DCT

1:23-cv-00055

SZ DJI Technology Co Ltd v. Textron Specialized Vehicles Inc

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Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00055, D. Del., 01/17/2023
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because both Defendants are organized under the laws of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s E-Z-GO golf carts equipped with "Geofencing" features and "ELiTE Lithium powertrains" infringe three patents related to vehicle restriction zones and battery-compensated motor control.
  • Technical Context: The technologies at issue involve creating precise, often irregularly shaped, virtual boundaries (geofences) to control vehicle behavior and dynamically adjusting motor output to compensate for battery power degradation, both of which are significant for managing fleets of electric vehicles.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2015-03-09 Priority Date for ’116 and ’121 Patents
2016-03-01 Priority Date for ’224 Patent
2020-05-05 ’224 Patent Issued
2022-10-04 ’116 Patent Issued
2022-10-25 ’121 Patent Issued
2023-01-17 Complaint Filed

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

U.S. Patent No. 11,462,116 - "Polygon Shaped Vehicle Restriction Zones"

  • Patent Identification: U.S. Patent No. 11,462,116, titled "Polygon Shaped Vehicle Restriction Zones," issued on October 4, 2022. (Compl. ¶8).
  • The Invention Explained:
    • Problem Addressed: The patent describes the need to control vehicle flight within or near irregularly shaped regions, such as airports or buildings, where simple circular restriction zones are inadequate. (’116 Patent, col. 1:21-29).
    • The Patented Solution: The invention proposes creating complex, polygonal restriction zones by combining smaller, standardized geometric shapes called "flight-restriction strips." Each strip is defined by two circles at its ends connected by tangent lines. By linking these strips together, the system can form a precise boundary around an irregular area and direct a vehicle to take a "flight response measure" (e.g., stop or turn away) if it gets too close. (’116 Patent, Abstract; col. 2:37-44).
    • Technical Importance: This method allows for the creation of more granular and accurately shaped geofences than traditional circular or simple polygonal methods, which is critical for safely managing autonomous or semi-autonomous vehicles near sensitive areas. (’116 Patent, col. 1:30-37).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1. (Compl. ¶14).
    • Essential elements of claim 1, a method, include:
      • Receiving two or more points associated with a restriction region.
      • Generating one or more restriction strips along a boundary of the region by connecting adjacent points.
      • Wherein at least one restriction strip is configured to have an area encompassed by a first circle, a second circle, and one or more lines running tangent to both circles.
      • Automatically causing a ground vehicle to undertake one or more response measures based on its location or movement relative to the restriction region.
    • The complaint expressly reserves the right to assert additional claims. (Compl. ¶15).

U.S. Patent No. 11,482,121 - "Open Platform for Vehicle Restricted Region"

  • Patent Identification: U.S. Patent No. 11,482,121, titled "Open Platform for Vehicle Restricted Region," issued on October 25, 2022. (Compl. ¶9).
  • The Invention Explained:
    • Problem Addressed: The patent recognizes that various public and private parties may desire to impose operational restrictions on vehicles in certain areas, creating a need for a centralized platform to manage the creation and enforcement of these restriction regions. (’121 Patent, col. 1:21-27).
    • The Patented Solution: The invention provides a system that acts as an "open platform" for managing restriction regions. It allows a plurality of users to input parameters, such as the location of a private property, to define a restricted zone. The system then authenticates the user's identity to determine if they are authorized to create such a zone, stores the parameters, and implements automated response measures for vehicles that interact with the newly defined region. (’121 Patent, Abstract; col. 2:15-32).
    • Technical Importance: This technology facilitates a collaborative or crowdsourced approach to geofence management, enabling property owners, government agencies, and other stakeholders to define and enforce vehicle operating rules in specific geographic areas. (’121 Patent, col. 2:4-14).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1. (Compl. ¶19).
    • Essential elements of claim 1, a system, include:
      • One or more processors configured to receive parameters for a designated restriction region for a ground vehicle from a user, where the parameters include a location associated with a private property.
      • The processors are further configured to authenticate an identity of the user to determine if they are authorized to designate the restriction region.
      • In response to authorization, the processors store the parameters to a database and associate one or more response measures with the region.
      • The processors implement the response measures to affect the operation of the ground vehicle when it is within or near the region.
    • The complaint expressly reserves the right to assert additional claims. (Compl. ¶20).

U.S. Patent No. 10,640,224 - "Motor Control Method, Apparatus, and System"

  • Multi-Patent Capsule
    • Patent Identification: U.S. Patent No. 10,640,224, titled "Motor Control Method, Apparatus, and System," issued May 5, 2020. (Compl. ¶10).
    • Technology Synopsis: The patent addresses the technical problem of performance degradation in battery-powered electric motors as the battery discharges and its voltage drops. (’224 Patent, col. 1:21-37). The patented solution involves a control system that continuously obtains an electrical parameter of the battery (e.g., current voltage), calculates a "compensation amount" for the motor's control signal based on this parameter, and then modifies the control signal to counteract the effect of the voltage drop, thereby maintaining stable motor performance. (’224 Patent, Abstract; col. 2:41-49).
    • Asserted Claims: The complaint asserts at least independent claim 12. (Compl. ¶24).
    • Accused Features: The complaint accuses the "ELiTE Lithium powertrain" used in a range of E-Z-GO golf carts of infringement. (Compl. ¶23-24).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are various models of E-Z-GO golf carts, including the RXV, Freedom RXV, Liberty, Express, Hauler, Refresher Oasis, and Shuttle models. (Compl. ¶13, ¶18, ¶23-24).

