DCT

4:25-cv-04166

Intellectros LLC v. Deere & Co

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-04166, C.D. Ill., 01/16/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Central District of Illinois because Defendant maintains a regular and established place of business in Moline, Illinois, and has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s private 5G networks, deployed in its manufacturing facilities, infringe patents related to high-accuracy device positioning and radio link failure handling in multi-cell wireless environments.
  • Technical Context: The dispute centers on advanced features within 5G telecommunication standards that enable precise location tracking and robust connectivity, technologies critical for industrial automation and the Internet of Things (IoT).
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the alleged infringement, including claim charts for the patents-in-suit, via a letter dated April 30, 2025. This allegation forms the basis for Plaintiff's claim of willful infringement. This filing is a First Amended Complaint, indicating a prior version was filed and subsequently modified.

Case Timeline

Date Event
2013-01-18 U.S. Patent No. 9,794,839 Priority Date
2013-12-26 U.S. Patent No. 9,755,797 Priority Date
2017-09-05 U.S. Patent No. 9,755,797 Issued
2017-10-17 U.S. Patent No. 9,794,839 Issued
2020 Defendant's 5G implementation allegedly began
August 2023 Defendant's Waterloo Works 5G network reportedly became operational
2025-04-30 Plaintiff sent pre-suit notice letter to Defendant
2025-05-16 Plaintiff allegedly followed up on notice letter
2026-01-16 First Amended Complaint Filed

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

U.S. Patent No. 9,755,797 - *"Localization-Based Beamforming Scheme for Systems with Multiple Antennas"*

  • Patent Identification: U.S. Patent No. 9,755,797, “Localization-Based Beamforming Scheme for Systems with Multiple Antennas,” issued September 5, 2017.

The Invention Explained

  • Problem Addressed: The patent’s background section describes that conventional 3D positioning algorithms, such as observed-time-difference-of-arrival (OTDOA), require signals from four base stations to solve for a user equipment’s (UE) three-dimensional coordinates (x, y, z). Obtaining good accuracy often requires the fourth base station to be deployed at a significantly different height, which introduces additional cost (’797 Patent, col. 1:11-21).
  • The Patented Solution: The invention proposes a method for 3D positioning that reduces the required number of base stations from four to three. It achieves this by using the multi-antenna array of the "serving" base station to perform beamforming. This allows the UE to estimate its own "elevation angle" relative to the serving base station. This elevation angle measurement effectively provides the third dimension of location data, replacing the need for a signal from a fourth base station. ('797 Patent, Abstract; col. 2:25-45).
  • Technical Importance: This approach aimed to lower the infrastructure cost and complexity of implementing high-accuracy 3D positioning in cellular networks, a key enabler for location-based services. ('797 Patent, col. 2:20-24).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('797 Patent, col. 9:64-10:24; Compl. ¶11).
  • Claim 1 requires a method performed by a UE comprising the following essential elements:
    • Receiving a plurality of positioning reference signals (PRSs) from multiple base stations, where the PRS from the serving base station is applied with "distinct beamforming vectors for multiple OFDM symbols."
    • Estimating line-of-sight (LOS) paths for time of arrival (TOA) and time difference of arrival (TDOA) measurements.
    • Estimating an "elevation angle" based on the LOS path measurements from the serving base station's PRS, corresponding to the multiple OFDM symbols.
    • Determining if the UE knows the base station positions.
    • Calculating the UE's position using the TDOA measurements and the elevation angle when the base station positions are known.
  • The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 9,794,839 - *"Mechanism for Radio Link Monitoring and Radio Link Failure Handling in Small Cell Networks"*

  • Patent Identification: U.S. Patent No. 9,794,839, “Mechanism for Radio Link Monitoring and Radio Link Failure Handling in Small Cell Networks,” issued October 17, 2017.

The Invention Explained

  • Problem Addressed: In cellular networks featuring an "anchor-based architecture," a UE can be simultaneously connected to a primary "anchor" base station for control signaling and a secondary "drift" base station for additional data throughput. The patent notes that standard radio link monitoring (RLM) procedures focus only on the connection to the anchor. If the link to the drift base station fails, the anchor may be unaware and continue to attempt data forwarding, leading to inefficiency and a poor user experience. (’839 Patent, col. 2:37-54).
  • The Patented Solution: The patent discloses a method to improve network robustness. When a UE detects a radio link failure (RLF) on its primary connection to the anchor base station, it is configured to send an "RLF indication" to the secondary (drift) base station. This creates an alternative communication path to inform the network of the failure, allowing the drift base station to participate in the recovery process, for instance by helping to facilitate a handover to a new anchor. ('839 Patent, Abstract; col. 4:20-33).
  • Technical Importance: This mechanism enhances the reliability of dual-connectivity systems by ensuring that link failures are communicated more robustly, enabling faster service restoration and more efficient network management. ('839 Patent, col. 2:55-59).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('839 Patent, col. 11:33-12:2; Compl. ¶21).
  • Claim 1 requires a method comprising the following essential elements:
    • Establishing an RRC connection with an "anchor base station (eNB)."
    • Configuring a "first cell group" (served by the anchor) with a primary cell (PCELL) and associating a "first MAC entity" with the anchor.
    • Configuring a "second cell group" (served by a "drift base station") and associating a "second MAC entity" with the drift eNB.
    • Performing RLM/RLF, and upon detecting an RLF on the PCELL, de-associating the first MAC entity and "sends an RLF indication to the drift eNB."
  • The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

