DCT
5:25-cv-01755
Autel Intelligent Technology Corp Ltd v. Shenzhen Xtooltech Intelligent Co Ltd
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Autel Intelligent Technology Corp., Ltd. (People's Republic of China) and Autel US Inc. (New York)
- Defendant: Shenzhen XTOOLTech Intelligent Co., Ltd. (People's Republic of China) and XTOOLTech USA Inc. (California)
- Plaintiff’s Counsel: Dorsey & Whitney LLP
- Case Identification: 5:25-cv-01755, C.D. Cal., 10/31/2025
- Venue Allegations: Venue is alleged to be proper as 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 automotive diagnostic scan 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 diagnostic systems, which mechanics and technicians use to interface with a vehicle's onboard computers to identify faults, view live data, and test components.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2018-01-08 | ’451 Patent Priority Date |
| 2023-12-19 | ’451 Patent Issue Date |
| 2025-10-31 | 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"
- Patent Identification: 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: In conventional vehicle diagnostic systems, the small connection device (often called a VCI or "dongle") that plugs into the car must perform complex protocol conversions to translate commands from a diagnostic tablet into a format the car's network can understand. This requires the VCI to have a relatively powerful and expensive main chip. (’451 Patent, col. 1:34-43).
- The Patented Solution: The invention shifts the resource-intensive task of protocol conversion from the VCI to the main diagnostic device (e.g., the tablet). The tablet itself converts a user's command into the final "standard transmission data" required by the vehicle's bus system (like a CAN bus). The VCI then acts as a simpler, less expensive bridge, merely passing this pre-formatted data to the vehicle. This approach is intended to lower the hardware costs of the VCI. (’451 Patent, Abstract; col. 7:29-39).
- Technical Importance: This architecture allows for the use of a lower-cost, less powerful VCI, reducing the overall hardware expense of the diagnostic system. (’451 Patent, col. 5:5-10).
Key Claims at a Glance
- The complaint asserts independent claims 1, 5, and 11. (Compl. ¶¶ 21, 23, 24).
- Independent Claim 1 (Method):
- Reading an operation performed by a user on an interface
- Converting the operation into a corresponding diagnostic instruction
- Converting the diagnostic instruction into standard transmission data
- Synchronously sending the standard transmission data
- Independent Claim 5 (Method):
- Synchronously receiving standard transmission data corresponding to detection data from the automobile network
- Converting the standard transmission data into detection data
- Independent Claim 11 (Device):
- A display screen, a first communication unit, at least one processor, and a memory
- The memory stores instructions that cause 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
- Synchronously send the standard transmission data
III. The Accused Instrumentality
Product Identification
- The XTOOL D8S Bidirectional Scan Tool ("XTOOL D8S"). (Compl. ¶14).
Functionality and Market Context
- The XTOOL D8S is an automotive diagnostic system comprising a tablet-style main unit and a Vehicle Communication Interface (VCI) module that connects to a vehicle's OBD-II port. (Compl. p. 8). It is alleged to perform functions such as reading ECU information, reading and clearing trouble codes, viewing live data, and conducting bidirectional actuation tests. (Compl. ¶¶ 21, p. 9, n.7). The complaint presents a product marketing image from an Amazon page showing the device sending "commands" to and "receiving" data from a vehicle, illustrating its bidirectional capabilities. (Compl. p. 17). The complaint alleges that the Defendants are direct competitors to the Plaintiff in the automotive diagnostics field. (Compl. ¶¶ 2, 20).
IV. Analysis of Infringement Allegations
11,845,451 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An automobile diagnostic method for an automobile diagnostic device... | The XTOOL D8S is an automobile diagnostic device that performs a diagnostic method. (Compl. p. 7). | ¶21 | col. 19:15-19 |
| reading an operation performed by a user on an interface, and converting the operation into a corresponding diagnostic instruction; | The device has a touchable display where a user performs an operation (e.g., tapping a button), which the complaint alleges must necessarily be converted into a diagnostic instruction. (Compl. p. 9). | ¶21 | col. 7:58-8:9 |
| converting the diagnostic instruction into standard transmission data corresponding to the diagnostic instruction; | The complaint alleges the diagnostic instruction must be converted into standard transmission data to communicate with the vehicle, and provides a screenshot of data logs showing what it identifies as the resulting data packet (07E02101). (Compl. p. 9). | ¶21 | col. 8:10-21 |
| wherein the sending the standard transmission data corresponding to the diagnostic instruction comprises: synchronously sending the standard transmission data corresponding to the diagnostic instruction. | The complaint alleges the data transmission is synchronous, providing screenshots of data packet logs with timestamps as evidence of this temporal relationship. (Compl. p. 10). | ¶21 | col. 19:28-32 |
11,845,451 Patent Infringement Allegations (Claim 5)
| Claim Element (from Independent Claim 5) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An automobile diagnostic method for an automobile diagnostic device... | The XTOOL D8S is an automobile diagnostic device that performs a diagnostic method. (Compl. p. 12). | ¶21 | col. 19:61-65 |
| wherein the receiving standard transmission data corresponding to the detection data of the automobile network comprises: synchronously receiving the standard transmission data corresponding to the detection data of the automobile network. | The complaint alleges the device receives data from the vehicle, such as "live data," and that this transmission is synchronous. (Compl. pp. 13-14). A screenshot of data logs shows a reply packet (07E86101) from the VCI to the device. (Compl. p. 15). | ¶21 | col. 19:5-12 |
