DCT

1:25-cv-04786

Fleet Connect Solutions LLC v. Nextraq LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-04786, N.D. Ga., 08/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Georgia because Defendant maintains established and regular places of business in the district, including a specific office in Atlanta, and has committed acts of patent infringement from those locations.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet tracking and management solutions infringe nine patents related to wireless communication protocols, handheld data management for field operations, and navigation tracking.
  • Technical Context: The technology at issue falls within the vehicle telematics and fleet management industry, a sector focused on monitoring and coordinating vehicle fleets for logistics, field services, and transportation.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date Event
2000-09-18 Priority Date for ’586, ’751, and ’581 Patents
2001-09-21 Priority Date for ’040 and ’845 Patents
2002-09-09 Priority Date for ’153 Patent
2002-11-04 Priority Date for ’837 Patent
2004-07-20 Priority Date for ’388 Patent
2005-08-10 Priority Date for ’968 Patent
2005-11-01 Issue Date for U.S. Patent No. 6,961,586
2006-06-06 Issue Date for U.S. Patent No. 7,058,040
2007-04-17 Issue Date for U.S. Patent No. 7,206,837
2007-08-21 Issue Date for U.S. Patent No. 7,260,153
2009-09-29 Issue Date for U.S. Patent No. 7,593,751
2010-02-02 Issue Date for U.S. Patent No. 7,656,845
2010-06-22 Issue Date for U.S. Patent No. 7,742,388
2010-06-22 Issue Date for U.S. Patent No. 7,741,968
2013-07-23 Issue Date for U.S. Patent No. 8,494,581
2025-08-23 Complaint Filing Date

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’s background section describes the problem of radio frequency interference between different wireless technologies operating in the same unlicensed radio band, such as Bluetooth and IEEE 802.11 in the 2.4 GHz band, which can lead to data corruption and require retransmissions ('040 Patent, col. 1:21-31).
  • The Patented Solution: The invention proposes a method to mitigate this interference by implementing a Time Division Multiple Access (TDMA) scheme. The method involves computing and sharing time-slots between the two different communication media, allocating specific slots to each medium, and instructing the respective transceivers to transmit only during their assigned slots, thereby avoiding simultaneous, interfering transmissions ('040 Patent, Abstract; col. 2:4-12).
  • Technical Importance: This approach provided a framework for the coexistence of multiple, potentially conflicting wireless standards on a single device, which became increasingly important as devices began incorporating both short-range (e.g., Bluetooth) and long-range (e.g., Wi-Fi) communication capabilities ('040 Patent, col. 1:16-25).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶28).
  • Essential elements of Claim 1:
    • A method for data transmission over first and second media that overlap in frequency.
    • Computing one or more TDMA time-slot channels to be shared between the media.
    • Allocating one or more time-slots to the first medium.
    • Allocating one or more of the remaining time-slots to the second medium.
    • Dynamically adjusting the number of time-slots assigned to one of the media during 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 ongoing demand for higher data rates in digital communication systems like IEEE 802.11, and the need for new high-rate devices to remain compatible with existing, standard-rate devices ('388 Patent, col. 1:62 - col. 2:7).
  • The Patented Solution: The invention proposes increasing the data rate by modifying the standard packet structure to include additional subcarriers. Specifically, the method describes generating a packet with a standard preamble structure (containing first and second training symbols) and then increasing the packet's size by adding subcarriers to the second training symbol, creating an "extended packet" that can carry more data ('388 Patent, Abstract; col. 5:42-67).
  • Technical Importance: This technique offered a path to boost data throughput in established wireless protocols without fundamentally breaking compatibility, allowing for incremental performance gains in mixed-device environments ('388 Patent, col. 2:1-7).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶37).
  • Essential elements of Claim 1:
    • A method comprising generating a packet with a size corresponding to a protocol for network transmission.
    • The packet comprises a preamble with a first training symbol and a second training symbol.
    • Increasing the packet's size by adding subcarriers to the second training symbol to produce an extended packet.
    • The quantity of subcarriers in the extended packet's second training symbol is greater than in the first training symbol.
    • Transmitting the extended packet from an antenna.

U.S. Patent No. 7,656,845 - “Channel Interference Reduction” (issued February 2, 2010)

  • Technology Synopsis: As a continuation of the application leading to the ’040 Patent, this patent addresses the same technical problem of radio frequency interference between co-located wireless systems (e.g., Bluetooth and 802.11) operating in overlapping frequency bands. It likewise proposes a solution based on allocating and managing communication resources between the different media to prevent simultaneous transmissions ('845 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶53).
  • Accused Features: The accused features are Defendant's wireless communication systems, which allegedly must manage co-located transceivers (Compl. ¶¶17-19).

U.S. Patent No. 7,260,153 - “Multi Input Multi Output Wireless Communication Method and Apparatus…” (issued August 21, 2007)

  • Technology Synopsis: This patent relates to Multi-Input Multi-Output (MIMO) wireless communication systems. It aims to solve the problem of "cross-talk interference" that arises in MIMO systems when the propagation channel characteristics are imperfectly estimated, proposing a method to achieve more robust and predictable extended range and data rates ('153 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶62).
  • Accused Features: The accused features are the alleged use of MIMO and Orthogonal Frequency-Division Multiplexing (OFDM) techniques in the Accused Products' wireless transceivers (Compl. ¶19).

