DCT

1:23-cv-00801

Staton Techiya LLC v. Harman Intl Industries Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:23-cv-00801, D. Del., 06/18/2024
  • Venue Allegations: Venue is alleged to be proper as Defendant is a Delaware corporation and therefore resides in the District of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s HALOsonic automotive acoustic management systems infringe three patents related to vehicle audio processing, collaborative sensing, and situation awareness.
  • Technical Context: The technology concerns automotive acoustic management systems that use microphones, speakers, and processors to actively modify the sound environment inside a vehicle for purposes of safety, comfort, and functionality.
  • Key Procedural History: The complaint alleges a significant pre-suit relationship between the parties, beginning in October 2018, that included a mutual non-disclosure agreement, meetings between executives, and the sharing of Plaintiff’s prototypes, marketing materials, and proprietary whitepapers. Plaintiff alleges it sent Defendant a slide deck in February 2019 that identified certain patents-in-suit, which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2008-06-19 U.S. Patent No. 8,319,620 Priority Date
2008-09-22 U.S. Patent No. 11,610,587 Priority Date
2010-12-30 U.S. Patent No. 11,589,329 Priority Date
2012-11-27 U.S. Patent No. 8319620 Issues
2018-10-01 Plaintiff allegedly begins sending prototypes to HARMAN (approx.)
2019-02-01 Plaintiff allegedly sends "Opportunity Overview" slide deck to HARMAN (approx.)
2020-05-04 HARMAN allegedly confirms review of Plaintiff's patent portfolio
2023-02-21 U.S. Patent No. 11589329 Issues
2023-03-21 U.S. Patent No. 11610587 Issues
2024-06-18 Amended Complaint Filed

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

U.S. Patent No. 8,319,620 - "Ambient Situation Awareness System and Method for Vehicles," issued November 27, 2012

The Invention Explained

  • Problem Addressed: The patent’s background section describes the safety problem that occurs when drivers are unable to hear important external warning sounds, such as emergency sirens, because of loud in-cabin audio systems or ventilation fans (’620 Patent, col. 1:59-65). Prior art is described as failing to teach a method for modifying a driver alert based on the sound level inside the vehicle cabin (’620 Patent, col. 2:1-4).
  • The Patented Solution: The invention is a vehicle system that uses both an external (“ambient”) microphone to detect specific external sounds (“sonic signatures”) and an internal microphone to measure the sound pressure level (SPL) inside the cabin (’620 Patent, col. 3:38-44). A processor analyzes the external sound; if a known signature like a siren is identified, the system then evaluates the internal cabin SPL and determines whether and how to present an alert to the driver, ensuring the warning is audible over any in-cabin noise (’620 Patent, col. 4:30-43).
  • Technical Importance: The technology aims to enhance vehicle safety by creating a system that can dynamically adjust alerts to overcome the variable and often loud acoustic environment inside a modern vehicle (’620 Patent, col. 2:1-4).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶32).
  • The essential elements of claim 1 include:
    • A notification device in the vehicle configured to emit an audio signal.
    • An internal microphone configured to measure an internal acoustic signal in the vehicle.
    • An ambient microphone configured to measure an ambient acoustic signal external to the vehicle.
    • A processor configured to determine an internal sound pressure level (SPL) based on the internal signal, identify at least one sonic signature from the ambient signal, and, upon identification, determine whether to send an emit signal to the notification device based on the internal SPL.

U.S. Patent No. 11,589,329 - "Information Processing Using a Population of Data Acquisition Devices," issued February 21, 2023

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of individual electronic devices, noting that fusing information from multiple devices can yield valuable insights that a single device cannot obtain on its own (’329 Patent, col. 5:2-8).
  • The Patented Solution: The patent describes a distributed system where a "controller" can adaptively select a subset of devices from a larger population (e.g., smartphones, vehicle sensors) for data acquisition (’329 Patent, Abstract). The controller receives sensor data, such as audio, from the selected devices over a communication link and combines the information to determine a characteristic of the environment, such as the presence of speech (’329 Patent, col. 2:2-17). This allows for collaborative sensing and analysis among a network of devices (’329 Patent, col. 7:41-49).
  • Technical Importance: This technology provides a framework for networked, collaborative sensing, allowing a group of devices to perform complex environmental analysis that would be beyond the capability of any single device in the group (’329 Patent, col. 1:42-54).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶46).
  • The essential elements of claim 1 include:
    • A device among a plurality of acoustic devices, configured as a controller.
    • The controller is configured to perform operations comprising:
      • selecting a subset of acoustic devices from the plurality for acquiring sensor acoustic data, where the subset can interchange data over a communication link.
      • receiving a first set of sensor acoustic data from a first acoustic device of the subset.
      • receiving a second set of sensor acoustic data from a second acoustic device of the subset.
      • analyzing the data from one or both devices (or a combination) to identify if speech is present.

