DCT
2:19-cv-03050
Dale Progress Ltd v. Fued
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dale Progress, Ltd. (Republic of Korea)
- Defendant: Charles Fued d/b/a Rockville Audio (New York)
- Plaintiff’s Counsel: Gioconda Law Group PLLC
- Case Identification: 2:19-cv-03050, E.D.N.Y., 05/22/2019
- Venue Allegations: Venue is alleged to be proper in the Eastern District of New York because the Defendant's principal place of business is located in the district, and the Defendant allegedly transacts business and has committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle Android car receiver, which incorporates screen mirroring functionality, infringes patents related to a remote resource access interface for connecting a portable device to a secondary display and control system.
- Technical Context: The technology at issue involves mirroring a smartphone's display and user interface onto a vehicle's built-in infotainment screen, enabling control of the smartphone's applications through the vehicle's touchscreen.
- Key Procedural History: The complaint does not mention any prior litigation or post-grant proceedings. U.S. Patent No. 9,686,504 is a continuation of the application family that includes U.S. Patent No. 8,320,461. The complaint alleges that Defendant had notice of the patents at least as of the filing date of the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2008-02-20 | Priority Date for '504 and '461 Patents |
| 2012-11-27 | U.S. Patent No. 8,320,461 Issued |
| 2017-06-20 | U.S. Patent No. 9,686,504 Issued |
| 2019-05-22 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,686,504 (the '504 Patent) - Remote Resource Access Interface Apparatus
- Patent Identification: U.S. Patent No. 9,686,504, "Remote Resource Access Interface Apparatus," issued June 20, 2017. (Compl. ¶10).
The Invention Explained
- Problem Addressed: The patent background describes that portable electronic devices like PDAs and mobile phones suffer from "manipulation inconvenience" due to their small display screens and keypads, limiting their usability. ('504 Patent, col. 1:35-44).
- The Patented Solution: The invention is a "remote resource access interface apparatus" (e.g., a vehicle head unit) that connects to a portable device to overcome its limitations. The apparatus receives video information from the portable device, adjusts it for its own (typically larger) display, and presents it to the user. It also detects user inputs, such as touches on its screen, and transmits corresponding information back to the portable device, allowing the user to control the portable device through the interface apparatus. The system is designed to manage communications and map inputs between two devices with different screen specifications and key sets. ('504 Patent, Abstract; col. 2:45-67; Fig. 1).
- Technical Importance: The described technology aims to improve the "extendibility and portability of a portable device" by allowing it to leverage the more user-friendly input/output hardware of an external system. ('504 Patent, col. 2:50-54).
Key Claims at a Glance
- The complaint asserts independent claim 2 and dependent claims 3-9, as well as independent claim 1. (Compl. ¶12).
- Independent Claim 2 recites the essential elements of the apparatus:
- A "touch input detection unit" to detect touch and generate position information.
- A "communication unit" to exchange key information, input information, and video information with a portable device.
- A "video output unit" with a screen specification different from the portable device, which displays adjusted video information.
- A "key advisor unit" to receive touch position information and output "supportable key information" to the video output unit.
- The claim further requires that the video is adjusted based on the portable device's supported resolutions and that touch position information is mapped to key values of the portable device.
U.S. Patent No. 8,320,461 (the '461 Patent) - Remote Resource Access Interface Apparatus
- Patent Identification: U.S. Patent No. 8,320,461, "Remote Resource Access Interface Apparatus," issued November 27, 2012. (Compl. ¶22).
The Invention Explained
- Problem Addressed: The '461 Patent addresses the same problem as the '504 Patent: the inconvenience of using portable devices with small screens and keypads. ('461 Patent, col. 1:25-30).
- The Patented Solution: The solution is an interface apparatus that initiates a connection with a portable device by sending a "connection establishment request message" containing its own screen resolution capabilities. In response, it receives the portable device's "supportable key information." After connection, the apparatus displays video from the portable device on its larger screen and maps its own key inputs to control the portable device, including through a "key configuration mode." ('461 Patent, Abstract; Fig. 3).
- Technical Importance: Like the '504 Patent, this invention seeks to enhance the user experience of a portable device by allowing it to be controlled via a more capable external interface. ('461 Patent, col. 2:40-44).
Key Claims at a Glance
- The complaint asserts independent claim 9 and claims 1, 2, 4-8, and 10. (Compl. ¶24).
- Independent Claim 9 recites the core elements:
- A "key input unit" to generate input key values.
- A "communication unit" that transmits a connection request and receives a response containing screen resolution and supportable key information from the portable device.
