DCT
1:23-cv-22541
Drone Control LLC v. Miami Labs Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Drone-Control LLC (Delaware)
- Defendant: MIAMI LABS, INC. d/b/a OpenStore (Delaware)
- Plaintiff’s Counsel: León Cosgrove Jiménez, LLP
- Case Identification: 1:23-cv-22541, S.D. Fla., 07/07/2023
- Venue Allegations: Venue is alleged to be proper in the Southern District of Florida based on Defendant having its corporate headquarters in Miami, conducting substantial business, and committing alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s radio-controlled drones infringe patents related to control systems that translate a user's commands from the operator's frame of reference to the drone's frame of reference.
- Technical Context: The technology at issue involves control systems for unmanned aerial vehicles (drones) that simplify flight operation by making the controls intuitive regardless of the drone's orientation.
- Key Procedural History: The asserted patents stem from a large family of applications sharing a priority claim back to 2008. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the asserted patents.
Case Timeline
| Date | Event |
|---|---|
| 2008-02-12 | Earliest Priority Date for all Asserted Patents |
| 2016-12-28 | Application filed for what became the ’117 Patent |
| 2018-03-16 | Application filed for what became the ’226 Patent |
| 2018-10-09 | U.S. Patent No. 10,095,226 Issues |
| 2018-12-21 | Application filed for what became the ’205 Patent |
| 2019-04-02 | U.S. Patent No. 10,248,117 Issues |
| 2022-03-22 | U.S. Patent No. 11,281,205 Issues |
| 2023-07-07 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,095,226 - “Radio Controlled Aircraft, Remote Controller And Methods For Use Therewith,” issued October 9, 2018
The Invention Explained
- Problem Addressed: The patent describes the difficulty of operating radio-controlled (RC) aircraft because a user must constantly consider the vehicle's orientation to provide the correct control inputs; for example, a "right turn" command from the user must be translated to a "left turn" input if the aircraft is flying towards the user (U.S. Patent No. 10,095,226, col. 1:36-47).
- The Patented Solution: The invention is a control system within the RC vehicle that receives "command data" based on the user's perspective (a first coordinate system) and, using motion data from on-board sensors, "transforms" it into "control data" based on the vehicle's own perspective (a second coordinate system). This allows the vehicle to execute commands intuitively, so that pushing forward on a joystick always moves the vehicle away from the user, regardless of which way it is facing (’226 Patent, col. 4:1-24; Fig. 5).
- Technical Importance: This technology, often referred to as "headless mode," lowers the skill barrier for operating drones, making them more accessible to novice and casual users by eliminating the need for complex mental transposition of controls (’226 Patent, col. 1:45-47).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶24).
- Claim 1 is directed to a radio-controlled (RC) vehicle comprising:
- A receiver for an RF signal from a remote indicating command data from the remote's perspective.
- One or more motion sensors to generate motion data indicating the RC vehicle's position and orientation.
- A processor that transforms the command data into control data based on the motion data and in accordance with the RC vehicle's perspective.
- The command data and control data both include "yaw-velocity" data.
- A plurality of control devices to control the vehicle's motion based on the transformed control data.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,248,117 - “Radio Controlled Aircraft, Remote Controller And Methods For Use Therewith,” issued April 2, 2019
The Invention Explained
- Problem Addressed: The patent addresses the same problem as the '226 Patent: the non-intuitive nature of controlling an RC aircraft when its orientation does not align with the user's (U.S. Patent No. 10,248,117, col. 1:36-47).
- The Patented Solution: The '117 Patent also discloses a system for transforming user commands from a user-centric coordinate system to a vehicle-centric coordinate system. The system uses a processor and motion sensor on the aircraft to ensure that user commands for direction are executed relative to the user, not the aircraft's "imaginary pilot" (’117 Patent, col. 3:20-30; col. 4:11-28).
- Technical Importance: This control method simplifies the user experience and broadens the market for RC aircraft by making them easier to fly without extensive training (’117 Patent, col. 1:45-47).
Key Claims at a Glance
- The complaint asserts at least independent claim 9 (Compl. ¶40).
- Claim 9 is directed to a radio-controlled (RC) vehicle comprising:
- A receiver for an RF signal from a remote indicating command data from a user's perspective.
- A motion sensor to generate motion data.
- A processor that transforms the command data into control data based on the motion data and in accordance with the vehicle's perspective.
