DCT

0:25-cv-60318

Peregrine Data LLC v. Garmin Intl Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 0:25-cv-60318, S.D. Fla., 02/18/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Southern District of Florida.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to multi-camera systems for vehicles that continuously record their surroundings for later evidentiary use.
  • Technical Context: The technology pertains to automotive event data recorders or "dashcams," a market segment focused on vehicle security and providing objective evidence after traffic incidents.
  • Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier, related patent. The complaint does not mention any other prior litigation or proceedings.

Case Timeline

Date Event
2004-04-15 '619 Patent Priority Date
2010-03-12 '619 Patent Application Filing Date
2012-11-27 '619 Patent Issue Date
2025-02-18 Complaint Filing Date

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's background section describes the difficulty in establishing reliable evidence after a vehicle accident or crime due to the scarcity of dependable witnesses and the danger of distracting a driver who tries to monitor or record events while operating a vehicle (’619 Patent, col. 1:15-43).
  • The Patented Solution: The invention proposes a system of multiple cameras placed around the perimeter of a vehicle to create a 360-degree field of view (’619 Patent, col. 2:30-35). These cameras continuously record image data to a central controller, which the driver cannot easily access, thereby preserving a complete record of events without distracting the driver from the primary task of safe driving (’619 Patent, col. 2:12-20; Fig. 1). The recorded data can then be recovered offline for use in legal or insurance proceedings.
  • Technical Importance: The system aims to provide a comprehensive and objective record of events surrounding a vehicle, intended to improve the efficiency and accuracy of legal proceedings related to traffic incidents (’619 Patent, col. 2:3-13).

Key Claims at a Glance

  • The complaint does not specify which claims it asserts, referring only to "Exemplary '619 Patent Claims" in a non-proffered exhibit (Compl. ¶10). The independent claims of the patent are Claims 1 and 2.
  • Independent Claim 1 recites a method with the following essential elements:
    • Placing a plurality of cameras in circumferentially spaced positions around a vehicle's periphery at about its middle vertical height and fixedly securing them.
    • Activating all cameras to operate continuously throughout an entire trip.
    • Recording images from each camera in a corresponding separate file.
    • Using separate node files to provide eight separate files of real-time data.
    • Using the cameras as a set where each operates separately and individually.
    • Locating the apparatus so it is inaccessible to a driver during the trip.
  • Independent Claim 2 recites a similar method with elements for selecting and positioning cameras, selecting a digital recording medium with separate tracks in a secure location, continuously energizing the system, recording data on separate tracks, and retrieving the information after the trip to reconstitute image sequences relative to the vehicle's position.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products or services by name (Compl. ¶10). It refers generally to "Exemplary Defendant Products" that are purportedly identified in an external chart not attached to the complaint (Compl. ¶10, ¶15).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s unspecified "Exemplary Defendant Products" directly infringe the patent by practicing the claimed technology (Compl. ¶10). The pleading states that claim charts comparing the patent claims to the accused products are provided in "Exhibit 2" (Compl. ¶15-16). However, this exhibit was not included with the complaint document provided for analysis. Therefore, a detailed element-by-element breakdown is not possible. The infringement theory is based on the allegation that the accused products embody the patented method of using a multi-camera, continuous-recording system in a vehicle (Compl. ¶15).

  • Identified Points of Contention: Based on the patent claims and the general nature of the allegations, the infringement analysis raises several questions:
    • Scope Questions: Will the placement of cameras in typical consumer dash-cam products (e.g., on a windshield or dashboard) meet the claim limitation of being "at about the middle of its vertical height"? (’619 Patent, col. 8:51-52). Does the user interface on a modern Garmin camera system render the apparatus "inaccessible to the driver" as required by the claims? (’619 Patent, col. 9:6-9).
    • Technical Questions: What evidence does the complaint provide that the accused products' data management system creates a "corresponding separate file" for each camera and uses "separate node files" as recited in Claim 1? (’619 Patent, col. 8:61-col. 9:3). The specific data architecture claimed in the patent may not match the architecture used in the accused products.

V. Key Claim Terms for Construction

  • The Term: "inaccessible to the driver" (Claim 1(f); Claim 2(g))

    • Context and Importance: This term is critical because many commercial automotive camera systems include buttons, touchscreens, or other controls that a driver can physically access. The construction of "inaccessible" will likely determine whether a large category of modern products falls within the scope of the claims.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s stated purpose is to avoid driver distraction (’619 Patent, col. 2:14-16). A party could argue that "inaccessible" refers to the system’s core recording function being automatic and tamper-proof during operation, even if ancillary features are physically reachable.
      • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes this point, stating, "it is preferably inacessible to the driver while driving the vehicle" and specifically mentions a battery switch located in an inaccessible position (’619 Patent, col. 5:52-56). This could support a construction requiring complete physical inaccessibility of the system’s controls.

  • The Term: "recording images acquired by each camera in a corresponding separate file" (Claim 1(c))

    • Context and Importance: Practitioners may focus on this term because the specific method of data storage is a precise technical limitation. Infringement will depend on whether an accused system, which might combine multiple video streams into a single container file, can be said to record in "separate file[s]."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue that if video data from different cameras is stored in logically distinct tracks within a single file, this could meet the spirit of the limitation.
      • Evidence for a Narrower Interpretation: The claim language, particularly when read in conjunction with the subsequent limitation requiring "eight separate files of real-time recorded data" (from Claim 1(d), which is based on a preferred embodiment with eight lenses), suggests a specific architecture of physically separate data files on the storage medium. The specification discusses creating "separate node files to provide eight separate tracks of real-time recorded data" (’619 Patent, col. 5:26-29), reinforcing a more literal interpretation.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product literature and website materials" that instruct customers on how to use the products in an infringing manner and sells the products for that infringing use (Compl. ¶13-14).
  • Willful Infringement: The willfulness allegation is based on post-suit conduct. The complaint asserts that being served with the complaint provides Defendant with "actual knowledge" and that any continued infringement thereafter is willful (Compl. ¶12-13). No facts supporting pre-suit knowledge are alleged.

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

  1. An Evidentiary Threshold: A threshold issue for the Plaintiff will be to connect its generalized infringement allegations to specific accused products, as the complaint fails to identify any, and to demonstrate how those products meet the patent’s highly specific limitations.
  2. Definitional Scope: The case may turn on claim construction, particularly the meaning of "inaccessible to the driver." The court’s interpretation will determine whether the claims can read on modern camera systems with user-facing controls or are restricted to sealed systems with no driver interface.
  3. A Question of Technical Architecture: A key factual dispute will likely concern the data storage methods. The case will require a technical comparison of whether the accused systems' method of recording video streams maps onto the patent’s specific requirement for a "corresponding separate file" for each camera.