I. Executive Summary and Procedural Information
- Parties & Counsel:
- Case Identification: 1:25-cv-00867, D. Del., 07/11/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Foxwell Technology Inc. is a Delaware corporation that resides in the district, and Defendant Shenzhen Foxwell Technology Co., Ltd is not a U.S. resident but has allegedly engaged in infringing activity within the district.
- Core Dispute: Plaintiff alleges that Defendant’s NT 604 Elite automotive diagnostic tool infringes a patent related to methods and systems for vehicle diagnostics that divide processing tasks between a diagnostic device and a simpler connection device.
- Technical Context: The technology concerns handheld devices that interface with a vehicle's On-Board Diagnostics (OBD-II) port to communicate with its internal computer network, enabling technicians to retrieve fault codes and analyze real-time performance data.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date |
Event |
| 2018-01-08 |
U.S. Patent No. 11,845,451 Priority Date |
| 2023-12-19 |
U.S. Patent No. 11,845,451 Issue Date |
| 2025-07-11 |
Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,845,451 - "Automobile Diagnostic Method, Apparatus, Device and System, and Diagnostic Connection Device"
- Patent Identification: U.S. Patent No. 11,845,451, issued December 19, 2023 (’451 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section identifies a problem in prior art automotive diagnostic systems where the "diagnostic connection device" (e.g., a Vehicle Communication Interface or VCI) requires a powerful and expensive main chip. This is because the VCI itself must handle the resource-intensive "protocol conversion between a link layer and a physical layer" to communicate with the vehicle network, resulting in high hardware costs for the VCI device ('451 Patent, col. 1:35-43).
- The Patented Solution: The invention proposes a system architecture that offloads this complex protocol conversion from the specialized, single-purpose connection device to the more powerful, general-purpose "automobile diagnostic device" (such as a personal computer or smartphone) ('451 Patent, col. 7:30-40). By leveraging the superior processing and memory resources of the diagnostic device, the connection device can be made with simpler, less expensive hardware, as its primary role is reduced to relaying data ('451 Patent, Abstract; col. 6:1-10).
- Technical Importance: This architectural shift aimed to reduce the hardware cost and complexity of the VCI dongle that physically connects to the vehicle, making diagnostic tools more accessible and cost-effective ('451 Patent, col. 6:6-10).
Key Claims at a Glance
- The complaint asserts independent claims 1, 5, and 11 ('451 Patent, col. 18:13-20:65; Compl. ¶21).
- Independent Method Claim 1 recites an automobile diagnostic method performed by a diagnostic device, with essential elements including:
- reading a user operation and converting it into a diagnostic instruction;
- converting the diagnostic instruction into standard transmission data; and
- synchronously sending that standard transmission data.
- Independent Method Claim 5 recites an automobile diagnostic method performed by a diagnostic device, with essential elements including:
- receiving standard transmission data corresponding to detection data from the vehicle network;
- converting that standard transmission data into detection data; and
- wherein the receiving step comprises synchronously receiving the standard transmission data.
- Independent Apparatus Claim 11 recites an automobile diagnostic device, with essential elements including:
- a display screen and a first communication unit;
- at least one processor; and
- a memory storing instructions that, when executed, cause the processor to perform steps including reading a user operation, converting it into a diagnostic instruction, converting that instruction into standard transmission data, and synchronously sending the standard transmission data.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the Foxwell NT 604 Elite Automotive Diagnostic Tool (Compl. ¶2).
