DCT
2:18-cv-00475
Dale Progress Ltd v. Toyota Motor Sales USA Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dale Progress Ltd. (Republic of Korea)
- Defendant: Toyota Motor Sales, U.S.A., Inc. (California)
- Plaintiff’s Counsel: Hansley Law Firm, PLLC
- Case Identification: 2:18-cv-00475, E.D. Tex., 02/04/2019
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has a regular and established place of business in the district, specifically its headquarters in Plano, Texas, and has transacted business and committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s vehicle infotainment systems, which incorporate Apple CarPlay functionality, infringe patents related to a remote interface for accessing and controlling a portable electronic device.
- Technical Context: The technology concerns the integration of smartphones with in-vehicle infotainment systems, allowing a vehicle's display and controls to serve as the primary user interface for the phone's applications.
- Key Procedural History: The operative complaint is a Fifth Amended Complaint, suggesting a developed case history prior to the filing of this document. The complaint does not mention any prior litigation or post-grant proceedings involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2008-02-20 | Priority Date for ’461 and ’504 Patents |
| 2012-11-27 | U.S. Patent No. 8,320,461 Issues |
| 2017-06-20 | U.S. Patent No. 9,686,504 Issues |
| 2019-02-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,686,504 - “Remote Resource Access Interface Apparatus,” Issued June 20, 2017
The Invention Explained
- Problem Addressed: The patent describes the inconvenience of using portable electronic devices like smartphones due to their small display screens and keypads, as well as the waste of resources from redundant input/output modules across multiple personal devices (’504 Patent, col. 1:26-39).
- The Patented Solution: The invention is an external interface apparatus that connects to a portable device. This apparatus has its own display and input controls. It is designed to handle the technical challenge of displaying video from the portable device on its own screen, which may have different specifications (e.g., resolution), and translating its own user inputs into commands the portable device can understand (’504 Patent, Abstract; col. 2:1-12). A "key advisor unit" manages the exchange of capability information and maps inputs to the portable device (’504 Patent, col. 4:48-62).
- Technical Importance: This approach aims to improve the "extendibility and portability of a portable device" by allowing it to leverage larger, more convenient external displays and input systems (’504 Patent, col. 1:43-47).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2-9 (Compl. ¶12). Claim 2 is representative and detailed in the complaint (Compl. ¶11).
- Claim 2 (dependent on Claim 1) requires:
- A remote resource access interface apparatus comprising:
- A "touch input detection unit" to detect touch on a display screen and generate touch position information.
- A "communication unit" to receive "supportable key information" from a portable device, transmit "input key information" to the device, and receive "video information" from the device.
- A "video output unit" with a display screen having a different screen specification (e.g., resolution) than the portable device.
- A "key advisor unit" to receive touch position information, output supportable key information to the video output unit, and map touch position information to key values of the portable device.
- Wherein "adjusted video information" is displayed based on the portable device's screen resolution information.
- The complaint reserves the right to assert other claims (Compl. ¶12).
U.S. Patent No. 8,320,461 - “Remote Resource Access Interface Apparatus,” Issued November 27, 2012
The Invention Explained
- Problem Addressed: As with the related ’504 Patent, the ’461 Patent addresses the limitations of small screens and keypads on portable devices and the redundancy of I/O components (’461 Patent, col. 1:11-34).
- The Patented Solution: The invention is a remote interface that establishes a connection with a portable device, transmits a request for the device's capabilities, and receives a response containing screen resolution and "supportable key information" (’461 Patent, col. 2:46-56). The interface then displays video from the portable device, adjusted for the interface's screen, and enters a "key configuration mode" to map its own inputs to the keys of the portable device (’461 Patent, Fig. 3).
- Technical Importance: The invention seeks to improve the usability of portable devices by allowing them to be controlled through a more capable external interface, such as one integrated into a vehicle (’461 Patent, col. 1:40-47; col. 5:15-21).
Key Claims at a Glance
- The complaint asserts independent claim 9 and other claims 1, 2, and 4-8 (Compl. ¶24). Claim 9 is representative and detailed in the complaint (Compl. ¶23).
