DCT

2:21-cv-00389

Intellectual Ventures II LLC v. Toyota

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:21-cv-00389, E.D. Tex., 10/19/2021
  • Venue Allegations: Plaintiff alleges that venue is proper in the Eastern District of Texas because Toyota maintains regular and established places of business in the District. The complaint identifies an authorized dealer, Shapen Toyota in Marshall, Texas, as a place of business that Toyota establishes, ratifies, and controls for the purpose of selling and servicing the accused infringing vehicles.
  • Core Dispute: Plaintiff alleges that a wide range of Toyota and Lexus vehicles, specifically their infotainment, navigation, telematics, and wireless communication systems, infringe eleven patents related to in-vehicle networking, wireless hotspot technology, camera systems, and safety features.
  • Technical Context: The technologies at issue cover core functionalities of modern automotive electronics, including in-vehicle data buses, mobile internet access, advanced driver-assistance systems (ADAS), and location-based services.
  • Key Procedural History: The complaint alleges that Toyota received actual knowledge of all patents-in-suit via a letter dated October 18, 2021, one day prior to the filing of the complaint. This allegation forms the primary basis for the claims of willful infringement.

Case Timeline

Date Event
1999-10-06 U.S. Patent No. 7,484,008 Priority Date
2000-06-15 U.S. Patent No. 6,832,283 Priority Date
2002-03-08 U.S. Patent No. 7,684,318 Priority Date
2002-06-27 U.S. Patent No. 9,602,608 Priority Date
2003-03-13 U.S. Patent No. 7,382,771 Priority Date
2004-08-25 U.S. Patent No. 9,232,158 Priority Date
2004-12-14 U.S. Patent No. 6,832,283 Issued
2005-04-29 U.S. Patent No. 8,953,641 Priority Date
2005-09-22 U.S. Patent No. 9,291,475 Priority Date
2006-05-08 U.S. Patent No. 9,681,466 Priority Date
2006-05-08 U.S. Patent No. 10,292,138 Priority Date
2006-12-27 U.S. Patent No. 8,811,356 Priority Date
2008-06-03 U.S. Patent No. 7,382,771 Issued
2009-01-27 U.S. Patent No. 7,484,008 Issued
2010-03-23 U.S. Patent No. 7,684,318 Issued
2014-08-19 U.S. Patent No. 8,811,356 Issued
2015-02-10 U.S. Patent No. 8,953,641 Issued
2016-01-05 U.S. Patent No. 9,232,158 Issued
2016-03-22 U.S. Patent No. 9,291,475 Issued
2017-03-21 U.S. Patent No. 9,602,608 Issued
2017-06-13 U.S. Patent No. 9,681,466 Issued
2019-05-14 U.S. Patent No. 10,292,138 Issued
2021-10-19 Complaint Filing Date

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

U.S. Patent No. 6,832,283 - “METHOD FOR ADDRESSING NETWORK COMPONENTS”

The Invention Explained

  • Problem Addressed: The patent addresses the complexity of addressing individual electronic components within a vehicle’s data bus system, particularly when configurations vary between vehicles and when those components need to communicate with an external network like the Internet (Compl. ¶34; ’283 Patent, col. 1:12-23).
  • The Patented Solution: The invention proposes a dual-addressing method. Components on a first network (e.g., the in-vehicle bus) are assigned a "first address" for internal communication, which is stored in a central register. When a component communicates with a second, external network, it is assigned a "second address" (e.g., an IP address). Crucially, addressing within the first network occurs using "function-specific address components," allowing identical functional units (like two amplifiers) to be addressed in a consistent manner regardless of their physical location in the network (Compl. ¶34; ’283 Patent, Abstract, col. 2:13-33).
  • Technical Importance: This approach was designed to simplify network management in increasingly complex automotive electronic systems by abstracting a component's function from its physical network address, facilitating both internal communication and external network access (Compl. ¶34; ’283 Patent, col. 2:34-47).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 (Compl. ¶67).
  • Essential elements of Claim 1 include:
    • A method for addressing components of a first network in a data bus system in a transport vehicle.
    • Each component is assigned a first address for communication within the network, and these first addresses are stored in a central register.
    • At least one component of the first network communicates with a second network and is assigned a second address by that second network.
    • Within the first network, addressing is based on function-specific address components, such that identical function blocks are addressed via identical function-specific address components.

