DCT

8:25-cv-00386

WirelessWerx IP LLC v. Voxx Intl Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-00386, M.D. Fla., 02/14/2025
  • Venue Allegations: Venue is based on allegations that Defendant has committed acts of infringement in the district and maintains regular and established places of business within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s products and services infringe a patent related to methods for controlling movable entities by using pre-configured geographical zones and waypoints.
  • Technical Context: The technology at issue involves remote asset tracking and geofencing, a commercially significant field for fleet management, logistics, and vehicle security systems.
  • Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It also discloses that Plaintiff and its predecessors have entered into prior settlement licenses with other entities but alleges these did not involve admissions of infringement or licenses to produce a patented article, a point relevant to potential marking defenses and damages calculations.

Case Timeline

Date Event
2004-11-05 U.S. Patent No. 7,323,982 Priority Date
2008-01-29 U.S. Patent No. 7,323,982 Issues
2025-02-14 Complaint Filed

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

  • Patent Identification: U.S. Patent No. 7,323,982 (“Method and System to Control Movable Entities”), issued January 29, 2008 (the “’982 Patent”). (Compl. ¶12).

The Invention Explained

  • Problem Addressed: The patent’s background section notes that contemporary GPS vehicle tracking systems were often limited to relaying location information to a control center for display on a map, lacking more advanced, autonomous control capabilities. (’982 Patent, col. 1:48-54).
  • The Patented Solution: The invention describes a system where a transponder attached to a movable entity (e.g., a vehicle) is loaded with data defining a geographical zone. A microprocessor within the transponder is programmed to detect the occurrence of an event based on the entity's status relative to that zone (e.g., entering or leaving it) and, in response, execute a pre-configured operation (e.g., lock the doors). (’982 Patent, Abstract; col. 2:1-4). This allows for location-aware actions to be executed locally on the device.
  • Technical Importance: This approach enables automated, location-based control (geofencing) without requiring constant communication with a central server, which could increase efficiency and reduce operating costs for applications like fleet management. (’982 Patent, col. 1:36-40).

Key Claims at a Glance

  • The complaint asserts infringement of at least Claim 1 of the ’982 Patent. (Compl. ¶¶16, 21).
  • The essential elements of independent claim 1 are:
    • A method to wirelessly control an entity having an attached transponder, comprising:
    • loading from a computing device to a transponder's memory a plurality of coordinates;
    • programming a microprocessor of the transponder to define a geographical zone by creating an enclosed area on a pixilated image using said plurality of coordinates, wherein said enclosed area is representative of a geographical zone;
    • programming the microprocessor in the transponder to determine the occurrence of an event associated with a status of the entity in relation to the geographical zone; and
    • configuring the microprocessor to execute a configurable operation if the event occurs.
  • The complaint reserves the right to assert infringement of other claims, including claims 1-16 and 1-61. (Compl. ¶¶16, 21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific products by name, referring to them generally as "Defendant's Accused Products" or products and services "in the field of wireless control." (Compl. ¶¶16, 21).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the specific functionality of the accused instrumentalities. It alleges broadly that Defendant "develops, designs, manufactures, distributes, markets, offers to sell and/or sells infringing products and services" throughout the United States. (Compl. ¶3). It further alleges these products are used by businesses and individuals. (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" that was not attached to the pleading. (Compl. ¶21). In the absence of the chart, the infringement theory is based on the complaint's narrative allegations. Plaintiff alleges that Defendant directly infringes the ’982 Patent by making, using, selling, and offering for sale the Accused Products. (Compl. ¶16). The complaint asserts that Defendant "put the inventions claimed by the ’982 Patent into service (i.e., used them)" and that these infringing uses are enabled by Defendant's systems, products, and services. (Compl. ¶21).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Factual Questions: A primary factual question will be whether Plaintiff can produce evidence showing that Defendant’s unspecified "Accused Products" perform all steps of the asserted claims. Specifically, discovery will need to establish whether the accused devices are programmed to "define a geographical zone by creating an enclosed area on a pixilated image" locally on the device, as required by Claim 1.
  • Scope Questions: The case will raise the question of which specific products fall under the umbrella of the "Accused Products." The lack of specificity in the complaint suggests this will be a point of contention and a focus of early discovery.

V. Key Claim Terms for Construction

The Term: "pixilated image"

Context and Importance

This term is central to the claimed method of defining a "geographical zone" in Claim 1. Its construction will determine whether the claim is limited to specific graphical map representations or can read on more abstract, modern forms of geofencing data.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes forming a zone by assigning coordinates to pixels and connecting them, which could be argued to encompass any digital grid-based representation of a geographical area, not just a visual image. (’982 Patent, col. 2:9-12).
  • Evidence for a Narrower Interpretation: The patent includes a specific embodiment describing an "80/80-pixel map." (’982 Patent, col. 15:59-61). A party could argue that the use of the word "image" and this specific embodiment limits the claim scope to a literal, graphical representation that is visually rendered, rather than a non-visual data structure.

The Term: "programming a microprocessor ... to define a geographical zone"

Context and Importance

This active step is distinct from the preceding step of "loading...coordinates." Practitioners may focus on this term because its definition will be critical to determining where the infringing act must occur. The dispute may center on whether simply loading a pre-defined zone file satisfies this limitation, or if it requires the accused device itself to perform the computational work of creating the zone from raw data.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: A party might argue that loading a complete zone definition effectively "programs" the microprocessor with the necessary information to recognize that zone, thus satisfying the limitation.
  • Evidence for a Narrower Interpretation: The claim structure separates "loading" coordinates from "programming...to define a geographical zone." (’982 Patent, col. 27:30-41). This separation suggests that "programming" is an additional, active step of creation or definition performed by the microprocessor on the transponder, not merely the passive receipt of a completed zone file from a server.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Defendant instructs customers on how to use the products in an infringing manner through "product instruction manuals" and online support services. (Compl. ¶¶22-23). The contributory infringement claim adds the allegation that the accused products are not staple articles of commerce and their only reasonable use is an infringing one. (Compl. ¶23).

Willful Infringement

The complaint alleges willful infringement based on post-suit knowledge of the ’982 Patent from the filing of the complaint. (Compl. ¶22). It further alleges that Defendant made "no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims of the '982 Patent were invalid." (Compl. ¶¶17-18). The prayer for relief seeks treble damages for both pre- and post-lawsuit infringement. (Compl., Prayer ¶¶5-6).

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

  1. A key evidentiary question will be one of technical proof: Can Plaintiff demonstrate that Defendant’s unspecified products perform the specific method of Claim 1? The core of this issue will be whether the accused devices locally execute the claimed step of "creating an enclosed area on a pixilated image" to define a geofence.

  2. A central legal issue will be one of definitional scope: How will the court construe the term "pixilated image"? Whether this term is limited to a graphical, visual map or can be interpreted to cover abstract data grids will be critical in determining if the ’982 Patent, filed in 2005, reads on modern geofencing technologies.

  3. A significant procedural and damages issue will revolve around Plaintiff's status as a non-practicing entity and its history of prior settlements. This will likely focus the damages analysis on establishing a reasonable royalty and may invite a defense based on the patent marking statute, which Plaintiff attempts to preemptively address in the complaint.