Voice Control Vehicles LLC v. Yuneec USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Voice Control Vehicles, LLC (Texas)
  • Defendant: Yuneec USA Inc. (California)
  • Plaintiff’s Counsel: Fernald Law Group; Nelson Bumgardner Albritton PC
• Case Identification: 8:19-cv-01809, C.D. Cal., 09/20/2019
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement and maintains a regular and established place of business within the Central District of California.
• Core Dispute: Plaintiff alleges that Defendant’s Mantis Q drone, when used with its associated mobile application and a smartphone, infringes a patent related to voice-activated command systems for remotely controlled vehicles.
• Technical Context: The technology concerns the use of voice commands to operate functions on unmanned vehicles, such as drones, to supplement traditional manual joystick controls.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent-in-suit via a letter dated January 14, 2019, approximately eight months prior to filing the lawsuit. This allegation may be used to support claims for enhanced damages.

Case Timeline

Date	Event
2005-05-06	’860 Patent Priority Date
2013-03-19	’860 Patent Issue Date
2018-09-21	Accused Product User Manual Date
2019-01-14	Date of Plaintiff's Notice Letter to Defendant
2019-09-20	Complaint Filing Date

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

U.S. Patent No. 8,401,860 - "Voice-Activated Command and Control for Remotely Controlled Model Vehicles"

The Invention Explained

• Problem Addressed: The patent describes the difficulty of operating increasingly complex remotely controlled (R/C) model vehicles, particularly aircraft. An operator must maintain manual dexterity on primary flight controls ("joysticks") while also keeping a constant visual line-of-sight with the vehicle. Looking away from the vehicle to locate and actuate secondary or "auxiliary" switches on the controller can cause the operator to lose orientation and crash the vehicle ('860 Patent, col. 2:6-23).
• The Patented Solution: The invention provides a system that allows an operator to use voice commands to control certain vehicle functions, thereby freeing the operator's hands to remain on the primary flight controls and their eyes to remain on the vehicle ('860 Patent, col. 3:3-14). The system includes a microphone to receive verbal commands and a control module to translate those commands into wireless signals sent to the vehicle. The patent also describes two-way systems that provide audible feedback to the operator confirming receipt or status of a command ('860 Patent, Abstract; col. 3:21-25).
• Technical Importance: The technology aimed to improve the safety and usability of R/C vehicles by off-loading control of auxiliary functions from manual switches to a voice-based interface, which could reduce operator distraction during flight ('860 Patent, col. 2:37-40).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (Compl. ¶13).
• The essential elements of independent claim 1 are:
  • A voice-activated command and control system for a line-of-sight remotely controlled model that has "trim control functions" required for stable flight and an on-board controller.
  • The system itself comprises:
    • a) a portable microphone for receiving an audible command;
    • b) a portable voice-activated control module that transmits a control signal based on the command;
    • c) wherein the microphone and module allow an operator to use their voice to remotely control at least one function of the model; and
    • d) a portable hand-held controller with manual "trim-function controls" that can achieve stable flight "independently of the voice-activated control module."
• The complaint does not explicitly reserve the right to assert dependent claims, but the infringement allegations are not limited to Claim 1.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is the Yuneec Mantis Q drone (the "Accused Product"), when used "in combination with the Accused Product's app and a smartphone" (Compl. ¶13).

Functionality and Market Context

• The Mantis Q is a quadcopter drone that can be controlled through two primary methods. The first is a traditional, physical hand-held remote controller with joysticks that manage the drone's primary flight movements, such as lateral and vertical propulsion (Compl. Ex. B, p. 3). The second is a voice control feature, enabled through a mobile application on a smartphone, which allows an operator to speak commands such as "Takeoff," "Landing," or "Take a picture" into the smartphone's microphone to execute those functions on the drone (Compl. Ex. B, p. 5, 7). The complaint alleges these two control systems constitute the infringing system (Compl. Ex. B, p. 2). A diagram from the user manual illustrates the various parts of the hand-held remote controller, including the control sticks, power button, and camera controls (Compl. Ex. B, p. 8).

IV. Analysis of Infringement Allegations

'860 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A voice-activated command and control system for a line-of-sight remotely controlled model having trim control functions that are required for stable propulsion and control of the model...	The Mantis Q drone is a remotely controlled model, and its manual joystick controls for lateral and vertical propulsion are alleged to be the claimed "trim control functions" required for stable flight. A diagram in the user manual shows these flight controls.	Ex. B, p. 3	col. 1:47-59
...the model having an on-board controller to (a) receive trim control function signals...by wireless transmission and (b) control the trim control functions...	On information and belief, an onboard controller in the Mantis Q drone receives wireless signals from the hand-held controller and executes them to move the quadcopter.	Ex. B, p. 4	col. 3:25-33
a) a portable microphone for receiving an audible command from an operator;	The microphone on the user's smartphone, when running the accused app, functions as the portable microphone for receiving voice commands.	Ex. B, p. 5	col. 7:34-40
b) a portable voice-activated control module for transmitting a control function signal responsive to the audible command received by the microphone to the model by wireless transmission;	On information and belief, the smartphone app and/or the hand-held controller act as the control module, processing voice commands like "take off" and transmitting a corresponding RF command to the drone. A screenshot provided in the complaint shows a user giving a "take off" command.	Ex. B, p. 6	col. 7:41-54
c) wherein the portable microphone and portable voice-activated control module allow the operator, using his or her voice, to speak a word command...to voice activate and remotely control at least one of said control functions...	The accused system allows an operator to speak commands like "Takeoff" to control the drone. A table from the user manual lists available voice commands.	Ex. B, p. 7	col. 11:5-20
d) a portable hand-held controller with manually operated trim-function controls...whereby stable propulsion and control of the model can be achieved with the portable hand-held controller independently of the voice-activated control module.	The accused system includes a physical hand-held controller with joysticks that allows for stable flight control, and it is alleged this manual control can be achieved independently of the voice control functionality.	Ex. B, p. 9	col. 10:35-43