- A "video output unit" with a display screen larger than the portable device.
- A "key advisor unit" that extracts and outputs the supportable key information, displays keys of the portable device in a "key configuration mode," and receives corresponding inputs.
- The claim further requires that video resolution is adjusted, and that input key values from the apparatus are mapped to match the key values of the portable device.
III. The Accused Instrumentality
- Product Identification: The "Rockville AN7 2 Din 7" Android Car Receiver" is identified as the Accused Instrumentality, specifically when its "MirrorLink Functionality" is used. (Compl. ¶12, ¶24).
- Functionality and Market Context: The complaint alleges the Accused Instrumentality is an in-vehicle infotainment head unit. Its MirrorLink feature is described as providing "SmartPhone Mirroring with 2-Way Control," allowing a user to mirror an iPhone or Android phone's display onto the receiver's 7-inch touchscreen and control the phone's apps from the receiver. (Compl. ¶7). A diagram from MirrorLink.com, included in the complaint, illustrates the system architecture comprising a "MirrorLink Server" (the phone) and a "MirrorLink Client" (the car infotainment system). (Compl. p. 7). The complaint alleges that the accused product's use of this MirrorLink technology provides the infringing remote resource access. (Compl. ¶7). A screenshot from a product manual shows the user interface for connecting a phone. (Compl. p. 8).
IV. Analysis of Infringement Allegations
'504 Patent Infringement Allegations
| Claim Element (from Independent Claim 2) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a touch input detection unit configured to detect touch input on a display screen and to generate touch position information on a display screen | The Accused Instrumentality is alleged to have a touchscreen display that detects user touch for "2-Way Control" and handles this input via "key and pointer events" in the MirrorLink protocol. | ¶8, ¶20 | col. 4:26-36 |
| a communication unit configured to receive supportable key information from a compatible portable device... transmit input key information to the portable device and to receive video information... | The receiver allegedly establishes a connection with a smartphone via MirrorLink, receiving video for mirroring and transmitting user touch inputs back to the phone to control applications. | ¶9, ¶20 | col. 4:8-15 |
| a video output unit... having a display screen having a screen specification different from a screen specification of the portable device... | The receiver’s 7" display screen is alleged to be different from and larger than that of a smartphone, as shown in a visual comparison provided in the complaint. | ¶11, ¶20 | col. 4:29-35 |
| a key advisor unit configured to output the supportable key information to the video output unit wherein the key advisor unit is configured to receive the touch position information... | The MirrorLink API allegedly provides supportable key information by detecting the car’s status (e.g., park/drive mode) to determine available functions, which are then reflected on the display. | ¶13, ¶14, ¶20 | col. 4:37-54 |
| ...the adjusted video information is video data adjusted to screen resolution supported by the video output unit... | The complaint points to MirrorLink technical documents describing a "FramebufferUpdate" message that contains a "DesktopSize pseudo encoding rectangle with the new framebuffer resolution" to adjust the display. | ¶13, ¶16, ¶20 | col. 4:55-62 |
| ...the touch position information is mapped to one of key values indicated by the supportable key information of the portable device... | Touch events on the receiver are allegedly "signalled to the MirrorLink Server via a specific key symbol value, which uniquely identifies the event," thereby mapping the input from the receiver to the phone. | ¶8, ¶16, ¶20 | col. 4:55-62 |
'461 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a key input unit configured to generate input key values | The receiver's touchscreen allegedly allows users to generate input key values to control the mirrored smartphone. | ¶22, ¶32 | col. 3:13-17 |
| a communication unit configured to transmit a connection establishment request message... and... to receive a connection establishment response message including screen resolution information and supportable key information... | The MirrorLink protocol allegedly involves a device discovery and connection process where the client (receiver) and server (phone) exchange compatibility, resolution, and supported key information. | ¶24, ¶32 | col. 3:65-67 |
| a video output unit... having a display screen larger than the portable device... | The receiver's 7" display is alleged to be larger than a smartphone's display. A visual in the complaint shows the mirroring process from a smaller phone to the larger car screen. (Compl. p. 25). | ¶25, ¶32 | col. 4:19-25 |
| a key advisor unit configured to extract the supportable key information... and output the supportable key information... | The MirrorLink protocol is alleged to provide for the exchange of supported key information during connection establishment, which the receiver uses to configure the interface. A diagram shows a message exchange for this purpose. (Compl. p. 26). | ¶26, ¶30, ¶32 | col. 4:37-46 |
| wherein the key advisor unit displays... if a key configuration mode is activated, keys of the portable device... | The complaint alleges the MirrorLink API provides information about the car's park/drive status, which constitutes a mode that activates or restricts certain keys and functions presented on the receiver's display. | ¶26, ¶27, ¶32 | col. 4:37-46 |
| ...the video information is video data adjusted in resolution by the portable device for the video output unit... | The complaint references MirrorLink technical diagrams allegedly showing the adjustment of video resolution based on information exchanged between the devices. | ¶29, ¶30, ¶32 | col. 3:18-26 |
- Identified Points of Contention:
- Technical Questions: A primary question may be whether the general operations of the public MirrorLink standard, as described in the complaint, map precisely onto the specific structural components and sequences recited in the claims. For example, does the Accused Instrumentality contain a discrete software or hardware module that meets all the functional requirements of the claimed "key advisor unit", or are these functions distributed across the system in a way that falls outside the claim's scope?
