DCT

8:25-cv-01652

Fleet Connect Solutions LLC v. Pegasus Transtech LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-01652, M.D. Fla., 06/25/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Middle District of Florida because Defendant maintains regular and established places of business in the District, including multiple facilities in Tampa, from which it has allegedly committed acts of patent infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management telematics devices, software, and mobile applications infringe eight patents related to wireless communication, mobile data management, and navigation tracking technologies.
  • Technical Context: The technologies at issue address challenges in wireless communication protocols, mobile device functionality, and location-based services, which are foundational to the modern logistics and vehicle fleet management industry.
  • Key Procedural History: The complaint alleges willful infringement for two of the eight asserted patents, based on Defendant’s alleged knowledge of the patents as of the complaint’s filing and on an alleged policy of willful blindness toward the patent rights of others.

Case Timeline

Date Event
2000-09-18 Priority Date for U.S. Patent Nos. 6,961,586 and 7,593,751
2001-02-21 Priority Date for U.S. Patent No. 6,549,583
2001-09-21 Priority Date for U.S. Patent No. 7,058,040
2002-09-09 Priority Date for U.S. Patent No. 7,260,153
2002-11-04 Priority Date for U.S. Patent No. 7,206,837
2003-04-15 U.S. Patent No. 6,549,583 Issued
2004-07-20 Priority Date for U.S. Patent No. 7,742,388
2005-08-10 Priority Date for U.S. Patent No. 7,741,968
2005-11-01 U.S. Patent No. 6,961,586 Issued
2006-06-06 U.S. Patent No. 7,058,040 Issued
2007-04-17 U.S. Patent No. 7,206,837 Issued
2007-08-21 U.S. Patent No. 7,260,153 Issued
2009-09-29 U.S. Patent No. 7,593,751 Issued
2010-06-22 U.S. Patent No. 7,742,388 Issued
2010-06-22 U.S. Patent No. 7,741,968 Issued
2025-06-25 Complaint Filed

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

U.S. Patent No. 7,058,040 - "Channel Interference Reduction" (Issued June 6, 2006)

The Invention Explained

  • Problem Addressed: The patent describes the problem of radio frequency interference that occurs when multiple wireless communication standards, such as Bluetooth and IEEE 802.11, operate in the same unlicensed radio band (e.g., 2.4 GHz) in close proximity to each other (’040 Patent, col. 1:21-31). This co-channel interference can degrade performance and cause the destruction of data packets, forcing retransmissions (’040 Patent, col. 1:31-34).
  • The Patented Solution: The invention proposes a method to manage this interference by treating the overlapping media as a shared resource. It computes Time Division Multiple Access (TDMA) time-slots and allocates distinct slots to the different media, thereby preventing them from transmitting simultaneously (’040 Patent, col. 2:4-14). The system can also dynamically adjust the number of slots assigned to each medium to meet a desired level of service (’040 Patent, col. 2:19-23).
  • Technical Importance: This time-domain coordination approach provided a method for enabling the coexistence of disparate, popular wireless technologies within the increasingly crowded unlicensed spectrum (’040 Patent, col. 1:21-27).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶28).
  • Claim 1 Elements:
    • computing one or more time division multiple access (TDMA) time-slot channels to be shared between the first and second media for data transmission;
    • allocating one or more time-slot channels to the first medium for data transmission;
    • allocating one or more of the remaining time-slot channels to the second medium for data transmission; and
    • dynamically adjusting a number of time-slot channels assigned to one of the first and second media during the data transmission to remain within limits of a desired level of service.

U.S. Patent No. 7,742,388 - "Packet Generation Systems and Methods" (Issued June 22, 2010)

The Invention Explained

  • Problem Addressed: The patent addresses the persistent demand for higher data rates in wireless LAN environments and the corresponding need for high-rate devices to coexist and communicate with legacy devices that operate at lower, standardized rates (’388 Patent, col. 2:32-42).
  • The Patented Solution: The invention discloses a method for increasing the data rate by modifying the standard structure of a data packet. Specifically, it increases the packet size by adding subcarriers to the packet's training symbols to create an "extended data signal" (’388 Patent, col. 2:15-22). The specification describes techniques for generating these extended packets, such as by adding the new subcarriers into existing gaps in the frequency spectrum, and for receivers to detect them (’388 Patent, FIG. 7; col. 6:30-34).
  • Technical Importance: This method offers a way to boost data throughput beyond existing standards while creating a structure that may be detectable by both new and legacy devices, facilitating backward compatibility (’388 Patent, col. 2:4-11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶37).
  • Claim 1 Elements:
    • generating a packet with a size corresponding to a protocol used for a network transmission, wherein the packet comprises a preamble having a first training symbol and a second training symbol;
    • increasing the size of the packet by adding subcarriers to the second training symbol of the packet to produce an extended packet, wherein a quantity of subcarriers of the second training symbol is greater than a quantity of subcarriers of the first training symbol; and
    • transmitting the extended packet from an antenna.

