DCT

2:21-cv-00390

Intellectual Ventures I LLC v. Honda Motor Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:21-cv-00390, E.D. Tex., 10/19/2021
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Honda maintains "numerous regular and established places of business" in the District, primarily through a network of authorized Honda dealerships that it allegedly ratifies, controls, and holds out as its own places of business.
  • Core Dispute: Plaintiff alleges that Defendant’s automotive vehicles, equipped with infotainment, navigation, and wireless connectivity systems (such as HondaLink®), infringe eleven patents related to in-vehicle data networks, location-based services, mobile hotspots, and wireless communication protocols.
  • Technical Context: The technologies at issue cover key aspects of modern connected vehicles, including the architecture of in-vehicle data buses, the delivery of personalized location-based information, and the management of wireless data transmissions for features like mobile hotspots.
  • Key Procedural History: The complaint alleges that Defendant received actual notice of the patents-in-suit via a letter dated October 18, 2021, one day prior to the filing of the complaint, which forms the basis for the allegations of willful infringement.

Case Timeline

Date Event
1999-10-06 U.S. Patent No. 7,891,004 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
2004-05-01 U.S. Patent No. 8,953,641 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
2005-09-22 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
2010-03-23 U.S. Patent No. 7,684,318 Issued
2011-02-15 U.S. Patent No. 7,891,004 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 describes the challenge of addressing electronic components within a transport vehicle's data bus system, particularly in complex networks where components may be exchanged or where external networks need to communicate with specific in-vehicle components (’283 Patent, col. 1:16-42).
  • The Patented Solution: The invention proposes a method where components on an in-vehicle network (the "first network") are addressed based on their function, rather than just their physical location. Each component has a "first address" stored in a central register. A component that also connects to an external network (the "second network," e.g., the Internet) is assigned a "second address" by that external network. The key is that within the vehicle, addressing relies on "function-specific address components," which allows for consistent communication with functional blocks (like an amplifier) regardless of their physical configuration ('283 Patent, Abstract; col. 2:20-40).
  • Technical Importance: This approach provided a more flexible and robust framework for managing complex in-vehicle networks, facilitating easier component upgrades and enabling vehicle systems to interface with external networks for services like remote diagnostics (Compl. ¶36).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 (Compl. ¶69).
  • The essential elements of independent 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, 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 occurs based on "function-specific address components," where identical function blocks are addressed via identical function-specific address components.
  • The complaint reserves the right to assert additional claims (Compl. ¶77).

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"

The Invention Explained

  • Problem Addressed: The patent addresses the need to provide mobile users with information that is not only geographically relevant but also personally tailored to their explicitly stated interests (’608 Patent, Abstract).
  • The Patented Solution: The claimed method involves receiving a user's preference, their mobile device's location, and a geographic area limitation. The system maintains a database of "objects" (e.g., places or things) with associated attributes and locations. It then identifies a matching object by satisfying two conditions: the object's attributes match the user's preference, and its location is within the user's specified geographic area. Information about this matching object is then sent to the user ('608 Patent, Abstract; col. 2:4-18).
  • Technical Importance: This technology represents a move toward personalized, proactive location-based services, going beyond simple map-based points of interest to actively filter and present nearby opportunities based on a user's declared interests (Compl. ¶39).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 (Compl. ¶84).
  • The essential elements of independent Claim 1 include:
    • An electronic computer-implemented method for matching users with information.
    • Receiving a first user preference, a location of a mobile device of the first user, and a geographic area limitation.
    • Storing attributes and locations for a plurality of objects.
    • Determining a matching object based on its attributes satisfying the user preference and its location being within the geographic area limitation relative to the mobile device.
    • Sending information about the matching object to the first user.
    • The matching object is a person, place, and/or thing.
  • The complaint reserves the right to assert additional claims (Compl. ¶91).

U.S. Patent No. 7,891,004 - "METHOD FOR VEHICLE INTERNETWORKS"

Technology Synopsis

The patent relates to creating an "internetwork" within a vehicle by coupling multiple network elements across at least two different vehicle data buses (e.g., a high-speed and a low-speed bus) via a gateway node. This network can also be coupled to a remote computer outside the vehicle, allowing for remote control of vehicle functions (Compl. ¶42; ’004 Patent, Abstract).

Asserted Claims

Claim 68 (Compl. ¶99).

Accused Features

The complaint accuses Honda's Mobile Hotspot and HondaLink® systems, which allegedly use a gateway to bridge different in-vehicle networks (e.g., F-CAN and B-CAN) and a Telematics Control Unit to couple with remote computers for services like "Personal Data Wipe" (Compl. ¶¶100, 102-107).