Functionality and Market Context

  • The complaint alleges that certain models infringe the ’116 and ’121 Patents because they incorporate a "Geofencing feature." (Compl. ¶13, ¶18).
  • It further alleges that certain models infringe the ’224 Patent because they are equipped with the "ELiTE Lithium powertrain." (Compl. ¶23-24).
  • The complaint does not provide specific technical details about the operation of these features, instead referencing claim charts in Exhibits D, E, and F, which were attached to the complaint but are not included in the provided documents. No probative visual evidence provided in complaint.
  • The complaint alleges these products are made, used, offered for sale, sold, and/or imported in the United States by the Defendants. (Compl. ¶13, ¶18, ¶23).

IV. Analysis of Infringement Allegations

11,462,116 Infringement Allegations

The complaint alleges that the accused E-Z-GO golf carts equipped with the "Geofencing feature" directly infringe at least claim 1 of the ’116 Patent. (Compl. ¶13-14). The complaint states that the specific infringement contentions are set forth in an accompanying claim chart (Exhibit D), which was not provided for this analysis. The narrative infringement theory suggests that the geofencing feature allows for the creation of restricted zones on properties like golf courses (the "restriction region") and automatically controls the cart's movement (the "response measures") relative to these zones, thereby practicing the patented method.

  • Identified Points of Contention:
    • Technical Question: A primary technical question will be whether the accused "Geofencing feature" actually constructs its boundaries using the specific geometric method recited in claim 1—namely, by generating "restriction strips" formed by "a first circle, a second circle, and one or more lines running tangent" to them. Evidence of how the accused system defines and represents zone boundaries will be central.
    • Scope Question: A potential dispute may arise over whether the geofencing functionality for a "ground vehicle" like a golf cart falls within the scope of a patent whose specification heavily discusses unmanned aerial vehicles (UAVs).

11,482,121 Infringement Allegations

The complaint alleges that the accused E-Z-GO golf carts with the "Geofencing feature" directly infringe at least claim 1 of the ’121 Patent. (Compl. ¶18-19). The specific details of infringement are said to be in a claim chart (Exhibit E) that was not provided. The narrative theory suggests that Defendants' system functions as an "open platform" where users (e.g., golf course administrators) can define restricted regions for their private property, with the system authenticating the user, storing the defined zone, and enforcing it on the vehicles.

  • Identified Points of Contention:
    • Scope Question: The infringement analysis will likely focus on whether the accused system performs the claimed step of "authenticate[ing] an identity of the user to determine whether the user is authorized." A key question is whether a standard login for a course administrator constitutes the claimed authentication of authority over a specific "private property," or if the claim requires a more rigorous verification of property rights.
    • Technical Question: It will be a factual question whether the accused system is designed to receive inputs from a "plurality of users" to define different restriction regions, as contemplated by the patent's "open platform" concept.

V. Key Claim Terms for Construction

  • ’116 Patent, Claim 1

    • The Term: "restriction strip ... having an area encompassed by a first circle, a second circle, and one or more lines running tangent to the first circle and the second circle"
    • Context and Importance: This term defines the specific geometric building block of the claimed boundary. Infringement will depend on whether the accused geofencing system uses this exact "pill-shaped" geometry to define zones. Practitioners may focus on this term because its specificity presents a high bar for an accuser to prove literal infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states this method allows one to "accurately mimic the intended boundary region," which could suggest that other functionally similar methods for creating linear boundaries with rounded ends might be encompassed. (’116 Patent, col. 23:29-32).
      • Evidence for a Narrower Interpretation: The claim language is precise and is explicitly illustrated in Figure 6 and its corresponding description, which details an area "encompassed by a circle of radius RA centered at point A, a circle of radius RB centered at point B, and lines 208e and 209e tangent to the two circles." (’116 Patent, col. 23:25-29). This suggests the claim is limited to this specific geometric construction.

  • ’121 Patent, Claim 1

    • The Term: "authenticate an identity of the user to determine whether the user is authorized to designate the restriction region"
    • Context and Importance: This term is critical because it appears to require a two-part process: verifying who the user is (identity) and confirming their right to set a boundary (authorization). The case may turn on whether the accused system's access control meets this standard.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's abstract describes a system for receiving input from a user and obtaining associated information, which could be argued to cover a system where a user's role (e.g., "administrator") implies authorization without a separate verification step. (’121 Patent, Abstract).
      • Evidence for a Narrower Interpretation: The patent discusses confirming that a user "exercises control over the flight restriction region," for instance by being an "owner," "tenant or resident," or having authority conveyed by a "governing entity." (’121 Patent, col. 7:1-12). This suggests a system that does more than accept a simple login, requiring some verification of the user's real-world authority over the specified property.

VI. Other Allegations

  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 for the purpose of awarding attorneys' fees but does not plead the facts typically used to support a claim for enhanced damages due to willfulness under § 284. (Compl. p. 6).

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

The resolution of this dispute may depend on the answers to several key questions:

  • A core issue will be one of technical correspondence: for the ’116 patent, does discovery evidence show that the accused "Geofencing feature" constructs its boundaries using the specific "circle-tangent-circle" strip geometry required by the claims, or does it employ a fundamentally different geometric or algorithmic approach?
  • A central question of functional scope will arise for the ’121 patent: does the accused system’s user access protocol perform the claimed function of "authenticating" a user's authority over a specific private property, or is it a more general login system that falls short of the claim's requirement to verify authorization?
  • A key evidentiary question for the ’224 patent will be whether the accused "ELiTE Lithium powertrain" can be shown to practice the claimed method of dynamically calculating a "compensation amount" to modify a motor control signal specifically to counteract battery voltage drop, as distinguished from other known methods of battery or motor management.