U.S. Patent No. 7,484,008 - “APPARATUS FOR VEHICLE INTERNETWORKS”

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a need for a standardized, secure, and easily integrated network architecture within vehicles that can manage communication among diverse internal devices (e.g., controls, processors) and also provide a secure gateway to external networks like the Internet (Compl. ¶37; ’008 Patent, col. 1:11-20).
  • The Patented Solution: The patent describes a vehicle internetwork architecture centered on a gateway node. The asserted claim defines this node as comprising at least one interface port for receiving data packets, a "real-time processor" for performing real-time operations on those packets, and an "application processor" for high-level processing. The architecture explicitly separates low-level, time-sensitive network management from higher-level application functions, with the real-time processor coupled between the interface port and the application processor (Compl. ¶83; ’008 Patent, Abstract; col. 2:1-20).
  • Technical Importance: This architectural separation is intended to provide security for essential vehicle functions while facilitating the easy integration and addition of new devices and services, including those connecting the vehicle to external networks (Compl. ¶37; ’008 Patent, col. 2:1-20).

Key Claims at a Glance

  • The complaint asserts Claim 75 (Compl. ¶83).
  • Essential elements of Claim 75 include:
    • A "method node" (an apparatus, later corrected to "gateway node" in a Certificate of Correction) configured to couple to network elements.
    • The gateway node comprises at least one interface port to receive data packets.
    • It further comprises at least one real-time processor for real-time operations on the data packets.
    • It further comprises at least one application processor for high-level processing functions.
    • The real-time processor is coupled between the interface port and the application processor.

U.S. Patent No. 9,291,475 - “DEVICE, SYSTEM AND METHOD FOR CONTROLLING SPEED OF A VEHICLE USING A POSITIONAL INFORMATION DEVICE”

  • Technology Synopsis: The patent relates to systems that use a vehicle's location and speed information to determine if the vehicle is exceeding the local speed limit and to alert a user or a remote party of the violation (Compl. ¶40). The system compares GPS-derived speed against map data containing speed limits and can transmit a violation notification to a remote computing system (Compl. ¶98).
  • Asserted Claims: Independent Claim 15 (Compl. ¶98).
  • Accused Features: The complaint accuses Toyota’s Safety Connect™ and Remote Connect™ systems, which offer features like automatic collision notification and the ability for owners to set speed parameters for guest drivers and receive alerts (Compl. ¶¶ 100-101).

U.S. Patent No. 7,382,771 - “MOBILE WIRELESS HOTSPOT SYSTEM”

  • Technology Synopsis: The patent describes a mobile wireless hotspot system for use in a vehicle. The system is described as "stand-alone," enabling client devices (e.g., laptops, phones) to connect via a short-range wireless access point (like Wi-Fi) and access the Internet through a long-range wireless interface (like cellular) without needing an external service controller server (Compl. ¶¶ 43, 113).
  • Asserted Claims: Independent Claim 1 (Compl. ¶113).
  • Accused Features: The accused features are Toyota's Entune™ and Lexus Enform™ Wi-Fi Connect services, which provide in-vehicle 4G LTE hotspots for passenger devices, often through providers like AT&T (Compl. ¶¶ 112, 114, 115).

U.S. Patent No. 9,232,158 - “LARGE DYNAMIC RANGE CAMERAS”

  • Technology Synopsis: The patent relates to digital cameras that expand dynamic exposure range (Compl. ¶46). The claimed system comprises a plurality of channels, each with a sensor, and a processing component. The processor determines an integration time for each channel and combines the data from the channels to provide a composite image, allowing for better imaging in scenes with both very bright and very dark areas (Compl. ¶127).
  • Asserted Claims: Independent Claim 9 (Compl. ¶127).
  • Accused Features: The complaint accuses Toyota’s Bird’s Eye View and Panoramic View Camera systems, which use multiple cameras (front, side, and rear) to create a combined overhead view of the vehicle (Compl. ¶¶ 126, 130, 131).

U.S. Patent No. 9,681,466 - “SCHEDULING TRANSMISSIONS ON CHANNELS IN A WIRELESS NETWORK”

  • Technology Synopsis: The patent relates to mechanisms for supporting Internet Protocol data flows in a wireless system, specifically concerning how a user equipment (UE) allocates resources for uplink data transmission (Compl. ¶49). The claimed UE receives allocation messages and allocates resources for different data channels based on a priority scheme involving multiple parameters derived from the channels (Compl. ¶140).
  • Asserted Claims: Independent Claim 1 (Compl. ¶140).
  • Accused Features: The complaint accuses Toyota vehicles equipped with Mobile Hotspot systems and 4G LTE modems, which function as user equipment (UE) under 3GPP standards (Compl. ¶¶ 139, 142, 145).

