DCT
5:24-cv-00797
FBA Operating Co v. RNG Intl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: FBA Operating Co. (North Carolina)
- Defendant: RNG INTERNATIONAL, INC. D/B/A RENOGY (California)
- Plaintiff’s Counsel: Bochner PLLC
- Case Identification: 5:24-cv-00797, C.D. Cal., 04/16/2024
- Venue Allegations: Venue is alleged to be proper based on Defendant's principal place of business being located in the district, along with allegations of infringing acts and substantial revenue derived from the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Renogy ONE Core" wireless leveling product infringes a patent related to systems and methods for leveling vehicles using a sensor and a smart device.
- Technical Context: The technology at issue falls within the recreational vehicle (RV) accessories market, specifically addressing the need for simplified, accurate vehicle leveling.
- Key Procedural History: The complaint alleges that Plaintiff sent a cease-and-desist letter to Defendant on January 26, 2024, notifying it of the alleged infringement. Defendant allegedly acknowledged receipt of the letter but had not provided a substantive response prior to the complaint's filing. The patent-in-suit was assigned from its original assignee, Command Electronics, LLC, to Plaintiff FBA Operating Co. on December 23, 2021.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-05 | U.S. Patent No. 10,890,925 Priority Date |
| 2021-01-12 | U.S. Patent No. 10,890,925 Issued |
| 2021-12-23 | ’925 Patent assigned from Command Electronics, LLC to FBA Operating Co. |
| 2024-01-26 | Plaintiff allegedly sent cease-and-desist letter to Defendant |
| 2024-02-07 | Defendant allegedly acknowledged receipt of letter |
| 2024-04-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,890,925 - "VEHICLE LEVELING SYSTEMS, DEVICES AND METHODS AND COMPUTER PROGRAM PRODUCTS FOR LEVELING VEHICLES USING SMART DEVICES," Issued January 12, 2021
The Invention Explained
- Problem Addressed: The patent addresses the common challenges of leveling a recreational vehicle (RV), describing the traditional method using bubble levels as an imprecise, trial-and-error process that is "prone to user error" and may require "many attempts" to achieve a level position in both pitch (front-to-back) and roll (side-to-side) directions (Compl. ¶¶9-10; ’925 Patent, col. 2:1-33).
- The Patented Solution: The invention is a system comprising a sensor device affixed to the vehicle and a separate smart device, like a smartphone, that wirelessly communicates with the sensor (’925 Patent, Abstract). The sensor, containing a digital accelerometer, measures the vehicle's inclination; this data is processed to calculate the specific height adjustments needed for each axis and is then displayed to the user on the smart device, providing clear instructions to simplify the leveling process (’925 Patent, col. 6:21-49).
- Technical Importance: The invention provides a system for "easily and inexpensively leveling a recreational vehicle" that improves upon the imprecise and iterative manual methods previously used (Compl. ¶10).
Key Claims at a Glance
- The complaint asserts independent claims 1 (system), 10 (method), and 15 (non-transitory computer readable medium) (Compl. ¶¶21, 23, 25).
- The essential elements of independent claim 1 include:
- A sensor device secured to a vehicle, comprising a printed circuit board with a digital accelerometer and a processor.
- A smart device with a display screen in wireless communication with the sensor device.
- The system is configured to determine "adjustment pairs" (a height adjustment amount and a corresponding direction) needed to level the vehicle.
- The smart device is configured to display an "image representative of the vehicle" and to "simultaneously display the height adjustment amount and corresponding adjustment direction of each adjustment pair adjacent to each respective section of the vehicle" shown in the image.
- The smart device is configured to update the display "substantially in real time" as adjustments are made.
- The complaint notes that claims 2-9, 11-14, and 16-20 depend from these independent claims (Compl. ¶20).
III. The Accused Instrumentality
Product Identification
- The accused product is the "Renogy Wireless RV Leveling System," also marketed as the "Renogy ONE Core" (Compl. ¶¶1, 27).
Functionality and Market Context
- The complaint alleges the accused product is a system for leveling RVs that includes a sensor device using accelerometers to determine the vehicle's angle and a smart device that wirelessly communicates with the sensor (Compl. ¶36). The system displays leveling instructions on the smart device to the user in "near real time" (Compl. ¶36). The complaint includes a screenshot from Defendant's website describing the product as having a "Built-in RV leveling sensor for stability and comfort" (Compl. ¶34). The product is offered for sale on Defendant's website and on Amazon.com, and is alleged to "directly compete" with Plaintiff's own product (Compl. ¶¶33-35).
