DCT

2:25-cv-04453

Fleet Connect Solutions LLC v. Vehicle Tracking Solutions LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-04453, E.D.N.Y., 08/08/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of New York because Defendant maintains regular and established places of business in the district and has committed the alleged acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management and tracking solutions infringe seven patents related to wireless communications, data packet generation, intelligent trip notification, field operations using handheld devices, and group navigation tracking.
  • Technical Context: The technologies at issue span from the physical layer of wireless communication to application-level software for managing mobile assets, a domain critical to the logistics, transportation, and field service industries.
  • Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the asserted patents.

Case Timeline

Date Event
2000-09-18 Earliest Priority Date for U.S. Patent Nos. 6,961,586; 7,593,751; 8,494,581
2002-09-09 Earliest Priority Date for U.S. Patent No. 7,260,153
2002-11-04 Earliest Priority Date for U.S. Patent No. 7,206,837
2004-07-20 Earliest Priority Date for U.S. Patent No. 7,742,388
2005-08-10 Earliest Priority Date for U.S. Patent No. 7,741,968
2005-11-01 U.S. Patent No. 6,961,586 Issues
2007-04-17 U.S. Patent No. 7,206,837 Issues
2007-08-21 U.S. Patent No. 7,260,153 Issues
2009-09-29 U.S. Patent No. 7,593,751 Issues
2010-06-22 U.S. Patent No. 7,742,388 Issues
2010-06-22 U.S. Patent No. 7,741,968 Issues
2013-07-23 U.S. Patent No. 8,494,581 Issues
2025-08-08 Complaint Filed

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

U.S. Patent No. 7,742,388 - “Packet Generation Systems and Methods” (Issued June 22, 2010)

The Invention Explained

  • Problem Addressed: The patent describes a need in wireless communications, such as IEEE 802.11 systems, for higher data rates and more efficient use of bandwidth, while ensuring that newer, high-rate devices can coexist with legacy devices in the same network environment (’388 Patent, col. 1:18-67).
  • The Patented Solution: The invention proposes increasing the data rate of a wireless transmission by adding subcarriers to a standard data packet to create an "extended data signal" (’388 Patent, Abstract; col. 2:15-20). This modification to the packet structure, as illustrated in the signal processing chain of Figure 6, is intended to increase data throughput (’388 Patent, col. 6:15-22).
  • Technical Importance: This approach provided a method for increasing bandwidth efficiency in wireless local area networks, a key objective for evolving standards seeking to support more demanding applications.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶27).
  • The essential elements of claim 1 include:
    • Generating a packet with a size corresponding to a protocol, where the packet has a preamble with a first and a second training symbol.
    • Increasing the packet's size by adding subcarriers to the second training symbol to create an extended packet.
    • The quantity of subcarriers in the second training symbol being greater than in the first.
    • Transmitting the extended packet from an antenna.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,260,153 - “Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range and Extended Rate Across Imperfectly Estimated Channels” (Issued August 21, 2007)

The Invention Explained

  • Problem Addressed: The patent addresses a technical challenge in advanced Multi-Input Multi-Output (MIMO) wireless systems where imperfectly estimated channel information leads to "cross-talk interference" between data sub-streams, which degrades communication performance and reliability (’153 Patent, col. 3:51-65).
  • The Patented Solution: The invention claims to solve the cross-talk problem through a method of evaluating and modifying the communication channel. It uses "Channel Matrix Metrics" and applies "Pre-Equalizer" and "Post-Equalizer" operators to transform a "Bad" channel into a "Good" one, thereby making high-speed data transmission more robust and predictable (’153 Patent, Abstract; col. 4:32-57).
  • Technical Importance: The invention addresses a fundamental obstacle to realizing the theoretical capacity gains of MIMO systems, aiming to improve their performance in practical, real-world wireless environments with inherent noise and interference.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶43).
  • The essential elements of claim 1 include:
    • Defining a "channel matrix metric" which is a predefined function of a channel matrix's singular values and provides a measure of cross-talk signal-to-noise ratio (SNR).
    • Obtaining an estimated channel matrix.
    • Performing a singular value decomposition (SVD) on the estimated channel matrix to obtain estimated channel singular values.
    • Calculating a crosstalk measure for each data sub-stream from the defined channel matrix metric and the estimated singular values.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification" (Issued April 17, 2007)

