DCT
0:22-cv-02749
Redmon Jeang LLC v. TurnSignl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Redmon Jeang LLC (Texas)
- Defendant: TurnSignl, Inc. (Delaware) and TurnSignl Foundation (Minnesota)
- Plaintiff’s Counsel: Fox Rothschild LLP; Munck Wilson Mandala, LLP
- Case Identification: 0:22-cv-02749, D. Minn., 11/14/2022
- Venue Allegations: Venue is alleged to be proper in the District of Minnesota because Defendants have their principal place of business in the state and have committed alleged acts of infringement, including offering to sell the accused product, within the District.
- Core Dispute: Plaintiff alleges that Defendants’ TurnSignl mobile application and service, which provides on-demand video access to attorneys during traffic stops, infringes three patents related to mobile legal counsel systems.
- Technical Context: The technology at issue involves using a mobile device application to connect a user (typically a driver) with a remote attorney in real-time to observe and provide guidance during a police encounter.
- Key Procedural History: The patents-in-suit were all recently issued in September and November of 2022. The instant filing is a First Amended Complaint, filed less than a week after the issuance of two of the three asserted patents. No other procedural events are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2016-07-19 | Priority Date for ’395, ’861, and ’862 Patents |
| 2022-09-13 | U.S. Patent No. 11,443,395 Issues |
| 2022-11-08 | U.S. Patent No. 11,494,861 Issues |
| 2022-11-08 | U.S. Patent No. 11,494,862 Issues |
| 2022-11-14 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,443,395 - "Mobile Legal Counsel System and Method" (issued Sep. 13, 2022)
The Invention Explained
- Problem Addressed: The patent background describes the "deeply-rooted problem" of "police brutality and killing" and states a desire to "defuse and de-escalate tense situations between the police and members of the general public" ('395 Patent, col. 1:50-53, col. 2:3-5).
- The Patented Solution: The invention is a system that uses technology to introduce a licensed attorney into a police encounter to serve as a "live observer, witness, and intermediary" ('395 Patent, col. 2:9-11). The system comprises a mobile device with an app that, upon command, communicates with a remote server. The server automatically determines the vehicle's location and jurisdiction, identifies a suitable lawyer, and notifies them, enabling a bi-directional audio and video session between the driver and the lawyer ('395 Patent, Abstract; Fig. 2).
- Technical Importance: The technology proposes an immediate, on-demand method for introducing third-party legal oversight into potentially volatile real-world encounters, using ubiquitous mobile and network technology ('395 Patent, col. 2:5-11).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 and states that this claim is exemplary (Compl. ¶¶22, 23).
- Independent Claim 1 requires:
- A mobile device with a video camera and display screen for use in a vehicle.
- A remote server and a database storing information about lawyers licensed in at least one jurisdiction.
- The mobile device executing an application that, upon command, communicates with the remote server.
- The remote server being configured to automatically determine the vehicle's location, identify the associated jurisdiction, identify a lawyer licensed in that jurisdiction, and "immediately automatically directly notify" that lawyer.
- The system enabling bi-directional audio and video communication, with the lawyer's image streamed to the mobile device and the mobile device's video streamed to the lawyer and stored in the remote database.
U.S. Patent No. 11,494,861 - "Mobile Legal Counsel System and Method" (issued Nov. 8, 2022)
The Invention Explained
- Problem Addressed: The patent addresses the same problem of de-escalating tense police encounters through technological intervention, citing the threat of "police brutality and shooting" ('861 Patent, col. 2:23-24).
- The Patented Solution: The system is described for a "user subscriber" and adds a specific sequence of server-side actions to the process ('861 Patent, col. 5:50-51). After the server identifies a lawyer, it transmits a notification, must "receive an acceptance of legal representation engagement" from the lawyer's computing device, and only then does it "automatically and immediately set up a video communication session" ('861 Patent, col. 8:51-9:19).
- Technical Importance: This patent builds on the core concept by claiming a more defined handshake protocol between the system and the remote attorney, including a formal acceptance step before establishing the communication link ('861 Patent, col. 8:51-56).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 and states that this claim is exemplary (Compl. ¶¶37, 38).
- Independent Claim 1 requires:
- A system with a remote server/database, video camera, and display screen.
- A mobile device that, upon command, communicates its location to the server.
- The server configured to search lawyer records, identify a lawyer for the corresponding jurisdiction, and transmit a notification.
- The server configured to "receive an acceptance of legal representation engagement" from the lawyer's device.
- Following acceptance, the server automatically sets up a bi-directional video session between the user and lawyer.
