DCT

1:25-cv-00962

Cerebrum Sensor Tech Inc v. Revvo Tech Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00962, D. Del., 07/31/2025
  • Venue Allegations: Venue is asserted in the District of Delaware based on Defendant Revvo Technologies, Inc. being a Delaware corporation and therefore residing in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s tire-mounted sensor products infringe a patent related to sensor assemblies for monitoring dynamic objects like vehicle tires.
  • Technical Context: The technology involves advanced, in-tire sensors that monitor a range of tire parameters to improve vehicle safety, performance, and fuel efficiency, a field of increasing importance with the growth of autonomous vehicle systems.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-issuance notice on June 16, 2025, informing Defendant that the application for the patent-in-suit had been allowed by the USPTO. This allegation may be used to support claims for willful infringement.

Case Timeline

Date Event
2019-10-31 '051 Patent Priority Date
2022-10-10 Accused Product First Use in Commerce
2025-06-16 Plaintiff allegedly notifies Defendant of patent application allowance
2025-07-01 '051 Patent Issue Date
2025-07-31 Complaint Filing Date

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

U.S. Patent No. 12,344,051 - "Sensor assemblies and systems for monitoring a dynamic object," issued July 1, 2025

The Invention Explained

  • Problem Addressed: The patent's background section identifies the inadequacy of then-current Tire Pressure Monitoring Systems (TPMS). It states that most systems only monitor tire pressure and that temperature readings are often for the tire's air, not the more critical rubber temperature, rendering the data misleading. Furthermore, advanced tire-mounted sensors were described as impractical due to excessive size, weight, and difficulty in securely affixing them to diverse tire surfaces ('051 Patent, col. 3:4-40).
  • The Patented Solution: The invention is a sensor assembly designed for attachment to a dynamic object, such as the inner surface of a vehicle tire. It consists of a housing that contains an electrical sensor device, which is mechanically secured within the housing's internal cavity by structural features rather than potting compounds ('051 Patent, col. 13:1-5). This housing is, in turn, attached to a separate retaining member that is bonded to the tire surface ('051 Patent, Abstract; FIG. 1). This two-part design is intended to protect the sensor, allow for its reuse in new tires, and enable the monitoring of multiple parameters beyond simple pressure, such as tread depth and alignment ('051 Patent, col. 17:21-30, col. 5:14-25).
  • Technical Importance: The patent asserts that this approach provides more comprehensive and accurate real-time tire data, which is critical for improving vehicle safety and performance, particularly for autonomous vehicles that depend entirely on sensor feedback ('051 Patent, col. 2:6-18).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 56 (Compl. ¶30).
  • Independent Claim 1 recites a sensor assembly comprising:
    • A housing with an internal cavity.
    • An electrical sensor device disposed within the cavity.
    • The housing has "one or more surface features" that are "configured to contact the electrical sensor device to prevent movement" of the device within the cavity.
    • The electrical sensor device is configured to "sense, transmit and/or receive information regarding surrounding conditions, orientation and/or location."
  • Independent Claim 56 recites a similar sensor assembly, adding the limitation that:
    • The internal cavity "includes an unfilled open space inside the housing."

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Revvo Tire Sensor Products," which includes the "Revvo Pro Tire Mounted Sensor" (Compl. ¶17).

Functionality and Market Context

The complaint alleges these are tire-mounted sensor products that Revvo offers for sale, makes, uses, and imports into the U.S. (Compl. ¶¶17-18). The functionality is described through references to Revvo’s website and product guides, which are attached as exhibits to the complaint (Compl. ¶¶20-21). A trademark filing specimen, described in the complaint, provides visual evidence of the accused product. A picture of the noted Revvo hardware with the mark affixed is included in Exhibit G (Compl. ¶25).

IV. Analysis of Infringement Allegations

The complaint references an exemplary infringement claim chart in Exhibit B, which was not publicly filed with the complaint (Compl. ¶¶19, 30). In the absence of a detailed claim chart, the infringement theory must be summarized from the complaint's narrative allegations.

Plaintiff alleges that Defendant’s Accused Revvo Tire Sensor Products constitute "sensor assemblies" that meet the limitations of at least claims 1 and 56 of the '051 Patent (Compl. ¶30). The core of the infringement allegation is that the physical construction and operation of products like the Revvo Pro Tire Mounted Sensor embody the patented invention. The complaint asserts that Defendant infringes by making, using, selling, offering for sale, and/or importing these products (Compl. ¶30).