U.S. Patent No. 7,206,837 - “Intelligent Trip Status Notification” (issued April 17, 2007)

  • Technology Synopsis: This patent describes methods for providing periodic trip status information, such as estimated time-of-arrival, to a user in transit. The system estimates these metrics based on a plurality of data inputs, including the user's current location, calendrical time (time and date), historical travel statistics, and current or forecasted weather and traffic conditions ('837 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶71).
  • Accused Features: The accused features are the fleet management and vehicle tracking software applications, which provide trip status and ETA information to users and managers (Compl. ¶16).

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

  • Technology Synopsis: This patent, related to the '586 patent, describes systems and methods for using handheld devices to conduct field operations. The invention provides users with portable access to industry-specific programs and enables data synchronization with remote servers, facilitating two-way communication for real-time assistance and information exchange ('751 Patent, Abstract).
  • Asserted Claims: At least independent claim 6 (Compl. ¶80).
  • Accused Features: The accused features include Defendant's driver mobile applications (e.g., NexTraq Connect) and fleet management software, which are used to manage field operations and communicate data between drivers and a central system (Compl. ¶16).

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

  • Technology Synopsis: This patent describes methods for conducting field assessments using handheld computing devices. The invention focuses on enabling two-way communication between field personnel and remote computing resources (e.g., servers) to facilitate real-time access to programs, assistance, and information relevant to the field assessment ('586 Patent, Abstract).
  • Asserted Claims: At least independent claim 9 (Compl. ¶89).
  • Accused Features: The accused features include Defendant's driver mobile applications and management software used for field data collection and communication (Compl. ¶16).

U.S. Patent No. 8,494,581 - “System and Methods for Management of Mobile Field Assets via Wireless and Held Devices” (issued July 23, 2013)

  • Technology Synopsis: This patent, also related to the '586 patent family, describes systems for managing mobile field assets, including personnel and inventory, through wireless handheld devices. The system facilitates bi-directional data delivery between enterprise-based servers and field devices to support dispatch, data synchronization, and logistics ('581 Patent, Abstract).
  • Asserted Claims: At least independent claims 21 and 22 (Compl. ¶98).
  • Accused Features: The accused features are Defendant's fleet tracking and management solutions that manage mobile assets (vehicles and drivers) and facilitate data exchange (Compl. ¶16).

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

  • Technology Synopsis: This patent describes a system for "permissive navigational tracking," where one device selectively transmits its location data to one or more other devices. The system allows a "master" device to maintain and display the geographic positions of a plurality of other devices in a group ('968 Patent, Abstract).
  • Asserted Claims: At least independent claim 4 (Compl. ¶107).
  • Accused Features: The accused features are Defendant's fleet management software (e.g., Vehicle Tracking, NexTraq View) that allows a central user to track the location of multiple vehicles in a fleet (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as "NexTraq and/or MICHELIN Connected Fleet fleet tracking and management solutions" (Compl. ¶16). This includes a broad range of products: (1) software applications such as Vehicle Tracking and MyConnectedFleet; (2) driver mobile apps like NexTraq Connect; (3) hardware transceivers and tracking units such as the MEMS4 LTE/GPS MODULE and various LMU/TTU series units; and (4) dashcam and Electronic Logging Devices (ELDs) (Compl. ¶16).

Functionality and Market Context

The complaint alleges the Accused Products perform wireless communications using various protocols including Bluetooth, IEEE 802.11, and LTE (Compl. ¶17). Their alleged technical functions include generating and transmitting data packets, communicating via multiple wireless transceivers, processing OFDM symbols, and performing singular value decomposition of channel matrices (Compl. ¶¶18, 19). These products are marketed as solutions for commercial fleet tracking and management.

IV. Analysis of Infringement Allegations

The complaint repeatedly references infringement exhibits (Exhibits A through I) that correspond to each asserted patent; however, these exhibits were not filed with the complaint (Compl. ¶¶28, 37, 53, 62, 71, 80, 89, 98, 107). In the absence of claim charts, the infringement analysis is based on the narrative allegations in the complaint. No probative visual evidence provided in complaint.

Narrative Summary for U.S. Patent No. 7,058,040

The complaint alleges that by making and using the Accused Products, Defendant directly infringes at least claim 1 (Compl. ¶¶27-28). The infringement theory appears to be that the Accused Products, which employ multiple wireless technologies such as Bluetooth, Wi-Fi, and LTE (Compl. ¶17), must necessarily implement a method for mitigating interference between these co-located radios. The complaint alleges the products "transmit data over various media" and "compute time slot channels" (Compl. ¶19), which Plaintiff contends maps to the claimed method of computing, allocating, and dynamically adjusting TDMA time-slots between different media to maintain a level of service.

