DCT
3:25-cv-00457
Platform Science Inc v. Fleet Connect Solutions LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Platform Science, Inc. (Delaware)
- Defendant: Fleet Connect Solutions LLC (Texas)
- Plaintiff’s Counsel: FISH & RICHARDSON P.C.
- Case Identification: 3:25-cv-00457, S.D. Cal., 05/14/2025
- Venue Allegations: Plaintiff Platform Science alleges venue is proper in the Southern District of California because it is headquartered in San Diego, where the accused products were designed and developed. It further alleges that Defendant Fleet Connect purposefully directed its patent enforcement activities at Platform Science in the district by suing its customers in California and engaging in direct licensing negotiations with Platform Science.
- Core Dispute: Plaintiff seeks a declaratory judgment that its fleet management platform and tracking solutions do not infringe fourteen patents owned by Defendant, which Defendant has asserted in a litigation campaign against Plaintiff's customers.
- Technical Context: The patents-in-suit relate to technologies for vehicle tracking, dynamic routing, field service management, and wireless communications, which are foundational to the modern commercial fleet and logistics industry.
- Key Procedural History: The complaint alleges that this declaratory judgment action arises from a series of infringement lawsuits filed by Fleet Connect against Platform Science's major customers, including Schneider National Carriers, Werner Enterprises, and C.R. England. In those cases, Fleet Connect alleges infringement based on the customers' use of Platform Science's products. The complaint notes that a court in one of the underlying customer cases ruled that an attempt by Fleet Connect to amend its complaint to add certain expired patents would be futile. Platform Science states it is actively defending and indemnifying its customers in the ongoing litigations.
Case Timeline
| Date | Event |
|---|---|
| 1999-09-10 | ’391 Patent Priority Date |
| 2000-02-01 | ’810 Patent Priority Date |
| 2000-09-18 | ’586, ’751, ’184, ’044, ’565 Patents Priority Date |
| 2001-09-21 | ’040, ’845 Patents Priority Date |
| 2002-01-10 | ’223 Patent Priority Date |
| 2002-08-06 | ’810 Patent Issue Date |
| 2002-11-04 | ’837 Patent Priority Date |
| 2003-04-28 | ’153 Patent Priority Date |
| 2005-07-20 | ’388 Patent Priority Date |
| 2005-08-10 | ’968 Patent Priority Date |
| 2005-09-06 | ’223 Patent Issue Date |
| 2005-11-01 | ’586 Patent Issue Date |
| 2006-06-06 | ’040 Patent Issue Date |
| 2007-04-17 | ’837 Patent Issue Date |
| 2007-08-21 | ’153 Patent Issue Date |
| 2009-09-22 | ’751 Patent Issue Date |
| 2009-09-29 | ’391 Patent Issue Date |
| 2010-02-02 | ’845 Patent Issue Date |
| 2010-06-22 | ’968 Patent Issue Date |
| 2010-06-22 | ’388 Patent Issue Date |
| 2014-10-14 | ’184 Patent Issue Date |
| 2015-04-01 | Plaintiff's customer Schneider begins leasing facility in the district |
| 2016-03-29 | ’044 Patent Issue Date |
| 2017-08-29 | ’565 Patent Issue Date |
| 2024-09-30 | Defendant attempts to amend complaint in C.R. England case |
| 2024-11-15 | Court rules Defendant's amendment in C.R. England case would be futile |
| 2025-01-07 | Defendant contacts Plaintiff's counsel regarding NDA |
| 2025-01-17 | NDA agreed to between Plaintiff and Defendant |
| 2025-02-17 | Defendant sues Plaintiff's partner, PACCAR |
| 2025-04-07 | Defendant sues Plaintiff's supplier, CalAmp |
| 2025-05-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,941,223 - "Method and system for dynamic destination routing"
- Issued: September 6, 2005
The Invention Explained
- Problem Addressed: The patent's background describes vehicle navigation systems that calculate a static route at the beginning of a trip but cannot dynamically adjust that route in response to real-time events like traffic jams that occur during the drive (’223 Patent, col. 1:11-34).