- During the session, video is streamed in both directions and stored in the remote database.
U.S. Patent No. 11,494,862 - "Mobile Legal Counsel System and Method" (issued Nov. 8, 2022)
- Technology Synopsis: The ’862 Patent claims a mobile lawyer system initiated by a "one-click command" from the user ('862 Patent, col. 12:1-4). Like the related patents, it aims to de-escalate police encounters by connecting a user to a remote attorney via a mobile app, server, and bi-directional video stream to provide real-time observation and legal guidance ('862 Patent, Abstract). The claim structure is similar to the '861 patent, including a step of receiving an "acceptance of engagement" from a selected lawyer.
- Asserted Claims: Independent Claim 1 is asserted as exemplary (Compl. ¶¶52, 53).
- Accused Features: The complaint alleges the TurnSignl system infringes by providing a system that, upon a user command, uses a mobile app to communicate the user's location to a remote server, which then identifies and connects the user to a lawyer for a bi-directional video session (Compl. ¶¶54-57).
III. The Accused Instrumentality
Product Identification
- The "TurnSignl App" and the associated "TurnSignl mobile application system" (collectively, the "Accused System") (Compl. ¶¶15, 23).
Functionality and Market Context
- The complaint describes the Accused System as an "on-demand, real-time service that provides 24/7 legal guidance from an attorney to drivers" during traffic stops or car accidents (Compl. ¶17).
- Functionality is initiated "at the press of a button or voice command," which allows the user to "Connect in Real-Time," "Start Recording," and "Video Chat with Attorney" (Compl. ¶¶16, 17).
- A recording of the encounter is "immediately saved to your personal cloud" (Compl. ¶16).
- The service is offered via a subscription model ($6.99/month or $60/year), with a free version available through the non-profit TurnSignl Foundation (Compl. ¶18).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'395 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mobile device having at least one video camera configured for mounting inside the passenger compartment of a vehicle and capture video images of a driver of the vehicle; the mobile device further incorporating a display screen viewable by the driver of the vehicle | The Accused System includes a mobile device with a video camera and a display screen, configured for use in a vehicle to capture video of the driver. | ¶24 | col. 2:15-24 |
| a remote server and a database configured to store information about a plurality of lawyers licensed in at least one jurisdiction | The Accused System includes a remote server and a database storing information about lawyers licensed in at least one jurisdiction. | ¶25 | col. 2:38-48 |
| the mobile device executing a mobile application configured, upon command from the driver... to communicate with the remote server, wherein the remote server is configured to automatically determine a location... identify a jurisdiction... identify at least one lawyer... and immediately automatically directly notify the at least one identified lawyer for assistance | The Accused System includes a mobile application that, on command, communicates with a remote server configured to automatically determine location, identify the jurisdiction and a licensed lawyer, and immediately notify the lawyer. | ¶26 | col. 4:31-42 |
| the display screen... configured to live-stream a video image of the... lawyer... and the at least one video camera is configured to automatically live-stream video... for viewing by the... lawyer and for storage in the remote database, where the... mobile device being configured to automatically enable bi-directional audio and video communication... | The Accused System includes a display screen to live-stream video of the lawyer and a camera to live-stream video to the lawyer and for storage, enabling bi-directional audio/video communication. | ¶27 | col. 4:56-65 |
'861 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a remote server and a remote database; at least one video camera; at least one display screen; a mobile device executing a mobile application... configured, upon command from the user subscriber, to automatically and immediately communicate a current location of the mobile device to the remote server | The Accused System is a mobile lawyer system with a server, database, camera, and display, and includes a mobile app that upon command communicates its location to the server. | ¶¶39, 40 | col. 5:50-60 |
| the remote server being configured to: automatically search a plurality of information records... automatically identify at least one lawyer licensed in a jurisdiction that correspond to the current location of the mobile device | The remote server is configured to automatically search its database to identify a lawyer licensed in the jurisdiction corresponding to the mobile device's location. | ¶41 | col. 5:61-6:2 |
| automatically transmit at least one notification to at least one computing device associated with the identified at least one lawyer | The remote server is configured to automatically transmit a notification to the identified lawyer's computing device. | ¶41 | col. 8:49-51 |
| receive an acceptance of legal representation engagement from the computing device associated with the at least one lawyer | The remote server is configured to receive an acceptance of legal representation engagement from the lawyer's computing device. | ¶41 | col. 8:51-53 |
| automatically and immediately set up a video communication session between the... lawyer and the mobile device, so that live video data of the user subscriber is automatically transmitted to the... lawyer and live video data of the... lawyer is automatically transmitted to the display screen | The remote server is configured to automatically set up a video session, transmitting the user's video to the lawyer and the lawyer's video to the user's display screen. | ¶41 | col. 8:54-63 |
| during the video communication session, the... display screen being configured to stream live video data of the... lawyer, and the... video camera being configured to capture and live-stream video of the user subscriber... for viewing by the... lawyer and for storage in the remote database | During the session, the system's display screen streams the lawyer's video, and its camera streams the user's video to the lawyer for viewing and to the remote database for storage. | ¶42 | col. 9:11-19 |
- Identified Points of Contention:
- Technical Questions: The complaint's infringement allegations track the claim language in a conclusory manner. A central point of contention will be whether the Accused System's actual technical implementation performs the specific functions as claimed. For example, what evidence demonstrates that the server's process for selecting and notifying a lawyer is fully "automatic" and "direct" ('395 Patent), as opposed to involving manual selection or an intermediate dispatch queue?
