DRB Systems LLC v. Sonny's Enterprises LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: DRB Systems LLC (Ohio)
  • Defendant: Sonny's Enterprisess LLC (Delaware)
  • Plaintiff’s Counsel: DLA Piper US LLP
• Case Identification: 1:23-cv-00960, D. Del., 08/31/2023
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation and is therefore deemed to reside in the district.
• Core Dispute: Plaintiff alleges that Defendant’s SmartSTOP Anticollision System for car washes infringes a patent related to using computer vision and a central controller to monitor vehicles and prevent collisions within a car wash tunnel.
• Technical Context: The technology addresses the prevention of vehicle collisions in automated car wash tunnels, a risk heightened by modern automotive features like automatic emergency braking systems.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of the patent-in-suit via a letter dated April 11, 2023. The complaint also states that Plaintiff’s own commercial product, NoPileups, is sold under virtual patent marking for the patent-in-suit.

Case Timeline

Date	Event
2016-07-25	'283 Patent Priority Date
2021-09-21	'283 Patent Issue Date
2023-04-11	Plaintiff's counsel allegedly sent notice letter to Defendant
2023-05-08	Defendant allegedly described and depicted the accused SmartSTOP system in online promotional materials
2023-08-31	Complaint Filing Date

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

U.S. Patent No. 11,127,283 - "Systems and Methods to Prevent Carwash Collisions" (Issued Sep. 21, 2021)

The Invention Explained

• Problem Addressed: The patent addresses the problem of vehicle collisions inside automated car wash tunnels, which can occur if a vehicle "jumps a roller on the conveyor" or if its movement is otherwise altered (e.g., by a driver applying brakes or an automatic braking system engaging) ('283 Patent, col. 1:29-55). Such incidents can lead to "damaging and expensive pileups," a problem not adequately solved by prior art systems that may only monitor a vehicle's entry and exit points ('283 Patent, col. 1:34-35, col. 2:33-37).
• The Patented Solution: The invention proposes a system using one or more vision devices (e.g., cameras, LIDAR, RADAR) to monitor the car wash tunnel ('283 Patent, col. 5:1-9). A central controller receives visual data from these devices, tracks the positions of multiple vehicles, creates a "modeled path" for a vehicle's expected movement, and issues a "stop conveyor command" if the vehicle's actual tracked position deviates from this modeled path ('283 Patent, Abstract; col. 10:49-63). This allows for continuous monitoring along the entire length of the tunnel ('283 Patent, col. 2:35-40).
• Technical Importance: The claimed solution provides a more robust collision avoidance system than single-point sensors by tracking the vehicle's complete journey through the tunnel, which may be particularly important for addressing unpredictable movements caused by modern vehicle technologies (Compl. ¶¶11, 28).

Key Claims at a Glance

• The complaint asserts infringement of independent claim 1 and dependent claims 2-4 (Compl. ¶40).
• The essential elements of independent claim 1 are:
  • A carwash tunnel;
  • An automotive-vehicle conveyor configured to move vehicles along a substantially linear path;
  • Automotive-vehicle washing equipment;
  • A vision device attached to the tunnel to receive visual data of vehicle locations;
  • A central controller configured to perform a set of functions, including:
    • controlling the conveyor and washing equipment;
    • receiving the visual data;
    • tracking the positions of multiple vehicles;
    • creating a modeled path of a vehicle moving through the tunnel; and
    • giving a stop conveyor command if a tracked vehicle position does not match the modeled path.
• The complaint reserves the right to assert other claims (Compl. ¶40).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant’s "SmartSTOP Anticollision System" ("SmartSTOP") (Compl. ¶29).

Functionality and Market Context

• The complaint alleges that SmartSTOP is an "AI detection technology that prevents in-tunnel accidents" (Compl. ¶31). It is described as using "Optical Object Tracking (OOT) based on machine learning" to monitor the entire length of the car wash tunnel and up to 15 feet of the tunnel exit (Compl. ¶30). The system is designed to "immediately shut[] down conveyor and equipment when a potential threat is detected" (Compl. ¶30). A promotional graphic included in the complaint depicts the SmartSTOP system monitoring vehicles with colored overlays inside a car wash tunnel (Compl. p. 15). The system is marketed as a way for car wash operators to prevent incidents and costly downtime (Compl. ¶31).

