Integrated Engineering LLC v. Euro Motorparts Group Uk Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Integrated Engineering, LLC (Utah)
  • Defendant: EMPI, Inc. d/b/a 034Motorsport (Delaware); RacingLine Limited (England and Wales)
  • Plaintiff’s Counsel: Maschoff Brennan Gilmore Israelsen & Mauriel LLP
• Case Identification: 3:25-cv-09118, N.D. Cal., 11/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants transact business and have committed acts of infringement in the district. It is further alleged that EMPI has a regular and established place of business in Fremont, California, and that both parties have previously admitted to the propriety of venue in prior related court filings.
• Core Dispute: Plaintiff alleges that Defendants’ vehicle performance tuning products, which allow users to update vehicle engine control units (ECUs) via a smartphone and a diagnostic port dongle, infringe a patent related to mobile vehicle flashing technology.
• Technical Context: The lawsuit concerns the aftermarket automotive performance industry, where consumers use electronic hardware and software to modify, or "flash," a vehicle's onboard computer modules to enhance performance.
• Key Procedural History: The complaint notes this is a Third Amended Complaint, with the case having been transferred from the Central District of California. It also references a related Declaratory Judgment action previously filed by the Defendants in the Northern District of California seeking invalidation of the same patent-in-suit, suggesting Defendants were aware of the patent prior to the filing of the current complaint.

Case Timeline

Date	Event
2023-05-01	EMPI's "R4 Dongle" compatible with accused software becomes available ("May 2023 - PRESENT")
2023-10-29	’159 Patent Priority Date
2024-10-08	’159 Patent Issue Date
2025-02-14	Plaintiff allegedly notifies EMPI of infringement via correspondence
2025-06-27	RacingLine allegedly gains knowledge of the patent by filing a Declaratory Judgment action
2025-11-03	Complaint Filing Date

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

U.S. Patent No. 12,112,159 - "System and Methods for Staging Data and Updating Vehicle Modules Using Staged Data"

• Patent Identification: U.S. Patent No. 12,112,159, "System and Methods for Staging Data and Updating Vehicle Modules Using Staged Data," issued October 8, 2024.

The Invention Explained

• Problem Addressed: The patent addresses the risk of damaging a vehicle's electronic modules during the software update process, known as "flashing" (U.S. Patent No. 12,112,159, col. 1:25-36). Traditional reprogramming methods can be disrupted by unreliable wired or wireless connections, causing data to become "scrambled," which can result in a failed update and potentially permanent damage to the vehicle module (’159 Patent, col. 4:17-23).
• The Patented Solution: The invention proposes a two-stage system to isolate the sensitive vehicle programming step from potentially faulty data transmission. First, a user interface device (e.g., a smartphone) sends a complete re-program file to a "smart dongle" connected to the vehicle's onboard diagnostic (OBD) port (’159 Patent, Abstract). This dongle acts as a local cache, receiving and storing the entire file (’159 Patent, col. 2:60-67). The dongle verifies the integrity of the received data, for instance by using checksums, before initiating any programming (’159 Patent, col. 4:30-34). Only after the data is fully staged and verified on the dongle does the dongle itself execute the high-fidelity process of writing the data to the vehicle module, thereby minimizing the risk of corruption from an unstable connection to the user's phone (’159 Patent, col. 3:52-62). The system architecture is depicted in Figure 3, showing the distinct roles of the user device (105) and the smart dongle (320).
• Technical Importance: This approach aims to increase the reliability and safety of aftermarket vehicle tuning by creating a secure buffer between the user's device and the vehicle's critical electronic systems (’159 Patent, col. 4:24-34).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶31).
• The essential elements of Claim 1 include:
  • A system comprising a user interface device and a programming device.
  • The user interface device is configured to receive and store a re-program file and display a GUI to initiate the process.
  • The programming device is configured to couple to a vehicle's onboard port.
  • The programming device is configured to receive messages from the user interface device and store "mapping-and-byte data" in a local cache.
  • The programming device re-programs the vehicle module using that locally cached mapping-and-byte data.
  • The programming device transmits a success message after determining a "checksum condition is satisfied."
• The complaint alleges infringement of "one or more claims," which may include dependent claims not explicitly detailed (Compl. ¶31).

III. The Accused Instrumentality

Product Identification

• The accused products are combinations of hardware and software sold by EMPI (under the "034Motorsport" brand) and RacingLine (Compl. ¶11). These include EMPI’s "Dynamic+ Performance Software," "Dynamic+ End User Flashing Kit (including smart dongle)," and "034SPI (Smartphone Interface) Mobile Flashing application," as well as RacingLine’s "Power Delivery Module (PDM)," "PDM App-Connect," and "Performance Software" (Compl. ¶11).

Functionality and Market Context

• The accused products form a system that allows users to "update or 'flash' a vehicle ECU via the factory on-board diagnostic (OBD) port" (Compl. ¶11). The system consists of a smartphone application that communicates wirelessly with a hardware dongle plugged into the vehicle's OBD port (Compl. ¶¶15, 16). The complaint alleges these systems allow users to "easily flash your car, change fuel maps," and "Quickly and safely reflash [their] Engine Control Unit (ECU)" (Compl. ¶¶15, 16). Visuals provided in the complaint depict the smartphone app interfaces for both EMPI and RacingLine products, which allow a user to select a software tune and initiate the flashing process. For example, a screenshot from a YouTube video shows the RacingLine PDM App-Connect interface with a large "COMMIT AND FLASH!" button (Compl. p. 10). Another visual shows the various hardware dongles offered by EMPI, including a newer model compatible with the accused smartphone interface app (Compl. p. 9, Exhibit 7 at 7).

