DCT

1:25-cv-06514

Fleet Connect Solutions LLC v. Nextraq LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-06514, N.D. Ga., 11/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Georgia because Defendant maintains regular and established places of business in the district and has committed acts of patent infringement from those locations.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management and tracking solutions infringe six U.S. patents related to mobile vehicle communications, location-based information systems, and the management of mobile field assets.
  • Technical Context: The technology at issue falls within the domain of vehicle telematics and mobile workforce management, a market critical for logistics, transportation, and field service industries that rely on real-time vehicle tracking, dispatch, and data synchronization.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date Event
1999-09-10 Priority Date for ’270, ’723, and ’926 Patents
2000-09-11 ’270 Patent Application Filed
2000-09-18 Priority Date for ’044, ’565, and ’949 Patents
2003-10-06 ’723 Patent Application Filed
2003-11-10 ’926 Patent Application Filed
2003-11-11 ’270 Patent Issued
2006-08-15 ’723 Patent Issued
2006-10-17 ’926 Patent Issued
2013-08-27 ’926 Patent Certificate of Correction Issued
2014-09-08 ’044 Patent Application Filed
2016-03-15 ’565 Patent Application Filed
2016-03-29 ’044 Patent Issued
2017-07-26 ’949 Patent Application Filed
2017-08-29 ’565 Patent Issued
2020-06-02 ’949 Patent Issued
2025-11-13 Complaint Filed

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

U.S. Patent No. 6,647,270 - "VEHICLETALK," issued November 11, 2003

The Invention Explained

  • Problem Addressed: The patent’s background section identifies limitations in conventional mobile communication systems like cellular phones and CB radios for vehicle-to-vehicle contact, citing the impracticality of discovering a nearby driver's phone number and the lack of privacy in broadcast radio. (’270 Patent, col. 1:16-34).
  • The Patented Solution: The invention proposes a system where mobile units within vehicles incorporate a broadband RF transceiver, a position determining means such as a GPS receiver, and a microprocessor. (’270 Patent, col. 2:51-55). This combination allows a vehicle to construct and transmit data packets containing unique identification information as well as its current position, speed, and direction, enabling communication with other similarly equipped vehicles or with fixed roadside networks. (’270 Patent, Abstract; col. 4:55-67).
  • Technical Importance: The technology represents an early framework for vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2I) communication, a foundational concept for modern intelligent transportation and connected vehicle systems. (Compl. ¶20).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶24).
  • Claim 1 is a system claim for transmitting communications between remote units, with each unit comprising:
    • a memory storing a unique identifier;
    • a transceiver for wireless communication;
    • a GPS receiver for outputting a position signal;
    • a microprocessor that constructs data packets from data fields, including sender information (a unique identifier and GPS-derived data) and receiver information (the address of the desired remote unit).

U.S. Patent No. 7,092,723 - "SYSTEM AND METHOD FOR COMMUNICATING BETWEEN MOBILE UNITS," issued August 15, 2006

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’270 Patent, this patent addresses the same technical problem: the shortcomings of existing communication methods for drivers seeking to communicate with operators of other vehicles in motion. (’723 Patent, col. 1:26-42).
  • The Patented Solution: The patent describes a vehicle and system for communication that includes a remote unit with a GPS receiver, a transceiver, a microprocessor, and memory. (’723 Patent, col. 4:1-15). The microprocessor is configured to generate a communication by constructing data packets from a plurality of data fields, including sender and receiver information, which enables the exchange of location and status information between mobile units. (’723 Patent, Abstract).
  • Technical Importance: This patent builds on the foundational V2V concept by further detailing the system architecture and method for generating data packets within a digital mobile communication system. (Compl. ¶30).

Key Claims at a Glance

  • The complaint asserts at least independent claim 19. (Compl. ¶33).
  • Claim 19 is a system claim for transmitting communications between remote units, with each unit comprising:
    • a unique identifier;
    • a transceiver for wireless communication;
    • a global positioning system receiver for a position signal;
    • a microprocessor configured to receive the position signal and generate a baseband communication by constructing at least one data packet from data fields;
    • a memory configured to store received data and user input, including information unique to the user.

U.S. Patent No. 7,123,926 - "SYSTEM AND METHOD FOR PROVIDING INFORMATION TO USERS BASED ON THE USER'S LOCATION," issued October 17, 2006

  • Technology Synopsis: Belonging to the same family as the ’270 and ’723 patents, the ’926 patent focuses on using a mobile unit's location to provide advisory communications. (Compl. ¶38). The system is designed to alert a user to relevant events based on their geographic position, such as an approaching emergency vehicle, an accident scene, or specific road conditions. (’926 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted. (Compl. ¶41).
  • Accused Features: The complaint accuses Defendant’s products that provide drivers with location-based alerts, routing, and other status information. (Compl. ¶¶ 15.c, 40).