- Scope Questions: The claims recite specific sequences of events (e.g., notify, then receive acceptance, then set up session). The infringement analysis will depend on whether the Accused System follows the same sequence. A key question for the '861 and '862 patents is what technical action constitutes "an acceptance of legal representation engagement." Does the act of a lawyer joining a video call meet this limitation, or does the claim require a more formal, explicit acceptance step?
V. Key Claim Terms for Construction
For the ’395 Patent:
- The Term: "immediately automatically directly notify"
- Context and Importance: This sequence of adverbs is central to defining the required speed, automation, and communication path for contacting the lawyer. Practitioners may focus on this term because the defense could argue that the TurnSignl system involves intervening steps, human operators, or indirect notifications (e.g., a general broadcast to available attorneys) that fall outside the scope of "immediately," "automatically," and "directly."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's flowchart shows a direct arrow from "IDENTIFY SUITABLE LAWYER(S)" to "SEND ALERT TO LAWYER(S)," which may support an interpretation that no intervening functional steps are required ('395 Patent, Fig. 2).
- Evidence for a Narrower Interpretation: The plain meaning of "directly" suggests a point-to-point communication without intermediaries. The repeated use of both "immediately" and "automatically" could be argued to impose a high standard of both speed and lack of human intervention, potentially narrowing the term to exclude systems with any processing delays or manual review.
For the ’861 Patent:
- The Term: "receive an acceptance of legal representation engagement"
- Context and Importance: This term's construction is critical because it defines a specific legal and technical event that must occur before the video session is established. The case may turn on whether the action of an attorney clicking a "connect" or "join call" button in the accused app constitutes an "acceptance of... engagement."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's stated purpose is to allow a lawyer to "provide live legal guidance to the user" ('861 Patent, col. 2:18-19). Plaintiff may argue that any volitional act by the lawyer to connect with the user, knowing the purpose is to provide such guidance, constitutes an implied acceptance of a limited-scope engagement.
- Evidence for a Narrower Interpretation: The phrase "legal representation engagement" has a specific meaning in the legal field that typically implies the formation of an attorney-client relationship. A defendant could argue this requires more than simply joining a video call, such as an explicit confirmation screen with disclaimer language. The specification does not describe a specific embodiment of this "acceptance" step, leaving its meaning open to construction.
VI. Other Allegations
- Indirect Infringement: The complaint states that Plaintiff "expressly reserves the right to investigate and allege" induced and contributory infringement (Compl. ¶¶29, 44, 59). While no formal count of indirect infringement is made, the complaint's description of Defendants' website instructing users on how to use the app could form the basis for a future inducement claim (Compl. ¶¶15-17).
- Willful Infringement: The complaint alleges that Defendants had knowledge of the patents "at minimum, as a result of the filing of this lawsuit" (Compl. ¶¶28, 43, 58). This allegation currently only supports a claim for post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof: The complaint's allegations are conclusory. The case will likely depend on what discovery reveals about the specific architecture and workflow of the TurnSignl system. Does its server-side logic, lawyer notification protocol, and connection process technically operate in the specific, automated, and sequential manner required by the asserted claims?
- A second key issue will be one of definitional scope: The dispute may turn on the construction of key claim terms. Can the phrase "acceptance of legal representation engagement" ('861 and '862 Patents) be construed to cover the act of a lawyer joining a video call, or does it require a more formal, explicit confirmation that is absent from the accused system? Similarly, can the accused system's notification method be considered a "directly notify" function as required by the '395 Patent?