U.S. Patent No. 11,610,587 - "Personalized Sound Management and Method," issued March 21, 2023

  • Technology Synopsis: The patent describes a system for personalized sound management to address auditory overload from the environment (’587 Patent, col. 1:22-34). The invention includes a user interface and an audio device with a microphone, speaker, processor, and data buffers. The system is configured to detect a sonic signature, notify the user, modify the data in the buffer, and, in response to a user request (such as a voice command or manual input), send a portion of the data stored in the buffer to the speaker (’587 Patent, Abstract; Compl. ¶63).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶60).
  • Accused Features: The complaint alleges that the HALOsonic system’s cockpit, which functions as a user interface and processor, infringes by using microphones to capture ambient sound, placing a portion of the microphone signal in a buffer for analysis of a sonic signature (e.g., for "external speech recognition"), and sending data from the buffer to the car speakers upon a user request (Compl. ¶64).

III. The Accused Instrumentality

Product Identification

  • The representative accused product is the HARMAN HALOsonic system, which the complaint describes as a set of "tailormade sound solutions" for vehicles (Compl. ¶25-26).

Functionality and Market Context

  • The HALOsonic system is alleged to be an automotive acoustic management system comprising features such as Electronic Sound Synthesis (ESS), Engine Order Cancellation (EOC), and Road Noise Cancellation (RNC) (Compl. ¶26, ¶28). The complaint alleges the system utilizes external sensors, referred to as Sound and Vibration Sensors (SVS), mounted on vehicle surfaces to capture external sounds, as well as internal microphones to capture in-cabin sounds (Compl. ¶27, ¶36). A feature called Sound2Target is described as combining active noise cancellation with electronic sound synthesis to simultaneously remove unwanted noise while augmenting desired sounds (Compl. p.8 visual). The complaint alleges these features are used for functions like "external speech recognition" and "verbal interaction" (Compl. ¶64). The complaint provides a marketing diagram illustrating a sensor for invisible vehicle integration enabling exterior speech recognition and acoustic sensing (Compl. p.6 visual).

IV. Analysis of Infringement Allegations

’620 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a notification device in the vehicle configured to emit an audio signal The Accused Product utilizes the standard speaker system in a vehicle to generate a desired audio signal within the cabin. ¶36 col. 4:13-16
an internal microphone configured to measure an internal acoustic signal in the vehicle The Accused Product uses internal microphones to measure an internal acoustic signal within the vehicle's cabin. ¶36 col. 4:30-32
an ambient microphone configured to measure an ambient acoustic signal external to the vehicle The Accused Product uses HARMAN External Microphones, such as the Sound and Vibration Sensor, placed on the vehicle's exterior to capture ambient sound. A diagram from Defendant's materials depicts this external sensor functionality (Compl. p.6 visual). ¶36, ¶27 col. 4:38-40
and a processor configured to: determine an internal sound pressure level (SPL)..., identify at least one sonic signature from the ambient acoustic signal, and when the at least one sonic signature is identified, determine whether to send an emit signal... to emit the audio signal based on the internal SPL The complaint alleges a processor is configured to perform these steps. It determines an internal sound level from the internal signal, identifies a "signature sound" from the ambient signal, and then determines whether to send an emit signal to the notification device. The "Sound2Target" feature is alleged to combine noise cancellation and sound synthesis to achieve a desired vehicle sound signature (Compl. p.8 visual). ¶36 col. 3:28-34
  • Identified Points of Contention:
    • Technical Questions: A key question is whether the HALOsonic system’s alleged function—managing continuous powertrain and road noise through cancellation and synthesis—equates to the claimed process of identifying a discrete external "sonic signature" (like an emergency siren) and then emitting a responsive "audio signal" (an alert). The complaint does not specify what "signature sound" the Accused Product allegedly identifies in the manner claimed by the patent.
    • Scope Questions: The dispute may focus on the scope of "sonic signature." The patent’s examples focus on specific, acute warning events like sirens and horns, which raises the question of whether the term can be construed to cover the generalized engine and road noise that features like EOC and RNC are designed to manage.