Identified Points of Contention

  • Technical Question: A central factual dispute will likely concern the internal construction of the accused products. The case may require evidence establishing whether the products use "surface features" to mechanically secure the internal electronics, as claimed in the patent, or if they rely on a different method, such as being filled with an encapsulating material, a technique the patent claims to improve upon ('051 Patent, col. 12:50-66).
  • Scope Question: For infringement of claim 56, a key question will be whether the accused product’s housing contains an "unfilled open space." The existence, nature, and definition of such a space will be a point of both factual evidence and legal argument.

V. Key Claim Terms for Construction

1. "surface features... configured to contact the electrical sensor device to prevent movement of the electrical sensor device within the internal cavity" (Claim 1)

Context and Importance

This limitation defines the core mechanism for securing the electronics. Its construction is critical because it distinguishes the claimed invention from methods that might use adhesives or potting compounds. Practitioners may focus on this term because the infringement analysis will depend on whether the internal structure of the accused product meets this functional and structural definition.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes these features in general terms, such as "one or more surface features... that contact the electrical sensor device to retain its position" ('051 Patent, col. 4:12-14) and can be in the form of "ribs or tabs" ('051 Patent, col. 9:49-51). This language could support an interpretation covering various internal projections that provide some level of contact and stabilization.
  • Evidence for a Narrower Interpretation: Specific embodiments depict more defined structures, such as a "slot or recessed groove that extends laterally along the wall structure inside surface" ('051 Patent, col. 9:29-32) or an "edge formed between the intersecting inside surfaces of the housing wall structure and top cover" ('051 Patent, col. 9:53-55). This could support a narrower definition requiring a specific type of mechanical interlock, rather than incidental contact.

2. "unfilled open space inside the housing" (Claim 56)

Context and Importance

This term distinguishes claim 56 from claim 1 and adds a specific structural requirement to the housing. Infringement of claim 56 will hinge on finding a space within the accused product that meets the court's construction of this term.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition, which may support an argument for applying the term’s plain and ordinary meaning to encompass any void or air gap within the housing not occupied by the sensor or its structural supports.
  • Evidence for a Narrower Interpretation: The specification notes that in one example, "an open space exists above and below the electrical sensor device" ('051 Patent, col. 4:14-15). A party could argue that this suggests the "unfilled open space" must be a deliberately designed void of a particular character or location, rather than any incidental, microscopic space remaining after assembly.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement.

  • Inducement is alleged based on Defendant having knowledge of the '051 Patent and "intentionally instructing or otherwise encouraging" customers and end users to use the accused products in an infringing manner, citing Defendant's instructional materials (Compl. ¶32).
  • Contributory infringement is alleged on the basis that the accused products are a "material part of the claimed inventions," are not staple articles of commerce, and have "no other substantial use" apart from the infringing use (Compl. ¶33).

Willful Infringement

The complaint alleges that Defendant’s infringement has been willful (Compl. ¶36). This is based on allegations that Defendant had knowledge of the '051 Patent since its issue date of July 1, 2025, and, more specifically, had pre-suit knowledge due to a notification from Plaintiff on June 16, 2025, which provided Revvo with the USPTO's notice of allowance for the patent application (Compl. ¶31).

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

  • A core issue will be one of evidentiary proof: The case will likely depend on discovery into the internal architecture of the Accused Revvo Tire Sensor Products. A dispositive question will be whether the products are built with the claimed "surface features" that mechanically fix the internal electronics in place, or if they achieve stabilization through an alternative method like encapsulation, potentially placing them outside the scope of the claims.
  • A second central issue will be one of claim construction: The court's interpretation of the term "surface features... configured to... prevent movement" will be pivotal. Whether this term is construed broadly to include any stabilizing contact or narrowly to require a specific mechanical interlock will significantly impact the infringement analysis.
  • Finally, a key question for damages will be willfulness: Given the complaint’s allegation of pre-issuance notice of allowance, the court will have to determine if Defendant’s conduct after receiving this notice was "objectively reckless." The answer will determine Defendant’s potential exposure to enhanced damages.