Peregrine Data LLC v. Netradyne Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (New Mexico)
  • Defendant: Netradyne, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01179, D. Del., 09/22/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Delaware corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to vehicle-mounted camera systems that continuously record the surrounding environment for later evidentiary use.
• Technical Context: The technology concerns automotive perimeter viewing and recording systems, a field with significant market relevance for commercial fleet management, insurance, and legal evidence gathering.

Case Timeline

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

U.S. Patent No. 8,319,619 - "Stored vision for automobiles"

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

The Invention Explained

• Problem Addressed: The patent identifies a need for reliable evidence following vehicle accidents, road rage incidents, or crimes, noting the scarcity of reliable witnesses and the danger of distracting a driver who attempts to manually monitor or record such events. (’619 Patent, col. 1:20-44). The patent aims to provide a solution that avoids distracting the driver from the primary task of operating the vehicle safely. (’619 Patent, col. 2:14-19).
• The Patented Solution: The invention is a system comprising multiple cameras placed around the perimeter of a vehicle that continuously and automatically record visual data to a central digital storage medium. (’619 Patent, Abstract; col. 2:19-23). A key aspect is that the recorded information is intended for "off line" recovery after the vehicle is stopped, allowing for the preservation of evidence without requiring any driver interaction during operation. (’619 Patent, col. 2:16-19, 45-53; Fig. 1). The system is described as being "inaccessible to the driver while driving the vehicle." (’619 Patent, col. 2:56-57).
• Technical Importance: The patent describes a comprehensive, automated system for 360-degree vehicle surveillance at a time when such technology was not widely available, addressing the evidentiary challenges in post-accident legal proceedings. (’619 Patent, col. 1:56-67).

Key Claims at a Glance

The complaint does not identify specific asserted claims, alleging infringement of "one or more claims" (Compl. ¶11). The patent contains two independent method claims.

• Independent Claim 1: A method of observing and recording events surrounding an automobile, comprising the essential elements of:

  • Placing and fixedly securing multiple cameras in circumferentially spaced positions around the vehicle's periphery at about its middle vertical height, with fields of view directed outwardly.
  • Activating all cameras to operate continuously throughout an entire 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.
  • Using the cameras as a set where each camera operates "separately and individually."

• Independent Claim 2: A method for a driver to automatically obtain and recover images, comprising the essential elements of:

  • Positioning multiple cameras in a circumferentially spaced relationship around the vehicle's periphery.
  • Selecting a digital recording medium with multiple "separate recording tracks" and placing it in a secure location.
  • Continuously energizing the cameras and recording medium to acquire and record images on the separate tracks.
  • Using the cameras as a set where each operates "separately and individually."
  • Arranging the apparatus to be "inaccessible to the driver" while driving.
  • Retrieving the recorded information from the separate tracks after the trip concludes.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its body. (Compl. ¶11). It refers to "Exemplary Defendant Products" that are purportedly identified in claim charts provided in "Exhibit 2." (Compl. ¶¶ 11, 13). This exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’619 Patent by making, using, selling, or importing the "Exemplary Defendant Products." (Compl. ¶11). The pleading states that "Exhibit 2 includes charts comparing the Exemplary '619 Patent Claims to the Exemplary Defendant Products" and that these charts show the products "satisfy all elements of the Exemplary '619 Patent Claims." (Compl. ¶13). The complaint incorporates these charts by reference but does not attach them or provide any narrative description of the specific infringing functionality. (Compl. ¶14). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent’s claim language, the infringement analysis may raise several technical and legal questions.

• Scope Questions: Claim 1 requires placing cameras "at about the middle of its vertical height." (’619 Patent, col. 6:53-54). A potential issue is whether modern vehicle camera systems, which are often mounted high on a windshield or integrated into side mirrors, fall within the scope of this limitation.
• Technical Questions: Both independent claims require a specific data architecture where each camera's data is recorded in a "separate file" or on "separate recording tracks." (’619 Patent, col. 6:62-63; col. 7:20-21). A central question will be whether the accused products' data management and storage methods meet this limitation, or if they use a different architecture, such as a single container file with multiplexed data streams.

V. Key Claim Terms for Construction

"inaccessible to the driver" (Claim 2)

• Context and Importance: This term is central to the patent's stated purpose of preventing driver distraction. (’619 Patent, col. 5:50-57). The definition will be critical to determining infringement, as it distinguishes the claimed invention from systems that allow for driver interaction. Practitioners may focus on whether this requires physical or merely functional inaccessibility.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that it is "preferably inacessible to the driver while driving," which could suggest that complete inaccessibility is a preferred embodiment rather than a strict requirement for all implementations. (’619 Patent, col. 2:56-57).
  • Evidence for a Narrower Interpretation: The specification discusses locating apparatus "in such a way that it cannot distract the driver" and specifically mentions a "battery switch located in a position that is inaccessible to the driver while driving," supporting an interpretation that requires physical unavailability. (’619 Patent, col. 5:50-57).

"separate file" / "separate recording tracks" (Claims 1 and 2)

• Context and Importance: These terms define the required data structure for the recorded images. The interpretation will determine whether systems that store data from multiple cameras in a single, logically organized file infringe, or if the claims are limited to systems that create physically distinct files or tracks for each camera feed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that any data structure allowing for the independent recovery and analysis of each camera's feed meets the functional goal of the limitation, regardless of the underlying file architecture.
  • Evidence for a Narrower Interpretation: The patent is specific, stating an embodiment uses "separate node files to provide eight separate tracks of real-time recorded data obtained from the respective lenses," language that suggests a literal one-to-one correspondence between a physical lens and a distinct data file or track. (’619 Patent, col. 5:25-30).

VI. Other Allegations

Willful Infringement

The complaint does not contain specific factual allegations to support willful infringement, such as pre-suit knowledge of the patent or egregious conduct. The prayer for relief requests that the case be declared "exceptional" for the purpose of recovering attorneys' fees under 35 U.S.C. § 285 but does not explicitly plead willfulness. (Compl. ¶ E.i).

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

• A core issue will be one of definitional scope: can the physical placement limitation requiring cameras "at about the middle of [the vehicle's] vertical height" be construed to cover modern camera systems that may be mounted in different locations, such as high on a windshield?
• A key evidentiary question will be one of technical implementation: does the accused products' data storage architecture create the "separate file" or "separate recording tracks" for each camera as recited in the claims, or does it utilize a more integrated data management approach that falls outside the claim scope?
• The case may also turn on the interpretation of operability and access: does the claim term "inaccessible to the driver" require complete physical inaccessibility, or can it be satisfied by software-based lockouts or user interface designs that prevent interaction while the vehicle is in motion?