  • Identified Points of Contention:
    • Evidentiary Question: What evidence does the complaint provide that the Accused Products perform the specific steps of "computing... TDMA time-slot channels," "allocating" them between different media, and "dynamically adjusting" this allocation based on a "desired level of service," as required by claim 1? The allegations appear conclusory.
    • Technical Question: Does the generic function of a modern wireless chipset managing coexistence between, for example, LTE and Bluetooth, operate via the specific TDMA time-slot allocation and dynamic adjustment mechanism described in the patent, or does it use alternative, non-infringing techniques?

Narrative Summary for U.S. Patent No. 7,742,388

The complaint alleges direct infringement of at least claim 1 (Compl. ¶¶36-37). The theory appears to be that the Accused Products, in implementing wireless protocols such as IEEE 802.11n or LTE (Compl. ¶17), "generate packets for network transmissions" (Compl. ¶19). Plaintiff contends this process meets the limitations of claim 1, which requires starting with a two-part training symbol and then "increasing the size of the packet by adding subcarriers to the second training symbol."

  • Identified Points of Contention:
    • Scope Question: Does the packet generation in modern OFDM-based standards like 802.11n or LTE, which inherently define high-throughput packet structures, constitute "adding subcarriers" to a pre-existing, smaller packet structure in the manner claimed?
    • Technical Question: What evidence demonstrates that the accused devices’ packet generation method specifically involves modifying the second training symbol of the preamble, as opposed to defining a different preamble structure altogether or modifying only the data portion of the packet?

V. Key Claim Terms for Construction

For the ’040 Patent

  • The Term: "dynamically adjusting a number of time-slot channels... to remain within limits of a desired level of service" (Claim 1)
  • Context and Importance: This term is central to the inventive concept of an adaptive system that manages interference. The dispute may center on whether the Accused Products perform any "dynamic adjusting" at all, and if so, whether that adjustment is driven by a measured "level of service" as contemplated by the patent, or by some other factor. Practitioners may focus on this term because it requires not just allocation, but a specific, feedback-driven modification of that allocation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the purpose as being to "adjust for quality of service" ('040 Patent, col. 3:56-61), which could be argued to encompass a wide range of performance-based adjustments.
    • Evidence for a Narrower Interpretation: The Summary of the Invention describes a specific sequence of "detecting the medium that fails to meet said desired level of service; allocating the medium to a configuration having additional time slots; and transmitting an additional channel assignment message" ('040 Patent, col. 2:22-27). This language suggests a specific, reactive process that may limit the scope of "dynamically adjusting."

For the ’388 Patent

  • The Term: "increasing the size of the packet by adding subcarriers to the second training symbol" (Claim 1)
  • Context and Importance: The infringement case for this patent depends on whether the accused high-rate packets are formed by this specific modification process. Defendant may argue its packets are constructed according to a standard that defines a native high-rate structure, rather than by "adding" subcarriers to a smaller, baseline structure. Practitioners may focus on this term because it ties the inventive step to a specific part of the packet preamble.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The Abstract describes the invention more generally as "increasing the standard size of a packet... by adding subcarriers to the packet to produce an extended data signal" ('388 Patent, Abstract), which might be argued to cover additions anywhere in the packet.
    • Evidence for a Narrower Interpretation: Claim 1 explicitly requires adding the subcarriers "to the second training symbol." The detailed description explains this in the context of taking a legacy 52-subcarrier packet and creating a 56-subcarrier packet by populating previously unused bins, a specific technical implementation that could be argued to narrow the claim's scope ('388 Patent, col. 5:42-67).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced and contributory infringement of the ’388 and ’968 Patents. The allegations are based on Defendant inducing its customers and end-users to use the Accused Products in an infringing manner through actions such as distributing instructions, advertising, and providing technical support (Compl. ¶¶39-41, 109-111).

Willful Infringement

The complaint alleges willful infringement of the ’388 and ’968 Patents. The basis for willfulness is Defendant's alleged knowledge of the patents "at least as of the date Defendant was notified of the filing of this action," indicating a theory of post-suit willfulness (Compl. ¶¶38, 108). The complaint also alleges a pre-suit "willful blindness" based on an asserted "policy or practice of not reviewing the patents of others" (Compl. ¶¶42, 112).

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

  • A primary issue will be one of evidentiary sufficiency: Given the absence of claim charts and the conclusory nature of the allegations, can the plaintiff produce technical evidence to demonstrate that the Accused Products, which implement complex, standardized communication and software protocols, actually perform the specific, granular steps recited in the asserted claims?
  • A second core issue will be one of technological mapping: For the communications patents (’040, ’388, etc.), can methods for ensuring performance in modern wireless systems (e.g., LTE/Wi-Fi coexistence, 802.11n packet structures) be fairly mapped onto claim language rooted in the technological context of the early 2000s, or will there be a fundamental mismatch in technical operation?
  • A third key question will be one of claim scope: For the software and navigation patents (’837, ’968, etc.), the dispute may turn on whether the claims are construed broadly enough to cover common features in modern fleet management systems (e.g., map-based group tracking, ETA calculations), or if the specific limitations in the claims allow the defendant to distinguish its implementation as non-infringing.