  • Patent Identification: U.S. Patent No. 7,206,837, "Intelligent Trip Status Notification," issued April 17, 2007 (Compl. ¶46).
  • Technology Synopsis: The patent addresses the inconvenience for a user in transit of manually and repeatedly estimating their time of arrival (’837 Patent, col. 1:11-37). The solution is a method to automatically and periodically provide trip status information, such as ETA, by processing data including the user's location, calendrical time, mode of travel, and historical travel data (’837 Patent, Abstract).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶52).
  • Accused Features: The complaint accuses Defendant's fleet management platform, which provides trip status notifications and ETA calculations, of infringement (Compl. ¶¶15, 51-52).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices" (Issued September 29, 2009)

  • Patent Identification: U.S. Patent No. 7,593,751, "Conducting Field Operations Using Handheld Data Management Devices," issued September 29, 2009 (Compl. ¶55).
  • Technology Synopsis: The patent identifies the problem of less-experienced field personnel lacking access to critical information, guidance, and support, which can lead to inaccurate or inefficient work (’751 Patent, col. 1:21-41). The invention describes a handheld device with industry-specific software that provides guided workflows, data collection tools, and two-way communication with remote resources to assist with field operations (’751 Patent, Abstract).
  • Asserted Claims: At least claim 6 is asserted (Compl. ¶61).
  • Accused Features: The IntelliShift Mobile App and associated platform, which are used to manage and execute field operations, are accused of infringement (Compl. ¶¶15, 60-61).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices" (Issued November 1, 2005)

  • Patent Identification: U.S. Patent No. 6,961,586, "Field Assessments Using Handheld Data Management Devices," issued November 1, 2005 (Compl. ¶64).
  • Technology Synopsis: Similar to the ’751 Patent, this patent addresses the challenges faced by field personnel who may lack experience or access to necessary information (’586 Patent, col. 1:20-33). The patented solution is a system using handheld devices to provide assessors with portable access to industry-specific programs and enable two-way communication with remote computers for real-time assistance and data synchronization (’586 Patent, Abstract).
  • Asserted Claims: At least claim 9 is asserted (Compl. ¶70).
  • Accused Features: Defendant's IntelliShift platform and Mobile App, used for conducting field assessments and managing field data, are the accused features (Compl. ¶¶15, 69-70).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices" (Issued July 23, 2013)

  • Patent Identification: U.S. Patent No. 8,494,581, "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices," issued July 23, 2013 (Compl. ¶73).
  • Technology Synopsis: This patent relates to systems for managing mobile field assets, including personnel and inventory. The invention provides for communication from enterprise servers to handheld devices in the field to support functions such as dispatch, data synchronization, logistics, and personnel management using bidirectional data delivery over wireless networks (’581 Patent, Abstract).
  • Asserted Claims: At least claims 21 and 22 are asserted (Compl. ¶79).
  • Accused Features: The IntelliShift platform's features for managing mobile field assets, personnel, and inventory via wireless handheld devices are accused of infringement (Compl. ¶¶15, 78-79).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group" (Issued June 22, 2010)

  • Patent Identification: U.S. Patent No. 7,741,968, "System and Method for Navigation Tracking of Individuals in a Group," issued June 22, 2010 (Compl. ¶82).
  • Technology Synopsis: The patent identifies a lack of systems allowing a user to permissively and selectively share their location with a chosen group for tracking and navigational assistance (’968 Patent, col. 1:36-43). The solution is a system where a sending device selectively transmits navigation data to a receiving party (or parties) over time, enabling group tracking and coordinated navigation (’968 Patent, Abstract).
  • Asserted Claims: At least claim 4 is asserted (Compl. ¶88).
  • Accused Features: The group tracking and navigation features of the IntelliShift platform are accused of infringing this patent (Compl. ¶¶15, 87-88).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "IntelliShift fleet management platform and tracking solutions" (Compl. ¶15). This includes specific hardware such as IntelliShift dashcams, IntelliShift OBD II Asset Trackers (e.g., AT-620, AT-502), and Vehicle Gateways (e.g., VG-800), as well as the IntelliShift Mobile App software (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges the Accused Products perform wireless communications using various protocols such as Bluetooth, IEEE 802.11, and LTE (Compl. ¶16). Their functionality is described as generating and transmitting data packets for wireless communications (Compl. ¶17) and performing complex signal processing, including "singular value decomposition of estimated channel matrices" (Compl. ¶18). From an end-user perspective, these products provide a suite of services for fleet management, asset tracking, and management of mobile field operations (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint references Exhibits A through G, which allegedly contain detailed infringement analysis for each asserted patent (Compl. ¶¶27, 43, 52, 61, 70, 79, 88). As these exhibits were not filed with the complaint and are therefore not available for analysis, this report summarizes the narrative infringement theories presented in the body of the complaint.

