DCT
1:25-cv-01356
Air Lift Co v. Bag Riders LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Air Lift Company (Michigan)
- Defendant: Bag Riders, LLC (Vermont)
- Plaintiff’s Counsel: McDonald Hopkins PLC
- Case Identification: 1:25-cv-01356, W.D. Mich., 11/04/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant, a former authorized distributor of Plaintiff's products, expressly consented to venue in the Western District of Michigan in the parties' Distributor Agreement.
- Core Dispute: Plaintiff alleges that Defendant’s aftermarket air suspension management system infringes a patent related to a modular control system for vehicle suspension.
- Technical Context: The technology concerns electronic control systems for aftermarket vehicle air suspensions, a market segment focused on vehicle customization for performance and aesthetics.
- Key Procedural History: The complaint alleges the parties had a prior business relationship under a Distributor Agreement, which Plaintiff terminated one day before filing suit. Plaintiff alleges it sent a cease-and-desist letter regarding the alleged infringement approximately five weeks before filing the complaint, putting Defendant on notice.
Case Timeline
| Date | Event |
|---|---|
| 2006-10-30 | ’506 Patent Priority Date |
| 2014-12-14 | Distributor Agreement entered into between Plaintiff and Defendant |
| 2016-09-13 | ’506 Patent Issue Date |
| 2017-10-01 | (At least by) Plaintiff begins marking patented products with ’506 Patent number |
| 2025-01-01 | (Early 2025) Defendant's marketing materials allegedly begin describing infringing features |
| 2025-08-27 | Defendant allegedly posts disparaging video to YouTube |
| 2025-09-26 | Plaintiff sends Cease-and-Desist letter to Defendant |
| 2025-11-03 | Plaintiff terminates Distributor Agreement with Defendant |
| 2025-11-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,440,506 - "Modular Control System," Issued September 13, 2016
The Invention Explained
- Problem Addressed: The patent's background section describes the need for flexibility in the aftermarket vehicle systems industry (U.S. Patent No. 9,440,506, col. 8:51-56). Unlike original equipment manufacturer (OEM) systems engineered for a single vehicle, aftermarket systems must be adaptable to multiple vehicles and system variations, which traditionally required separate, costly engineering for each configuration (ʼ506 Patent, col. 8:56-64). The patent also notes that customers desire simple interfaces and installations, while suppliers want to use common components to reduce costs and offer expansion capabilities (ʼ506 Patent, col. 9:1-8).
- The Patented Solution: The invention is a modular control system architecture that allows a single driver interface unit to communicate with and control multiple, separate aftermarket control units (e.g., for air suspension, dampers, etc.) through either a wired or wireless connection (ʼ506 Patent, Abstract). This "open architecture" is designed to allow for flexible configurations (e.g., one, two, or four-point suspension control) and future expansion by adding more control units, all managed through a central interface which can be a standalone device or integrated into a vehicle's existing head unit (ʼ506 Patent, col. 9:11-24; col. 10:10-15; Fig. 37).
- Technical Importance: The approach sought to standardize control architecture in the fragmented aftermarket vehicle modification industry, enabling manufacturers to develop a common platform of interchangeable components rather than bespoke systems for each application. (ʼ506 Patent, col. 8:60-68).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶44).
- The essential elements of claim 1 include:
- A vehicle head unit with a user interface.
- A vehicle engine control unit (VECU) in communication with the head unit.
- An aftermarket control unit that communicates with the head unit and is connected to an aftermarket system (e.g., an air suspension system).
- The head unit relays a control signal to the aftermarket control unit based on user interaction.
- The aftermarket control unit generates and sends a return signal to the head unit, representing a system characteristic like air pressure or suspension height.
- The aftermarket control unit itself contains a housing with air passages, an air pressure sensor, and multiple valves.
- The user interface on the head unit displays information based on the output from the air pressure sensor.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused product is the "Bag Riders' PRO Control System" (Compl. ¶6).
Functionality and Market Context
- The complaint describes the PRO Control System as an aftermarket electronic management system for vehicle air suspension (Compl. ¶43). The system is comprised of a "Head Unit Controller" with a digital user interface, a manifold/ECU (Electronic Control Unit), and associated wiring and plumbing that connects to a vehicle's power sources (battery and ignition) and the air suspension components (air springs, compressors, tank) (Compl. ¶44, p. 10). A wiring and plumbing diagram provided in the complaint illustrates the system's architecture, showing how the controller, manifold, and suspension hardware are interconnected. (Compl. ¶44, p. 10). The head unit controller displays real-time air pressure for each corner of the vehicle's suspension (Compl. ¶44, p. 12).
- The complaint alleges the PRO Control System is a direct competitor to Plaintiff's own "Air Lift Performance 3H and 3P Air Management Systems," which embody the ’506 Patent (Compl. ¶6, ¶8).