  • Defendant’s private 5G wireless networks deployed within its manufacturing facilities, including its factory in East Moline, Illinois (Compl. ¶11, ¶21). The complaint also lists numerous John Deere mobile applications as part of the "Accused Instrumentality" (Compl. ¶11).

Functionality and Market Context

  • The complaint alleges Defendant uses these private 5G networks, which are compliant with 3GPP 5G standards, to support its "smart industrial" strategy (Compl. ¶11, p. 3). Alleged use cases include connecting over 100 automated guided vehicles (AGVs), wireless torque tools, and using "geolocation" to track components on the factory floor (Compl. ¶11, pp. 4, 6).
  • The network is alleged to utilize Nokia 5G radios and operate on Citizens Broadband Radio Service (CBRS) spectrum licenses (Compl. ¶11, p. 6).
  • The complaint cites Defendant's CTO, who describes the private 5G network as "foundational" and part of the company's "secret sauce of how we do manufacturing," suggesting its significant commercial importance (Compl. ¶11, p. 5).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,755,797 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
receiving a plurality of positioning reference signals (PRSs) from a plurality of base stations ... wherein the UE receives a PRS transmission from a serving base station applied with distinct beamforming vectors for multiple OFDM symbols using multiple antennas; The Accused Instrumentality, being compliant with the 5G standard, practices a positioning method where a UE receives PRSs from multiple base stations (TPs), and the PRS from the serving station is transmitted with distinct beamforming vectors in multiple OFDM symbols. ¶12 col. 4:47-50
estimating a plurality of line-of-sight (LOS) paths and corresponding indexes of the PRSs for time of arrival (TOA) and time difference of arrival (TDOA) measurements; The Accused Instrumentality, compliant with the 5G standard, uses LOS/NLOS indicators to estimate LOS paths and corresponding PRS indexes for TOA/TDOA measurements. ¶13 col. 2:31-33
estimating an elevation angle of the UE based on the estimated LOS paths of the PRS from the serving base station, wherein the UE estimates the elevation angle based on multiple LOS path measurements that correspond to the multiple OFDM symbols in one subframe; The Accused Instrumentality, compliant with the 5G standard, estimates an elevation angle (Angle of Departure) based on multiple LOS path measurements from the serving station's PRS that correspond to multiple OFDM symbols in one subframe. A visual from an Ericsson blog post depicts this beamforming and angle estimation process (Compl. p. 14). ¶14 col. 2:33-36
determining whether the UE knows the plurality of base station positions; and The Accused Instrumentality, compliant with the 5G standard, provides the UE with the geographical coordinates of base stations via a Location Management Function (LMF), allowing the UE to know the positions. ¶15 col. 2:39-42
calculating a UE position based on the TOA/TDOA measurements and the elevation angle when the UE knows the plurality of base stations positions. The Accused Instrumentality, compliant with the 5G standard, estimates the UE position using DL-TDOA and DL-AoD methods once it acquires the geographical coordinates of the base stations. ¶16 col. 2:36-39
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the methods prescribed by the 5G standard, on which the complaint relies, are coextensive with the methods claimed in the '797 Patent. The patent's 2013 priority date predates the finalization of 5G standards, raising the possibility of material differences between the patented invention and the standardized implementation.
    • Technical Questions: What evidence does the complaint provide that Defendant's network actually implements the specific 5G positioning features (DL-TDOA, DL-AoD) alleged to infringe? The complaint's infringement theory rests on the network's compliance with the 5G standard, but the connection between the general use of "geolocation" for asset tracking (Compl. ¶12) and the specific, multi-step method of claim 1 may be a point of dispute.

