Monitor Systems LLC v. MH Corbin LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Monitor Systems LLC (New Mexico)
  • Defendant: MH. Corbin LLC (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01390, D. Del., 11/17/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the District, and has committed acts of patent infringement in the District.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified traffic monitoring products infringe a patent related to an automated system for monitoring traffic and issuing citations for violations.
• Technical Context: The technology at issue involves automated traffic surveillance systems that use a network of stationary sensors to detect violations and a remote server to process data and issue citations, aiming to reduce the need for human intervention.
• 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
2007-11-01	’533 Patent Priority Date
2010-04-01	’533 Patent Application Filing Date
2012-09-04	’533 Patent Issue Date
2025-11-17	Complaint Filing Date

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

U.S. Patent No. 8,260,533 - “Traffic monitoring system,” issued September 4, 2012 (’533 Patent)

The Invention Explained

• Problem Addressed: The patent describes conventional traffic monitoring systems as being localized, requiring substantial investment in hardware and wiring, and typically needing significant human involvement for operation and decision-making regarding violations (’533 Patent, col. 2:4-7, 48-52).
• The Patented Solution: The invention proposes a cost-effective and expandable system comprising multiple, autonomous "stationary traffic monitoring points" (STMPs) that collect data on moving vehicles. These STMPs use mobile communication networks to transmit vehicle and violation data to a remote server, which automatically processes the information, classifies violations, and can issue electronic citations without direct human intervention (’533 Patent, Abstract; col. 3:11-34). The system architecture, illustrated in FIG. 1, emphasizes the decentralized data collection by STMPs (2) and centralized, automated processing by a remote database server (6).
• Technical Importance: This approach sought to create a scalable, automated traffic enforcement network that could be deployed more broadly and cost-effectively than prior art systems by leveraging existing mobile communication infrastructure and reducing reliance on manual oversight.

Key Claims at a Glance

• The complaint asserts infringement of one or more claims of the ’533 Patent, with the incorporated (but not attached) claim charts identifying "Exemplary ’533 Patent Claims" (Compl. ¶11). Claim 1 is the sole independent claim.
• Independent Claim 1:
  • A plurality of remotely programmable stationary traffic monitoring points located in proximity to roads;
  • A remote server in communication with the stationary traffic monitoring points and adapted to automatically issue citations for traffic laws violations;
  • Each stationary traffic monitoring point including a radio module for interfacing to a mobile communication network;
  • Each stationary traffic monitoring point including a module for automatically receiving information about a moving vehicle from the moving vehicle;
  • Each stationary traffic monitoring point including a module for automatically measuring movement parameters of the vehicle;
  • Each stationary traffic monitoring point including a processor for automatically determining whether the moving vehicle is in violation of traffic laws, for classifying traffic violations and for determining occurrence of abnormal events; and
  • Each stationary traffic monitoring point including means for automatic storing and transmitting information about the moving vehicle, the parameters of the moving vehicle and the determination to a remote server over the mobile communication network and then over the Internet.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers generally to "Exemplary Defendant Products" that are allegedly identified in claim charts attached as Exhibit 2, which was not filed with the complaint (Compl. ¶¶11, 16).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’533 Patent (Compl. ¶16). Based on these allegations, the accused instrumentalities are traffic monitoring systems that allegedly satisfy all elements of the asserted claims, including the capabilities to monitor vehicles, determine traffic violations, and communicate with a central system (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the specific 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’s "Exemplary Defendant Products" directly infringe the ’533 Patent by practicing the claimed technology (Compl. ¶¶11, 16). The complaint incorporates by reference claim charts, provided as Exhibit 2, which allegedly compare the asserted claims to the accused products (Compl. ¶17). As Exhibit 2 was not provided with the complaint, a detailed element-by-element analysis is not possible. The narrative theory is that the Defendant's products, when made, used, or sold, satisfy all elements of at least one claim of the ’533 Patent (Compl. ¶16).

Identified Points of Contention

• Factual Questions: The primary question will be factual: what is the specific architecture and functionality of the accused "Exemplary Defendant Products"? Without this information, it is impossible to assess how they map to the claim limitations.
• Scope Questions: A potential dispute may arise over the scope of "automatically determining whether the moving vehicle is in violation." The analysis will question whether the accused products perform this determination and classification entirely without human intervention, as the claim language suggests, or if they require manual review, which could place them outside the claim’s scope.
• Technical Questions: What evidence does the complaint provide that the accused products are "remotely programmable" as required by the claim? The complaint lacks any specific allegations on this technical point, which may become a focus of dispute.

V. Key Claim Terms for Construction

The Term: "stationary traffic monitoring point" (STMP)

• Context and Importance: This term defines the core data-gathering component of the claimed system. Its construction is critical because it will determine what kind of physical device qualifies as an STMP. The dispute will likely center on the degree of autonomy, physical form factor, and permanence required for a device to be considered "stationary."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, not limiting the STMP to a specific form. The specification states the STMP "is preferably in the form of an electronic device with a built-in module for a mobile communications network connection," suggesting other forms are possible (’533 Patent, col. 3:16-19).
  • Evidence for a Narrower Interpretation: The specification describes placing the STMP on "lamp posts, traffic sign posts, advertising billboards, etc.," suggesting a fixed, semi-permanent installation (’533 Patent, col. 4:39-41). FIG. 2 depicts the STMP as a distinct hardware unit mounted on a pole (2). A defendant may argue this context limits the term to non-portable, physically mounted roadside hardware.

The Term: "automatically determining whether the moving vehicle is in violation of traffic laws"

• Context and Importance: This term is central to the invention's purported advance over prior art that required human intervention. Practitioners may focus on this term because the level of automation required by "automatically determining" will be a key issue. Infringement will depend on whether the accused system makes the legal conclusion of a "violation" without human input.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the STMP can "itself automatically process the violation and issue the citation in electronic form," which could be read to encompass a system where the final step is reviewed, but the initial "determination" is automated (’533 Patent, col. 5:4-6).
  • Evidence for a Narrower Interpretation: The claim requires the STMP's processor to perform the determination, suggesting the decision must be made at the local device level before transmission. The abstract describes "automatic software tools for determining the parameters of the vehicles... and for comparing them with the permissible parameters," which points toward a machine-driven comparison and conclusion without human judgment (’533 Patent, Abstract).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’533 Patent (Compl. ¶14).

Willful Infringement

Willfulness is alleged based on post-suit knowledge. The complaint asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement," and that any continued infringement thereafter is willful (Compl. ¶¶13-14).

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

Based on the complaint, the litigation will likely focus on the following central questions:

1. A core issue will be one of factual proof: Given the lack of specificity in the complaint, the initial phase of the case will focus on discovering the precise technical operation and architecture of the accused "Exemplary Defendant Products" to determine if they perform the functions required by the claims.
2. A key legal question will be one of definitional scope: Can the term "automatically determining," in the context of the patent's specification, be construed to cover systems that may involve some level of human review or confirmation, or does it require a completely autonomous process from data capture to the legal conclusion of a violation?
3. A final evidentiary question will be one of technical capability: What evidence will emerge to show that the accused products meet specific technical limitations recited in the claims, such as being "remotely programmable" and including a processor that performs local violation "classifying," as distinct from merely collecting and transmitting raw data?