- The Patented Solution: The invention proposes a two-stage method. First, a system determines an initial "optimal route" using "static information" like map data (’223 Patent, col. 2:8-10). Second, while the vehicle is in transit, the system receives "additional information" (e.g., real-time traffic data) and continuously compares the vehicle's actual travel parameters against the parameters expected for the optimal route. If a significant deviation occurs or conditions change, indicating the route is no longer optimal, the system automatically determines a new optimal route using the additional information (’223 Patent, col. 2:10-17; Fig. 3).
- Technical Importance: The technology aimed to advance navigation systems from providing a single, pre-determined path to offering a continuously optimized travel plan that adapts to real-world conditions as they unfold (’223 Patent, col. 2:8-17).
Key Claims at a Glance
- The complaint identifies independent claim 19 as being asserted by Fleet Connect (Compl. ¶65).
- The essential elements of method claim 19 are:
- Determining, based on static information, an optimal route;
- Receiving additional information;
- Determining, based on a comparison of the vehicle's real travel parameters with the optimal route's travel parameters, whether the route remains optimal; and
- Determining a new optimal route using the additional information when the original route is no longer optimal.
- The claim specifies that "travel parameters" include at least one of travel time and traveled distance (Compl. ¶68).
U.S. Patent No. 7,206,837 - "Intelligent trip status notification"
- Issued: April 17, 2007
The Invention Explained
- Problem Addressed: The patent's background highlights the difficulty and inconvenience for a person in transit to accurately estimate their time of arrival, given the complexity of factors like traffic, weather, and time-of-day variations (’837 Patent, col. 1:10-24).
- The Patented Solution: The invention describes a method where a system receives the location of a mobile device and uses that location in conjunction with "at least one historical travel time statistic" to estimate "time-of-arrival bounds" for a given destination (’837 Patent, col. 2:3-16; Abstract). This calculated arrival window is then transmitted back to the user's mobile device, providing a more intelligent and data-driven ETA.
- Technical Importance: This approach enhances the accuracy of ETA predictions by incorporating historical data, moving beyond simple calculations based only on current speed and remaining distance (’837 Patent, col. 2:5-9).
Key Claims at a Glance
- The complaint identifies independent claim 1 as being asserted by Fleet Connect (Compl. ¶73).
- The essential elements of method claim 1 are:
- Receiving a location of a mobile communications device in transit;
- Estimating time-of-arrival bounds for the device at its destination for a confidence interval, where the estimation is based on (a) the device's location and (b) at least one historical travel time statistic; and
- Sending the estimated time-of-arrival bounds to the mobile device.
- (Compl. ¶76).
U.S. Patent No. 7,741,968 - "System and method for navigation tracking of individuals in a group"
- Issued: June 22, 2010
- Technology Synopsis: This patent describes a system for group tracking where a "master" portable device can communicate with other devices in a group. The system enables the master device to receive and display the current geographic location of each group member and to send "converging instructions" and generate ETAs to facilitate a rendezvous (Compl. ¶¶52, 84).
- Asserted Claims: Independent claim 4 (Compl. ¶81).
- Accused Features: The complaint alleges Fleet Connect has accused Platform Science’s fleet management products, as used by customers such as Schneider and C.R. England, of infringement (Compl. ¶81).
U.S. Patent No. 6,429,810 - "Integrated air logistics system"
- Issued: August 6, 2002
- Technology Synopsis: The patent discloses a method for tracking a shipping container. The method involves attaching an electronic communications unit to the container, generating a transaction-specific identification code, and using that code to initiate a status inquiry from a user to the unit via a ground communications system (’810 Patent, Abstract; Compl. ¶92).
- Asserted Claims: Independent claim 1 (Compl. ¶89).
- Accused Features: The complaint alleges Fleet Connect has accused Platform Science’s products, as used by customers such as Werner and C.R. England, of infringement (Compl. ¶89).
