Peregrine Data LLC v. LYTX Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (NM)
  • Defendant: Lytx, Inc. (DE)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:24-cv-01177, D. Del., 10/22/2024
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant has an established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to multi-camera, continuous vehicular recording systems designed for evidentiary purposes.
• Technical Context: The technology addresses the field of automotive telematics and video recording, where capturing a comprehensive, tamper-resistant record of a vehicle's surroundings is valuable for accident reconstruction, insurance claims, and legal proceedings.
• Key Procedural History: The patent-in-suit claims priority back to a 2004 provisional application and is subject to a terminal disclaimer, which may limit its enforceable term. The complaint does not mention any prior litigation or inter partes review proceedings involving the patent.

Case Timeline

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

• Patent Identification: U.S. Patent No. 8,319,619, "Stored vision for automobiles," issued November 27, 2012.

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty in obtaining reliable evidence after vehicle accidents or crimes, noting the scarcity of credible witnesses and the danger of distracting a driver who tries to manually monitor or record events. (’619 Patent, col. 1:18-44).
• The Patented Solution: The invention proposes an automated, perimeter optical viewing system for a vehicle. Multiple cameras are positioned around the automobile to continuously capture and record a 360-degree view onto a central digital medium, allowing the driver to remain focused on driving. (’619 Patent, Abstract; col. 2:5-18). The system is designed to be largely inaccessible to the driver during operation to prevent distraction and ensure a complete record is preserved for later, off-line recovery and use in legal proceedings. (’619 Patent, col. 2:50-57; Fig. 1).
• Technical Importance: The described method aims to create a comprehensive and objective evidentiary record of events surrounding a vehicle, independent of driver action or G-force sensor activation, to improve the efficiency and accuracy of legal and insurance investigations. (’619 Patent, col. 1:58-67).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary claims" without identifying them specifically, but Claim 1 is the first independent method claim. (Compl. ¶11).
• Key elements of independent Claim 1 include:
  • Placing a plurality of cameras in circumferentially spaced positions around the vehicle's periphery "at about the middle of its vertical height" and fixing them with fields of view directed outwardly.
  • Activating all cameras to operate continuously throughout a trip.
  • Recording images from each camera into a "corresponding separate file."
  • Using "separate node files to provide eight separate files of real-time recorded data" from the respective cameras.
  • Locating the apparatus so that it is "inaccessible to a driver throughout the entire trip."
• The complaint does not explicitly reserve the right to assert dependent claims.

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 an attached but unprovided Exhibit 2. (Compl. ¶11).

Functionality and Market Context

The complaint alleges that Defendant makes, uses, sells, and imports products that practice the technology claimed by the ’619 Patent. (Compl. ¶11). It further alleges that Defendant distributes "product literature and website materials" that direct end users to use the products in an infringing manner. (Compl. ¶14). The complaint does not provide sufficient detail for a technical analysis of the accused products' specific functionality or market position.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference an external claim chart exhibit (Exhibit 2) that was not provided with the filing. Therefore, a narrative summary of the infringement allegations is presented below.
No probative visual evidence provided in complaint.

Narrative Infringement Theory

Plaintiff alleges that Defendant’s "Exemplary Defendant Products" directly infringe one or more claims of the ’619 Patent. (Compl. ¶11). The core of the infringement theory, as inferred from the complaint, is that these products constitute systems that use multiple vehicle-mounted cameras to continuously record the surrounding environment, thereby practicing the patented method. (Compl. ¶¶ 11, 16). The complaint alleges that Defendant’s own internal testing and use of the products also constitutes direct infringement. (Compl. ¶12). The allegations rely entirely on the comparisons made in the unprovided claim charts. (Compl. ¶16).

Identified Points of Contention

• Scope Question: Claim 1 requires placing cameras "at about the middle of [the automobile's] vertical height." (’619 Patent, col. 8:53-54). A central dispute may arise over whether this language can be construed to cover modern commercial dashcam products, which are typically mounted high on a vehicle's windshield, rather than at its vertical midpoint.
• Technical Question: The claim recites a specific data architecture: "using separate node files to provide eight separate files of real-time recorded data obtained from the respective cameras." (’619 Patent, col. 8:62-65). A key evidentiary question will be whether the accused products actually implement this specific "eight separate files" structure, or if their data recording and storage method is technically distinct.
• Scope Question: Claim 1 further requires "locating all apparatus needed for carrying out the method so that it is inaccessible to a driver." (’619 Patent, col. 9:2-5). The interpretation of "inaccessible" will be critical. The court will have to determine whether this requires complete physical inaccessibility or if it can read on systems that have user-facing interfaces or controls, which might be argued to be accessible to the driver.

V. Key Claim Terms for Construction

"at about the middle of its vertical height" (’619 Patent, col. 8:53-54)

• Context and Importance: The construction of this locational term is fundamental to the scope of infringement. A narrow definition could exclude a significant portion of the commercial vehicle camera market, particularly windshield-mounted devices.
• Intrinsic Evidence for a Broader Interpretation: The specification suggests integrating lenses into "current headlight, brake light, and/or side marker electrical housings," which exist at various vertical positions on a vehicle, not strictly at the geometric middle. (’619 Patent, col. 4:47-50). This may support an argument that "about the middle" is not a rigid limitation.
• Intrinsic Evidence for a Narrower Interpretation: The claim language itself is precise. The patent does not explicitly describe or depict embodiments located far from the vertical centerline, which could support a construction closer to the plain and ordinary meaning of "middle."

"inaccessible to a driver" (’619 Patent, col. 9:4)

• Context and Importance: This term is tied to the patent's stated goal of preventing driver distraction. Its construction will determine whether systems with any form of driver interface or controls can fall within the claim's scope.
• Intrinsic Evidence for a Broader Interpretation: The specification states the apparatus is "preferably inacessible to the driver while driving the vehicle," which could be interpreted as a preferred feature rather than a strict requirement of complete physical isolation. (’619 Patent, col. 2:56-57).
• Intrinsic Evidence for a Narrower Interpretation: The patent repeatedly emphasizes that a driver's main priority is safety and that the system is designed to avoid distraction. (’619 Patent, col. 2:13-15). This focus, along with a specific preference for an "inaccessible" battery switch, could support a stricter definition that prohibits any driver interaction with the system while the vehicle is in use. (’619 Patent, col. 5:55-57).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, asserting that since the service of the complaint, Defendant has acted with knowledge. The alleged inducing acts include selling the accused products and distributing "product literature and website materials" that instruct customers on how to use the products in a manner that allegedly infringes the ’619 Patent. (Compl. ¶¶ 14-15).

Willful Infringement

The complaint does not use the term "willful." However, it lays a foundation for post-suit enhanced damages by alleging that the filing of the complaint provides Defendant with "actual knowledge" and that any continued infringement thereafter is done despite this knowledge. (Compl. ¶¶ 13-14).

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

• A core issue will be one of definitional scope: can the patent's specific locational and functional limitations—written in the context of 2004-era technology—be construed to cover modern telematic products? Specifically, the case may turn on whether a windshield-mounted camera is "at about the middle of [a] vehicle's vertical height" and whether a system with a user interface can be deemed "inaccessible to a driver" as required by the claims.
• A key evidentiary question will be one of technical implementation: beyond general functionality, the infringement analysis will depend on whether Plaintiff can prove that the accused products’ data management architecture meets the highly specific claim requirement of using "separate node files to provide eight separate files of real-time recorded data." A mismatch on this technical detail could present a significant hurdle to proving infringement.