DCT

2:25-cv-06695

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; Hatch Law, P.C.
Case Identification: 2:25-cv-06695, C.D. Cal., 09/10/2025
Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant maintains established and regular places of business in the district and has committed acts of infringement there. The complaint also notes that Defendant has not contested venue in this district in prior litigation.
Core Dispute: Plaintiff alleges that Defendant’s fleet telematics and asset tracking products infringe five patents related to wireless communication signal processing, dynamic vehicle routing, and mobile asset management.
Technical Context: The technology at issue falls within the fleet telematics and mobile resource management sector, a commercially significant market focused on tracking, managing, and communicating with vehicles and other mobile assets.
Key Procedural History: The complaint references prior litigation, Sunset Licensing LLC v. CalAmp Corp., in which Defendant allegedly did not contest the propriety of venue in the Eastern District of Texas. No prior proceedings involving the asserted patents, such as Inter Partes Reviews, are mentioned.

Case Timeline

Date	Event
1999-09-10	’955 Patent Priority Date
2000-09-18	’184 Patent Priority Date
2001-02-21	’583 Patent Priority Date
2001-08-21	’616 Patent Priority Date
2002-01-10	’223 Patent Priority Date
2003-04-15	’583 Patent Issue Date
2003-10-14	’616 Patent Issue Date
2005-09-06	’223 Patent Issue Date
2008-11-11	’955 Patent Issue Date
2014-10-14	’184 Patent Issue Date
2025-09-10	Complaint Filing Date

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

U.S. Patent No. 6,549,583 - “Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN,” Issued April 15, 2003

The Invention Explained

Problem Addressed: The complaint alleges that the claimed inventions improve upon the function and operation of "preexisting error estimation methods" used in wireless communications (Compl. ¶25).
The Patented Solution: The complaint describes the invention as a method for estimating pilot phase error in an Orthogonal Frequency Division Multiplexed (OFDM) receiver (Compl. ¶30). The method first determines "pilot reference points" from a preamble waveform that precedes the data. It then estimates an "aggregate phase error" for a subsequent data symbol by using a "maximum likelihood-based estimation" that considers the complex signal measurements from all pilots in that symbol relative to the reference points (Compl. ¶30).
Technical Importance: The approach is presented as an improvement to the functionality and operation of prior art error estimation techniques in OFDM systems (Compl. ¶25).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶29).
The essential elements of claim 1, as described in the complaint, include:
- determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform;
- estimating an aggregate phase error of a subsequent OFDM data symbol relative to the pilot reference points using complex signal measurements corresponding to each of the plurality of pilots of the subsequent OFDM data symbol and the pilot reference points; and
- wherein the estimating step comprises performing a maximum likelihood-based estimation using the complex signal measurements. (Compl. ¶30).

U.S. Patent No. 6,633,616 - “OFDM Pilot Tone Tracking for Wireless LAN,” Issued October 14, 2003

The Invention Explained

Problem Addressed: The complaint asserts that the invention provides inventive components that "improve upon the function and operation of preexisting error estimation methods" (Compl. ¶35).
The Patented Solution: The complaint describes a method of pilot phase error estimation in an OFDM receiver that involves parallel processing paths and specific operational timing (Compl. ¶40). One path determines pilot reference points from a preamble waveform and then determines a phase error estimate for a subsequent data symbol. A "parallel path" processes both the preamble and the subsequent data symbol with a fast Fourier transform (FFT). Critically, the claim requires that the phase error estimation step is completed before the FFT processing of the subsequent data symbol is finished (Compl. ¶40).
Technical Importance: This architectural and temporal arrangement is alleged to be an improvement over prior art error estimation methods (Compl. ¶35).