U.S. Patent No. 6,961,586 - "Field assessments using handheld data management devices"
- Issued: November 1, 2005
- Technology Synopsis: This patent describes a method of conducting a field assessment where a user with a handheld device is given access to an "industry-specific field assessment program module." This module enables the user to perform tasks such as construction analysis or HVAC system analysis by executing the program, providing field-specific information, and retrieving data in support of the assessment (Compl. ¶¶54, 100).
- Asserted Claims: Independent claim 9 (Compl. ¶97).
- Accused Features: The complaint alleges Fleet Connect has accused Platform Science’s products, as used by customers such as Schneider and C.R. England, of infringement (Compl. ¶97).
U.S. Patent No. 7,593,751 - "Conducting field operations using handheld data management devices"
- Issued: September 22, 2009
- Technology Synopsis: The patent covers a method for managing data during a field operation with a handheld device that includes memory, a microprocessor, a GPS module, a display, a user interface, and a wireless communication module. The claimed method enables a user to access instructions, including mapped directions from a program or remote server, to find a location and manage data collection and communication (’751 Patent, Abstract; Compl. ¶¶105, 108).
- Asserted Claims: Independent claim 6 (Compl. ¶105).
- Accused Features: The complaint alleges Fleet Connect has accused Platform Science’s products, as used by customers such as Schneider and C.R. England, of infringement (Compl. ¶105).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are collectively identified as "Platform Science's 'fleet management platform and tracking solutions'" (Compl. ¶42). The complaint provides a non-exhaustive list of specific products and services, including PS Navigation, PS Analytics, PS Telematics, PS Workflow, PS Asset Tracking, Fleet Management Software, and hardware such as the Connected Vehicle Device (CVD) and In-Vehicle Display Tablet (ELD Tablet) (Compl. ¶¶7, 42, 44).
Functionality and Market Context
The accused products constitute an "open platform" that allows commercial trucking fleets to develop, customize, and integrate telematics, applications, and Internet of Things (IoT) solutions (Compl. ¶40). The complaint states that Fleet Connect's infringement allegations rely on public-facing materials, such as the Platform Science website, rather than on technical analysis of the products themselves (Compl. ¶44). The products are used by major commercial carriers, and the complaint alleges that Fleet Connect's lawsuits against these customers have "placed a cloud over Platform Science and its products and have disrupted its business" (Compl. ¶18).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement and states that Fleet Connect's infringement contentions are detailed in claim charts attached to the underlying customer complaints as Exhibits 15-27 (Compl. ¶43). As these exhibits were not provided with the complaint, the following analysis is based on the complaint's narrative summary of its non-infringement positions.
No probative visual evidence provided in complaint.
’223 Patent Infringement Allegations
- The complaint asserts that the Accused Products do not infringe claim 19 of the ’223 Patent because they do not satisfy at least limitation 19[a] (Compl. ¶69). This limitation requires the step of "determining, based on static information, an optimal route" (Compl. ¶68). The complaint’s position suggests that the accused system does not perform this specific, isolated step of calculating an initial route using only static data before considering dynamic data.
Identified Points of Contention
- Technical Question: A central factual question for the court will be how the accused Platform Science navigation system actually calculates an initial route. Does the system’s algorithm first generate a route based exclusively on static data (e.g., maps, speed limits) and only subsequently introduce dynamic data (e.g., real-time traffic), as the claim requires? Or does it use an integrated approach where static and dynamic data are considered together from the outset?
- Scope Questions: The dispute may turn on the definition of "static information." The question for claim construction could be whether this term is limited to unchanging map data or if it could be interpreted more broadly to include predictable, but variable, data like historical traffic patterns for a given time of day.
’837 Patent Infringement Allegations
- The complaint alleges non-infringement of claim 1 of the ’837 Patent on the basis that the Accused Products do not meet limitation 1[b] (Compl. ¶77). This element requires "estimating the time-of-arrival bounds... based on... at least one historical travel time statistic" (Compl. ¶76). This suggests Platform Science's position is that its ETA calculations do not rely on stored historical travel data.