IV. Analysis of Infringement Allegations
9,440,506 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a vehicle head unit mounted in the vehicle and having a user interface; | The accused "Head Unit Controller" is mounted in the vehicle and has a digital user interface. A photograph shows the controller mounted in a vehicle's interior. (Compl. ¶44, p. 10). | ¶44 | col. 24:26-29 |
| a vehicle engine control unit in communication with said vehicle head unit; | The system's connection to the vehicle’s ignition (IGN +) and battery (+12 V Batt) allegedly places the head unit controller in communication with the vehicle's engine control unit. | ¶44 | col. 25:6-9 |
| an aftermarket control unit in communication with said vehicle head unit and at least one aftermarket system connected to the vehicle, | The accused manifold is identified as an aftermarket control unit that is in communication with the head unit controller and connected to the aftermarket air suspension system. | ¶44 | col. 25:10-14 |
| wherein upon interaction of a user at said user interface, said vehicle head unit relays a system control signal to said at least one aftermarket control unit, | A user pressing a button on the head unit controller allegedly sends a command signal to the manifold to inflate or deflate the air springs. | ¶44 | col. 25:15-18 |
| wherein said at least one aftermarket control unit generates a return signal representative of a characteristic of said aftermarket system and communicates said return signal to said head unit; | The manifold allegedly reads pressure data from its sensors and transmits those values back to the head unit controller. | ¶44 | col. 25:19-22 |
| wherein said aftermarket system is an air suspension system, wherein said characteristic...is one of an air pressure or a suspension height, | The accused aftermarket system is alleged to be an air suspension system, and the head unit displays the characteristic of air pressure. The complaint includes a photo of the head unit displaying four pressure values. (Compl. ¶44, p. 12). | ¶44 | col. 25:23-25 |
| wherein said aftermarket air control unit includes a housing with a plurality of air passages, an air pressure sensor...a plurality of valves...said aftermarket control unit controlling said valves... | The accused manifold is alleged to be a housing with internal air passages, pressure sensors, and multiple valves that it controls in response to signals from the head unit. | ¶44 | col. 25:26-34 |
| wherein said user interface on said vehicle head unit displays information representative of said output representative of said air pressure. | The user interface on the accused head unit controller allegedly displays real-time air pressure for each circuit, representing the outputs from the manifold's sensors. | ¶44 | col. 25:31-34 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused standalone "Head Unit Controller" meets the definition of a "vehicle head unit" as used in the patent. The specification discloses embodiments where the interface is integrated into a vehicle’s multifunction OEM infotainment system (ʼ506 Patent, Fig. 37), which raises the question of whether the claim term is limited to such integrated systems or also covers dedicated, single-purpose aftermarket controllers.
- Technical Questions: The complaint alleges that connecting to the vehicle's ignition and battery satisfies the limitation "a vehicle engine control unit in communication with said vehicle head unit." (Compl. ¶44, p. 10). This may raise the question of whether providing power and an ignition-on signal constitutes "communication" in the manner contemplated by the patent, which also describes more substantive data exchange, such as using vehicle speed from the VECU to adjust suspension settings (ʼ506 Patent, col. 25:10-14).
V. Key Claim Terms for Construction
The Term: "vehicle head unit"
Context and Importance: The definition of this term is critical because the accused product uses a dedicated, standalone controller, not an integrated OEM infotainment system. The infringement analysis depends on whether this standalone device can be considered a "vehicle head unit." Practitioners may focus on this term because the patent's own examples create potential ambiguity.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract refers more generally to a "user interface operable by the user to control the aftermarket system" without limiting it to an OEM unit (ʼ506 Patent, Abstract). Claim 1 itself only requires the unit be "mounted in the vehicle and having a user interface," a description which a standalone controller could meet (ʼ506 Patent, col. 25:5-6).
- Evidence for a Narrower Interpretation: The detailed description and Figure 37 explicitly depict a "vehicle head unit 1000" as a multi-function touchscreen dashboard display with icons for radio, climate, phone, and the aftermarket suspension system (ʼ506 Patent, Fig. 37; col. 25:35-47). This specific embodiment could be used to argue that a "vehicle head unit" is understood in the art as an integrated OEM system, not a single-purpose aftermarket controller.
The Term: "in communication with"
Context and Importance: The complaint alleges the "in communication with [a] vehicle engine control unit" limitation is met by connecting to the vehicle's ignition and battery. Whether this constitutes "communication" will be a key point of dispute. If the term requires substantive data exchange beyond a simple power/on signal, the infringement allegation could be challenged.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not specify the type or content of the communication. An argument could be made that an ignition signal, which communicates the engine's state (on/off) to the head unit, satisfies the plain meaning of the term.
- Evidence for a Narrower Interpretation: The specification discloses that the system may be "programmed to operate the...height control system, as a function of one or more parameters provided by the VECU," such as "vehicle speed, brake pressure and throttle position." (ʼ506 Patent, col. 25:7-14). This suggests that "communication" was contemplated as a data link for sharing vehicle performance parameters, a more complex interaction than receiving power.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant had knowledge of the ’506 Patent and intentionally induced infringement by end users through "instructions, promotional materials, videos, and other documentation." (Compl. ¶47). This allegation is supported by the claim that Defendant was a former distributor of Plaintiff's own patented products and thus had full knowledge of the patent (Compl. ¶47). The complaint also alleges inducement by selling the PRO Control System to distributors and dealers with the intent that they resell or install it for others (Compl. ¶48).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the ’506 Patent, gained from its status as an "Authorized Distributor" of Plaintiff's patented products which have been marked since at least October 2017 (Compl. ¶23, ¶24, ¶47). Willfulness is further alleged based on Defendant's continued infringement after receiving a cease-and-desist letter on September 26, 2025 (Compl. ¶38, ¶40, ¶49).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "vehicle head unit," which the patent specification illustrates as an integrated OEM infotainment screen, be construed to cover the accused product's dedicated, single-purpose aftermarket controller?
- A second key issue will be one of technical scope: does a connection to a vehicle’s ignition and battery sources satisfy the claim requirement that the head unit be "in communication with" the vehicle engine control unit, or does the patent’s disclosure of using VECU data like vehicle speed implicitly require a more substantive data exchange?