IV. Analysis of Infringement Allegations

'159 Patent Infringement Allegations

Claim Element (from Independent Claim 1) -	Alleged Infringing Functionality -	Complaint Citation	Patent Citation
A system for staging data and updating vehicle modules using staged data, the system comprising: a user interface device...configured to: receive and store a re-program file from a server; and display a graphical user interface configured to receive a user input to initiate a re-program process for at least one onboard module of a vehicle;	The EMPI "034SPI (Smartphone Interface)" and RacingLine "PDM App-Connect" mobile applications, which allow users to select and initiate vehicle flashing. -	¶¶11, 15, 16	col. 31:51-58
and a programming device configured to be physically and communicably coupled to an onboard port of the vehicle... -	The EMPI "Dynamic+ End User Flashing Dongle" and the RacingLine "Power Delivery Module," which physically connect to a vehicle's OBD port. -	¶¶11, 16	col. 31:59-62
the programming device is configured to: receive, via a defined sequence of messages with the user interface device, and store, via defined operations with a local cache, one or combinations of...data map (collectively, mapping-and-byte data);	The dongles allegedly connect wirelessly to the smartphone apps and control the flashing of a vehicle, which the complaint alleges performs the same function as the patented invention.	¶¶16, 17	col. 32:4-13
in response to receiving an instruction message from the user interface device, re-program the at least one onboard module using the mapping-and-byte data; -	The smartphone apps are used to control the flashing of the vehicle's ECU or TCU via the dongle. -	¶¶15, 16	col. 32:14-17
and in response to determining a checksum condition is satisfied, transmit a re-program success message to the user interface device. -	The complaint does not provide sufficient detail for analysis of this specific element. '		col. 32:18-21

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the meaning of "programming device." The patent describes a "smart dongle" with local processing, caching, and verification capabilities (’159 Patent, col. 4:26-34). The question will be whether the accused dongles are merely simple wireless-to-wired passthrough interfaces or if they possess the "smart" functionalities required by the claims.
  • Technical Questions: The complaint alleges the accused products function in a similar way to the patented invention but does not provide specific evidence that they perform the crucial step of staging and verifying the entire data file in a "local cache" on the dongle before beginning to program the vehicle module, as required by the claim. The core technical question is whether the accused system architecture mirrors the patent’s two-stage, buffered process or operates as a more direct, real-time data stream from the phone to the vehicle.

V. Key Claim Terms for Construction

• The Term: "programming device"

• Context and Importance: This term's construction is critical because it defines the required functionality of the accused hardware dongle. The dispute will likely center on whether the accused EMPI and RacingLine dongles are sophisticated enough to qualify as the claimed "programming device." Practitioners may focus on this term because the patent repeatedly describes the device as a "smart dongle" that relocates "reprogramming-related processing directly to the OBD data port physical interface" (’159 Patent, col. 4:24-28).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not use the word "smart" and only requires the device be "configured to" perform certain functions like receiving, storing, and reprogramming, which could arguably be read on a device with a simple processor and buffer.
  • Evidence for a Narrower Interpretation: The specification describes the programming device as including "a processor and a local memory storage" and executing "operations to write specific byte strings" (’159 Patent, col. 3:20-24). It is explicitly distinguished from prior art systems by its ability to receive the entire data transfer and perform checksum verification before programming the module, suggesting more than a simple passthrough function is required (’159 Patent, col. 4:28-34).

• The Term: "store, via defined operations with a local cache...mapping-and-byte data"

• Context and Importance: This phrase is the functional heart of the invention, describing the data staging process. The infringement analysis will depend on whether the accused dongles perform this specific type of storage operation or use a different data handling method, such as a transient stream or a simple temporary buffer.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "local cache" is not explicitly defined and could be argued to cover any form of temporary memory on the device used during data transfer.
  • Evidence for a Narrower Interpretation: The specification describes a process where "data is transferred in it's entirety...to the smart dongle" and "Only when the data has been completely transferred and checksum verified" does the dongle program the module (’159 Patent, col. 4:28-32). This context suggests that "store...with a local cache" requires holding the complete, verified re-program data, not just buffering small packets in transit.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants encourage and facilitate infringement through "promotional and marketing materials, instructional materials, [and] product manuals" that instruct customers on how to use the accused products in an infringing manner (Compl. ¶36).
• Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint alleges EMPI knew of the ’159 patent since at least February 14, 2025, via a letter from Plaintiff's counsel (Compl. ¶33). It alleges RacingLine has known of the patent since at least June 27, 2025, when it filed a Declaratory Judgment action against Plaintiff concerning the patent (Compl. ¶34).

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

• A core issue will be one of technical operation: does the accused system architecturally perform the specific two-stage "stage-and-verify-then-program" data transfer process required by Claim 1, or does it function as a direct data conduit from the smartphone to the vehicle's ECU, a method the patent sought to improve upon?
• The case will also turn on a question of definitional scope: can the term "programming device," as described in the context of a "smart dongle" that performs local processing and verification, be construed to cover the accused hardware dongles? The outcome will likely depend on evidence revealing the internal data handling capabilities of the accused products.