U.S. Patent No. 9,794,839 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
establishing a radio resource control (RRC) connection by a user equipment (UE) with an anchor base station (eNB) in a mobile communication network; The Accused Instrumentality, compliant with 5G standard, practices Multi-Radio Dual Connectivity (MR-DC) where a UE establishes an RRC connection with a master node (anchor). ¶22 col. 3:4-6
configuring a first cell group containing one or multiple serving cells served by the anchor eNB... wherein the UE associates a first MAC entity with the anchor eNB...; The network configures a Master Cell Group (MCG) served by the master node (anchor), and the UE associates a first MAC entity with the master node for scheduling. ¶23 col. 3:7-12
configuring a second cell group containing one or multiple secondary serving cells (SCELLS) served by a drift base station (eNB), wherein the UE associates a second MAC entity with the drift eNB...; The network configures a Secondary Cell Group (SCG) served by a secondary node (drift), and the UE associates a second MAC entity with the secondary node for scheduling. ¶24 col. 3:13-17
...wherein the UE detects an RLF event on the PCELL and de-associating the first MAC entity with the anchor eNB, and wherein the UE also sends an RLF indication to the drift eNB. The 5G standard allegedly discloses that upon detection of a radio link failure (RLF) on the MCG, the UE suspends MCG transmission, de-associates the MAC for the master node, and sends an MCG RLF indication to the secondary node (drift eNB). A diagram of this failure handling process is provided (Compl. p. 52). ¶25 col. 3:18-24
  • Identified Points of Contention:
    • Scope Questions: The claims use terminology specific to the LTE standard (e.g., "eNB"). The accused system is a 5G network, which uses different terminology (e.g., "gNB," "Master Node," "Secondary Node"). The case may turn on whether these terms can be construed to cover their functional equivalents in the 5G standard.
    • Technical Questions: Does the 5G standard's procedure for "fast MCG link recovery," where a failure message is sent via the Secondary Cell Group (SCG) to the Master Node (Compl. p. 49), meet the claim limitation of sending an "RLF indication to the drift eNB"? The parties may dispute whether the drift eNB is a recipient of the indication or merely a conduit for it.

V. Key Claim Terms for Construction

  • Patent: '797 Patent

    • The Term: "estimating an elevation angle of the UE"
    • Context and Importance: This is the inventive concept that purports to eliminate the need for a fourth base station. The dispute will likely focus on whether the 5G standard's Angle of Departure (AoD) measurement is equivalent to the claimed "elevation angle."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent abstract and summary describe the concept broadly as estimating an "elevation angle of the UE based on the estimated LOS paths from the serving base station" ('797 Patent, Abstract; col. 2:33-36). This could support an argument that any method deriving vertical position from the serving station's signal is covered.
      • Evidence for a Narrower Interpretation: The specification provides a specific geometric formula relating the elevation angle ("α") to the UE's coordinates ('797 Patent, Fig. 2; col. 4:5-8). A party could argue that the claim should be limited to an estimation process consistent with this disclosed mathematical relationship.

  • Patent: '839 Patent

    • The Term: "sends an RLF indication to the drift eNB"
    • Context and Importance: This limitation defines the novel signaling path that forms the core of the invention. Its interpretation will be critical to determining if the 5G standard's failure recovery mechanism infringes.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's goal is to improve RLF handling by involving the drift eNB in the process ('839 Patent, col. 4:20-33). Language describing the drift eNB "passing" the indication to the anchor could support a view that the drift eNB is an intended, active recipient in the communication chain, even if not the final destination.
      • Evidence for a Narrower Interpretation: A party could argue that the plain meaning of "to the drift eNB" requires the drift eNB to be the intended endpoint of the communication. The specification discusses the UE sending the indicator to the drift eNB, which then passes it to the anchor, potentially distinguishing the "recipient" from a mere "forwarder" ('839 Patent, col. 4:25-28).

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement. The infringement counts are for direct infringement by Defendant's use of the accused systems (Compl. ¶11, ¶21).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant’s alleged pre-suit knowledge of the patents-in-suit. Plaintiff claims to have sent a letter with claim charts to Defendant on April 30, 2025, and alleges that any infringement after this date was intentional (Compl. ¶27).

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

  • A core issue will be one of technological translation: can claims drafted with terminology from one wireless standard (LTE) be construed to read on the analogous but architecturally distinct components of a later standard (5G)? This question is central to the infringement analysis for both asserted patents.
  • A key evidentiary question will be one of operational reality vs. standard compliance: does the complaint’s reliance on the capabilities of the 5G standard and Defendant's public statements provide sufficient factual basis to allege that Defendant's private network actually performs the specific multi-step methods of the asserted claims?
  • A critical claim construction question will be one of definitional directionality: for the ’839 patent, does sending a failure message via a secondary base station’s resources constitute sending an indication to that secondary base station, or is the secondary station merely a transport layer for a message directed elsewhere?