U.S. Patent No. 9,299,044 - "SYSTEM AND METHODS FOR MANAGEMENT OF MOBILE FIELD ASSETS VIA WIRELESS HANDHELD DEVICES," issued March 29, 2016

  • Technology Synopsis: This patent addresses the management of mobile field assets, including personnel and equipment, using wireless handheld devices. (’044 Patent, col. 1:23-29). The invention facilitates bi-directional data delivery between enterprise servers and field devices to support functions like dispatch, data synchronization, logistics, and providing remote access to programs and information for field operators. (’044 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted. (Compl. ¶51).
  • Accused Features: The complaint targets Defendant's fleet management platforms used for job scheduling, workflow management, and data exchange between field personnel and central operations. (Compl. ¶¶ 15, 50).

U.S. Patent No. 9,747,565 - "SYSTEM AND METHODS FOR MANAGEMENT OF MOBILE FIELD ASSETS VIA WIRELESS HANDHELD DEVICES," issued August 29, 2017

  • Technology Synopsis: Continuing the technology of the ’044 patent, the ’565 patent describes systems for managing mobile assets in the field using handheld data management devices. (Compl. ¶57). It enables real-time communication to facilitate remote access to programs and information related to field operations, inventory management, and industry-specific tasks like project analysis and customer invoicing. (’565 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 is asserted. (Compl. ¶60).
  • Accused Features: The allegations are directed at Defendant’s products that provide software and hardware for managing mobile assets and coordinating field operations. (Compl. ¶¶ 15, 59).

U.S. Patent No. 10,671,949 - "SYSTEM AND METHODS FOR MANAGEMENT OF MOBILE FIELD ASSETS VIA WIRELESS HANDHELD DEVICES," issued June 2, 2020

  • Technology Synopsis: This patent, from the same family as the '044 and '565 patents, specifically claims a method for project management involving device-server synchronization. The method involves a server providing a "template" listing a first set of tasks to a handheld device; the device later reports the status of those tasks by synchronizing with the server, which then updates the template with a second set of tasks (e.g., for a subsequent worker or work shift). (’949 Patent, col. 14:1-17; Fig. 9).
  • Asserted Claims: At least independent claim 1 is asserted. (Compl. ¶69).
  • Accused Features: The complaint accuses Defendant's platforms that synchronize job schedules and task lists between field personnel and a central server, enabling workflow management across a fleet. (Compl. ¶¶ 15.c, 68).

III. The Accused Instrumentality

Product Identification

  • The accused products are the "NexTraq" and "Michelin Connected Fleet Powered By NexTraq" fleet management and tracking solutions. (Compl. ¶15).

Functionality and Market Context

  • The Accused Products comprise a suite of hardware and software for commercial fleet management. This includes in-cab devices like tablets and smartphones running Electronic Logging Device (ELD) applications (e.g., NexTraq ELD Android/iOS), which are used for regulatory compliance. (Compl. ¶15.a). The system also includes various asset tracking devices (e.g., VT-3030, NexTraq® Dashcams) equipped with GPS, sensors, and multi-mode wireless transceivers (e.g., GNSS/GPS, LTE, 5G, Bluetooth) for monitoring vehicles and equipment. (Compl. ¶15.b). This hardware communicates with software platforms like the NexTraq Web Portal and Michelin SmarterDriver app, which provide functionality for routing, location tracking, status monitoring, and workflow management. (Compl. ¶15.c). The reference to ELD mandates by the USDOT suggests the products serve a commercially significant and regulated market. (Compl. ¶15.a).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, Exhibits A-F, which purportedly contain detailed infringement evidence for each asserted patent. In the absence of these exhibits, the infringement analysis is based on the narrative allegations in the complaint.

'270 Patent Infringement Allegations

  • Narrative Infringement Theory: The complaint alleges that Defendant’s Accused Products form a system that practices at least Claim 1. (Compl. ¶24). The in-vehicle hardware, such as asset tracking devices and in-cab tablets, allegedly function as the claimed "remote units." (Compl. ¶15.b). These units are alleged to contain the claimed "microprocessor," "transceiver," and "GPS receiver." (Compl. ¶15.b). The complaint further suggests that in operation, these units generate and transmit "data packets" containing a unique device identifier and GPS-derived location ("sender information") over wireless networks, thus meeting the core limitations of the asserted claim. (Compl. ¶¶ 15, 16, 23).
  • Identified Points of Contention:
    • Scope Questions: Claim 1 recites a "system for transmitting...communications...between a plurality of remote units." A point of contention may be whether the accused system, which appears to operate on a client-server model where devices communicate primarily with a central NexTraq platform, meets this "between...remote units" limitation, which the patent specification often describes in the context of vehicle-to-vehicle communication.
    • Technical Questions: The infringement analysis will likely require evidence showing how the data transmitted by the Accused Products is structured. A question for the court may be whether standard network protocol headers and payloads used in modern cellular communications contain discrete data fields that map onto the claimed "sender information" and "receiver information," specifically the "address of the desired remote unit."