- Claim 9 (independent) requires:
- A remote resource access interface apparatus comprising:
- A "key input unit" to generate input key values.
- A "communication unit" to transmit a connection request, receive a response with screen resolution and "supportable key information," and subsequently transmit input key information and receive video information.
- A "video output unit" with a display screen larger than the portable device's.
- A "key advisor unit" to extract supportable key information and, if a "key configuration mode" is activated, display keys of the portable device on the video output unit and receive corresponding keys from the key input unit.
- Wherein key values from the input unit match the portable device's key values, and video is adjusted based on screen resolution information.
- The complaint reserves the right to assert other claims (Compl. ¶24).
III. The Accused Instrumentality
Product Identification
The "Accused Instrumentalities" are various 2019 model year Toyota and Lexus vehicles, including the Toyota Avalon, Corolla Hatchback, Camry, C-HR, RAV4, and Sienna, and the Lexus ES, LC, LS, NX, RC, RC F, and UX, that are equipped with Apple CarPlay functionality (Compl. ¶12, ¶24).
Functionality and Market Context
The accused functionality involves the vehicle's infotainment system (head unit) connecting to a user's Apple iPhone. When connected, the CarPlay system displays a modified version of the iPhone's user interface on the vehicle's larger, built-in touchscreen (Compl. ¶20, p. 6). The complaint alleges that the vehicle's touchscreen and other physical controls are used to interact with applications running on the iPhone, with the system managing the differences in screen resolution and input methods between the two devices (Compl. ¶20, p. 12-13). This diagram shows how CarPlay adjusts its user interface to different screen resolutions and pixel densities. (Compl. ¶13, p. 13).
IV. Analysis of Infringement Allegations
’504 Patent Infringement Allegations
| Claim Element (from Independent Claim 1, as incorporated into 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 built-in touchscreen display of the accused vehicles, which detects user gestures like tapping and dragging to interact with the CarPlay interface. This diagram illustrates the types of touch gestures supported by CarPlay. (Compl. ¶20, p. 11). | ¶20 | col. 4:26-31 |
| 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 from the portable device | The hardware (e.g., USB port) and software protocols that connect the vehicle's head unit to the user's iPhone, allowing for the two-way exchange of control inputs, video data, and capability information. This architectural diagram depicts the communication link between the car and the iPhone. (Compl. ¶20, p. 12). | ¶20 | col. 4:8-15 |
| a video output unit configured to display adjusted video information...having a display screen having a screen specification different from a screen specification of the portable device | The vehicle's infotainment display screen, which is larger and has a different resolution than the iPhone's screen. The system allegedly adjusts the video output from the iPhone to fit the car's display. | ¶20 | col. 4:29-35 |
| a key advisor unit configured to...receive the touch position information...and the touch position information is mapped to one of key values indicated by the supportable key information... | A software component, identified as the "Resource Manager" in Apple's documentation, that allegedly processes touch inputs from the car's screen and maps them to corresponding actions or "key values" on the connected iPhone. This diagram shows a "Resource Manager" handling requests between the car and phone. (Compl. ¶20, p. 14). | ¶20 | col. 4:48-62 |
Identified Points of Contention
- Scope Questions: Does the term "key advisor unit" read on a software module within the broader Apple CarPlay ecosystem, or does the patent require a dedicated hardware or software component within the "remote... apparatus" itself?
- Technical Questions: What evidence demonstrates that the accused system "maps" touch position information to "key values" as claimed? The complaint relies on high-level developer documents; the actual implementation of how a raw touch coordinate (x,y) is translated into a functional command will be a central technical question.