U.S. Patent No. 10,292,138 - “DETERMINING BUFFER OCCUPANCY AND SELECTING DATA FOR TRANSMISSION ON A RADIO BEARER”

  • Technology Synopsis: This patent, related to the ’466 Patent, also concerns telecommunications, specifically a technique for a User Equipment (UE) to intelligently manage data transmission over a shared channel (Compl. ¶52). The claimed UE receives parameters for radio bearers, determines their buffer occupancies, reports this to the network, receives a single allocation of uplink resources, and then selects data for transmission in a two-iteration process based first on the received parameters and second on the buffered data (Compl. ¶157).
  • Asserted Claims: Independent Claim 1 (Compl. ¶157).
  • Accused Features: The complaint again accuses vehicles with Toyota’s Mobile Hotspot System and 4G LTE modems that operate as UEs compliant with 3GPP standards (Compl. ¶¶ 156, 159).

U.S. Patent No. 8,953,641 - “METHODS AND APPARATUS FOR MULTI-CARRIER COMMUNICATIONS WITH VARIABLE CHANNEL BANDWIDTH”

  • Technology Synopsis: The patent relates to multi-carrier communication with variable channel bandwidth, such as in an OFDMA system (Compl. ¶55). The claimed mobile station receives broadcast information in a first, narrow band and uses that information to determine the bandwidth of a second, wider band for data communication, allowing for flexible bandwidth allocation (Compl. ¶177).
  • Asserted Claims: Independent Claim 11 (Compl. ¶177). Note: The complaint mistakenly references "at least claim 1" in ¶178 but reproduces Claim 11 in ¶177.
  • Accused Features: The accused products are vehicles with Mobile Hotspot systems and 4G LTE modems that are compliant with 3GPP standards for OFDMA systems (Compl. ¶¶ 176, 179, 181).

U.S. Patent No. 8,811,356 - “COMMUNICATIONS IN A WIRELESS NETWORK”

  • Technology Synopsis: The patent relates to methods for communication in a wireless network, particularly concerning resource allocation for an uplink physical control channel (Compl. ¶58). The claimed user equipment (UE) has a processor configured to receive resource allocation information and to send data over a shared channel and signals over a control channel in different, non-overlapping time intervals (Compl. ¶200).
  • Asserted Claims: Independent Claim 1 (Compl. ¶200).
  • Accused Features: The complaint accuses vehicles with Mobile Hotspot systems and 4G LTE modems that comply with 3GPP standards for uplink control and shared channels (Compl. ¶¶ 199, 202).

U.S. Patent No. 7,684,318 - “SHARED-COMMUNICATIONS CHANNEL UTILIZATION FOR APPLICATIONS HAVING DIFFERENT CLASS OF SERVICE REQUIREMENTS”

  • Technology Synopsis: This patent describes a technique for stations in a local area network to intelligently share a communications channel by differentiating between latency-tolerant and latency-intolerant applications (Compl. ¶61). The claimed method involves queuing data frames, and setting a length of time for a transmit opportunity based on the priority of the queue, allowing higher-priority data to be transmitted in larger bursts (Compl. ¶217).
  • Asserted Claims: Independent Claim 1 (Compl. ¶217).
  • Accused Features: The complaint accuses Toyota and Lexus models that provide Wi-Fi connectivity, which supports Quality of Service (QoS) capabilities via the IEEE 802.11 standard's Enhanced Distributed Channel Access (EDCA) mechanism for prioritized queuing (Compl. ¶¶ 216, 219, 220).

U.S. Patent No. 9,602,608 - “SYSTEM AND METHOD FOR NOTIFYING A USER OF PEOPLE, PLACES OR THINGS HAVING ATTRIBUTES MATCHING A USER'S STATED PREFERENCE”