’329 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a device among a plurality of acoustic devices; wherein the device is configured as a controller The system is implemented in the vehicle, and the vehicle's cockpit functions as a controller. ¶50 col. 2:4-5
wherein the controller is configured to perform operations comprising: selecting a subset of acoustic devices from among the plurality of acoustic devices for acquiring sensor acoustic data, wherein the subset of acoustic devices are configured to interchange device information and data over a communication link The complaint alleges the controller selects a subset of devices for acquiring data, such as internal and external microphones. Captured acoustic data is allegedly transmitted to the cockpit over a communication link where it is analyzed. ¶50 col. 12:31-35
receiving a first set of sensor acoustic data from a first acoustic device of the selected subset of acoustic devices The controller receives acoustic data captured by HARMAN External Microphones placed on the exterior of the vehicle. ¶50 col. 12:36-40
receiving a second set of sensor acoustic data from a second acoustic device of the selected subset of acoustic devices The controller can also use internal microphones to capture internal acoustic data within the cabin for analysis. ¶50 col. 12:36-40
and analyzing at least one of the first set of sensor acoustic data or the second set of sensor acoustic data or a combination of both to identify if speech is present Data from the microphones is allegedly analyzed to identify speech. The complaint alleges this is performed for features like "external speech recognition" and "verbal interaction" (Compl. p.11 visual). ¶50, ¶64 col. 10:48-56
  • Identified Points of Contention:
    • Scope Questions: A principal question is whether the term "plurality of acoustic devices" from which a "subset" is selected can read on a fixed vehicle architecture with one set of internal microphones and one set of external microphones. The patent specification discusses a "population of data acquisition devices," such as a large number of smartphones in a metropolitan area, suggesting a more dynamic and distributed network (’329 Patent, col. 3:13-28).
    • Technical Questions: What evidence does the complaint provide that the HALOsonic system performs an active "selecting" of a subset of devices? The patent describes an adaptive process, but the complaint describes a seemingly fixed architecture, raising the question of whether this element is met or is instead a point of technical dispute.

V. Key Claim Terms for Construction

For the ’620 Patent:

  • The Term: "sonic signature"
  • Context and Importance: The infringement analysis for the '620 Patent may depend heavily on how this term is defined. A broad construction covering any identifiable acoustic pattern could support Plaintiff's theory that managing engine noise is infringement. A narrower construction, potentially limited to discrete, external warning sounds as exemplified in the patent, could support a non-infringement argument. Practitioners may focus on this term because the accused functionality (general noise management) appears different from the patent's primary examples (siren detection).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general, referring to "at least one sonic signature" without express limitation to a specific type of sound (’620 Patent, cl. 1).
    • Evidence for a Narrower Interpretation: The specification repeatedly uses "sirens" and "car horns" as the primary examples of signature sounds the system is designed to detect (’620 Patent, col. 2:20-25). The summary of the invention also frames the technology in the context of detecting "malfunction of a vehicle subsystem" or other acute sounds like sirens (’620 Patent, col. 2:11-25).

For the ’329 Patent:

  • The Term: "selecting a subset of acoustic devices from among the plurality"
  • Context and Importance: This term appears central to the novelty of the invention, which is based on collaborative sensing among a population of devices. Infringement will likely require proof that the accused system performs an active "selection" rather than simply processing data from a fixed set of inputs. The distinction between a dynamic selection process and a static, pre-configured architecture will be a critical issue.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not specify that the selection must be dynamic or change over time; it only requires that an operation of "selecting" occurs.
    • Evidence for a Narrower Interpretation: The specification describes a system that may "adaptively enable particular subsets of the devices" and "selectively configure enabled devices" based on triggering events (’329 Patent, col. 3:28-33). The flowchart in Figure 3 includes a decision block for "ADJUST SUBSET?" which implies a dynamic, ongoing selection process, not a one-time configuration (’329 Patent, Fig. 3, col. 12:58).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that HARMAN actively induces infringement by "users of the Accused Product" for all three asserted patents (Compl. ¶37, ¶51, ¶65). The allegations are based on HARMAN selling the HALOsonic product with knowledge and intent that its ordinary operation by customers will practice the claimed methods.
  • Willful Infringement: The complaint alleges willful infringement for all three patents. For the ’620 Patent, willfulness is predicated on alleged pre-suit notice. The complaint alleges that by February 2019, HARMAN had received an "Opportunity Overview" slide deck from Plaintiff that specifically identified the '620 Patent (Compl. ¶18, ¶33). A visual from this alleged deck is included in the complaint, showing the '620 patent number highlighted under a feature category (Compl. p.4 visual). For the '329 and '587 patents, willfulness is based on knowledge gained after the filing and service of the original complaint in this action (Compl. ¶47, ¶61).

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

  1. A core issue will be one of definitional scope: can the term "sonic signature" from the ’620 patent, rooted in the context of detecting discrete events like sirens, be construed to cover the continuous engine and road noise managed by the HALOsonic system’s noise cancellation and sound synthesis features?
  2. A key evidentiary question will be one of operational equivalence: does the accused HALOsonic system, with its seemingly fixed set of internal and external microphones, perform the dynamic process of "selecting a subset of acoustic devices" from a "plurality" as required by the ’329 patent, or is there a fundamental mismatch in technical operation?
  3. Given the detailed allegations of pre-suit meetings and the provision of a patent-identifying slide deck, a central question for damages will be willfulness: can Plaintiff establish that HARMAN possessed pre-suit knowledge of its infringement of the '620 patent, and that its conduct was egregious enough to warrant enhanced damages under 35 U.S.C. § 284?