Dale Progress Ltd v. Allgo Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dale Progress Ltd. (Republic of Korea)
  • Defendant: Allgo Systems, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC; Hansley Law Firm, PLLC
• Case Identification: 1:19-cv-00823, D. Del., 05/03/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in the district, has transacted business there, and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s smartphone-to-vehicle connectivity software suite infringes patents related to a remote resource access interface apparatus that mirrors a portable device's display and controls onto an external system.
• Technical Context: The technology at issue facilitates the integration of portable devices like smartphones with automotive infotainment systems, allowing a vehicle's built-in dashboard screen and controls to operate applications running on the user's phone.
• Key Procedural History: The complaint does not reference prior litigation or post-grant proceedings. U.S. Patent No. 9,686,504 is a continuation of the application family that includes U.S. Patent No. 8,320,461 and is subject to a terminal disclaimer.

Case Timeline

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

U.S. Patent No. 9,686,504, “Remote Resource Access Interface Apparatus,” Issued June 20, 2017

The Invention Explained

• Problem Addressed: The patent describes the problem of portable electronic devices like PDAs and mobile phones having small display screens and keypads, which creates "manipulation inconvenience" and limits their usability, despite their advanced functionalities (’504 Patent, col. 1:35-38). Furthermore, the proliferation of such devices with redundant hardware and software components results in a "waste of resources" ('504 Patent, col. 1:40-41).
• The Patented Solution: The invention is an external "remote resource access interface apparatus" (e.g., a vehicle head unit) designed to connect to a portable device. This apparatus has its own, typically larger, display and input mechanisms. The solution involves the apparatus and the portable device exchanging capability information, such as screen resolution and supported functions. This allows the portable device's video output to be adjusted for the apparatus's screen and enables the apparatus's physical or touch-screen controls to operate the portable device by mapping inputs accordingly ('504 Patent, Abstract; FIG. 1).
• Technical Importance: This technology provides a framework for enabling "screen mirroring" standards that allow applications on a portable device to be operated via a separate, more user-friendly interface, such as a vehicle's integrated dashboard display ('504 Patent, col. 1:48-54).

Key Claims at a Glance

• The complaint asserts independent claim 2, as well as claims 1 and 3-9 (Compl. ¶11-12).
• The essential elements of independent claim 2 include:
  • A "touch input detection unit" to detect touch on a display screen and generate position information.
  • A "communication unit" to exchange key information and video information with a portable device.
  • A "video output unit" with a screen specification (e.g., resolution) different from the portable device, configured to display adjusted video information.
  • A "key advisor unit" that receives the touch position information and maps it to key values of the portable device, where the video information is adjusted based on the screen resolution information exchanged between the devices.
• The complaint reserves the right to assert additional claims.

U.S. Patent No. 8,320,461, “Remote Resource Access Interface Apparatus,” Issued November 27, 2012

The Invention Explained

• Problem Addressed: The patent identifies the same technical problem as the '504 patent: the limited usability of portable devices due to their small screens and keypads (’461 Patent, col. 1:22-29).
• The Patented Solution: The invention describes an interface apparatus that initiates a connection with a portable device by sending a request signal. In response, it receives the portable device's capabilities, including supported screen resolutions and function keys. The apparatus then uses this information to display video from the device on its own larger screen and to configure its inputs. A central element is a "key configuration mode" where the apparatus's keys are matched to the functions of the portable device ('461 Patent, Abstract; FIG. 3).
• Technical Importance: The invention provides a method for an external I/O system to discover and adapt to the capabilities of a connected portable device, forming a basis for technologies that integrate personal electronics with platforms like vehicle infotainment systems ('461 Patent, col. 1:40-48).

Key Claims at a Glance

• The complaint asserts independent claim 9, as well as claims 1-2, 4-8, and 10 (Compl. ¶23-24).
• The essential elements of independent claim 9 include:
  • A "key input unit" to generate input key values.
  • A "communication unit" that transmits a "connection establishment request message" and receives a "connection establishment response message" containing screen resolution and supportable key information, and subsequently exchanges input key and video information.
  • A "video output unit" with a display screen larger than the portable device.
  • A "key advisor unit" that, when a "key configuration mode" is activated, displays keys of the portable device and receives corresponding keys from the key input unit, ultimately mapping key values between the apparatus and the portable device.
• The complaint reserves the right to assert additional claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "RACE Smartphone Connectivity suite," which provides "embedded SDKs that enable automotive head units to connect to and control applications running on smartphones and tablets" (Compl. ¶12). The complaint specifies that these products are "MirrorLink implementations" (Compl. ¶12).