Functionality and Market Context
The complaint describes the NT 604 Elite as a handheld automotive diagnostic device that connects to a vehicle's On-Board Diagnostic II (OBD-II) port via a diagnostic cable (Compl. p. 6, fn. 3). Its functions include reading diagnostic trouble codes, viewing live data streams, and establishing bi-directional communication with a vehicle's electronic control units (Compl. p. 7, fn. 4; p. 9, fn. 11). The complaint alleges the device internally comprises a "Device Module" and a "Vehicle Communication Interface ('VCI') Module" (Compl. p. 6). The complaint also presents a photograph of the device's internal circuit board with areas labeled to correspond to these alleged modules (Compl. p. 7). Plaintiff alleges that the defendants are direct competitors and that the accused product "copies and implements" the patented technology (Compl. ¶2).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,845,451 Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) |
Alleged Infringing Functionality |
Complaint Citation |
Patent Citation |
| An automobile diagnostic method for an automobile diagnostic device... |
The Foxwell NT604 Elite is alleged to be an automobile diagnostic device that performs a diagnostic method. |
¶21 |
col. 7:25-30 |
| reading an operation performed by a user on an interface, and converting the operation into a corresponding diagnostic instruction; |
The device has physical buttons for user input, and the complaint alleges the device must necessarily convert this user input operation into a diagnostic instruction to request data from the vehicle. |
¶21 |
col. 8:58-9:2 |
| converting the diagnostic instruction into standard transmission data corresponding to the diagnostic instruction; |
The complaint alleges that to utilize standard vehicle communication protocols (e.g., ISO 15765), the diagnostic instruction must be converted into a standard transmission data format. |
¶21 |
col. 8:10-16 |
| wherein the sending the standard transmission data...comprises: synchronously sending the standard transmission data corresponding to the diagnostic instruction. |
The device allegedly sends data to the vehicle's network over a CAN bus, which the complaint asserts is a synchronous transmission, supported by screenshots of data packet logs. |
¶21 |
col. 2:13-16 |
U.S. Patent No. 11,845,451 Infringement Allegations (Claim 5)
| Claim Element (from Independent Claim 5) |
Alleged Infringing Functionality |
Complaint Citation |
Patent Citation |
| An automobile diagnostic method for an automobile diagnostic device... |
The Foxwell NT604 Elite is alleged to be an automobile diagnostic device that performs a diagnostic method. |
¶21 |
col. 7:25-30 |
| receiving standard transmission data corresponding to the detection data of the automobile network; |
The VCI module connects to the automobile network and allegedly receives detection data, which is transmitted as standard transmission data. |
¶21 |
col. 2:41-45 |
| converting the standard transmission data corresponding to the detection data into detection data; |
The device allegedly allows a user to scan for Diagnostic Trouble Codes (DTCs), which requires converting the received standard transmission data into readable detection data. |
¶21 |
col. 2:46-49 |
| wherein the receiving standard transmission data...comprises: synchronously receiving the standard transmission data... |
The complaint alleges the device receives "live" data readings from the vehicle's control systems, which typically uses synchronous transmission, and provides data packet logs as evidence. |
¶21 |
col. 2:54-58 |
U.S. Patent No. 11,845,451 Infringement Allegations (Claim 11)
| Claim Element (from Independent Claim 11) |
Alleged Infringing Functionality |
Complaint Citation |
Patent Citation |
| An automobile diagnostic device, comprising: a display screen; |
The device includes a 4.3" TFT color LCD display. The complaint includes a diagram from the user manual identifying the display screen (Compl. p. 16). |
¶21 |
col. 5:13 |
| a first communication unit configured to send and receive data; |
The complaint alleges the device must have a communication unit to establish communication with the vehicle. |
¶21 |
col. 5:14-15 |
| at least one processor; |
The complaint alleges the device provides numerous diagnostic functions that necessarily require a processor. A photograph of the device's internal circuit board shows a component labeled "Processor" (Compl. p. 17). |
¶21 |
col. 5:16 |
| a memory communicatively connected to the at least one processor... |
The device includes memory, and the complaint includes a photograph of the internal circuit board with a component labeled "Memory" (Compl. p. 17). |
¶21 |
col. 5:17-18 |
| the memory stores an instruction that...causes the at least one processor to read an operation performed by a user on an interface...convert the operation into a corresponding diagnostic instruction...convert the diagnostic instruction into standard transmission data...and synchronously send the standard transmission data... |
The complaint realleges the method steps from Claim 1, arguing that the device's processor is executing stored instructions to perform these functions. |
¶21 |
col. 5:19-20:11 |
Identified Points of Contention
- Architectural Questions: The ’451 Patent's core concept involves separating the "automobile diagnostic device" from the "diagnostic connection device" to offload processing. The complaint alleges the accused NT 604 Elite, an integrated handheld unit, contains a "Device Module" and a "VCI Module." A central question will be whether this alleged internal architecture maps onto the patent's claimed separation of devices, and what evidence supports this specific division of processing labor within the accused product.
