DCT
5:25-cv-01755
Autel Intelligent Technology Corp Ltd v. Shenzhen Xtooltech Intelligent Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Autel Intelligent Technology Corp., Ltd. (China) and Autel US Inc. (New York)
- Defendant: Shenzhen XTOOLTech Intelligent Co., Ltd. (China) and XTOOLTech USA Inc. (California)
- Plaintiff’s Counsel: Dorsey & Whitney LLP
- Case Identification: 5:25-cv-01755, C.D. Cal., 07/11/2025
- Venue Allegations: Venue is alleged to be proper because Defendant XTOOL is not a U.S. resident and has engaged in infringing activity in the district, and Defendant XTOOL USA resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s XTOOL D8S automotive diagnostic tool infringes a patent related to the method and system for communicating between a diagnostic device and a vehicle's network.
- Technical Context: The technology concerns automotive on-board diagnostics (OBD), specifically how handheld diagnostic tools communicate with a vehicle's electronic control units (ECUs) to retrieve data and perform tests.
- Key Procedural History: No prior litigation, IPR proceedings, or other significant procedural events are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2018-01-08 | ’451 Patent Priority Date |
| 2023-12-19 | ’451 Patent Issue Date |
| 2025-06-27 | Date Plaintiff retrieved accused product information from Amazon.com |
| 2025-07-11 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,845,451 - "Automobile Diagnostic Method, Apparatus, Device and System, and Diagnostic Connection Device," issued December 19, 2023
The Invention Explained
- Problem Addressed: The patent describes a problem in prior art automotive diagnostic systems where the diagnostic connection device (the "VCI" or "dongle" that plugs into the car) must perform complex and resource-intensive protocol conversions to communicate with the vehicle. This increases the hardware requirements and cost of the VCI device itself ('451 Patent, col. 1:35-43).
- The Patented Solution: The invention proposes offloading this protocol conversion work from the low-power VCI to the more powerful main diagnostic device (e.g., a tablet or smartphone). The main device reads a user's command, converts it into the final "standard transmission data" (like CAN bus data), and sends this ready-to-transmit data to the VCI. The VCI's role is simplified to merely passing this data to the vehicle's network, thereby reducing the VCI's required processing power and cost ('451 Patent, col. 2:50-65; Fig. 1).
- Technical Importance: This approach allows for the production of less expensive and less complex VCI hardware, as the computationally heavy tasks are handled by the main diagnostic tool, which typically already has significant processing and memory resources ('451 Patent, col. 6:1-9).
Key Claims at a Glance
- The complaint asserts independent claims 1, 5, and 11 (Compl. ¶21).
- Independent Claim 1 (Method):
- An automobile diagnostic method for a diagnostic device, comprising:
- reading an operation performed by a user on an interface, and converting the operation into a corresponding diagnostic instruction;
- converting the diagnostic instruction into standard transmission data corresponding to the diagnostic instruction; and
- sending the standard transmission data, wherein the sending comprises: synchronously sending the standard transmission data.
- Independent Claim 11 (Apparatus):
- An automobile diagnostic device, comprising:
- a display screen;
- a first communication unit configured to send and receive data;
- at least one processor; and
- a memory communicatively connected to the processor, wherein the memory stores an instruction that, when executed, causes the processor to:
- read an operation performed by a user on an interface;
- convert the operation into a corresponding diagnostic instruction;
- convert the diagnostic instruction into standard transmission data; and
- synchronously send the standard transmission data.
- The complaint does not explicitly reserve the right to assert dependent claims, but infringement of "one or more claims" is alleged (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
- The XTOOL D8S Bidirectional Scan Tool (the "Device") (Compl. ¶2).
Functionality and Market Context
- The XTOOL D8S is an automotive diagnostic device, described as an Android-based tablet that connects to a vehicle to perform diagnostics and testing (Compl. ¶¶14, 19).
- Its functions include reading ECU information, reading/clearing trouble codes, viewing live data, and performing "Actuation Tests (Bi-Directional Control)" (Compl. p. 8). This "bi-directional" capability, which involves both sending commands to and receiving data from the vehicle, is highlighted in marketing materials (Compl. p. 16).
- The complaint alleges the XTOOL D8S connects to a Vehicle Communication Interface ("VCI") module, which in turn connects to the vehicle's network to obtain data (Compl. p. 7). A provided photograph shows the accused XTOOL tablet connected to a separate "Diagnostic Module" and an "Automotive ECU" on a test bench, illustrating the system's components (Compl. p. 7).
- The complaint positions the XTOOL D8S as a direct competitor to Autel's own products (Compl. ¶¶2, 3).