Functionality and Market Context

• The RACE suite is alleged to provide the core software technology that allows an automotive head unit to project a smartphone's user interface onto the in-vehicle display, a process the complaint refers to as "screen scraping" (Compl. ¶28, p. 28). A diagram in the complaint shows the data flow for audio, control, and display between a smartphone and a head unit (Compl. ¶27, p. 27).
• The technology enables control of the smartphone's applications through the head unit's native inputs, including "touch, knobs and steering wheel controls" (Compl. ¶20, p. 8).
• The complaint alleges that the accused products are part of the "leading smartphone connectivity technologies" that are "demanded by automotive OEMs" to provide application connectivity to customers (Compl. ¶20, p. 8). A software block diagram illustrates the architecture of the "AllGo Mirror Link Client SDK" as the interface between the car head unit hardware and the smartphone (Compl. ¶20, p. 9).

IV. Analysis of Infringement Allegations

'504 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A question for the court may be whether the "key advisor unit," described as a distinct module in the patent's figures, can be construed to read on the allegedly infringing functionality, which is distributed across software layers in the accused SDK.
• Technical Questions: The complaint alleges that the accused system maps touch position information to "key values" of the portable device. A key factual question will be what evidence supports this specific mapping mechanism, beyond the general allegation that touch inputs are "directed to the phone."

'461 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement theory hinges on whether the accused system's "drive mode" and "park mode," which dynamically change available functions for safety, can be construed as the "key configuration mode" recited in the claim. The patent's description and figures suggest a more explicit, step-by-step setup process (see '461 Patent, FIG. 3).
• Technical Questions: Does the communication handshake in the accused MirrorLink system constitute the specific "connection establishment request message" and "response message" recited in the claim? The court may need to determine if the series of protocol messages cited in the complaint collectively meet this limitation.

V. Key Claim Terms for Construction

• The Term: "key advisor unit" ('504 Claim 2; '461 Claim 9)

  • Context and Importance: This term names a core structural component in the asserted independent claims of both patents. Practitioners may focus on this term because its construction will determine whether the accused software-based system, which consists of various libraries and protocols, meets the definition of this "unit."
  • Intrinsic Evidence for a Broader Interpretation: The specification describes the unit by its functions, stating it "extracts supportable key information... and transmits the supportable key information to the video output unit" ('461 Patent, col. 3:9-12). This language may support a functional interpretation where any component or set of components that performs the recited actions qualifies.
  • Intrinsic Evidence for a Narrower Interpretation: The patent's block diagrams depict the "key advisor unit" (e.g., item 140 in FIG. 1) as a distinct structural block, separate from the "communication unit" and "key input unit". This may support an interpretation requiring a discrete, identifiable module rather than a set of distributed software functions.

• The Term: "key configuration mode" ('461 Claim 9)

  • Context and Importance: This term is a crucial condition that triggers a key function of the "key advisor unit" in claim 9. The dispute will likely center on whether the accused product's "drive/park mode" functionality is equivalent to this claimed mode.
  • Intrinsic Evidence for a Broader Interpretation: The claim language states, "if a key configuration mode is activated," without further defining the trigger or nature of the mode in the claim itself ('461 Patent, col. 6:58-59). This could support an argument that any operational mode that alters the configuration of available keys falls within the term's scope.
  • Intrinsic Evidence for a Narrower Interpretation: The patent's detailed flowchart (FIG. 3) illustrates a specific process for this mode, which involves steps like "display one of keys of portable device on display screen" and "match input key to key value displayed" ('461 Patent, FIG. 3, steps 360-380). This detailed embodiment may be used to argue for a narrower construction that requires a similar user-involved setup sequence, which may not be present in the accused product's automatic mode switching.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by providing its products to "customers, resellers and end-use consumers" (Compl. ¶14, ¶26). The alleged acts of inducement include advertising, providing instructions, and supplying the software components necessary to practice the claimed methods (Compl. ¶17, ¶29).
• Willful Infringement: Willfulness is alleged based on Defendant having received notice of the patents "at least as of the date this lawsuit was filed" (Compl. ¶15, ¶27). The prayer for relief seeks treble damages for any post-filing infringement (Compl. p. 42, ¶D).

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

• A core issue will be one of definitional scope: can the term "key advisor unit", depicted in the patents as a discrete hardware block, be construed to cover the distributed software libraries and protocols within the accused MirrorLink SDK? This raises a fundamental question of structural equivalence between the patent's disclosure and the accused software architecture.
• A second central issue will be one of modal equivalence: does the accused product's automatic switching between a safety-restricted "drive mode" and an unrestricted "park mode" meet the requirements of the "key configuration mode" recited in the '461 patent, which the specification illustrates as a more deliberate, step-by-step setup process?
• A key evidentiary question will be one of functional mapping: beyond general allegations of "directing" inputs, what specific evidence will show that the accused system performs the precise mapping of "touch position information" to "key values of the portable device" as required by the '504 patent, and that its communication protocol performs the specific request-and-response sequence claimed in the '461 patent?