- The command data and control data both include "yaw-velocity" data.
- A plurality of control devices to control motion based on the control data.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,281,205 - “Radio Controlled Aircraft, Remote Controller And Methods For Use Therewith,” issued March 22, 2022
Technology Synopsis
The '205 patent, like the other asserted patents, discloses a system for simplifying drone control. It claims a vehicle with specific motion sensors (an accelerometer and a gyroscope) that receives command data (including roll, pitch, and yaw-velocity) from a user's perspective and transforms it into control data for the vehicle's perspective, allowing for intuitive operation (U.S. Patent No. 11,281,205, col. 1:32-47, Abstract).
Asserted Claims
The complaint asserts at least independent claim 1 (Compl. ¶56).
Accused Features
The complaint alleges that the Accused Products, as a whole, infringe by providing a device with a receiver, motion sensors, and a processor that performs the claimed transformation of command data to control data, including specific data types for roll, pitch, and yaw (Compl. ¶57).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Defendant's radio-controlled aircraft, specifically the EXO X7 Ranger PLUS, EXO Cinemaster 2, EXO Mini, and EXO Blackhawk 2 Pro (collectively, the "Accused Products") (Compl. ¶15). The complaint provides an image of the EXO X7 Ranger PLUS drone (Compl. ¶15, p. 4).
Functionality and Market Context
The complaint alleges the Accused Products are radio-controlled vehicles that are configured to receive RF signals from a remote control device (Compl. ¶25, ¶41, ¶57). The core accused functionality is the on-board processing that allegedly transforms command data based on the user's coordinate system into control data for the vehicle's coordinate system, enabling intuitive flight control (Compl. ¶25, ¶41, ¶57). The complaint alleges Defendant sells and provides detailed operating instructions and tutorials for these products via its website (Compl. ¶¶16-17).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,095,226 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a receiver configured to receive a radio frequency (RF) signal from a remote control device, the RF signal indicating command data in accordance with a first coordinate system...from a perspective of the remote control device | The Accused Products comprise a remote controlled vehicle (RCV) configured to receive an RF signal from a remote control device (RCD) that contains command data based upon a first coordinate system established from the perspective of the RCD. | ¶25 | col. 5:1-5 |
| one or more motion sensors configured to generate motion data, wherein the motion data indicates a position of the RC vehicle and an orientation of the RC vehicle | The Accused Products include at least one motion sensor configured to indicate a position of the RCV and its orientation. | ¶25 | col. 5:10-18 |
| a processor coupled to the one or more motion sensors and to the receiver, the processor configured to transform the command data into control data based on the motion data and in accordance with a second coordinate system, wherein the second coordinate system is from a perspective of the RC vehicle | The Accused Products include a processor coupled to the motion sensor(s) and receiver, configured to transform the command data into control data based on the motion data and in accordance with a second coordinate system established from the perspective of the RC vehicle. | ¶25 | col. 5:19-24 |
| wherein the command data includes yaw-velocity command data, wherein the control data includes yaw-velocity control data, and wherein the yaw-velocity control data is related to the yaw-velocity command data | The command data includes yaw-velocity command data, the control data includes yaw-velocity control data, and the yaw-velocity control data is related to the yaw-velocity command data. | ¶25 | col. 4:50-55 |
| a plurality of control devices coupled to the processor...configured to control motion of the RC vehicle based on the control data | The Accused Products include a plurality of control devices coupled to the processor that are configured to control motion of the RCV based on the control data. | ¶25 | col. 5:26-32 |
U.S. Patent No. 10,248,117 Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a receiver that is configured to receive an RF signal, from a remote control device (RCD), that contains command data based upon a coordinate system that is established from the perspective of the RCD | The Accused Products provide an RCV with a receiver configured to receive an RF signal from an RCD, with command data based on a coordinate system from the RCD's perspective. | ¶41 | col. 5:1-5 |
| a motion sensor configured to generate motion data | The Accused Products include a motion sensor configured to generate motion data. | ¶41 | col. 5:10-12 |
| a processor coupled to the motion sensor and the receiver that is configured to transform the command data into control data that is based on a second coordinate system that is established from the perspective of the RCV | The Accused Products include a processor coupled to the motion sensor and receiver that is configured to transform the command data into control data based on a second coordinate system established from the RCV's perspective. | ¶41 | col. 5:19-24 |
| wherein the command data includes yaw-velocity command data and the control data includes yaw-velocity control data, and wherein the yaw-velocity control data is related to the yaw-velocity command data | The command data includes yaw-velocity command data, the control data includes yaw-velocity control data, and the yaw-velocity control data is related to the yaw-velocity command data. | ¶41 | col. 4:50-55 |
| and one or more control devices coupled to the processor that are configured to control the motion of the RCV based on the control data | The Accused Products include one or more control devices coupled to the processor configured to control the motion of the RCV based on the control data. | ¶41 | col. 5:26-32 |
Identified Points of Contention
- Technical Questions: The complaint's infringement allegations largely mirror the language of the claims without providing specific technical evidence of how the accused functionality is implemented. A central question will be what evidence demonstrates that the Accused Products' software and hardware actually perform the claimed "transformation" of command data from a first coordinate system to a second, as opposed to implementing a different, more generic form of intuitive or "headless" flight control.