’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 vehicle's touchscreen, physical knobs, and other controls that allow a user to interact with the CarPlay interface, thereby generating input commands. | ¶32 | col. 3:13-17 |
| a communication unit configured to transmit a connection establishment request message...and...receive a connection establishment response message including screen resolution information and supportable key information | The initial handshake process between the vehicle's head unit and the iPhone, where the two devices allegedly exchange information about their respective capabilities, including screen size and supported input types, to establish the CarPlay session. | ¶32 | col. 3:65-67 |
| a video output unit configured to display the video information...having a display screen larger than the portable device | The vehicle's infotainment display, which is physically larger than the screen of the connected iPhone, on which the adjusted video from the iPhone is shown. This diagram illustrates the system architecture, showing the larger car display as the output unit. (Compl. ¶27, p. 27). | ¶32 | col. 4:19-22 |
| a key advisor unit configured to extract the supportable key information...and output the supportable key information to the video output unit, wherein the key advisor unit displays on a display screen of the video output unit, if a key configuration mode is activated, keys of the portable device | A software component that allegedly extracts the iPhone's capabilities and, upon connection (the alleged "key configuration mode"), causes the CarPlay interface (the "keys of the portable device") to be displayed on the car's screen. | ¶32 | col. 4:37-46 |
Identified Points of Contention
- Scope Questions: What constitutes the activation of a "key configuration mode"? The complaint appears to equate the normal launch of the CarPlay interface with this claimed mode. A court will need to determine if the term requires a more specific, discrete setup process as depicted in the patent’s figures (’461 Patent, Fig. 3).
- Technical Questions: Does the initial connection handshake actually involve the transmission of "supportable key information" from the iPhone to the head unit in the manner claimed, or does the system operate on a different logic, such as the head unit simply reporting its own capabilities to the iPhone?
V. Key Claim Terms for Construction
"key advisor unit" (’504 Claim 2, ’461 Claim 9)
- Context and Importance: This is a non-standard, functionally-defined term that appears central to the inventive concept of mediating between the two devices. Its construction is critical because infringement will depend on whether a software module within the complex Toyota/Apple CarPlay system can be identified that performs all the functions recited for this "unit."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests this "unit" can be implemented in software on a general-purpose microprocessor, not necessarily a distinct piece of hardware (’461 Patent, col. 2:36-40). The claims define it by its functions: "extracting," "outputting," and "mapping."
- Evidence for a Narrower Interpretation: The detailed description and figures provide specific operational flows for the unit, such as extracting information from a "connection establishment response signal" and displaying keys in a "key configuration mode" (’461 Patent, Fig. 3, steps 330-340). A party could argue the term is limited to an apparatus that performs these specific, sequenced steps.
"key configuration mode" (’461 Claim 9)
- Context and Importance: This term appears to define a specific state of the apparatus. The infringement allegation for the ’461 Patent hinges on whether the standard operation of Apple CarPlay in the accused vehicles meets the definition of this mode. Practitioners may focus on this term because its definition could be dispositive of infringement for the ’461 patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined. It could be argued to broadly cover any operational state where the remote interface is configured to accept inputs that control the portable device.
- Evidence for a Narrower Interpretation: The patent’s flowchart presents "key configuration mode?" as a distinct decision point (step 350) that leads to a specific process of displaying and matching keys (steps 360-380) (’461 Patent, Fig. 3). This suggests a specific, user- or system-activated mode, potentially distinct from the normal operating state.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by selling the accused vehicles and providing advertising, information, and instructions that encourage and teach customers how to use the infringing Apple CarPlay functionality (Compl. ¶16-17, ¶28-29).
- Willful Infringement: The complaint alleges knowledge of the patents "at least as of the date this lawsuit was filed" (Compl. ¶15, ¶27). The prayer for relief requests treble damages for willful infringement from the time Defendant became aware of its allegedly infringing acts (Compl. Prayer for Relief ¶D).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the functionally-claimed terms "key advisor unit" and "key configuration mode", which originate in a patent describing a generic remote interface, be construed to read on the specific software architecture of the Apple CarPlay system as implemented in Defendant's vehicles? The outcome will likely depend on whether the court adopts a broad functional definition or one limited to the specific embodiments shown in the patents.
- A key evidentiary question will be one of technical mapping: what specific evidence, beyond Apple's general developer documentation, demonstrates that the accused systems perform the precise functions recited in the claims? The case may turn on details of the communication protocol, such as whether "supportable key information" is actually transmitted from the phone to the car, and how the system technically translates a touch on the car's screen into a command understood by the phone.