Identified Points of Contention
- Technical Question: An evidentiary issue will be to determine the data inputs for the accused system's ETA calculation. Does the system's algorithm consult a database of past travel times for similar routes or conditions, or does it derive its estimates exclusively from real-time data, such as current vehicle speed, live traffic flow, and distance to destination?
- Scope Questions: The term "historical travel time statistic" may require construction. A key question is whether a predictive model trained on historical data, but which operates on live inputs, is performing estimation "based on" a historical statistic in the manner contemplated by the patent.
V. Key Claim Terms for Construction
The Term: "static information" (from claim 19 of the ’223 Patent)
Context and Importance
Plaintiff’s non-infringement defense for the ’223 Patent appears to hinge on this term. Practitioners may focus on this term because its scope determines whether the accused system performs the claimed method's distinct sequential steps. A narrow definition would support Plaintiff's argument if its system integrates any non-static data in its initial calculation, whereas a broader definition could favor Defendant.
Intrinsic Evidence for Interpretation
- Evidence for a Narrower Interpretation: The patent repeatedly contrasts "static information" used for the initial route with "additional information" (such as traffic) received "during the drive" to check if the route remains optimal (’223 Patent, col. 5:15-25). This structure may support an interpretation that "static information" is limited to data that does not change during the trip, such as fixed map data and speed limits.
- Evidence for a Broader Interpretation: The patent does not explicitly define the term. Defendant might argue for a plain and ordinary meaning where "static" refers to any data available before the trip commences, which could potentially include historical or predictable traffic patterns.
The Term: "historical travel time statistic" (from claim 1 of the ’837 Patent)
Context and Importance
The non-infringement argument for the ’837 Patent centers on whether the accused system uses this type of data. The case may depend on whether the accused ETA calculation directly incorporates stored data about past trip durations, as the claim requires.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent specification strongly supports a broad reading. It explicitly states that a "novel feature" is the "use of the calendrical time (i.e., the time and date) for estimating time-of-arrival metrics," which directly implies reliance on historical patterns associated with specific times and dates (’837 Patent, col. 2:4-7). The patent's flowchart also depicts a step to "look up historical travel time data" (see ’837 Patent, Fig. 4, step 450).
- Evidence for a Narrower Interpretation: Plaintiff might argue that a system using a predictive model that was trained on historical data but which operates only on live inputs during the actual trip does not perform estimation "based on" a "historical travel time statistic" in the manner claimed. However, the specification's emphasis on using calendrical time as a direct input makes this a potentially challenging argument.
VI. Other Allegations
Indirect Infringement
The complaint acknowledges that Fleet Connect has "repeatedly alleged that Platform Science indirectly infringes the asserted patents" (Compl. ¶49). The alleged basis for indirect infringement appears to be that Platform Science provides the accused products to its customers and instructs them on how to use the allegedly infringing functionalities, thereby inducing infringement (Compl. ¶¶19, 48).
Willful Infringement
The complaint does not state that Fleet Connect has explicitly alleged willful infringement. However, it details extensive pre-suit knowledge, including Fleet Connect's lawsuits against Platform Science’s customers and direct engagement with Platform Science for licensing purposes, which could provide a basis for a future willfulness claim if infringement is found (Compl. ¶¶29-37).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of operational methodology: Do the accused Platform Science products function in the specific manner required by the patent claims? The case will likely require a deep technical dive to determine if the accused routing software calculates an initial route using only "static information" before considering other data (’223 Patent), and if its ETA calculations directly query and rely on a database of "historical travel time statistics" (’837 Patent).
- A key legal question will be one of definitional scope: The construction of the term "static information" in the ’223 Patent will be critical. Whether it is narrowly confined to fixed map data or can be read more broadly to include predictable data like historical traffic averages could determine the outcome of infringement for that patent.
- A third pivotal question will be evidentiary: Given that Fleet Connect’s allegations in the underlying cases are purportedly based on publicly available marketing materials (Compl. ¶44), the case will test whether the actual, technical operation of the Accused Products aligns with the functional descriptions used for marketing, and whether those descriptions map onto the specific limitations of the asserted claims.