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range and Extended Rate Across Imperfectly Estimated Channels" (Issued August 21, 2007)

  • Technology Synopsis: The patent addresses the problem of cross-talk interference in Multiple Input Multiple Output (MIMO) wireless systems that arises from imperfectly estimated communication channels. The proposed solution involves methods and apparatuses to solve this interference problem, enabling more robust and predictable extended range and data rates in MIMO communications.
  • Asserted Claims: Claim 1 is asserted (Compl. ¶53).
  • Accused Features: The complaint alleges that the Accused Products’ use of wireless communications, including performing singular value decomposition of channel matrices, infringes the ’153 patent (Compl. ¶19, ¶53).

U.S. Patent No. 6,549,583 - "Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN" (Issued April 15, 2003)

  • Technology Synopsis: The patent addresses performance degradation in Orthogonal Frequency Division Multiplexed (OFDM) receivers caused by phase noise from local oscillators. The solution is a method for estimating pilot phase error using a maximum likelihood approach, which compensates for poor radio performance and improves signal tracking under low signal-to-noise conditions.
  • Asserted Claims: Claim 1 is asserted (Compl. ¶62).
  • Accused Features: The complaint alleges the Accused Products perform error estimation in OFDM receivers, infringing the ’583 patent (Compl. ¶19, ¶62).

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification" (Issued April 17, 2007)

  • Technology Synopsis: The patent addresses the inconvenience for a person in transit to repeatedly estimate their time of arrival. The solution is an automated method that provides periodic trip status notifications to a user based on a variety of data inputs, including the device’s current location, calendrical time, historical travel data, traffic, and weather.
  • Asserted Claims: Claim 1 is asserted (Compl. ¶71).
  • Accused Features: The Accused Products are described as fleet management and tracking solutions, which allegedly provide functionality that infringes the ’837 patent (Compl. ¶16, ¶71).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices" (Issued September 29, 2009)

  • Technology Synopsis: This patent, a continuation of the application leading to the ’586 patent, describes systems and methods for conducting field operations using handheld devices. The invention provides users with access to industry-specific programs and enables data synchronization with remote servers to facilitate tasks like project management, inventory tracking, and sales.
  • Asserted Claims: Claim 6 is asserted (Compl. ¶80).
  • Accused Features: Defendant’s Transflo Driver apps and related handheld devices used in fleet management operations are alleged to infringe (Compl. ¶16, ¶80).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices" (Issued November 1, 2005)

  • Technology Synopsis: The patent addresses the needs of field personnel who may lack access to critical information by providing a handheld device with industry-specific assessment programs. The device enables two-way wireless communication with remote computing resources to facilitate real-time access to programs, data, and assistance.
  • Asserted Claims: Claim 9 is asserted (Compl. ¶89).
  • Accused Features: Defendant’s Transflo Driver apps and associated handheld devices and software, which provide fleet management and tracking solutions, are alleged to infringe (Compl. ¶16, ¶89).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group" (Issued June 22, 2010)

  • Technology Synopsis: The patent describes a system for permissive navigational tracking where a "sending party" device selectively transmits its location data to a "receiving party" device. This allows the receiving party to track the sending party and potentially provide return navigational guidance.
  • Asserted Claims: Claim 4 is asserted (Compl. ¶98).
  • Accused Features: The fleet management platform and tracking solutions offered by Defendant are alleged to infringe the ’968 patent (Compl. ¶16, ¶98).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Defendant’s fleet management and tracking solutions (Compl. ¶16). These include:
    • Hardware: Transflo vehicle telematics devices (e.g., T7 ELD, T9 ELD, TT600 series) and ELD Tablets.
    • Software/Services: Transflo fleet management websites and applications (e.g., Velocity+, Velocity Plus Command Center).
    • Mobile Applications: Transflo Driver apps (e.g., Transflo Driver Assist, Transflo Mobile+, Transflo HOS).

Functionality and Market Context

  • The complaint alleges these products form a comprehensive fleet management platform that provides vehicle tracking and wireless communications (Compl. ¶16).
  • Technically, the products are alleged to implement various wireless protocols, including Bluetooth and IEEE 802.11, and to perform functions such as generating and transmitting data packets, using OFDM receivers, and communicating via a plurality of wireless transceivers (Compl. ¶17-19).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent (Exhibits A-H) but does not include them in the filing (Compl. ¶28, 37, 53, 62, 71, 80, 89, 98). The infringement theories are therefore summarized based on the narrative allegations.

