Peregrine Data LLC v. Motive Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (New Mexico)
  • Defendant: Motive Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01180, D. Del., 09/22/2025
• Venue Allegations: Venue is asserted based on Defendant having an established place of business in the District of Delaware and having committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to vehicle-mounted, multi-camera systems for recording the surrounding environment.
• Technical Context: The technology concerns systems for continuously recording a 360-degree view around a vehicle to provide evidence for legal proceedings or security purposes, a domain relevant to fleet management and automotive safety systems.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

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, "Stored vision for automobiles", issued November 27, 2012.

The Invention Explained

• Problem Addressed: The patent addresses the difficulty of obtaining reliable evidence after a vehicle accident or crime, noting that human witnesses are scarce or unreliable and that existing forward-facing vehicle cameras do not capture all surrounding activity. (’619 Patent, col. 1:18-43). The inventor sought a way to record events without distracting the driver from their primary task of operating the vehicle safely. (’619 Patent, col. 2:11-18).
• The Patented Solution: The invention is a system of multiple cameras mounted around the vehicle's perimeter to provide a continuous, 360-degree view. (’619 Patent, col. 2:20-24, Fig. 2). This system continuously records image data from all cameras onto a central digital recorder, with the data from each camera stored in a separate file, creating a comprehensive record of events that can be retrieved and analyzed "off line" after a trip is completed. (’619 Patent, col. 6:61-65, col. 8:1-5). The system is designed to be inaccessible to the driver while driving to prevent distraction. (’619 Patent, col. 5:50-57).
• Technical Importance: This approach provides a method for comprehensive, passive evidence collection for vehicles, intended to improve the accuracy and efficiency of legal and insurance investigations following an incident. (’619 Patent, col. 1:12-15).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" and references "Exemplary '619 Patent Claims" in an exhibit that was not provided with the complaint. (Compl. ¶11, ¶13). The patent contains two independent claims, Claim 1 and Claim 2.
• Independent Claim 1 (Method):
  • Placing a plurality of cameras in circumferentially spaced positions around the periphery of an automobile at about the middle of its vertical height.
  • Fixedly securing them with fields of view directed outwardly.
  • Upon starting a trip, activating all cameras to operate continuously throughout the trip.
  • Throughout the trip, recording images from each camera in a corresponding separate file.
  • Using the separate file in a digital memory to separately record optical data from each camera.
  • Using the cameras as a set, with each operating separately and individually.
  • Locating all apparatus to be inaccessible to a driver throughout the trip.
• Independent Claim 2 (Method):
  • Selecting a plurality of cameras.
  • Positioning the cameras in a circumferentially spaced relationship around the periphery of the automobile, fixedly securing them at about the middle of the vertical height with fields of view directed outwardly.
  • Selecting a digital recording medium with separate recording tracks and positioning it in a secure location.
  • Upon starting and throughout a trip, electrically energizing the recording medium and all cameras to acquire and convert images into electrical information on separate tracks.
  • Using the separate tracks to separately record optical data from each camera.
  • Using the cameras as a set, with each operating separately and individually.
  • Arranging all apparatus to be inaccessible to the driver while driving.
  • When the trip is concluded, retrieving the recorded electrical information to reconstitute image sequences.
• 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 "Defendant products identified in the charts" and "Exemplary Defendant Products," but the referenced charts are not attached to the complaint. (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint does not provide any description of the functionality or market context of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’619 Patent but does not provide the claim charts referenced in its allegations (Compl. ¶13-14). The complaint states that these charts compare "Exemplary '619 Patent Claims to the Exemplary Defendant Products." (Compl. ¶13). Without these charts or a narrative description of the accused functionality, a detailed infringement analysis is not possible based on the complaint alone. The infringement theory rests entirely on the contents of the unprovided Exhibit 2. (Compl. ¶14).

