DCT
1:22-cv-00112
Aspiration Innovation Inc v. Ford Motor Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Aspiration Innovation, Inc. (Colorado)
- Defendant: Ford Motor Company (Delaware)
- Plaintiff’s Counsel: BUDO LAW, P.C.
- Case Identification: 1:22-cv-00112, E.D. Tex., 03/15/2022
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas on the basis that Ford has a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s SYNC 4 and SYNC 4A in-vehicle infotainment systems infringe a patent related to the creation, storage, and application of portable user profiles.
- Technical Context: The technology concerns systems for personalizing user settings (e.g., for seating, climate, audio) in complex environments, particularly within modern vehicles where such configurations can be stored and recalled.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the alleged infringement via a letter dated December 3, 2021.
Case Timeline
| Date | Event |
|---|---|
| 2006-05-26 | ’563 Patent - Earliest Priority Date |
| 2013-07-16 | ’563 Patent - Issue Date |
| 2021-12-03 | Plaintiff sends pre-suit notice letter to Defendant |
| 2022-03-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,489,563 - “Meta-configuration of profiles”, issued July 16, 2013 (’563 Patent)
The Invention Explained
- Problem Addressed: The patent addresses the challenge of storing user preference information (profiles) separately from the content or application the profiles are intended to modify, a problem that existed at the time of filing (Compl. ¶14; ’563 Patent, col. 1:25-27). This separation is intended to allow profiles to be portable and applicable across different environments.
- The Patented Solution: The invention describes a system centered around a "profile controller" that manages the creation, storage, and retrieval of profiles containing user-selected attributes. These profiles can be stored in a "profile repository" that is separate from the content itself and can be applied at runtime to configure a user's environment, for example, in a vehicle. ('563 Patent, Abstract; col. 2:7-17). The patent discloses an embodiment specifically for creating a profile for a vehicle based on driver preferences (Compl. ¶15; ’563 Patent, FIG. 15).
- Technical Importance: This approach provided a method for making user-specific settings portable and reusable across different devices or applications, a significant feature for increasingly complex and personalized software systems, such as automotive infotainment systems (’563 Patent, col. 30:48-55).
Key Claims at a Glance
- The complaint asserts at least independent claim 25 (’563 Patent, Compl. ¶28).
- The essential elements of independent claim 25 include:
- A method of sharing a profile with multiple sets of content data using a profile controller.
- Selecting a plurality of attributes to define a profile.
- Assigning a unique identifier to the profile.
- Storing the profile in a profile repository.
- Sending a notification that the profile is available for use by other content data.
- The complaint does not explicitly reserve the right to assert dependent claims but references "one or more claims" generally (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Ford’s SYNC 4 and SYNC 4A systems and vehicles that incorporate them, including the Lincoln Navigator, Lincoln Aviator, Lincoln Nautilus, and Lincoln Corsair (Compl. ¶19).
Functionality and Market Context
- The complaint alleges that the SYNC 4 and SYNC 4A systems allow drivers to create personal profiles that store and apply preferred settings for features like climate control, seat positions, audio systems, and mirror settings (Compl. ¶13, ¶20). The complaint references marketing materials that allegedly promote this functionality as a way for drivers to create a "desired environment via a profile unique to a given driver" (Compl. ¶32). The complaint also references instructional materials that allegedly illustrate for users how to set up a driver profile using the vehicle's display (Compl. ¶32).