- Scope Questions: The complaint alleges infringement by equating the functionality of the MirrorLink standard with the patented invention. The litigation may raise the question of whether the accused product's specific implementation of that standard practices every limitation. Further, it raises the question of whether the sequence of communications in MirrorLink (e.g., who initiates the connection, what information is in the request vs. the response) matches the specific sequence required by the claims of each patent.
V. Key Claim Terms for Construction
The Term: "key advisor unit" ('504 Patent, Claim 2; '461 Patent, Claim 9)
Context and Importance: This term appears to be a neologism coined by the patentee and is central to the claimed invention, acting as the "brain" of the interface apparatus. Its construction will be critical because the defendant may argue that its product, which implements the public MirrorLink standard, does not contain a single, discrete component corresponding to the claimed "key advisor unit".
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes its function in general terms, such as to "extracts supportable key information from the connection establishment response signal and transmits the supportable key information to the video output unit." ('461 Patent, col. 3:9-12). This functional language may support an interpretation covering any software module or set of modules that performs this task.
- Evidence for a Narrower Interpretation: The patent figures depict the "key advisor unit" as a distinct structural block. ('504 Patent, Fig. 1). The specification also describes it performing very specific functions, such as managing a "key configuration mode" where it "displays on a display screen... keys of the portable device" and matches inputs. ('461 Patent, col. 6:55-65). This may support a narrower construction limited to a unit that performs these specific, explicit configuration steps.
The Term: "supportable key information" ('504 Patent, Claim 2; '461 Patent, Claim 9)
Context and Importance: The content of this "information" and the protocol for its exchange are fundamental to how the claimed apparatus achieves interoperability. The dispute will likely focus on whether the general capability data exchanged in the MirrorLink protocol is the same as the specific "supportable key information" recited in the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes this as "information of function keys supported by the portable device." ('461 Patent, col. 2:55-56). This general description could be argued to encompass the types of device profiles and capabilities exchanged during a MirrorLink handshake.
- Evidence for a Narrower Interpretation: The flowchart in Figure 3 of the '461 Patent shows this information being extracted (Step 340) and then used in a specific "key configuration mode" (Step 350). This context may support an argument that the term is limited to information used in such an interactive setup process, as opposed to a more automated protocol exchange.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b). It asserts that the Defendant provides the accused receivers to customers and provides advertising and instructions that encourage and guide users to use the allegedly infringing MirrorLink functionality, with the intent to cause infringement. (Compl. ¶13-14, ¶16-18, ¶25-26, ¶28-30).
- Willful Infringement: Willfulness is alleged based on notice of the patents occurring "at least as of the date this lawsuit was filed." (Compl. ¶15, ¶27). The complaint seeks enhanced damages for any post-filing infringement. (Compl. Prayer for Relief ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical mapping: The complaint relies almost exclusively on public-facing documents about the MirrorLink standard to allege infringement by the Rockville product. A key evidentiary question will be whether the Plaintiff can demonstrate that the accused product's actual software and hardware architecture implements that standard in a way that contains structures corresponding to every element of the asserted claims, particularly the "key advisor unit".
- A second key question will be one of claim construction: Can the term "key advisor unit", described in the patent specification with specific roles in a "key configuration mode," be construed broadly enough to read on the distributed, protocol-based event and session management functions of the accused MirrorLink software?
- Finally, the case may turn on a question of procedural sequence: The patents ('461 in particular) claim a specific sequence for exchanging connection requests, screen resolutions, and key information. An important factual question will be whether the MirrorLink protocol, as implemented by the accused device, follows the exact same operational sequence as that recited in the claims, or if there is a fundamental mismatch in the communication handshake.