Minotaur Systems LLC v. Trimble Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Minotaur Systems LLC (Delaware)
  • Defendant: Trimble Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 1:24-cv-00789, D. Colo., 03/20/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the District of Colorado.
• Core Dispute: Plaintiff alleges that Defendant’s products, which are not specifically named in the complaint, infringe a patent related to in-vehicle systems that record and synchronize visual, non-visual, and biometric data.
• Technical Context: The technology concerns vehicle event data recorders that capture a comprehensive set of data points to reconstruct and analyze vehicle operation, particularly around incidents or "eccentric events."
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

Date	Event
2002-01-25	'376 Patent Priority Date (Provisional App. 60/351,968)
2003-01-27	'376 Patent Application Filing Date
2008-06-10	'376 Patent Issue Date
2024-03-20	Complaint Filing Date

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

U.S. Patent No. 7,386,376 - Vehicle visual and non-visual data recording system

• Patent Identification: U.S. Patent No. 7,386,376, Vehicle visual and non-visual data recording system, issued June 10, 2008.

The Invention Explained

• Problem Addressed: The patent asserts that prior vehicle data recorders were inadequate for comprehensively reconstructing accidents because they provided limited data, required expert analysis, lacked robust user interfaces, and did not explicitly record data about the vehicle's occupants. (’376 Patent, col. 1:26-37, col. 2:1-8).
• The Patented Solution: The invention proposes an integrated system to solve this problem by capturing and synchronizing three types of data: visual data from inside and outside the vehicle (potentially via a fish-eye camera), vehicle operational data (speed, braking), and occupant-specific data, including biometrics like heart rate. (’376 Patent, Abstract; col. 2:28-35). This data is continuously recorded to a circular buffer in volatile memory; upon detection of an "eccentric event" (e.g., a collision), a segment of data from before, during, and after the event is preserved by transferring it to non-volatile storage for later analysis (’376 Patent, col. 5:1-9, Fig. 5).
• Technical Importance: The system's proposed integration of occupant and biometric sensors with video and vehicle data represented an effort to move beyond simple data logging toward a system that could also anticipate hazardous conditions, such as driver drowsiness. (’376 Patent, col. 2:31-35, col. 2:41-43).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and refers to "Exemplary '376 Patent Claims" in its associated exhibits, but does not identify specific claims in the body of the complaint (Compl. ¶11). The analysis below focuses on the patent’s first independent claim.
• Independent Claim 1:
  • a data capture module capturing vehicle data and occupant data, wherein the data capture module captures biometric data;
  • a video capture module recording video data inside and outside the vehicle; and
  • a data recorder in the vehicle, the data recorder recording the vehicle data, the occupant data and the video data and continuously synchronizing the occupant data with the vehicle data.
• The complaint notes that Plaintiff may also assert infringement of other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in charts incorporated as Exhibit 2 (Compl. ¶11). This exhibit was not provided for analysis.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, as these details are presumably contained within the unprovided Exhibit 2 (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2, which was not available for this analysis (Compl. ¶¶16-17). The complaint's narrative states only that the "Exemplary Defendant Products practice the technology claimed by the '376 Patent" and "satisfy all elements of the Exemplary '376 Patent Claims" (Compl. ¶16). Without the referenced claim charts, a detailed analysis of the infringement allegations is not possible. No probative visual evidence provided in complaint.

Identified Points of Contention

• Based on the language of claim 1 of the ’376 Patent and the general nature of modern vehicle telematics, the infringement analysis may raise several technical and legal questions for the court.
  • Scope Questions: A central dispute may concern the definition of "biometric data." The court may need to determine if data derived from vehicle sensors (e.g., inferring fatigue from erratic steering) meets this limitation, or if the term is restricted to data from sensors that directly measure a physiological characteristic of the occupant, such as a heart-rate monitor as mentioned in the specification (’376 Patent, col. 2:41-42).
  • Technical Questions: A factual question will be whether the accused products perform "continuously synchronizing the occupant data with the vehicle data" as required by claim 1. The analysis will depend on the specific architecture of the accused systems and what evidence Plaintiff can produce to show that discrete data points related to an "occupant" are specifically and continuously time-correlated with vehicle and video data, rather than being collected as part of a general, unsynchronized data stream.

V. Key Claim Terms for Construction

• The Term: "biometric data"

• Context and Importance: This term appears in the first element of independent claim 1 and appears to be a key feature distinguishing the invention from prior art. The viability of the infringement claim may depend on whether data collected by the accused products, which may not include dedicated health sensors, can be characterized as "biometric."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue the term is broad, as the patent specification introduces the concept generally before providing a non-limiting example. The patent states the system uses "biometric sensors in order to anticipate an impending eccentric condition" (’376 Patent, col. 2:33-35) and later gives an example: "biometric sensors (such as a heart beat monitor)" (’376 Patent, col. 2:41-42). This "such as" language may support an interpretation that includes other data types related to the driver's physical state.
  • Evidence for a Narrower Interpretation: A party could argue the term is limited to direct physiological measurements. The specification's primary example is a "heart beat monitor" (’376 Patent, col. 4:30), and the system block diagram in Figure 1 shows "Biometrics" as a distinct input from other sensors like the "Drowsiness Detection System." This separation could suggest that data merely indicating a state like drowsiness, if not derived from a direct biological measurement, is not "biometric data" within the meaning of the claim.

• The Term: "occupant data"

• Context and Importance: This term is central to claim 1, and its scope will define what types of information about a vehicle's occupant fall within the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a lengthy and varied list of what may constitute occupant data: "occupant position data, occupant height data, occupant weight data, ... cellular phone in use, ... driver drowsiness data, heart-beat sensors." (’376 Patent, col. 5:44-49). This broad list could support an argument that any data point pertaining to the person inside the vehicle, whether physical or behavioral, qualifies.
  • Evidence for a Narrower Interpretation: A party might argue that the term should be construed in light of the patent's goal of creating a "complete record of the vehicle and occupant status" (’376 Patent, col. 2:34-35). This could support a reading that requires data directly measuring the physical status or position of the occupant (e.g., weight, position) rather than data about their use of ancillary devices (e.g., cellular phone). Furthermore, the requirement for "continuously synchronizing the occupant data" (’376 Patent, col. 8:19-20) may imply a certain type or quality of data amenable to such synchronization.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '376 Patent" (Compl. ¶14).

Willful Infringement

• The willfulness allegation is based on post-suit conduct. The complaint asserts that Defendant has had "actual knowledge of infringement" since the service of the complaint and that its continued alleged infringement is therefore willful (Compl. ¶¶13-14). No pre-suit knowledge is alleged.

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

• A core issue will be one of definitional scope: can the claim term "biometric data", which the patent illustrates with a heart-rate monitor, be construed to cover data types available in modern fleet telematics systems, such as driver scores or fatigue alerts derived from vehicle movement rather than direct physiological measurement?
• A key evidentiary question will be one of proof: because the complaint's infringement allegations are wholly contained in an unprovided exhibit, the case will turn on whether the evidence, once revealed, can demonstrate that the accused products meet every claimed element, particularly the requirement for "continuously synchronizing" specific "occupant data" with vehicle and video data in the manner described by the patent.
• The case also presents a damages question tied to the patent's 2008 issue date: the enforceability of the patent and any potential damages calculation will need to account for the significant evolution of vehicle telematics technology in the years since the patent was filed and issued.