DCT
1:25-cv-01836
All Terminal Services LLC v. Roboflow Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ALL TERMINAL SERVICES, LLC D/B/A CONGLOBAL TECHNOLOGIES (Illinois)
- Defendant: Roboflow, Inc. (Delaware, with a principal place of business in Iowa)
- Plaintiff’s Counsel: Arnall Golden Gregory LLP; Taft Stettinius & Hollister LLP
- Case Identification: 1:25-cv-01836, N.D. Ill., 02/21/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant purposefully availed itself of the district by advertising, marketing, offering for sale, and selling the accused systems to customers within the district.
- Core Dispute: Plaintiff alleges that Defendant’s computer vision and workflow automation products, including its "Yard Management System," infringe patents related to systems for monitoring and controlling railcars in a railway yard.
- Technical Context: The technology at issue involves using sensors, machine learning, and optical character recognition (OCR) to automate the identification, tracking, and management of assets like intermodal containers in complex logistical environments such as railyards.
- Key Procedural History: The complaint alleges that Plaintiff put Defendant on notice of infringement of the ’148 Patent via a letter dated December 3, 2024. The complaint notes that Defendant responded but allegedly failed to provide specific reasons for non-infringement.
Case Timeline
| Date | Event |
|---|---|
| 2019-11-18 | Earliest Priority Date for '148 and '183 Patents |
| 2024-06-25 | '148 Patent Issue Date |
| 2024-06-25 | Plaintiff announces issuance of '148 Patent via press release |
| 2024-12-04 | Defendant receives notice letter regarding '148 Patent infringement |
| 2025-02-04 | '183 Patent Issue Date |
| 2025-02-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,020,148 - "Control System for Railway Yard and Related Methods," issued June 25, 2024
The Invention Explained
- Problem Addressed: The patent describes the process of tracking shipping containers and railcars within a complex railway yard as "onerous" due to the high volume of tracks and trains, leading to potential inefficiencies and errors in routing. (’148 Patent, col. 1:30-38).
- The Patented Solution: The invention is a control system that automates this process. It employs "railyard sensors" (such as cameras) to gather data, which is sent to a server. The server uses this data, including images, to generate a detailed database of railcars, identifying attributes like type, logo, and classification. This database is then used to "selectively control" remote-controlled locomotives (RCLs) to efficiently position the railcars within the yard. (’148 Patent, Abstract; Fig. 13).
- Technical Importance: The technology aims to replace manual or semi-automated logistical processes with a fully integrated data-driven system, enhancing the accuracy and operational speed of managing assets in a railyard. (’148 Patent, col. 1:17-38).
Key Claims at a Glance
- The complaint asserts independent claim 1 and method claim 16. (Compl. ¶¶26, 37).
- Independent Claim 1 (System Claim) includes these essential elements:
- A plurality of remote control locomotives (RCLs) and associated sets of railcars.
- A plurality of railyard sensors configured to generate railyard sensor data.
- A server in communication with the RCLs and sensors.
- The server is configured to generate a database of the railcars from the sensor data, including railcar type, logo, and vehicle classification values.
- The server is configured to selectively control the RCLs to position the railcars based on the sensor data.
- The complaint reserves the right to assert other claims.
U.S. Patent No. 12,217,183 - "Control System for Railway Yard and Related Methods," issued February 4, 2025
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’148 Patent, the ’183 Patent addresses the same problem of the operational complexity and inefficiency inherent in managing railcars within a railway yard. (’183 Patent, col. 1:33-39).
- The Patented Solution: The ’183 Patent describes the same technological solution: a server-based control system that integrates data from railyard sensors (e.g., image and proximity sensors) to build a detailed database of railcars. This database underpins the server's ability to direct remote-controlled locomotives (RCLs) to manage railcar positioning, leveraging machine learning models (e.g., CNN, RNN) for tasks like OCR and object identification. (’183 Patent, Abstract; col. 2:1-15).
- Technical Importance: The invention provides an automated framework for logistical control in railyards, aiming to improve efficiency and reduce errors compared to traditional methods. (’183 Patent, col. 1:20-32).
Key Claims at a Glance
- The complaint does not specify which claims of the ’183 patent are asserted but alleges infringement of "at least one of the claims of the Asserted Patents." (Compl. ¶25).
- Independent Claim 1 (System Claim), as a representative example, includes these essential elements:
- A control system with one or more RCLs, railcars, and railyard sensors.
- A server with one or more processors and non-transitory computer-readable storage media.
- The media stores instructions that, when executed, cause the processors to perform steps.
- The steps include generating a database of the railcars based on sensor data.
- The steps include selectively controlling the RCLs to position the railcars.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant’s "Workflows” system, “Roboflow Inference” and “Yard Management System,” along with other similar interrelated products (collectively, the "Accused Systems"). (Compl. ¶2).
Functionality and Market Context
- The complaint alleges the Accused Systems employ sensors and optical character recognition (OCR) to track and manage railcars. (Compl. ¶19). A screenshot from Defendant's website, included in the complaint, describes a "yard management system" that uses computer vision to "accurately track intermodal containers in a yard" and process camera footage to retrieve information like "chassis ID, container ID, container brand." (Compl. p. 5).
- Another visual from the website outlines a four-step process for building a solution: "Train a model to identify containers," "Use Inference to deploy the model," "Identify unique containers in video feed," and "Run OCR on each unique container." (Compl. p. 5). This process is alleged to create databases containing railcar details and utilize machine learning to enable real-time control and positioning of railcars, thereby improving operational efficiency. (Compl. ¶19).