IV. Analysis of Infringement Allegations

'283 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a carwash tunnel	The SmartSTOP system operates within a carwash tunnel. A screenshot from Defendant's website shows the system operating inside an exemplary carwash tunnel.	¶42	col. 4:35-42
an automotive-vehicle conveyor attached to the carwash tunnel... configured to move a plurality of automotive vehicles inline along a substantially linear path	The SmartSTOP system is used with a carwash conveyor that moves vehicles. An annotated image from the system's installation guide identifies the conveyor as a key component of the environment.	¶43	col. 4:43-47
automotive-vehicle washing equipment attached to the carwash tunnel	The system operates with washing equipment. A promotional image shows washing brushes and sprayers alongside the conveyor.	¶44	col. 4:65-67
a vision device attached to the carwash tunnel... configured to receive visual data of respective locations of a plurality of automotive vehicles	SmartSTOP uses one or more vision devices (e.g., PoE Cameras) placed within the tunnel to receive visual data.	¶45	col. 5:1-9
a central controller configured to perform the functions of:	The complaint identifies "Sonny's smartSTOP Server" as the central controller. A block diagram shows the server as a central component of the network architecture.	¶¶49, 51	col. 4:48-57
controlling the conveyor to move or propel vehicles, change the conveyor speed, or to stop the conveyor	The SmartSTOP server can "immediately shut[] down" or "automatically pause[]" the conveyor when a threat is detected.	¶52	col. 10:50-52
controlling the washing equipment	The SmartSTOP server can "immediately shut[] down conveyor and equipment" when a threat is detected.	¶53	col. 10:52-53
receiving the visual data from the vision device	The server is configured to receive visual data from the in-tunnel cameras, which are required to be on the same network. A network setup diagram shows data from cameras routed to the server.	¶¶54, 55	col. 10:53-54
tracking the respective positions of a plurality of automotive vehicles...	The server tracks vehicle positions using data from cameras placed at multiple locations along the tunnel. The installation guide recommends camera placement to ensure every portion of the tunnel is visible.	¶¶56, 57	col. 10:54-58
creating a modeled path of an automotive vehicle moving through the carwash tunnel	The server allegedly generates "bounding boxes" to define a "modeled path" for a vehicle, representing the desired path to maintain a safe distance from other objects.	¶60	col. 10:59-61
giving a stop conveyor command if a tracked position of an automotive vehicle does not match the modeled path	The server can issue a stop command if a vehicle's tracked position does not match the modeled path, which is alleged to occur when "Optical Object Tracking (OOT)" detects a potential collision.	¶61	col. 10:61-63

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the accused system's use of "Optical Object Tracking (OOT) based on machine learning" and its generation of "bounding boxes" (Compl. ¶60) meets the claim requirement of "creating a modeled path" and comparing a "tracked position" to that path. The complaint equates these concepts, but a court may need to determine if the claim requires a more specific type of path modeling.
  • Technical Questions: The complaint identifies "Sonny's smartSTOP Server" as the "central controller" (Compl. ¶49). However, the complaint's own exhibit, a network block diagram, also shows a "Sonny's smartSTOP Controller Box" and a "Sonny's Tunnel Controller" (Compl. p. 18). This raises the question of whether all functions required of the "central controller" are performed by the server alone, or if they are distributed in a manner that might not satisfy the claim limitations as written.

V. Key Claim Terms for Construction

• The Term: "modeled path"

  • Context and Importance: This term appears to define the core logic of the claimed invention. The infringement analysis will likely turn on whether the accused system's method for detecting deviations—allegedly using "Optical Object Tracking" and "bounding boxes"—constitutes creating and using a "modeled path" as understood in the patent.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes a "modeling module" that "creates a virtual model of vehicles, paths, and progress through the wash tunnel" (col. 6:52-54). This general language could support an interpretation that covers any predictive model of expected vehicle location or safe travel corridors.
  • Intrinsic Evidence for a Narrower Interpretation: The claim requires comparing a "tracked position" to the "modeled path." A process flow diagram in the patent describes "filtering the flow through the field of vision against a modeled path" (col. 3:35-38). This could suggest the "path" is a more defined trajectory or set of parameters against which the vehicle's actual movement is measured, rather than a more general collision-detection zone.

• The Term: "central controller"

  • Context and Importance: The complaint alleges that the "SmartSTOP Server" is the "central controller" (Compl. ¶49). Practitioners may focus on this term because the claim requires this single component to perform a list of seven distinct functions. The viability of the infringement claim depends on whether the accused server performs all of them.
  • Intrinsic Evidence for a Broader Interpretation: The patent states the central controller may be any "suitable programmable logic controller," including "a general purpose logic controller (e.g., a computer)" (col. 4:48-52), suggesting flexibility in its physical form.
  • Intrinsic Evidence for a Narrower Interpretation: The claim recites "a central controller configured to perform the functions of..." followed by a conjunctive list. A defendant may argue that the functions are distributed across the multiple components shown in the complaint's network diagram (server, controller box, tunnel controller) (Compl. p. 18), and that no single "central controller" performs every recited function, thereby avoiding literal infringement.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant instructs its customers, via materials like the SmartSTOP Installation Guide, to use the system in an infringing manner (Compl. ¶¶47, 62). Contributory infringement is also alleged, based on the assertion that the SmartSTOP system is especially adapted for this use and has no substantial non-infringing use (Compl. ¶67).
• Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge of the '283 Patent. The complaint states that Defendant received a notice letter identifying the patent on April 11, 2023, more than four months before the suit was filed (Compl. ¶¶33, 69).

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

• A core issue will be one of definitional scope: can the term "modeled path," as described in the patent, be construed to read on the "bounding boxes" and "Optical Object Tracking" logic allegedly used by the accused system to detect potential collision threats?
• A second key issue will be one of architectural mapping: does the accused "SmartSTOP Server" meet the definition of the claimed "central controller" by performing all functions recited in the claim, or are those functions distributed among multiple network components in a way that avoids infringement of the single-controller limitation?
• An evidentiary question will be one of operational proof: can the Plaintiff demonstrate, beyond the marketing and installation materials cited, that the internal software logic of the SmartSTOP system actually performs the specific steps of "creating a modeled path" and comparing a "tracked position" to it, as required by the claim?