'723 Patent Infringement Allegations

  • Narrative Infringement Theory: The complaint alleges that the Accused Products constitute an infringing system under at least Claim 19. (Compl. ¶33). The theory appears to be that the combination of NexTraq's in-vehicle hardware and backend software creates a system for communication between mobile units. (Compl. ¶¶ 15, 32). The hardware is alleged to meet the "transceiver," "global positioning system receiver," and "microprocessor" elements, while the system's function of collecting and transmitting location and identifier data in structured packets is alleged to meet the claim's requirement for constructing data packets from a plurality of data fields. (Compl. ¶15.b-c).
  • Identified Points of Contention:
    • Scope Questions: Claim 19 requires a "memory configured to store...user input including information unique to the user." A potential dispute may arise over the definition of "user input." The analysis may question whether automatically generated data (e.g., driver ID from an ELD login) or configuration settings entered by a fleet manager constitute "user input" in the manner contemplated by the patent, or if the claim requires more direct, real-time input from the vehicle operator.
    • Technical Questions: As with the ’270 patent, a key technical question will be the mapping of the accused system's data structures onto the claimed "data packet" and its "plurality of data fields." Evidence will be needed to show that the accused system constructs packets in the claimed manner, rather than simply passing data through standardized communication layers.

V. Key Claim Terms for Construction

  • Term: "remote unit" (’270 Patent, Claim 1)

    • Context and Importance: This term defines the fundamental component of the claimed system. Its construction will determine whether the claim reads on a single, integrated piece of hardware or a distributed collection of components within a vehicle (e.g., a driver's smartphone, a separate telematics box, and the vehicle's onboard computer). Practitioners may focus on this term because the accused instrumentality is a system of discrete but communicating products.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract describes a system comprising various functional components, and the term "mobile unit" is used to describe the collection of these components within a vehicle, suggesting the claim may not be limited to a single physical housing. (’270 Patent, Abstract; col. 2:51-55).
      • Evidence for a Narrower Interpretation: Figure 2 of the patent depicts "mobile unit 16" as a block diagram where the microprocessor, memory, GPS, and other components are interconnected within a single dashed-line box, which could support a narrower construction requiring a more integrated device. (’270 Patent, Fig. 2).

  • Term: "template" (’949 Patent, Claim 1)

    • Context and Importance: The infringement allegation for the ’949 patent hinges on whether the job schedules or task lists within the Accused Products constitute a "template." This term is central to the claimed method of synchronizing and managing work across shifts or users.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes providing users with "instructions (e.g., templates, task/punch lists) and/or programs." (’949 Patent, col. 8:56-58). This broad, functional language suggests a "template" could encompass any structured list of tasks provided to a user.
      • Evidence for a Narrower Interpretation: The detailed description discusses the template in the context of tracking project status across different work shifts, where an "updated template is created by the server...for a subsequent worker based on the project's updated status." (’949 Patent, col. 11:23-27). This context could support a narrower definition requiring a structure specifically designed for multi-user, sequential task handoffs.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant contributes to and induces infringement by third parties, presumably its customers who use the Accused Products. (Compl. ¶¶ 11, 13). The allegations are based on Defendant offering its products and services for use in an infringing manner.
  • Willful Infringement: The complaint does not make an explicit allegation of willful infringement. It does, however, request that the Court declare the case "exceptional" and award attorneys' fees under 35 U.S.C. § 285. (Compl. ¶72.d).

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

  • A core issue for the earlier patents (’270, ’723, ’926) will be one of architectural scope: can claims rooted in a peer-to-peer or broadcast vehicle-to-vehicle communication model be construed to cover Defendant's modern, cloud-based fleet management system, where mobile units primarily communicate with a centralized server rather than directly with each other?
  • A central question for the later patents (’044, ’565, ’949) will be one of definitional scope: does a digital "job schedule" or "workflow" list in the accused software meet the claimed meaning of a "template," particularly as a mechanism for synchronizing unfinished tasks for a "subsequent worker," or is there a material difference in structure and function?
  • A key evidentiary question across all asserted patents will be one of technical mapping: in the absence of the referenced claim chart exhibits, the case will depend on discovery to establish whether the specific data structures, protocols, and operational steps of the accused system can be mapped onto the "data packets," "data fields," and method steps recited in the patent claims.