- Evidentiary Questions: For internal software operations like "converting the operation into a corresponding diagnostic instruction," the complaint alleges this "must necessarily" occur (Compl. p. 9). This raises the question of what direct evidence, beyond inference from the device's external inputs and outputs, the plaintiff will provide to prove these specific claimed conversion steps are performed by the accused product's processor as alleged.
V. Key Claim Terms for Construction
The Term: "automobile diagnostic device"
- Context and Importance: The patent's architecture distinguishes the "automobile diagnostic device" (element 10 in Fig. 1) from the "diagnostic connection device" (element 20). Infringement hinges on mapping the accused product, an integrated tool, onto this claimed architecture. Practitioners may focus on this term to dispute whether the accused product's alleged "Device Module" functions as the claimed "automobile diagnostic device" that performs the resource-intensive protocol conversion.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the device as one that can run diagnostic software, providing examples such as "a personal computer or a smartphone" ('451 Patent, col. 7:31-33), which could support an interpretation covering any component with sufficient processing capability.
- Evidence for a Narrower Interpretation: Figure 1 depicts the "automobile diagnostic device" (10) and "diagnostic connection device" (20) as two physically distinct boxes communicating wirelessly. This could support an argument that the term requires a physically separable unit, not an integrated module within a single housing.
The Term: "synchronously" (sending/receiving)
- Context and Importance: This term defines the required nature of the data transmission. The infringement case relies on demonstrating that the accused device's communication protocol meets this specific technical standard. The complaint supports its allegation by referencing the transmission of "live data" and providing screenshots of data packet logs (Compl. pp. 11, 14-15).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification introduces a "synchronous sending module" and "synchronous receiving module" ('451 Patent, col. 2:13, col. 2:54) but does not provide an explicit definition, which may suggest the term should be given its plain and ordinary meaning to one of skill in the art of data communications.
- Evidence for a Narrower Interpretation: The patent contrasts synchronous modules with asynchronous ones, which are described in the context of callback functions for sending and receiving sequential data packets ('451 Patent, col. 2:17-34). This contrast could be used to argue for a more specific technical meaning of "synchronously" that excludes methods involving callbacks or certain types of packet-based communication.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement of method claims 1 and 5, asserting that Defendants encourage infringement through "instructions, marketing materials, and technical support provided to customers and end users" (Compl. ¶24).
- Willful Infringement: Willfulness is alleged based on Defendants being "sophisticated competitors in the automotive diagnostics industry" who allegedly "had actual knowledge of Autel Technology's Asserted Patent and technology prior to or during the launch of the NT604 Elite" (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: can the plaintiff prove that the integrated architecture of the accused handheld tool, with its alleged internal "Device Module" and "VCI Module," corresponds to the ’451 patent’s distinct "automobile diagnostic device" and "diagnostic connection device," particularly regarding the claimed offloading of protocol conversion tasks?
- A key evidentiary question will be one of proving internal operation: beyond inferring function from external behavior, what direct evidence will be presented to demonstrate that the accused device’s processor executes instructions to perform the specific, claimed software steps of "converting" user operations and network data in the manner required by the patent claims?
- The case may also turn on a question of technical definition: does the data transmission protocol used by the accused device, as evidenced by data logs, meet the specific technical meaning of "synchronously" as that term is used in the claims and understood by a person of ordinary skill in the art?