DCT
0:25-cv-61603
Pivot Innovations LLC v. Seaai Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Pivot Innovations, LLC (Wyoming)
- Defendant: Sea.AI, Inc. (Florida)
- Plaintiff’s Counsel: Law Office Of Barbra Stern PA
- Case Identification: 0:25-cv-61603, S.D. Fla., 08/07/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and provides allegedly infringing products and services to residents of the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Sentry system," a maritime situational awareness product, infringes U.S. Patent No. 9,552,274, which the complaint describes as relating to a "method for vehicle traffic flow data acquisition and reporting for onboard vehicle navigation."
- Technical Context: The dispute ostensibly concerns maritime object detection and collision avoidance technology.
- Key Procedural History: A significant issue presented by the complaint is a fundamental discrepancy between its description of the asserted patent’s technology and claims, and the actual content of U.S. Patent No. 9552274. The complaint also references an inventor and a 2008 patent application filing date that do not correspond to the public record for the asserted patent.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-27 | Priority Date for U.S. Patent No. 9,552,274 |
| 2017-01-24 | Issue Date for U.S. Patent No. 9,552,274 |
| 2025-08-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,552,274 - "ENHANCEMENTS TO LOGGING OF A COMPUTER PROGRAM"
- Patent Identification: U.S. Patent No. 9,552,274, "ENHANCEMENTS TO LOGGING OF A COMPUTER PROGRAM", issued January 24, 2017.
The Invention Explained
- Problem Addressed: The patent addresses the problem that software logging practices are often arbitrary, resulting in either a lack of useful diagnostic data or an excess of "noisy" data, both of which complicate debugging and troubleshooting of production software failures (’274 Patent, col. 1:21-33, 1:56-64).
- The Patented Solution: The invention is a system that automates recommendations for improving a program's logging code. It does so by first constructing a "static call graph" of the software's methods, analyzing historical data from code repositories ("commit history") and bug trackers, and then using this data to identify methods that exhibit "ideal" logging behavior. This ideal behavior is then used as a benchmark to identify other methods in the code that have deficient or excessive logging, for which the system generates enhancement recommendations (’274 Patent, Abstract; col. 2:50-63).
- Technical Importance: The described technology aims to solve a common and resource-intensive problem in large-scale software development by introducing a data-driven, systematic approach to optimizing logging, a critical tool for software maintenance and diagnostics (’274 Patent, col. 1:28-33).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-7 (Compl. ¶10, ¶23).
- Independent claim 1 of the ’274 Patent recites a method comprising the following essential elements:
- ranking a plurality of methods in the source code of a computer program based on a relative importance value computed for each method;
- identifying a method that exhibits ideal logging behavior for the computer program, the method identified based at least in part on historical logging code modifications of the method;
- computing a logging behavior value for each of the plurality of methods;
- comparing the logging behavior value of a method having a highest relative importance value with the logging behavior value of the method that exhibits ideal logging behavior; and
- generating a recommendation for enhancing the logging code based at least in part on comparing the logging behavior values.
- The complaint asserts dependent claims 2-7, which further refine aspects of the method, such as comparing methods with the lowest relative importance or displaying specific types of recommendations (’274 Patent, col. 16:49-18:2).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant's "Sentry system" (Compl. ¶16).
Functionality and Market Context
- The complaint describes the Sentry system as a 360° situational awareness and surveillance system for marine vessels. It allegedly uses daylight and thermal cameras, along with machine vision and AI-processing, to detect and track marine traffic (e.g., other vessels, kayaks) and floating obstacles. The system is alleged to display tracked targets on an onboard display and automatically alert the user to potential collisions (Compl. ¶16).
IV. Analysis of Infringement Allegations
The complaint references a claim chart (Exhibit B) that was not included with the filing (Compl. ¶21). The complaint’s narrative infringement theory is based on a version of Claim 1 that is not present in the asserted ’274 Patent. The core of the complaint (Compl. ¶14) recites claim language for a "method for vehicle traffic flow data acquisition," which is entirely different from the language of the actual claims in the ’274 Patent, which are directed to enhancing software logging code.
A direct comparison using a claim chart is therefore impossible based on the provided documents. The table below highlights the fundamental discrepancy.
| Source | Claim 1 Preamble and Core Subject Matter |
|---|---|
| As Recited in Complaint | "A method for vehicle traffic flow data acquisition and reporting for onboard vehicle navigation..." involving acquiring data of vehicles at a first and second location, determining elapsed travel time, and computing a rate of travel. |
| As Recited in ’274 Patent | "A method for enhancing logging code in a computer program..." involving ranking methods based on importance, identifying "ideal logging behavior" from historical modifications, and generating recommendations. |
- Identified Points of Contention:
- Pleading Sufficiency: A threshold legal question is whether the complaint states a plausible claim for relief, given that its infringement allegations rely on claim language that does not exist in the patent it identifies by number. The asserted facts appear entirely disconnected from the asserted legal right.
- Technical Mismatch: The complaint alleges that a maritime object detection system infringes a patent. However, the actual patent is directed to a software development tool for analyzing and improving source code logs. This suggests a fundamental mismatch in the operative technology, raising the question of how the accused Sentry system could plausibly be alleged to practice the claimed method of analyzing software commit histories and bug trackers to recommend logging enhancements.
No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
Assuming the complaint were amended to assert the actual claims of the ’274 Patent, claim construction would be critical.
- The Term: "ideal logging behavior"
- Context and Importance: This term appears in independent claim 1 and is the cornerstone of the patented method. It defines the benchmark against which other methods are evaluated. The definition of what makes logging behavior "ideal" is central to determining infringement, as it dictates the nature of the analysis required by the claim. Practitioners may focus on this term because its potential ambiguity could be a key point of dispute over claim scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests that "ideal" behavior can be identified from methods whose logging statements have been "modified the most frequently" (’274 Patent, col. 3:12-14). This could support an argument that "ideal" is determined by a quantitative, frequency-based analysis.
- Evidence for a Narrower Interpretation: The patent also states that log enhancements made during a commit that fixes a "high priority bug can be considered highly refined" (’274 Patent, col. 4:63-65). This, along with the detailed description of computing a "LogB" value based on multiple metrics (col. 6:10-39), could support a narrower construction requiring a more complex, qualitative assessment beyond simple modification frequency.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by providing hardware and software through which customers practice the claimed methods (Compl. ¶18). It also makes a conclusory allegation that Defendant provides "instructions" (Compl. ¶35). The complaint alleges contributory infringement on the basis that Defendant supplies a material part of an infringing system that is not a staple article of commerce (Compl. ¶19).
- Willful Infringement: The complaint alleges willfulness based on "intentionally continuing their knowing infringement" (Compl. ¶29). The basis for knowledge appears to be post-notice, as the inducement allegation refers to knowledge "subsequent to notice" (Compl. ¶18).
VII. Analyst’s Conclusion: Key Questions for the Case
- A dispositive threshold issue is one of pleading integrity: does the complaint, which asserts a patent by number but bases its entire infringement theory on claim language and a technical field wholly unrelated to that patent, state a plausible claim for relief or is it subject to dismissal?
- Should the case proceed past the pleading stage, a key evidentiary question will be one of technical relevance: can Plaintiff produce any evidence to suggest that Defendant's maritime object-detection system performs the steps of the asserted patent, which relate to analyzing software development history to generate recommendations for enhancing source code logging statements?