IV. Analysis of Infringement Allegations
'148 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a control system for a railway yard | Defendant offers a "Yard Management System" for tracking intermodal containers in a yard. | ¶19 | col. 1:39-41 |
| a plurality of railyard sensors configured to generate railyard sensor data | The Accused Systems employ sensors, including cameras, to collect railyard data such as images. | ¶19 | col. 1:44-46 |
| a server... configured to generate a database associated with the sets of railcars based upon the railyard sensor data | The Accused Systems collect and analyze sensor data to "create databases containing railcar details such as type, logo, and classification." | ¶19 | col. 1:49-51 |
| the database comprising, for each railcar, a railcar type value, a railcar logo image, and a vehicle classification value | Defendant’s website describes processing footage to retrieve "chassis ID, container ID, container brand, and any other visual information." | ¶20, p. 5 | col. 1:51-53 |
| selectively control said plurality of RCLs to position the sets of railcars... based upon the railyard sensor data | The Accused Systems are alleged to "provide real-time control and positioning of railcars, improving operational efficiency." | ¶19 | col. 1:53-54 |
'183 Patent Infringement Allegations
The complaint does not specify an independent claim for the ’183 Patent. The following chart analyzes representative Claim 1 based on the general allegations.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A control system for a railway yard... comprising: one or more... railyard sensors... and a server... | Defendant provides the "Yard Management System" which uses sensors and a processing backend. | ¶19 | col. 19:31-41 |
| the server including one or more processors and one or more non-transitory computer-readable storage mediums storing instructions | The Accused Systems are software-based platforms ("Workflows," "Inference") that run on computer hardware. | ¶2 | col. 19:42-45 |
| instructions... cause the one or more processors to perform steps to: generate a database associated with the one or more railcars | Defendant's website describes a process to "Train a model," "Use Inference," "Identify unique containers," and "Run OCR" to retrieve container IDs, which is alleged to build a database. | ¶20, p. 5 | col. 19:50-51 |
| selectively control the one or more RCLs to position the one or more railcars | The complaint alleges the Accused Systems provide "real-time control and positioning of railcars." | ¶19 | col. 19:52-54 |
- Identified Points of Contention:
- Scope Questions: The patents claim a system that "selectively control[s]" remote-controlled locomotives ("RCLs") to "position" railcars. A central question may be whether Defendant's software, which is described as a tool to "build a yard management system," performs this specific physical control function itself, or if it merely provides analytical data that a customer then uses to manually or otherwise control its own hardware. The complaint's allegation of "real-time control" may be scrutinized for factual support.
- Technical Questions: A potential issue is whether Defendant provides a complete, infringing "control system," or merely software components (e.g., an inference engine, a workflow tool) that customers must integrate with their own sensors and control hardware. This raises the question of whether direct infringement can be attributed to the Defendant alone, or if the case will depend more heavily on theories of indirect infringement.
V. Key Claim Terms for Construction
- The Term: "selectively control said plurality of RCLs to position the sets of railcars" (from '148 Patent, Claim 1)
- Context and Importance: This term is central to the infringement analysis, as it defines the ultimate output of the claimed system. Practitioners may focus on this term because its construction will determine whether providing data and analytics is sufficient to meet the claim, or if direct, automated command-and-control of locomotive hardware is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract and summary describe the function at a high level, stating the server is "configured to selectively control the plurality of RCLs to position the sets of railcars," without mandating a specific mechanism. (’148 Patent, Abstract). This language could support an interpretation where providing the critical intelligence for a user to execute control meets the limitation.
- Evidence for a Narrower Interpretation: The detailed description and figures disclose specific modules for this function, such as a "locomotive module 131" configured to "control movement of locomotives" and a "communications module 133" that "builds control messages for the VTOS head end unit." (’148 Patent, Fig. 3; col. 5:19-34). This may support a narrower construction requiring a more direct, integrated electronic control link to the locomotive.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant knowingly encourages and instructs customers on how to use the Accused Systems in an infringing manner. (Compl. ¶30). The factual basis cited includes Defendant’s publicly available "instructions, tutorials, and materials (e.g., source code)" and website content describing "how to build a yard management system." (Compl. ¶¶31, 20).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the Asserted Patents. The complaint claims Defendant had knowledge no later than December 4, 2024, upon receiving a notice letter regarding the ’148 Patent. (Compl. ¶42). The allegation of willfulness is further supported by the claim that Defendant has not ceased its allegedly infringing activities after receiving notice. (Compl. ¶47).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional scope: does Defendant’s software platform, which provides data processing and workflow automation, meet the claim limitation of "selectively control[ling]" physical locomotives to "position" railcars? The case may turn on whether providing the intelligence for control is legally equivalent to performing the control itself.
- A key evidentiary question will be one of system integrity and attribution: does Defendant itself make, use, or sell a complete, infringing "control system," or does it provide a non-infringing software tool that its customers combine with their own hardware and operational methods to create a potentially infringing system? The resolution of this question will likely determine the viability of the direct infringement claim versus the indirect infringement claims.
- A third central question relates to knowledge and intent for indirect infringement: what evidence will emerge in discovery to show that Defendant, by providing developer tools and tutorials, specifically intended for its customers to build and operate systems that would practice every element of the patented claims, including the physical control and positioning of locomotives?