Identified Points of Contention

• Scope Questions: A central dispute may arise over the term "trim control functions." The patent defines this term in the context of traditional R/C airplanes, listing functions like ailerons, elevator, rudder, and throttle ('860 Patent, col. 1:55-59). The infringement allegation maps this term to a modern quadcopter's joystick controls for vertical and lateral propulsion (Compl. Ex. B, p. 3). The case may turn on whether the patent's definition of "trim" functions can be construed to read on the primary flight controls of a quadcopter, which operate on different aerodynamic principles.
• Technical Questions: The final limitation of claim 1 requires that stable flight be achievable with the hand-held controller "independently of the voice-activated control module." The complaint asserts this is met (Compl. Ex. B, p. 9). This raises the question of what level of "independence" is required by the claim. The analysis will likely focus on the software and hardware architecture of the accused system to determine if the manual control path is sufficiently separate from the voice control path, as contemplated by the patent's discussion of parallel control systems ('860 Patent, col. 10:1-12).

V. Key Claim Terms for Construction

• The Term: "trim control functions"

  • Context and Importance: This term appears in the preamble and body of claim 1 and defines the baseline manual controls that the patented voice system is designed to supplement. The definition of this term is critical because it will determine whether the primary flight controls of the accused quadcopter fall within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that the term should be read functionally to mean any primary flight controls necessary for stable flight, regardless of the vehicle type. The patent states these controls "collectively" are "generally to referred to herein as aircraft 'trim' controls" ('860 Patent, col. 1:55-56), which may suggest a term of art adopted for the patent's purposes rather than a strict limitation to airplanes.
    • Evidence for a Narrower Interpretation: The patent explicitly lists the controls as those for "ailerons (banking control)," "elevator (pitch control)," "rudder (yaw control)," and "engine throttle" ('860 Patent, col. 1:47-55). A party could argue that the term is therefore limited to these specific, conventional aircraft controls and does not extend to the different control paradigms of a multi-rotor drone.

• The Term: "independently of the voice-activated control module"

  • Context and Importance: This limitation in claim 1(d) describes the relationship between the manual controller and the voice-control system. Its construction will be central to determining whether the architecture of the accused Yuneec system, which integrates both control methods, infringes. Practitioners may focus on this term because it addresses the potential for operational backup and the separation of control pathways.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a "parallel-type system wherein operation of the voice-activated command control system is independent from operation of manual controls" ('860 Patent, col. 10:2-5). This could be interpreted to mean only that the user must be able to fly the vehicle using the manual controller without ever having to use voice commands, a condition the accused product appears to meet.
    • Evidence for a Narrower Interpretation: The patent contrasts the "parallel-type system" with a "series-type system" where operation is "interdependent" ('860 Patent, col. 10:5-9). An argument could be made that "independently" requires a specific level of electrical or software separation, where the manual controls provide an "operational backup" should the voice system fail ('860 Patent, col. 10:18-24). If the accused product's manual and voice controls are deeply integrated within the same microprocessor or software logic, it might not meet a narrower definition of "independent."

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement to infringe under 35 U.S.C. § 271(b). The factual basis for this claim is the allegation that Defendant provides "detailed instructions on how to use the Accused Products in combination with the Accused Product's app and a smartphone" (Compl. ¶20). The complaint cites its own claim chart (Exhibit B), which contains excerpts from the user manual instructing on the use of voice commands, as evidence of these instructions (Compl. ¶20; Ex. B, p. 5, 7).

Willful Infringement

• The complaint does not contain a separate count for willful infringement. However, it alleges that Defendant has had knowledge of the ’860 patent "since at least receipt of VCV's January 14, 2019 notice letter" (Compl. ¶18). This allegation of pre-suit knowledge of the patent could form the basis for a later claim of willful infringement for any infringing activity occurring after that date.

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

This dispute will likely center on fundamental questions of claim scope and technical architecture. The key issues for the court to resolve appear to be:

• A core issue will be one of definitional scope: can the term "trim control functions," which is defined in the patent using the specific controls of a conventional R/C airplane (ailerons, rudder, elevator), be construed to cover the integrated joystick controls of a modern quadcopter drone?
• A key evidentiary question will be one of architectural independence: does the accused product's integration of manual and voice controls satisfy the claim requirement that stable flight be achievable via the hand-held controller "independently of the voice-activated control module," or are the two systems too "interdependent" in their software and hardware implementation to meet this limitation as described in the patent?