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim charts in Exhibits B1 and B2 alleging infringement of at least Claim 25 (Compl. ¶28). The narrative allegations in the complaint support the following infringement theory for Claim 25:
’563 Patent Infringement Allegations
| Claim Element (from Independent Claim 25) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of sharing a profile with multiple sets of content data using a profile controller... | The SYNC 4/4A systems allegedly act as a profile controller to manage driver profiles with attributes that are applied to various vehicles. | ¶12 | col. 2:7-17 |
| selecting, at the direction of a user, a plurality of attributes... to define a profile to modify the presentation of content... | The SYNC 4/4A systems allegedly allow a driver to select preferred settings for climate, seats, audio, mirrors, and more, which are stored in a profile. | ¶13 | col. 4:10-21 |
| assigning a unique identifier to said profile... | The system allegedly creates a profile unique to a given driver. The complaint references an instructional video allegedly illustrating how to set up a driver profile. | ¶32 | col. 2:2-3 |
| storing said profile in a profile repository using said profile controller... | The created driver profile is allegedly stored in the vehicle's computer memory. | ¶13 | col. 5:47-67 |
| sending a notification using said profile controller that said profile is available for use by said content data for modifying presentation... | Ford allegedly induces infringement by distributing product literature and website materials instructing users on how to use the profile features. | ¶31-33 | col. 2:15-17 |
Identified Points of Contention
- Scope Questions: A central question may be whether the SYNC 4/4A system's architecture meets the definition of a "profile controller" using a "profile repository" that is "separate from and not embedded with the content" (’563 Patent, col. 2:3-4), given the complaint's allegation that profiles are stored in the "vehicle's computer memory" (Compl. ¶13). The dispute may turn on whether on-board vehicle memory is considered "separate" from the "content" (the vehicle's configurable systems) in the manner claimed by the patent.
- Technical Questions: The complaint's theory for the "sending a notification" element of claim 25 appears to rely on allegations of inducement through user manuals and advertisements (Compl. ¶31-33). A technical question for the court will be whether the accused system itself performs a technical step of "sending a notification" that a profile is available for other content, as required by the claim, and what evidence supports this specific functionality beyond user-facing instructions.
V. Key Claim Terms for Construction
The Term: "profile controller"
- Context and Importance: This term appears to be the central active component of the claimed method. Its construction will be critical for determining whether the software architecture of the SYNC 4/4A systems falls within the scope of the claims. Practitioners may focus on this term because the patent describes it as a component that negotiates with clients and sends messages, a potentially specific behavior that Ford may argue its system does not perform.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent provides a high-level functional description, stating it is used "to control the attributes of a profile to be used with selected content and other content" (’563 Patent, col. 2:7-9).
- Evidence for a Narrower Interpretation: The detailed description and FIG. 1C depict the "profile controller" as performing specific steps like "negotiates and receives profile data from client" and "sends 'Profile Updated' message," which could be argued to require a specific client-server or messaging architecture (’563 Patent, FIG. 1C, steps 172, 176).
The Term: "profile repository"
- Context and Importance: The location and nature of profile storage is a key aspect of the invention's portability feature. Whether the SYNC system's storage method (allegedly the "vehicle's computer memory" (Compl. ¶13)) qualifies as a "profile repository" under the patent's definition will likely be a significant point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The summary of the invention describes retrieving a profile from a repository that is "separate from and not embedded with the content" (’563 Patent, col. 2:3-4), which could be argued to mean logically separate, even if on the same physical hardware.
- Evidence for a Narrower Interpretation: The detailed description lists specific examples of external storage, such as "USB plug-ins, flash media, memory cards, hard drives," and access over networks, which could support an interpretation that the repository must be physically distinct or removable from the primary device (’563 Patent, col. 5:58-67).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement based on Ford's actions of selling the accused products and distributing materials such as advertisements, user manuals, and online instructional content that allegedly instruct and encourage customers to use the driver profile features in an infringing manner (Compl. ¶31-33).
- Willful Infringement: The complaint alleges willful infringement based on Defendant having received pre-suit notice of infringement via a letter dated December 3, 2021, and continuing its alleged infringing conduct after receiving notice and after the suit was filed (Compl. ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: can the patent’s concept of a "profile controller" managing a "profile repository" that is "separate from... the content" be construed to read on the integrated software and on-board memory of Ford's SYNC 4/4A systems?
- A key evidentiary question will be one of functional proof: does the accused SYNC system technically perform the claimed step of "sending a notification that said profile is available for use," and can Plaintiff provide direct technical evidence of this function beyond the inferential evidence of user-facing instructions and advertisements?