  • ’040 Patent Infringement Allegations (Prose Summary)

    • The complaint alleges that the Accused Products perform wireless communications using multiple protocols like Bluetooth and IEEE 802.11, which operate in shared, overlapping frequency bands (Compl. ¶17). The infringement theory appears to be that the Accused Products must necessarily manage the resulting interference by time-scheduling transmissions, which Plaintiff contends practices the claimed method of computing, allocating, and dynamically adjusting TDMA time-slots to coordinate access between different media (Compl. ¶20, 28).

  • ’388 Patent Infringement Allegations (Prose Summary)

    • The complaint alleges the Accused Products generate and transmit packets for wireless communications to achieve high data rates (Compl. ¶18). The infringement theory appears to be that, in doing so, the Accused Products create and transmit packets that contain more subcarriers than a baseline standard packet, thereby practicing the claimed method of "increasing the size of the packet by adding subcarriers" to a training symbol (Compl. ¶20, 37).

  • Identified Points of Contention:

    • Scope Questions: For the ’040 Patent, a central question may be whether the term "computing...TDMA time-slot channels," as used in the patent, reads on the alleged interference management performed by the Accused Products, which may implement standardized collision avoidance protocols rather than the specific allocation method claimed.
    • Technical Questions: For the ’388 Patent, a key technical question will be what evidence the complaint provides that the Accused Products perform the specific act of "adding subcarriers" to a pre-existing packet structure. The analysis may turn on whether using a higher-bandwidth mode within a standard like IEEE 802.11 constitutes "adding subcarriers" as claimed, or simply operating in a different, predefined format.

V. Key Claim Terms for Construction

  • Term (’040 Patent, Claim 1): "dynamically adjusting a number of time-slot channels"

    • Context and Importance: This term is central to the infringement analysis, as it requires an active, responsive allocation of network resources. The dispute may center on whether the Accused Products perform any such "dynamic adjustment" and, if so, whether it is based on the claimed "desired level of service."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent summary states the system can "dynamically adjust a number of time slots assigned to the media during the transmission" (’040 Patent, col. 2:19-21). This general language could support a broad construction covering any real-time change in time-slot allocation.
      • Evidence for a Narrower Interpretation: The detailed description links this adjustment to "quality of service," stating, "To adjust for quality of service, the process 10 can determine a desired level of service for one of the media during a transmission, and dynamically adjust a number of time slots..." (’040 Patent, col. 3:56-60). This could support a narrower reading limited to adjustments based on specific Quality of Service (QoS) metrics.

  • Term (’388 Patent, Claim 1): "increasing the size of the packet by adding subcarriers"

    • Context and Importance: Practitioners may focus on this term because it implies a specific method of packet creation (modification) rather than merely using a packet that is inherently larger. The infringement question depends on whether the Accused Products perform this claimed modification or simply use a different, pre-existing packet type defined by a standard.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s summary describes the invention as a method for "increasing the standard size of a packet...by adding subcarriers" (’388 Patent, col. 2:16-18). This language may support a construction where the key inventive concept is the resulting extended packet structure, not the specific real-time process of "adding."
      • Evidence for a Narrower Interpretation: The specification illustrates the process with figures showing subcarriers being added into spectral gaps or at the edges of a baseline packet structure (’388 Patent, FIG. 7). This visual and descriptive context may support a narrower construction requiring a direct modification of a specific, smaller packet format.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement for the ’388 and ’968 patents. The allegations are based on Defendant providing the Accused Products along with instructions, advertising, and technical support that allegedly guide customers to use them in an infringing manner (Compl. ¶39-41, 100-102). It is also alleged that the products contain "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶41, 102).
  • Willful Infringement: Willfulness is alleged for the ’388 and ’968 patents. The claim is based on alleged knowledge of the patents arising no later than the filing of the complaint, combined with an alleged "policy or practice of not reviewing the patents of others," which Plaintiff characterizes as willful blindness (Compl. ¶42-44, 103-105).

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

  • A core issue will be one of technical implementation: Can Plaintiff produce evidence that the internal operations of Defendant's off-the-shelf telematics systems, which likely implement established communication standards, perform the specific, and in some cases unconventional, methods of channel management and packet generation required by the patent claims?
  • The case may also turn on a question of definitional scope: For patents like the ’040 and ’388, can claim terms rooted in specific modification processes (e.g., “dynamically adjusting” time slots, “adding subcarriers”) be construed broadly enough to read on the use of standardized, multi-mode protocols that offer different, pre-defined operational formats?
  • A key evidentiary question will be one of functional mapping: For the patents related to handheld field operations and trip notifications (e.g., ’586, ’837), does the functionality of Defendant's fleet management software perform the specific series of steps and data processing recited in the asserted claims, or is there a fundamental mismatch in the claimed workflow versus the actual product operation?