Navog LLC v. Samsara Networks Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Navog LLC (NM)
  • Defendant: Samsara Networks Inc. (DE)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00333, D. Del., 03/18/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and has an established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to a GPS-based warning system designed to alert drivers of large vehicles to upcoming low-clearance obstacles.
• Technical Context: The technology operates within the vehicle telematics and fleet management sector, addressing the persistent and costly problem of vehicle collisions with low-clearance infrastructure such as bridges and tunnels.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history concerning the patent-in-suit. The complaint itself is presented as constituting Defendant's first notice of the alleged infringement.

Case Timeline

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

U.S. Patent No. 10,593,205 - “GPS and Warning System”

The patent-in-suit is U.S. Patent No. 10,593,205, issued March 17, 2020 (’205 Patent).

The Invention Explained

• Problem Addressed: The patent describes the challenge faced by drivers of high-profile vehicles (e.g., trucks, buses, RVs) who risk colliding with low-clearance structures like bridges, tunnels, and underpasses. The patent notes that at highway speeds, it can be difficult to stop in time once a low-clearance hazard is identified, leading to dangerous collisions and the costly process of finding an alternate route. (Compl. ¶9; ’205 Patent, col. 1:56-col. 2:3).
• The Patented Solution: The invention is a dedicated in-vehicle device that combines a GPS module with a computer module programmed with a database of low-clearance structures and their dimensions. The system is designed to monitor the vehicle's location, compare it against the database, and issue audible and visual warnings if the vehicle approaches a structure with insufficient clearance, while also suggesting alternative routes. (’205 Patent, Abstract; col. 4:36-58).
• Technical Importance: The technology aims to provide an automated, proactive safety system to prevent collisions, thereby improving safety and reducing logistical costs for commercial and recreational vehicle operators. (’205 Patent, col. 2:12-18).

Key Claims at a Glance

• The complaint asserts infringement of "Exemplary '205 Patent Claims" identified in an external exhibit, without specifying them in the complaint body. (Compl. ¶11). The patent's primary independent claim is Claim 1.
• The essential elements of independent Claim 1 include:
  • A main body forming a hollow interior volume.
  • A computer module located within the hollow interior volume, programmed with information about roads, bridges, and underpasses.
  • A GPS module located within the hollow interior volume to provide location information.
  • At least one warning mechanism (e.g., for a loud audible sound) connected to the computer module.
  • A display screen on the main body's outer surface to provide visual information, including the height of an approaching structure and alternate routes.
  • The computer module processes location data to determine when to trigger a warning as the device approaches a hazard within a predetermined distance.
• The complaint reserves the right to assert other claims, which may include dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" that allegedly infringe, but these products are identified only in "charts incorporated into this Count," referencing an external Exhibit 2 that was not provided with the complaint. (Compl. ¶¶ 11, 16). The defendant, Samsara Networks Inc., is a provider of fleet management and vehicle telematics systems.

Functionality and Market Context

The complaint does not describe the specific functionality of the accused products. It makes a conclusory allegation that the products "practice the technology claimed by the '205 Patent." (Compl. ¶16). It further alleges that Defendant distributes "product literature and website materials" that instruct on the use of these products. (Compl. ¶14). Without access to the referenced exhibits, the precise accused functionality remains unspecified in the pleading.

IV. Analysis of Infringement Allegations

The complaint states that infringement allegations are detailed in claim charts provided as Exhibit 2, but this exhibit is not included with the pleading. (Compl. ¶¶ 16, 17). The narrative infringement theory is limited to the assertion that the "Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '205 Patent Claims." (Compl. ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

Given the technology described in the ’205 Patent and the likely nature of Defendant's products as modern, cloud-based telematics systems, several points of contention may arise.

• Scope Questions: The patent claims describe a self-contained device comprising "a main body" with a "hollow interior volume" that contains the computer module and GPS module (’205 Patent, col. 6:12-25). A central question may be whether this language reads on a distributed system where processing may occur on a remote server and data is transmitted to an in-vehicle display, as is common in modern telematics. The interpretation of "main body" will be critical.
• Technical Questions: A key factual question will be whether the accused systems perform the specific functions claimed. For instance, does the accused system contain a pre-programmed database of underpass clearance measurements, or does it calculate risk using a different method? Does it provide warnings based on a "predetermined distance" as required by Claim 1? (’205 Patent, col. 6:50-54). The complaint provides no facts to answer these questions.

V. Key Claim Terms for Construction

The Term: "a main body" / "hollow interior volume"

Context and Importance

This term appears in Claim 1 and is foundational to the physical structure of the claimed invention. Its construction will likely determine whether the claims are limited to a single, self-contained hardware unit or if they can be construed to cover a distributed system with multiple components (e.g., an in-cab device and a remote server). Practitioners may focus on this term because Defendant’s system architecture is likely distributed.

Intrinsic Evidence for Interpretation

• Evidence for a Narrower Interpretation: The specification consistently depicts the invention as a single, portable device. Figure 1 shows a single housing (main body 110) containing all components. (’205 Patent, Fig. 1). The detailed description states the "computer module 120 located within hollow interior volume 114" and "GPS module 130 located within hollow interior volume 114," which may support an interpretation that all key components must be co-located within one physical housing. (’205 Patent, col. 4:41-48).
• Evidence for a Broader Interpretation: A party might argue that "main body" does not preclude electronic communication with external components and that the "hollow interior volume" limitation is met by the in-vehicle portion of a larger system. However, the claim language explicitly requires the computer and GPS modules to be "located within" that volume.

The Term: "computer module"

Context and Importance

The location and function of the "computer module" are central to Claim 1. The dispute will likely focus on whether this limitation requires a local processor performing all the claimed functions or if it can encompass a system where processing is distributed between an in-vehicle device and a remote cloud server.

Intrinsic Evidence for Interpretation

• Evidence for a Narrower Interpretation: Claim 1 recites the "computer module is located within the hollow interior volume." (’205 Patent, col. 6:16-17). This, combined with the figures, suggests a self-contained processing unit. Dependent Claim 4 further claims the "computer module is further adapted to prevent the automobile from being operated," a function that typically requires local hardware integration. (’205 Patent, col. 6:64-67).
• Evidence for a Broader Interpretation: The term "module" is often given a broad, functional meaning in patent law (means-plus-function analysis may apply). A plaintiff could argue that a "module" can be comprised of multiple, communicatively-linked components, including remote servers, that collectively perform the recited functions.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that since the filing of the complaint, Defendant has knowingly and intentionally induced infringement by selling the accused products and distributing "product literature and website materials" that instruct customers on their infringing use. (Compl. ¶¶ 14, 15).

Willful Infringement

The complaint does not use the term "willful." It pleads "Actual Knowledge of Infringement" based on "[t]he service of this Complaint," which may form a basis for seeking enhanced damages for any post-filing infringement. (Compl. ¶13). No allegations suggest pre-suit knowledge.

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

1. A core issue will be one of structural scope: Can the claim limitation of "a main body" containing a "computer module" and "GPS module" within its "hollow interior volume" be construed to cover a modern, distributed telematics architecture that separates in-vehicle hardware from remote cloud-based processing, or is it confined to the self-contained, all-in-one device depicted in the patent?
2. A second issue will be one of evidentiary proof: The complaint's infringement theory is asserted entirely through reference to an external, unprovided exhibit. A key question for the litigation will be whether Plaintiff can produce sufficient factual evidence demonstrating that Defendant's accused systems perform the specific functions recited in the claims, such as using a programmed database of structure heights and issuing warnings based on a "predetermined distance."