Key Claims at a Glance

The complaint asserts at least independent claim 12 (Compl. ¶39).
The essential elements of claim 12, as described in the complaint, include:
- determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform;
- processing, in a parallel path to the determining step, the OFDM preamble waveform with a fast Fourier transform;
- determining a phase error estimate of a subsequent OFDM symbol relative to the pilot reference points;
- processing, in the parallel path..., the subsequent OFDM symbol with the fast Fourier transform; and
- wherein the step of determining the phase error estimate is completed prior to the completion of the processing of the subsequent OFDM symbol with the fast Fourier transform in the parallel path. (Compl. ¶40).

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

Patent Identification: U.S. Patent No. 6,941,223, “Method And System For Dynamic Destination Routing,” Issued September 6, 2005 (Compl. ¶43).
Technology Synopsis: The patent addresses the problem of improving driver acceptance of dynamic vehicle routing systems (’223 Patent, col. 1:37-40). The solution is a method that determines an initial optimal route, receives additional real-time information during travel, and dynamically determines a new optimal route if a comparison of real travel parameters (e.g., travel time) against the planned parameters indicates the original route is no longer optimal (Compl. ¶50; ’223 Patent, Abstract).
Asserted Claims: At least independent claim 19 (Compl. ¶49).
Accused Features: The complaint alleges Defendant’s products perform a method for the dynamic destination routing of a vehicle (Compl. ¶50).

U.S. Patent No. 7,450,955 Capsule

Patent Identification: U.S. Patent No. 7,450,955, “System And Method For Tracking Vehicle Maintenance Information,” Issued November 11, 2008 (Compl. ¶53).
Technology Synopsis: The patent addresses limitations in prior vehicle communication systems (’955 Patent, col. 1:21-41). The invention is a method for tracking vehicle maintenance where a system administrator identifies a vehicle, determines an associated warning, generates a baseband message data packet containing the warning and unique identifiers, upconverts the data to radio frequency for transmission to the vehicle’s mobile unit, and receives a confirmation of receipt (Compl. ¶60; ’955 Patent, col. 2:53-67).
Asserted Claims: At least independent claim 1 (Compl. ¶59).
Accused Features: Defendant is accused of performing a method for tracking vehicle maintenance information via a system administrator (Compl. ¶60).

U.S. Patent No. 8,862,184 Capsule

Patent Identification: U.S. Patent No. 8,862,184, “System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices,” Issued October 14, 2014 (Compl. ¶63).
Technology Synopsis: The patent addresses the need for improved systems for managing mobile assets and personnel in the field (’184 Patent, col. 1:32-2:8). The claimed solution is a method comprising downloading a "field assessment program" to a handheld device from a geographically distant server, executing the program to assess a job, collecting data, using the device to obtain location information, rendering the data, and providing a job assessment (Compl. ¶70; ’184 Patent, col. 14:34-49).
Asserted Claims: At least independent claim 1 (Compl. ¶69).
Accused Features: The complaint alleges Defendant’s products perform a method of downloading and executing a field assessment program on a handheld device (Compl. ¶70).

III. The Accused Instrumentality

Product Identification: The Accused Products include a range of fleet management and asset tracking solutions, including the CalAmp Fleet Telematics Application/Software/Website, FleetOutlook, CalAmp iOn Fleet and Asset Management Application, and numerous hardware devices such as the LMU, HMU, TTU, and ATU series trackers (Compl. ¶17).
Functionality and Market Context: The complaint alleges the Accused Products perform wireless communications using protocols such as IEEE 802.11 and LTE (Compl. ¶18). Their functionality is described as performing error estimation in OFDM receivers; tracking, analyzing, and reporting vehicle maintenance needs and driver warnings; tracking vehicle locations; and enabling communication between a system administrator and remote units (Compl. ¶19-20). These products are marketed for fleet and asset management (Compl. ¶17).
Visual Evidence: No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart Exhibits A through G but does not attach them. The infringement theories are summarized below based on the narrative allegations in the complaint.

