Pivot Solutions LLC v. Sea Machines Robotics Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pivot Innovations, LLC (Wyoming)
  • Defendant: Sea Machines Robotics, Inc. (Delaware)
  • Plaintiff’s Counsel: Lambert Shortell & Connaughton
• Case Identification: 1:25-cv-13081, D. Mass., 10/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendant maintains a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s autonomous maritime navigation and situational awareness systems infringe a patent related to acquiring and reporting vehicle traffic flow data.
• Technical Context: The technology at issue involves using sensors to monitor vehicles at different points, calculating their rate of travel between those points, and reporting the data for purposes such as traffic analysis or automated violation detection.
• Key Procedural History: The complaint does not mention any prior litigation, post-grant proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2008-09-22	’724 Patent Priority Date
2017-01-24	’724 Patent Issue Date
2025-10-21	Complaint Filing Date

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

U.S. Patent No. 9,552,724 - A method for vehicle traffic flow data acquisition and reporting for onboard vehicle navigation

• Patent Identification: U.S. Patent No. 9,552,724, “A method for vehicle traffic flow data acquisition and reporting for onboard vehicle navigation,” issued January 24, 2017 (’724 Patent).

The Invention Explained

• Problem Addressed: The patent describes the societal costs of traffic congestion and the limitations of then-current traffic reporting methods, which often lacked real-time accuracy. It also identifies the need for a more efficient and safer way to detect traffic violations than conventional police patrols. (’724 Patent, col. 1:36-54, col. 2:11-21).
• The Patented Solution: The invention proposes a method and system where imaging systems are placed at different locations along a "route of travel, such as a highway, byway or waterway." These systems capture data of multiple vehicles, individually identify them, and calculate the elapsed time for each vehicle to travel between the locations. From this, a rate of travel is computed and can be broadcast to subscribers (e.g., other vehicles with navigation systems) or used by law enforcement to automatically detect speeding violations. (’724 Patent, Abstract; col. 3:11-25; Fig. 1).
• Technical Importance: The described technology aimed to provide granular, real-time traffic flow data for individual vehicles, an improvement over generalized congestion reports, and to enable automated traffic enforcement. (’724 Patent, col. 2:6-11).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 of the ’724 Patent (Compl. ¶14, ¶37).
• Independent Claim 1 requires:
  • acquiring, at a first location, data of multiple vehicles traveling through the first location, wherein said data is acquired from a source not traveling in the vehicle;
  • individually identifying the multiple vehicles from the first location data;
  • acquiring, at a second location, data of said multiple vehicles traveling through the second location;
  • determining an elapsed time of travel for the individually identified vehicles traveling through the two locations;
  • computing a rate of travel for each of the individually identified multiple vehicles based upon the elapsed time of travel; and
  • broadcasting the rate of travel for at least one of the individually identified multiple vehicles to a subscriber, which further comprises additionally broadcasting the acquired data to the subscriber.
• The complaint alleges infringement of "one or more claims" but focuses its specific allegations on Claim 1 (Compl. ¶1, ¶22).

III. The Accused Instrumentality

Product Identification

• The SM300 AI Powered Vessel Vision system (“SM300”) (Compl. ¶14, ¶21).

Functionality and Market Context

• The complaint describes the SM300 as a system that provides "maritime situational awareness" for a user's vessel. It employs sensors such as an "AI-RIS camera-based computer vision sensor," LIDAR, Radar, and AIS to gather information about surrounding marine traffic, including nearby vessels, objects, and obstacles. This data is processed and transmitted to a shipboard display or a remote shore-based center to enable "collision detection, avoidance, and dynamic path planning." (Compl. ¶21). The complaint does not provide sufficient detail for analysis of the product's market positioning or commercial importance.
  No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit B, but this exhibit was not included in the provided court filing (Compl. ¶26). The following is a summary of the narrative infringement theory presented in the complaint's text.

The complaint alleges that Defendant's SM300 system performs the method of Claim 1 of the ’724 Patent (Compl. ¶22). The theory suggests that the SM300, installed on a user's vessel, uses its array of sensors (e.g., camera, LIDAR, Radar, AIS) to acquire data about surrounding marine traffic (the "multiple vehicles") (Compl. ¶21). As the user's vessel and the surrounding traffic move, the SM300 allegedly acquires data at different points in time and space, corresponding to the claimed "first location" and "second location." The complaint asserts that the system processes this collected information and transmits it to an onboard user or shoreside operator (the "subscriber") for situational awareness, collision avoidance, and path planning, which allegedly constitutes the claimed steps of computing and broadcasting a rate of travel (Compl. ¶21).