IV. Analysis of Infringement Allegations
’925 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for leveling a vehicle, the system comprising: A sensor device secured to a vehicle...the sensor device comprising a printed circuit board that includes: a digital accelerometer...and a processor... | The accused product includes a sensor device that uses accelerometers to determine the angle of the vehicle. | ¶36 | col. 6:56-61 |
| a smart device in wireless communication with the sensor device, the smart device including a display screen; | The accused product includes a smart device that is in wireless communication with the sensor device. | ¶36 | col. 6:45-49 |
| wherein, based on the inclination of the vehicle as sensed by the sensor device, at least one of the sensor device and smart device is configured to determine adjustment pairs, each adjustment pair including a height adjustment amount and a corresponding adjustment direction... | The accused system displays "gathered adjustment heights and directions (each an "adjustment pair"...)" to the user. | ¶36 | col. 10:1-5 |
| wherein the display device of the smart device is configured to display at least one image representative of the vehicle and showing the respective sections of the vehicle and to simultaneously display the height adjustment amount and corresponding adjustment direction of each adjustment pair adjacent to each respective section of the vehicle shown in the at least one image; and | The smart device displays adjustment heights and directions on a display screen. A screenshot shows the Renogy ONE Core displaying leveling data (Compl. ¶34). | ¶36 | col. 10:27-33 |
| wherein the smart device is further configured to update the display screen, substantially in real time, as one or more of the height adjustment amounts are changed. | The display screen updates "in near real time." | ¶36 | col. 14:22-24 |
- Identified Points of Contention:
- Scope Questions: The claim requires the display of an "image representative of the vehicle." The screenshot provided in the complaint shows an icon of the accused product itself, not a schematic of an RV or trailer as depicted in the patent's figures (Compl. ¶34; ’925 Patent, Fig. 5A). This raises the question of whether the accused product's icon can be construed to meet this limitation.
- Technical Questions: Claim 1 requires the simultaneous display of adjustment amounts "adjacent to each respective section of the vehicle." The complaint provides a screenshot of the accused product's main screen, which shows a single leveling value, but does not depict the specific user interface that allegedly meets this multi-part display requirement (Compl. ¶34). The complaint does not provide sufficient detail for analysis of whether the accused product meets this element as claimed.
V. Key Claim Terms for Construction
The Term: "substantially in real time"
Context and Importance: This term of degree appears in the final limitation of claim 1 and is central to how the user interacts with the system. Its definition will determine the required update speed and responsiveness of the accused product's display. Practitioners may focus on this term because its inherent flexibility could be a key point of dispute regarding whether the accused product's update latency falls within the scope of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification also uses the phrase "near real time," which suggests that the inventor did not intend for the update to be strictly instantaneous, allowing for some processing delay (’925 Patent, col. 10:23, col. 14:22).
- Evidence for a Narrower Interpretation: The patent does not appear to provide a specific definition that would support a narrower construction, such as a maximum update interval. A defendant might argue that standard industry meanings or the context of user interaction demand a higher frequency than what the accused product provides.
The Term: "image representative of the vehicle"
Context and Importance: This term dictates what must be shown on the smart device's display alongside the leveling data. The infringement analysis depends on whether the graphic displayed by the accused product qualifies as a "representative" image.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself does not explicitly define the required level of detail for the image, which could support an argument that any icon intended to represent the vehicle would suffice.
- Evidence for a Narrower Interpretation: The embodiments shown in the patent consistently depict schematic outlines of a trailer or RV (e.g., ’925 Patent, Figs. 5A, 5B, 12). A party could argue that these consistent examples implicitly define the term to require more than a generic product icon, but rather a graphic that visually corresponds to the vehicle being leveled.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by its end-users, who are encouraged to use the accused system in a manner that practices the patented method of claim 10 (Compl. ¶48). The factual basis for inducement is Defendant's sale of the product intended for this specific use (Compl. ¶¶48, 51).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringement after receiving pre-suit notice of the ’925 Patent via a letter dated January 26, 2024 (Compl. ¶¶2, 28, 51). It is alleged that Defendant acknowledged receipt of this letter, establishing knowledge of the patent and the infringement allegations prior to the suit's filing (Compl. ¶¶29-30).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "image representative of the vehicle," which is exemplified in the patent by schematics of an RV, be construed to cover the product icon allegedly displayed by the accused system?
- A key evidentiary question will be one of functional performance: does the accused product's display meet the specific claim requirement to "simultaneously display the height adjustment amount...adjacent to each respective section of the vehicle," and can the Plaintiff provide sufficient evidence to demonstrate this specific functionality?
- A central question for damages will be willfulness: given the complaint's specific allegations of a pre-suit notification letter and acknowledged receipt, the Defendant's state of mind and conduct after being put on notice will be a critical factual inquiry.