• Identified Points of Contention: Lacking specific infringement allegations, potential disputes would likely arise from the specific limitations of the independent claims when applied to modern dash cam and fleet management systems.
  • Scope Questions: A central question may be whether Defendant's products, if they are camera systems, meet the specific placement requirements of the claims, such as being "at about the middle of [the automobile's] vertical height" and "around the periphery of the automobile." (’619 Patent, col. 8:43-46). Another question could be whether the accused systems are truly "inaccessible to the driver... while driving," as many modern systems have driver-facing interfaces. (’619 Patent, col. 7:4-6).
  • Technical Questions: A potential technical dispute could concern the claim requirement of recording images from each camera "in a corresponding separate file." (’619 Patent, col. 8:32-34). The court may need to determine if the data architecture of the accused products, which might use integrated video streams or different data structures, meets this limitation.

V. Key Claim Terms for Construction

• The Term: "at about the middle of its vertical height" (Claim 1(a), 2(b))

  • Context and Importance: This term defines the required vertical placement of the cameras on the vehicle. Its construction will be critical because many modern vehicle camera systems are mounted high on the windshield or integrated into side mirrors, which may or may not be considered "about the middle" of the vehicle's total vertical height. The outcome could determine whether a wide range of common camera placements fall within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of the term "about" suggests the patentee did not intend a precise mathematical midpoint. The specification offers a rationale for placement in "current head-light, brake light, and/or side marker electrical housings," which exist at various heights on a vehicle, suggesting some flexibility was contemplated. (’619 Patent, col. 4:47-49).
    • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes placement in corner housings, and the figures do not depict alternative placements like high on a windshield. (’619 Patent, Fig. 2; col. 4:3-4). A defendant might argue that "middle" should be construed relative to the main body of the car, potentially excluding placements near the roofline or low on bumpers.

• The Term: "inaccessible to the driver... while driving" (Claim 1(f), 2(g))

  • Context and Importance: This limitation requires that the entire apparatus be inaccessible. The definition of "inaccessible" is central to infringement, as many modern fleet management and dash cam systems include in-cab displays or controls that a driver can interact with. The dispute will question whether any driver interaction, even if not related to the core recording function, renders the system "accessible."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue "inaccessible" means the driver cannot tamper with or disrupt the continuous recording process itself, even if other non-essential features can be accessed. The patent's stated goal is to "not distract the driver," suggesting the focus is on preventing operational interference rather than any physical or software interaction. (’619 Patent, col. 2:13-15; col. 5:52-54).
    • Evidence for a Narrower Interpretation: The specification states it is "preferred to have the battery switch located in a position that is inaccessible to the driver while driving." (’619 Patent, col. 5:54-57). This explicit example of a switch being inaccessible could support a narrower reading that requires the physical hardware and its controls to be out of the driver's reach or control, which would exclude systems with any form of driver-facing interface.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement (inducement or contributory infringement). (Compl. ¶11).
• Willful Infringement: The complaint does not allege willful infringement. The prayer for relief requests that the case be declared "exceptional," but the complaint body lacks factual allegations of pre- or post-suit knowledge of the patent or egregious conduct that would typically support such a finding. (Compl. p. 4).

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

Given the limited detail in the complaint, the litigation will likely depend on facts developed during discovery. However, based on the patent itself, several core issues emerge:

• A core issue will be one of locational scope: Can the claim limitation requiring cameras to be placed "at about the middle of [the vehicle's] vertical height" be construed to cover the varied mounting positions of modern commercial vehicle cameras, such as high on a windshield or on side mirrors?
• Another key question will be one of definitional interpretation: How will the court construe the term "inaccessible to the driver," and will that construction encompass modern systems that feature driver-facing interfaces and controls, even if the core background recording function cannot be disabled by the driver?
• A fundamental evidentiary question will be one of technical implementation: Assuming the accused products are identified, does their method of storing video data—potentially as a composite stream or in a proprietary database format—satisfy the claim requirement of recording data from each camera into a "corresponding separate file"?