Crispify Ltd v. Bosch LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Crispify LTD (Israel)
  • Defendant: Robert Bosch LLC (United States)
  • Plaintiff’s Counsel: Whitestone Law
• Case Identification: 2:24-cv-10570, E.D. Mich., 03/06/2024
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Michigan based on Defendant's corporate headquarters and facilities related to the design, engineering, and sale of the accused products being located within the district.
• Core Dispute: Plaintiff alleges that Defendant’s RideCare Insight vehicle air quality monitoring system infringes a patent related to sensing and analyzing in-cabin air quality to detect smoking.
• Technical Context: The technology concerns in-vehicle sensor systems that monitor airborne particulates to provide real-time data on air quality, a feature of growing importance for fleet management and shared mobility services.
• Key Procedural History: The complaint alleges that Defendant was made aware of the patent-in-suit prior to the lawsuit and continued its allegedly infringing activities, forming the basis for a willfulness claim.

Case Timeline

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

U.S. Patent No. 11,731,486 - System for Monitoring and/or Controlling the Air Quality in a Vehicle

• Issued: August 22, 2023.

The Invention Explained

• Problem Addressed: The patent's background section identifies that vehicle cabins are small, enclosed spaces where air quality can be rapidly affected by factors like outside pollution, smoking, or the release of volatile organic compounds from interior materials, and that passengers lack means to monitor this air quality in real-time (ʼ486 Patent, col. 1:24-34).
• The Patented Solution: The invention is a control unit that receives sensing data from within a vehicle cabin, processes that data to generate a unified "calculated cabin's air quality data," and then outputs this information. A key feature is the generation of a "smoking score" by analyzing the temporal profile of the sensor data to recognize patterns indicative of smoking (ʼ486 Patent, Abstract; col. 4:30-35). This data can be displayed to a user or used to automatically operate the vehicle's climate control system (ʼ486 Patent, col. 1:39-53).
• Technical Importance: The technology provides a method for specifically identifying and quantifying smoking events inside a vehicle, distinguishing them from other air quality changes, for monitoring and control purposes (ʼ486 Patent, col. 4:15-29).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a control unit) and 14 (a method).
• Independent Claim 1 (Control Unit) requires:
  • An input module to receive sensing data indicating size, quantity, and concentration of particulate matter.
  • A processing module that processes the data to generate a "smoking score."
  • An output module to output the calculated air quality data.
  • The processing module is further configured to analyze a "temporal profile" of the sensing data and recognize "patterns" indicative of smoking to determine the smoking score.
• Independent Claim 14 (Method) requires the steps of:
  • Receiving sensing data indicating size, quantity, and concentration of particulate matter.
  • Processing the data to generate calculated air quality data including a "smoking score."
  • Outputting the calculated air quality data.
  • Analyzing a "temporal profile" of the sensing data and recognizing "patterns" indicative of smoking to determine the smoking score.
• The complaint also asserts dependent claims 2, 3, 4, 5, 8, 9, 13, 15, and 18 (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

• The Bosch RideCare Insight systems and components (Compl. ¶13).

Functionality and Market Context

• The complaint describes the RideCare Insight product as a system that uses an "intelligent sensor box" mounted inside a vehicle to monitor air quality, including the detection of smoke (Compl. ¶18, p. 7). This sensor box is shown mounted on a vehicle's windshield as a retrofit solution (Compl. p. 7). Data from the sensor is allegedly post-processed in a "backend using intelligent algorithms" to furnish a time stamp and duration for each smoking occurrence, which is then made available to customers via a dashboard (Compl. ¶18, p. 7; p. 9). The system is marketed as a way to "Ensure smoke-free vehicles," providing evidence for potential claims against renters or users (Compl. p. 7).

IV. Analysis of Infringement Allegations

’486 Patent Infringement Allegations (Claim 1 - Control Unit)

’486 Patent Infringement Allegations (Claim 14 - Method)

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the accused system's output (e.g., a "Total smoke" concentration value and a graphed timeline) meets the definition of the claim term "smoking score". The defense may argue its system provides raw or minimally processed data, while the patent claims a more specific, calculated "score."
  • Technical Questions: The infringement case may depend on the specific nature of the "intelligent algorithms" used by the accused product (Compl. p. 9). A key technical question is what evidence shows that the system performs the claimed function of "recognizing patterns" within a "temporal profile," as opposed to a simpler function like detecting when particulate concentration exceeds a predefined threshold.

V. Key Claim Terms for Construction

• The Term: "smoking score"

  • Context and Importance: This term appears in both asserted independent claims and appears to be a neologism central to the patent's contribution. The outcome of the case may hinge on whether the data output by the RideCare Insight system (e.g., "Total smoke 343,211.8 µg/m³" (Compl. p. 10)) constitutes a "smoking score".
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself defines the term broadly as being "indicative of levels of smoking residues or smoking smell being monitored in the cabin" (ʼ486 Patent, col. 12:37-39). This could support an argument that any quantitative output related to smoke meets the limitation.
    • Evidence for a Narrower Interpretation: The specification suggests the "smoking score" can be a "level-based presentation" (ʼ486 Patent, col. 4:26-29), which might be argued to require a specific, qualitative or tiered output (e.g., "low," "high") rather than just a concentration measurement.

• The Term: "analyzing temporal profile... recognizing patterns therein"

  • Context and Importance: This phrase describes the core analytical process for determining the "smoking score" and distinguishes the invention from simple threshold-based alerts. Practitioners may focus on this term because infringement requires showing that the accused system's algorithm performs this specific type of analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff could argue that any analysis of sensor data over a period of time, as depicted in the complaint's dashboard graph (Compl. p. 9), inherently involves analyzing a "temporal profile."
    • Evidence for a Narrower Interpretation: The specification states the processing module "identifies variations in the first data over time and classifies these variations to smoking events" (ʼ486 Patent, col. 4:33-35). A defendant might argue this requires a more sophisticated classification logic than what is evidenced in the complaint, which simply shows a concentration curve.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Bosch provides the accused products "with instructions, which are used to practice the patented methods" (Compl. ¶22). It also alleges contributory infringement by asserting that Bosch supplies a "material part of an infringing method and/or system" that is not a staple article of commerce and is incapable of substantial non-infringing use (Compl. ¶15).
• Willful Infringement: The complaint alleges that "Defendant has been made aware of the patent-in-suit but has continued to infringe and has refused to cease its infringing actions" (Compl. ¶1). This alleged pre-suit knowledge forms the basis of the claim for willful infringement (Compl. ¶24).

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

• A central issue will be one of definitional scope: Does the accused product's output, which the complaint shows as a quantitative particulate measurement ("Total smoke") and a concentration-over-time graph, satisfy the specific claim requirement of a calculated "smoking score"?
• A key evidentiary question will be one of technical operation: What discovery will reveal about the "intelligent algorithms" of the RideCare Insight backend? The case may turn on whether Plaintiff can prove that the system performs the claimed method of "analyzing a temporal profile" to "recognize patterns", or if Defendant can show its system employs a simpler, non-infringing detection method such as threshold comparison.