IV. Analysis of Infringement Allegations
’451 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| reading an operation performed by a user on an interface... | The XTOOL D8S has a touchable display that accepts user input on interface buttons. | ¶21 (p. 8) | col. 1:59-62 |
| ...and converting the operation into a corresponding diagnostic instruction; | The complaint alleges the device "must necessarily convert the user's input (the operation) into a diagnostic instruction" to perform functions like reading ECU information or performing actuation tests. | ¶21 (p. 8) | col. 1:63-65 |
| converting the diagnostic instruction into standard transmission data... | The complaint alleges the diagnostic instruction "must necessarily be converted to standard transmission data to communicate with the automobile." An image is provided showing the "device module sends 07E02101 to the VCI module" as evidence of this conversion. | ¶21 (p. 8) | col. 2:1-5 |
| wherein the sending the standard transmission data...comprises: synchronously sending the standard transmission data... | The complaint alleges "The transmission is synchronous" and that "Synchronous transmission is typically used for transmission of live data." A screenshot shows the VCI module replying to the device, allegedly synchronously. An image of live data graphing is also provided. | ¶21 (pp. 9-10) | col. 2:13-15 |
’451 Patent Infringement Allegations (Claim 11)
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display screen | The XTOOL D8S is alleged to include an 8-inch, 1024x768 resolution touchable display screen. | ¶21 (p. 15) | col. 5:13 |
| a first communication unit configured to send and receive data | The device must have a communication unit to connect to the vehicle. A marketing image shows "commands" flowing from the device to the car and data being "recieved," which is alleged to show the required bidirectional data flow. | ¶21 (pp. 15-16) | col. 5:14-15 |
| at least one processor | The device's technical specifications are cited as listing a "Quad-core processor 1.8GHz." | ¶21 (p. 16) | col. 5:16 |
| a memory communicatively connected to the at least one processor... | The device's specifications list "RAM 2G ROM 64G." The complaint alleges the memory and processor are necessarily communicatively coupled. | ¶21 (p. 16) | col. 5:17-18 |
| wherein the memory stores an instruction that...causes the...processor to...perform the recited steps | The complaint realleges the same functional steps as in Claim 1, arguing the processor executes instructions stored in memory to read user input from the touch screen, convert it to standard transmission data (e.g., CAN bus), and send it synchronously to the automobile network via the VCI. | ¶21 (p. 17) | col. 20:1-10 |
Identified Points of Contention
- Technical Question: The complaint provides a photograph of the accused system that identifies both a "VCI" and a "Diagnostic Module" as distinct hardware components communicating with an ECU (Compl. p. 7). This raises the question of how processing is actually divided. Does the "Diagnostic Module" perform the protocol conversion claimed by the patent (making the XTOOL tablet a simple display), or does the tablet perform the conversion and send "standard transmission data" to the VCI/module, as alleged?
- Scope Question: The patent's core concept is simplifying the VCI by moving protocol conversion to the main diagnostic device. The claim term "standard transmission data" is central to this. A key issue will be whether the data sent from the XTOOL D8S tablet to its VCI/module is "standard transmission data" (e.g., a fully formed CAN bus packet) or a higher-level "diagnostic instruction" that still requires significant protocol conversion by the VCI/module.
V. Key Claim Terms for Construction
The Term: "synchronously" send/receive
- Context and Importance: This term appears in the asserted independent claims 1, 5, and 11. The nature of the data transmission—whether it meets the specific definition of "synchronous"—is a critical limitation. Practitioners may focus on this term because the patent specification explicitly contrasts "synchronous" and "asynchronous" operations, suggesting a specific technical meaning beyond merely "at the same time" or "in real-time." The complaint supports its allegation by stating that live data transmission is "typically" synchronous, which may be a point of dispute (Compl. pp. 9-10).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition. A party could argue it should be given its plain and ordinary meaning in the context of data communication, such as a request/response protocol where an operation waits for a reply before proceeding. The patent states the method comprises "synchronously sending the standard transmission data" without further qualification in the claim itself ('451 Patent, col. 18:29-32).
- Evidence for a Narrower Interpretation: The patent describes a "synchronous sending module 5031" and, separately, an "asynchronous sending module 5032" which uses a "sending callback function" ('451 Patent, col. 11:19-41). This detailed description of an asynchronous alternative, involving callbacks to handle subsequent data packets, suggests "synchronous" implies a more direct, blocking method of sending, distinct from the callback-based asynchronous approach. This contrast could be used to argue for a narrower, more technically specific definition.
The Term: "standard transmission data"
- Context and Importance: This term defines the output of the key conversion step that distinguishes the invention from the prior art. Whether the accused device generates data that meets this definition is central to infringement. The complaint alleges that data like the hexadecimal string "07E02101" sent from the "device module" to the "VCI module" is an example of this (Compl. p. 8).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define it as data "corresponding to the diagnostic instruction" ('451 Patent, col. 18:24-26). This could be argued to cover any data format that represents the user's intent and is suitable for transmission over a vehicle bus.
- Evidence for a Narrower Interpretation: The specification provides specific examples, stating the diagnostic instruction is converted into "controller area network protocol standard transmission data" or "communication bus protocol standard transmission data" ('451 Patent, col. 2:1-10). This could support an argument that "standard transmission data" is not just any data, but data formatted according to a specific, low-level vehicle communication protocol (e.g., CAN, K-Line), as this is the data that would otherwise have been generated by the VCI in the prior art.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants induce infringement of method claims 1 and 5 by providing "instructions, marketing materials, and technical support" to customers and end users, which instruct them to use the XTOOL D8S in an infringing manner (Compl. ¶24). A marketing image showing bidirectional data flow is provided as evidence of such materials (Compl. p. 16).
- Willful Infringement: Willfulness is alleged based on Defendants being "sophisticated competitors" in the automotive diagnostics industry who allegedly had "actual knowledge of the '451 Patent and of its infringement, or were willfully blind" (Compl. ¶25). The allegation is based on Defendants' status and alleged pre-suit knowledge of Autel's patent and technology.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical function and architecture: Where does the protocol conversion actually occur in the accused XTOOL D8S system? The case may depend on evidence distinguishing the processing performed on the main tablet from the processing performed by the separate "VCI" and/or "Diagnostic Module" to determine if the system operates as claimed by offloading this key function from the connection hardware.
- A second core issue will be one of definitional scope: Can the term "synchronously", as used in the patent, be construed to read on the communication protocol of the accused device? The outcome may turn on whether "synchronous" is given a general meaning or a more specific technical definition based on its contrast with the "asynchronous" callback-based methods also described in the patent specification.