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise from applying a patent primarily described in the context of land-based highway traffic to a maritime navigation system. This raises the question of whether the term "vehicle" as used in the patent, which discusses automobiles and license plates, can be construed to read on the marine vessels tracked by the accused SM300 system (’724 Patent, col. 4:1-3). Further, a question exists regarding the claimed "first location" and "second location." The patent specification primarily illustrates fixed data acquisition points along a road, whereas the accused system is a mobile sensor platform on one vessel tracking other vessels (’724 Patent, Fig. 1). The interpretation of whether this mobile architecture meets the limitations of the claims will likely be a key issue.
  • Technical Questions: Evidentiary questions may focus on how the SM300 system technically functions. For example, what evidence does the complaint provide that the SM300's situational awareness features perform the specific step of "computing a rate of travel" for other vessels, as opposed to simply tracking their position and vector for collision avoidance? (Compl. ¶21). Additionally, the analysis may examine whether the system's use of sensors like AIS, which broadcasts unique vessel identifiers, meets the "individually identifying" limitation of the claim.

V. Key Claim Terms for Construction

The Term: "vehicle"

• Context and Importance: The construction of this term is fundamental to the infringement case. Practitioners may focus on this term because the patent’s specification is replete with examples related to cars, highways, and motorists, while the accused product operates exclusively in a maritime environment.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to land vehicles. The specification broadens the potential environment by stating the invention can be used along a "route of travel, such as a highway, byway or waterway" (’724 Patent, col. 3:15), which may support an interpretation that includes marine vessels.
  • Evidence for a Narrower Interpretation: The Background of the Invention section focuses entirely on the "interstate highway system," "automobiles," and "motorists" (’724 Patent, col. 1:36-41, 2:15-18). The detailed description also provides examples specific to land vehicles, such as identifying a vehicle by its license tag, which does not directly apply to ships (’724 Patent, col. 4:1-3).

The Term: "a source not traveling in the vehicle"

• Context and Importance: This term defines the required relationship between the sensor and the object being tracked. Its construction will determine whether the accused system's mobile architecture (a sensor on Ship A tracking Ship B) falls within the scope of a claim seemingly written for stationary sensors tracking moving cars.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain language of the claim could be interpreted to mean only that the data acquisition device is not physically installed on the vehicle being monitored. Under this reading, the SM300 system on a user's vessel is a "source not traveling in the" other vessels it tracks.
  • Evidence for a Narrower Interpretation: The patent's primary embodiment, illustrated in Figure 1 and described in the specification, shows stationary imaging systems "placed individually at different locations along a route of travel" (’724 Patent, col. 3:13-16). This context may support an argument that the "source" must be stationary relative to the route itself, not merely separate from the tracked vehicle.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating Defendant provides customers with hardware, software, and instructions that lead them to practice the claimed methods (Compl. ¶23, ¶40). It also alleges contributory infringement, asserting that Defendant supplies a material part of the infringing system that is not a staple article of commerce and is incapable of substantial noninfringing use (Compl. ¶24).
• Willful Infringement: Willfulness is alleged based on Defendant's purported "knowing infringement" and acting without a "good faith defense" (Compl. ¶34). The complaint also alleges inducement "subsequent to notice," suggesting knowledge of the patent (Compl. ¶23).

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

• A core issue will be one of definitional scope: can the term "vehicle," rooted in a patent specification focused on cars on highways, be construed to cover the marine vessels tracked by the accused maritime situational awareness system?
• Another central issue will be one of architectural mismatch: does the accused product—a mobile sensor platform on one vessel tracking other vessels—satisfy the claim requirements of acquiring data at a "first location" and a "second location" from a "source not traveling in the vehicle," when the patent's disclosure points heavily toward a system of stationary sensors along a fixed route?
• A key evidentiary question will be one of functional performance: does the accused system’s process of providing data for "collision detection, avoidance, and dynamic path planning" include the specific claimed steps of "computing a rate of travel" for other identified vessels and "broadcasting" that rate to a subscriber, or is there a fundamental difference in the technical operations performed?