- Scope Questions: The dispute may focus on the scope of "coordinate system...from a perspective of the remote control device." A key question for the court will be whether this term requires the specific polar coordinate system and mathematical transformations disclosed in the specification (e.g., ’226 Patent, col. 4:9-19), or if it can be read more broadly to cover any control scheme that makes drone flight direction relative to the operator.
V. Key Claim Terms for Construction
"transform the command data into control data based on the motion data"
- Context and Importance: This term is the technological core of the asserted claims. The definition of "transform" will be critical to determining infringement, as it distinguishes the patented invention from potentially conventional control schemes. Practitioners may focus on this term because its construction will determine whether any system that adjusts for drone orientation infringes, or only those that use a specific, mathematically-defined conversion process.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The general description suggests a functional outcome: "when a user commands the RC aircraft 102 to pitch forward, the RC aircraft will pitch forward from the perspective of the user, regardless of the actual orientation of the RC aircraft" (’226 Patent, col. 4:20-24). This language could support a construction covering any method achieving this result.
- Evidence for a Narrower Interpretation: The specification provides specific mathematical equations for this transformation:
φ1 = Ψ1 cos(φ3−θ) + Ψ2 sin(φ3−θ)andφ2 = Ψ2 cos(φ3−θ) − Ψ1 sin(φ3−θ)(’226 Patent, col. 4:16-19). This explicit disclosure may support a narrower construction limited to this or an equivalent mathematical process.
"first coordinate system ... from a perspective of the remote control device"
- Context and Importance: This term defines the input for the claimed "transformation." Its scope will determine what type of user control input falls within the claims. Whether this requires a specific type of controller or simply any controller where "forward" is relative to the user will be a pivotal issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the concept generally as a "user coordinate system that corresponds to the orientation of the user" (’226 Patent, col. 3:21-23), which could be interpreted broadly.
- Evidence for a Narrower Interpretation: The patent also describes a specific embodiment where the "user of the remote control device would orient the device with changes of θ, in order to face the RC aircraft 102, regardless of its position" (’226 Patent, col. 4:60-63). This could be used to argue for a narrower definition tied to the physical orientation of the remote control itself.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Defendant took active steps with the intent to cause infringement by "distributing instructions that guide users to use the Accused Products in an infringing manner" (Compl. ¶27, ¶43, ¶59). The allegations cite tutorials provided by the Defendant (Compl. ¶16, Ex. I). Contributory infringement is also alleged, based on the assertion that the Accused Products have special features that are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶28, ¶44, ¶60).
Willful Infringement
The complaint alleges that Defendant had knowledge of the asserted patents "at least as of the filing of the original complaint" (Compl. ¶26, ¶42, ¶58). This allegation supports a claim for post-filing willfulness but does not assert pre-suit knowledge, which is typically required to prove willfulness for pre-filing conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and scope: can the phrase "transform the command data," as used in the patents, be construed broadly to cover any "headless mode" flight control system, or is it limited to the specific mathematical equations and coordinate system transformations detailed in the patent specification? The outcome of this question will likely determine whether the accused functionality falls within the scope of the claims.
- A key evidentiary question will be one of technical proof: what evidence will Plaintiff produce to demonstrate that the internal software and hardware of the Accused Products perform the specific functions recited in the claims? The infringement allegations in the complaint are conclusory, and Plaintiff will bear the burden of proving that the accused drones operate in a manner that maps directly onto the claim limitations, particularly the transformation of data between two distinct coordinate systems.