  • Technology Synopsis: The patent relates to location-based and preference-based systems for providing information to mobile users (Compl. ¶64). The claimed method involves receiving a user's preference and location, storing a database of objects with attributes and locations, and determining a match based on both the user's preference and the object's proximity to the user within a geographic limit (Compl. ¶233).
  • Asserted Claims: Independent Claim 1 (Compl. ¶233).
  • Accused Features: The accused feature is the Toyota Dynamic Navigation system, which provides real-time map updates and allows users to search for points of interest (POIs) based on their location and preferences (Compl. ¶¶ 232, 234, 236).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are various infotainment, telematics, and connectivity systems installed in a wide range of Toyota and Lexus vehicles (Compl. ¶¶ 66, 82, 97, 112, etc.). These systems include Toyota Entune™, Toyota Safety Connect™, Toyota Remote Connect™, Lexus Enform™, and in-vehicle Wi-Fi Connect services (Compl. ¶¶ 31, 100, 101, 112).
  • Functionality and Market Context: The accused systems provide core features of modern connected vehicles. The infotainment systems are alleged to be built on the Media Oriented Systems Transport (MOST) standard, an in-vehicle multimedia network backbone (Compl. ¶¶ 68, 84). The complaint provides a system diagram showing how components like the display, radio, and amplifier are connected via the MOST network (Compl. p. 24). The telematics and connectivity services leverage GPS and cellular technology to provide features such as automatic collision notification, stolen vehicle location, remote vehicle monitoring (e.g., speed and location alerts for guest drivers), and a 4G LTE Wi-Fi hotspot for passenger devices (Compl. ¶¶ 100, 101, 115). The complaint alleges these systems are commercially significant and are marketed as key features across Toyota's and Lexus's most popular vehicle lines (Compl. ¶¶ 31, 97, 112). A photograph in the complaint shows the "SOS" button integrated into the vehicle's overhead console, which is part of the accused Toyota Safety Connect™ system (Compl. p. 30).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,832,283 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
Method for addressing components of a first network in a data bus system in a transport vehicle... Toyota vehicles use the MOST Automotive Multimedia Network ("MOST"), which is a data bus system within a transport vehicle. ¶69 col. 1:12-23
...in which each component is assigned a first address for mutual communication within the network and the first addresses are stored in a central register... In a MOST network, a NetworkMaster generates a "Central Registry," which is an image of the system configuration and contains the logical node address for each device. The complaint includes a table from the MOST specification showing an example of this Central Registry (Compl. p. 21). ¶70, ¶71 col. 3:9-15
...wherein at least one particular component of the first network communicates with a second network, said one component, when dialling into the second network, is assigned a second address by the second network... The vehicle's Infotainment System or Entune™ system (a component of the first network) communicates with external networks such as cellular networks (the second network) and is assigned a second address by that external network. ¶72, ¶73 col. 2:23-29
...and wherein, within the first network, addressing takes place on the basis of function-specific address components, identical function blocks of the components being addressed via identical function-specific address components. The MOST device model contains multiple components called "function blocks" (FBlocks), such as a tuner or amplifier. Addressing on the application level occurs via these function blocks. ¶70 col. 2:29-33
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the term "dialling into the second network," language from the year 2000, can be construed to cover the way a modern infotainment system establishes a data session over a cellular or other IP-based network.
    • Technical Questions: The infringement theory relies on Toyota's use of the MOST standard. A key factual question will be whether the "Central Registry" as defined in the MOST specification and allegedly used by Toyota functions as the "central register" required by the claim, and whether MOST "FBlocks" meet the definition of "function-specific address components."

U.S. Patent No. 7,484,008 Infringement Allegations

Claim Element (from Independent Claim 75) Alleged Infringing Functionality Complaint Citation Patent Citation
A method node configured to couple to a plurality of network elements, wherein the plurality of network elements includes a local area network and at least one peripheral electronic device coupled to the local area network... The infotainment architecture in accused vehicles includes a local area network (the MOST network) that couples peripheral electronic devices such as a Display Module, Radio Receiver, and Amplifier Assembly. The complaint includes a block diagram illustrating this architecture (Compl. p. 24). ¶85 col. 1:44-55
...the gateway node comprising: at least one interface port to receive data packets; The Display and Navigation Module Display Electronic Control Unit (ECU) allegedly performs the role of a gateway and includes at least one interface port to connect to the MOST bus. ¶86, ¶87 col. 10:1-12
...at least one real-time processor operable to configured to perform real-time operations on the data packets; and The standard MOST ECU architecture is alleged to include a MOST Intelligent Interface Controller (INIC) that manages the real-time flow of information to and from the MOST bus. A diagram of this architecture is provided in the complaint (Compl. p. 27). ¶87, ¶88 col. 12:4-6
...at least one application processor configured to perform high level processing functions... The standard MOST ECU architecture is alleged to include an External Host Controller that is responsible for high-level application processing. ¶87, ¶88 col. 12:7-9
...wherein the at least one real-time interface processor is coupled between the at least one interface port and the at least one application processor. The INIC (real-time processor) is alleged to manage data flow from the MOST bus (interface port) and is coupled to the External Host Controller (application processor) in the standard MOST architecture. ¶87, ¶88 col. 10:20-25
  • Identified Points of Contention:
    • Scope Questions: Claim 75 recites a "method node," an unusual term for an apparatus. A Certificate of Correction later changed this term to "gateway node." The interpretation of this term will be a critical issue. The plaintiff accuses the "Display and Navigation Module Display ECU" of being this node, raising the question of whether this specific component meets the claim's definition.
    • Technical Questions: Does the accused system's MOST Intelligent Interface Controller (INIC) perform "real-time operations on the data packets" as distinct from the "high level processing functions" of the External Host Controller? The case may depend on evidence showing that Toyota's actual implementation matches the standard MOST architecture diagrams cited in the complaint.