  • ’388 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe by performing wireless communications that, among other things, "generates and transmits packets" (Compl. ¶17). This functionality is alleged to practice at least claim 1 of the ’388 patent, with details purportedly provided in Exhibit A (Compl. ¶27). The complaint does not provide sufficient detail for analysis of specific claim elements.

  • ’153 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe by performing "singular value decomposition of estimated channel matrices, transmit data over various media, compute time slot channels, generate packets for network transmissions," and other methods of signal processing (Compl. ¶18). This functionality is alleged to practice at least claim 1 of the ’153 patent, with details purportedly provided in Exhibit B (Compl. ¶43). The complaint does not provide sufficient detail for analysis of specific claim elements.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • Term from the ’388 Patent: "adding subcarriers"

    • Context and Importance: This phrase appears in independent claim 1 and describes the core inventive act of modifying a standard packet to increase its data capacity. The central dispute may concern whether the methods used by the Accused Products to generate packets under modern wireless standards (e.g., 802.11n, LTE) constitute "adding subcarriers" to a baseline packet structure in the manner contemplated by the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not limit how or where in the process the subcarriers are added, potentially allowing it to cover various techniques for increasing spectral occupancy.
      • Evidence for a Narrower Interpretation: The specification describes adding subcarriers in a specific context, for example, by populating previously unused "bins" in an IFFT process (’388 Patent, col. 6:15-28). An accused infringer may argue the term should be limited to these specific disclosed embodiments.

  • Term from the ’153 Patent: "channel matrix metric"

    • Context and Importance: This term, found in independent claim 1, appears to be defined by the patentee and is central to the claimed method of evaluating channel quality. The infringement analysis will likely turn on whether the algorithms in the Accused Products calculate a value that meets the claim's multi-part definition: (1) it is a "metric," (2) derived from a "predefined function" of the channel matrix's "singular values," that (3) "provides a measure of cross-talk signal to noise ratio."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A plaintiff may argue that any algorithm that uses SVD outputs to assess channel quality for crosstalk implicitly calculates such a "metric," even if not explicitly named as such.
      • Evidence for a Narrower Interpretation: The specification ties this metric to a specific purpose: evaluating the "level of for-mentioned cross-talk interference" to classify channels as "Good" or "Bad" (’153 Patent, col. 4:39-57). This purpose-driven context may support a narrower construction limited to algorithms that perform this specific classification function.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for the ’388 and ’968 patents. Inducement allegations are based on Defendant allegedly providing instructions, advertising, and technical support that guide customers to use the Accused Products in an infringing manner (Compl. ¶¶29-30, 90-91). Contributory infringement is alleged on the basis that the Accused Products have "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶¶31, 92).
  • Willful Infringement: Willfulness is alleged for the ’388 and ’968 patents. The primary basis alleged is post-suit knowledge, stating Defendant had knowledge "at least as of the date Defendant was notified of the filing of this action" (Compl. ¶¶28, 89). The complaint also pleads willful blindness, alleging on "information and belief" that Defendant has a "policy or practice of not reviewing the patents of others" (Compl. ¶¶32, 93). The prayer for relief requests a finding of willful infringement and treble damages for the ’388 and ’968 patents specifically (Compl. ¶98.c).

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

  • A central technical question will be one of implementation: Do the Accused Products, which operate according to established wireless standards like LTE and IEEE 802.11, actually perform the specific and highly technical methods recited in the low-level communications patents (e.g., the ’388 and ’153 patents)? The case may turn on whether the patented methods describe unique, proprietary techniques or are simply abstract descriptions of functions inherent in modern standardized wireless systems.
  • A core issue will be one of definitional scope, particularly for the software-focused patents: Can the claims of the ’586, ’751, and ’581 patents, which were filed in the early 2000s and describe functions on "handheld data management devices" like PDAs, be construed to cover the functionality of a modern fleet-management application running on a general-purpose smartphone or tablet? This raises the question of whether the claims are limited to the specific device context of that era or are broad enough to read on today's mobile computing platforms.
  • A key evidentiary question will be one of functionality and proof: Given the absence of detailed claim charts in the complaint, a primary focus in discovery will be establishing the precise operation of the Accused Products. Plaintiff will bear the burden of showing, through source code, internal documents, and expert analysis, that the accused systems perform each element of the asserted claims, a potentially complex task for a multifaceted platform.