U.S. Patent No. 6,549,583 Infringement Allegations
The complaint alleges that the Accused Products infringe at least claim 1 by performing a method of pilot phase error estimation in an OFDM receiver (Compl. ¶30). The alleged method involves determining pilot reference points from an OFDM preamble and then estimating an aggregate phase error for a subsequent data symbol relative to those points. The complaint asserts that this estimation step is performed using a "maximum likelihood-based estimation" (Compl. ¶30).
U.S. Patent No. 6,633,616 Infringement Allegations
The complaint alleges that the Accused Products infringe at least claim 12 by performing a method of pilot phase error estimation using a specific parallel architecture and timing (Compl. ¶40). The alleged method includes determining pilot reference points, processing the preamble and a subsequent data symbol with a fast Fourier transform in a parallel path, and determining a phase error estimate for that subsequent symbol. The infringement allegation hinges on the assertion that this phase error estimation is completed prior to the completion of the FFT processing for the subsequent symbol (Compl. ¶40).

Identified Points of Contention

Scope Questions: For the ’583 Patent, a central question will be whether the specific algorithm used in the Accused Products for error estimation falls within the scope of the term "maximum likelihood-based estimation" as defined by the patent. For the ’616 Patent, a key question concerns the scope of "in a parallel path," specifically whether this requires physically distinct hardware paths or if it can be read on logically parallel software processes.
Technical Questions: For the ’583 Patent, a technical question is what evidence exists that the accused system's algorithm performs the specific mathematical operations required for maximum likelihood estimation. For the ’616 Patent, the analysis will require evidence of the internal architecture and operational timing of the accused receivers to determine if the phase error estimation is, in fact, completed before the FFT processing of the same data symbol, as the claim requires.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of intrinsic evidence, as it does not include the patent specifications for the ’583 and ’616 patents. However, based on the infringement allegations, the following terms are central.

For the ’583 Patent:

The Term: "maximum likelihood-based estimation"
Context and Importance: This term defines the core mathematical process of the claimed invention. The infringement dispute for the ’583 patent may turn entirely on whether the accused algorithm meets the technical and legal definition of this term. Practitioners may focus on this term because it is a specific, well-defined concept in signal processing, and the patent's own description will likely provide a basis for arguing its precise scope.
Intrinsic Evidence for Interpretation: The complaint does not provide sufficient detail for analysis of intrinsic evidence.

For the ’616 Patent:

The Term: "in a parallel path"
Context and Importance: This term is critical as it dictates the physical or logical architecture required to practice the invention. Defendant may argue for a narrow construction requiring physically separate processing circuits, while Plaintiff may argue for a broader construction that covers logically parallel or time-multiplexed software operations.
Intrinsic Evidence for Interpretation: The complaint does not provide sufficient detail for analysis of intrinsic evidence.

VI. Other Allegations

Indirect Infringement: The complaint alleges inducement of third parties to use the Accused Products (Compl. ¶14). It further alleges that Defendant "instructs its customers on how to install and use the Accused Products," for example through its website (Compl. ¶15). These allegations form the basis for a potential claim of induced infringement.
Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or a request for enhanced damages under 35 U.S.C. § 284. It does, however, request that the court declare the case "exceptional" and award attorneys' fees under 35 U.S.C. § 285 (Compl. ¶73.d).

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

The resolution of this case may depend on the court's determination of several key technical and legal questions:

A central issue will be one of algorithmic identity: Does the error correction algorithm in CalAmp’s OFDM-based products perform the specific mathematical steps required by the term "maximum likelihood-based estimation" as defined within the context of the ’583 patent?
A second core issue will be one of architectural equivalence: Do the accused receivers employ a processing architecture that can be considered a "parallel path," and does the system’s operational timing satisfy the "completed prior to" limitation of the ’616 patent’s asserted claim?
Across the five asserted patents, a key evidentiary question will be one of factual mapping: Can Plaintiff provide sufficient evidence to show that Defendant’s multi-function telematics platforms practice the specific, and often sequential, method steps recited in the claims for dynamic routing, maintenance tracking, and field asset management?