| converting the standard transmission data corresponding to the detection data into detection data; | The complaint alleges the received data must be converted into a format the diagnostic device can use, and that this conversion is necessary to display the data. (Compl. p. 14). | ¶21 | col. 9:11-15 |
11,845,451 Patent Infringement Allegations (Claim 11)
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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... | The XTOOL D8S device is alleged to include a display screen, a communication unit for vehicle connection, a quad-core processor, and RAM/ROM memory. (Compl. pp. 16-17). | ¶21 | col. 20:34-40 |
| the memory stores an instruction that ... when executed by the at least one processor, causes the at least one processor to read an operation performed by a user on an interface... | The device's touchable display accepts user input to initiate diagnostic functions. (Compl. p. 18). | ¶21 | col. 20:41-47 |
| convert the operation into a corresponding diagnostic instruction; | The complaint alleges the user's input must necessarily be converted into a diagnostic instruction for the device to function. (Compl. p. 18). | ¶21 | col. 20:47-49 |
| convert the diagnostic instruction into standard transmission data...; and | This instruction must then be converted into standard transmission data to be sent to the automobile network via the OBD-II connector. (Compl. p. 18). | ¶21 | col. 20:50-52 |
| synchronously send the standard transmission data corresponding to the diagnostic instruction. | The transmission is alleged to be synchronous, supported by screenshots of live data graphs, which the complaint notes are typically associated with synchronous transmission. (Compl. pp. 19-20). | ¶21 | col. 20:53-55 |
- Identified Points of Contention:
- Evidentiary Questions: The complaint frequently alleges that certain software conversions "must necessarily" occur within the accused device. (Compl. p. 9, 18). A central dispute may revolve around whether Plaintiff can produce evidence from discovery (e.g., source code) to prove these inferred internal operations actually take place as claimed, particularly that the protocol conversion occurs on the main tablet and not the VCI.
- Scope Questions: The meaning of "synchronously" will be a focal point. The complaint appears to use the term to mean a direct temporal relationship, as evidenced by data logs and live data graphing. (Compl. pp. 10, 19). The defense may argue for a narrower technical definition, such as a specific blocking communication protocol, that the accused device does not meet.
V. Key Claim Terms for Construction
- The Term: "standard transmission data"
- Context and Importance: This term is central to the patent's core concept of offloading protocol conversion from the VCI to the diagnostic tablet. The infringement case hinges on whether the data sent from the XTOOL D8S tablet to its VCI is already in the "standard transmission data" format required by the vehicle bus. Practitioners may focus on this term because its definition will determine where the inventive step must occur.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests this data is simply what complies with "a bus transmission standard." (’451 Patent, col. 9:1-3). This could be interpreted broadly to mean any data formatted for a vehicle communication protocol.
- Evidence for a Narrower Interpretation: The specification repeatedly gives specific examples, such as "CAN bus data protocol format" or "K bus data protocol format." (’451 Patent, col. 8:18-21). A party could argue the term should be limited to data that has been fully converted to a specific, final vehicle bus protocol format, not an intermediate format.
- The Term: "synchronously"
- Context and Importance: This term appears in the sending and receiving steps of the asserted independent claims (1, 5, and 11). Its definition is critical because if the accused device's communication method is not "synchronous," there can be no literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent contrasts a "synchronous sending module" with an "asynchronous sending module," where the asynchronous module uses callback functions. (’451 Patent, col. 2:13-20; Fig. 3). A party could argue that any communication that is not the specifically defined asynchronous callback method should be considered "synchronous."
- Evidence for a Narrower Interpretation: The specification describes the "synchronous sending module 5031" as a discrete component. (’451 Patent, col. 11:20-22). This could support an argument that "synchronously" refers to a specific, defined mode of operation rather than any non-asynchronous data transfer.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement of claims 1 and 5, asserting that Defendants provide "instructions, marketing materials, and technical support" that encourage customers and end users to operate the XTOOL D8S in an infringing manner. (Compl. ¶24).
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It asserts that Defendants are "sophisticated competitors" and had "actual knowledge of the '451 Patent and of its infringement" or were willfully blind to it, and that this knowledge existed "prior to or during the launch of the XTOOL D8S." (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof: Can the Plaintiff demonstrate, likely through technical discovery, that the accused XTOOL D8S tablet performs the claimed "converting" of diagnostic instructions into "standard transmission data," as opposed to this conversion happening within the VCI module, which would resemble the prior art the patent sought to improve upon?
- A key legal question will be one of definitional scope: How will the court construe the term "synchronously"? The outcome may depend on whether it is interpreted broadly as a simple temporal relationship in data transfer, as the complaint's evidence suggests, or more narrowly as a specific communication protocol that the accused system may not implement.