V. Key Claim Terms for Construction

U.S. Patent No. 6,832,283, Claim 1

  • The Term: "function-specific address components"
  • Context and Importance: This term is central to the patent's alleged novelty and the infringement allegation. The dispute will likely focus on whether the "FBlocks" (Function Blocks) in the accused MOST network architecture constitute "function-specific address components." Practitioners may focus on this term because it distinguishes the claimed invention from simple device-ID or location-based addressing.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests this concept applies to high-level functions, stating that a component for "Internet communication or satellite navigation can be addressed within the data bus by using the function-specific address for the function group" (’283 Patent, col. 3:22-26). This could support a reading on any address element tied to a device's purpose.
    • Evidence for a Narrower Interpretation: The patent’s detailed description and figures show a specific addressing scheme where an address is composed of different parts, including a "function-specific address component" that is distinct from a "logical address" component (’283 Patent, Fig. 2; col. 4:35-47). A defendant may argue the term is limited to this particular composite addressing structure.

U.S. Patent No. 7,484,008, Claim 75

  • The Term: "real-time processor"
  • Context and Importance: The infringement theory maps this term to the "MOST Intelligent Interface Controller" (INIC) in the accused systems. The viability of the infringement case depends on whether the INIC's role—managing data flow on the MOST bus—qualifies as a "real-time processor" performing "real-time operations" that is architecturally distinct from the "application processor" as claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the real-time processor as handling "real-time, low-latency, and high-bandwidth data transfers" and managing "real-time control and data transfer functions" (’008 Patent, col. 12:4-14). This could support a broad interpretation covering any dedicated network controller that manages time-sensitive data streams.
    • Evidence for a Narrower Interpretation: The patent depicts the "real time interface processor" as a specific block (1002) in a gateway architecture (Fig. 10), separate from the network buses themselves. A defendant could argue the term is limited to a processor within such a gateway that performs functions beyond simple bus management, and that a standard network interface controller does not meet this limitation.

VI. Other Allegations

  • Indirect Infringement: For each asserted patent, the complaint alleges induced infringement, stating that Toyota provides user manuals and instructions that direct customers to use the accused vehicles in an infringing manner (Compl. ¶¶ 77, 92). The complaint also pleads contributory infringement, alleging that the accused components are especially made for use in an infringing system and have no substantial non-infringing uses (Compl. ¶¶ 78, 93).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The basis is Toyota's alleged pre-suit knowledge or willful blindness, and specifically its alleged actual knowledge as of October 18, 2021, the date it allegedly received a notice letter from the plaintiff (Compl. ¶¶ 76, 91, 107).

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

  • A central issue will be one of architectural mapping: for multiple patents targeting in-vehicle networks (e.g., ’283, ’008), does Toyota’s implementation of the industry-standard MOST architecture in its vehicles conform to the specific, and in some cases decades-old, network and processor configurations required by the patent claims, or have functional and architectural differences emerged over time?
  • A key evidentiary question will be one of operational proof: beyond citing to industry standards, marketing materials, and system diagrams, what specific technical evidence demonstrates that the accused Toyota systems—from infotainment buses to 4G LTE modems—actually operate in the precise manner required to meet each limitation of the asserted claims?
  • A significant legal question will be one of claim scope versus modern technology: can claim terms rooted in the context of early 2000s networking (e.g., a component "dialling into the second network" in the '283 patent) or specific hardware layouts be construed to cover the functionality of modern, highly integrated, and software-defined automotive systems?