim itself defines the metric as "comprising a respective predefined function of channel matrix singular values... such that each of said predefined functions provides a measure of cross-talk signal to noise ratio (SNR)," tying the term directly to a specific mathematical foundation based on SVD and crosstalk SNR (’153 Patent, col. 17:51-57).

VI. Other Allegations

Indirect Infringement: The complaint alleges that Defendant committed acts of infringement "by contributing to and through its inducement of third parties" (Compl. ¶11). However, it does not plead specific facts to support the knowledge and intent requirements for these claims, such as referencing user manuals, marketing materials, or other instructions provided by Defendant to its customers.
Willful Infringement: The complaint does not include an explicit count for willful infringement, nor does it allege facts that would support a claim of pre-suit or post-suit knowledge of the patents, which are typically required to support such a claim.

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

A primary issue will be one of procedural sufficiency: given the complaint's skeletal nature and its complete reliance on unattached exhibits to detail its infringement theories for nine separate patents, a central question for the court will be whether the pleading provides sufficient factual content to state a plausible claim for relief under current federal standards.
A key technical question will be one of technological applicability: can the specific methods disclosed in the asserted patents, some of which date to the early 2000s and address specific problems of that era (e.g., Bluetooth/802.11 coexistence), be shown to be practiced by modern, standard-compliant telematic devices that utilize complex, multi-layered protocols like LTE?
The case will likely involve a significant battle over definitional scope: can claim terms rooted in the specific technical context of the patents, such as "dynamically adjusting... data channels" ('053 Patent) or "channel matrix metric" ('153 Patent), be construed broadly enough to read on the functionally similar but technologically distinct methods used in today's sophisticated wireless systems?