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 describes a device that uses positional information (e.g., from a GPS) to determine if a vehicle has committed a violation (such as speeding) and sends an indication of that violation to a remote computing system, which can then notify a recipient (Compl. ¶45; ’475 Patent, Abstract).

Asserted Claims

Claim 15 (Compl. ¶116).

Accused Features

The complaint accuses the HondaLink® system, which allegedly collects vehicle information like speed and location ("Driver Behavior Information") to determine violations and provides alerts (e.g., "Geofence Alert," "Security Alarm Alert") to a user's remote device via an LTE connection (Compl. ¶¶118-122).

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

Technology Synopsis

The patent claims a stand-alone mobile wireless hotspot system. The system comprises a short-range wireless access point (e.g., Wi-Fi), a long-range wireless Internet interface (e.g., cellular), and a LAN routing system to manage the data path between them, enabling client devices to access the Internet without needing an external service controller server (Compl. ¶48; ’771 Patent, Abstract).

Asserted Claims

Claim 1 (Compl. ¶131).

Accused Features

The complaint accuses Honda's "In-Vehicle Wi-Fi" or "Mobile Hotspot System," which uses Wi-Fi for short-range access and a cellular connection (e.g., 4G LTE via AT&T) for long-range Internet access, allegedly operating as a stand-alone system (Compl. ¶¶132-135).

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

Technology Synopsis

The patent relates to a camera system comprising a plurality of channels, each with its own sensor. A processing component determines the integration time of each channel and combines the data from the different channels to provide a single, high-dynamic-range image (Compl. ¶51; ’158 Patent, Abstract).

Asserted Claims

Claim 9 (Compl. ¶144).

Accused Features

The complaint accuses Acura models equipped with "Surround-View," which allegedly uses four exterior cameras (sensors) and a processing component that combines the images from the cameras to create a combined 360° view of the vehicle (Compl. ¶¶146-148).

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

Technology Synopsis

The patent describes a user equipment (UE) that receives allocation messages from a network and allocates resources for uplink transmission across multiple data channels based on parameters associated with each channel, prioritizing data from channels with certain parameters over others (Compl. ¶54; ’466 Patent, Abstract).

Asserted Claims

Claim 1 (Compl. ¶157).

Accused Features

The complaint accuses Honda vehicles equipped with a Qualcomm 4G LTE modem (as part of the Mobile Hotspot or HondaLink® systems), which operates as a UE and allegedly allocates uplink resources according to 3GPP standards for logical channel prioritization (Compl. ¶¶159-164).

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

Technology Synopsis

The patent describes a user equipment (UE) that determines buffer occupancies for multiple radio bearers, reports this to a network, receives a single allocation of uplink resources, and then selects data for transmission from the bearers in a multi-iteration process based on received parameters and buffered data (’138 Patent, Abstract; Compl. ¶57).

Asserted Claims

Claim 1 (Compl. ¶173).

Accused Features

The complaint accuses Honda vehicles with a Qualcomm 4G LTE modem (UE), which allegedly determines buffer status for various radio bearers, reports this to the network, and selects data for uplink transmission based on 3GPP-compliant scheduling and prioritization procedures (Compl. ¶¶175-183).

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

Technology Synopsis

The patent describes a method for managing data transmission on a shared channel by queuing data frames and setting the length of a station's "transmit opportunity" based on the priority of the queue, allowing for differentiation based on class of service (Compl. ¶60; ’318 Patent, Abstract).

Asserted Claims

Claim 1 (Compl. ¶192).

Accused Features

The complaint accuses the "In-Vehicle Wi-Fi" functionality in Honda vehicles, which allegedly utilizes the IEEE 802.11 standard's Enhanced Distributed Channel Access (EDCA) mechanism to provide Quality of Service (QoS) by using different access categories and queues to prioritize traffic (Compl. ¶¶194-198).

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

Technology Synopsis

The patent describes a mobile station for an OFDMA system that receives broadcast information in a narrow "first band" and uses that information to determine the bandwidth of a wider "second band" for data communication, allowing for variable channel bandwidth operation (’641 Patent, Abstract; Compl. ¶63).

Asserted Claims

Claim 11 (Compl. ¶208).

Accused Features

The complaint accuses Honda vehicles with a Qualcomm 4G LTE modem and Snapdragon Automotive platform, which allegedly operate in an OFDMA system compliant with 3GPP standards where the device receives broadcast information (e.g., on the Physical Broadcast Channel) in a narrow, fixed band to determine the parameters of the wider operational channel bandwidth (Compl. ¶¶209-220).

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

Technology Synopsis

The patent describes a user equipment (UE) that receives resource allocation information on a downlink control channel. It is configured to send data on a physical uplink shared channel during assigned time intervals, and to send a signal on a separate physical uplink control channel during time intervals when it is not sending data (’356 Patent, Abstract; Compl. ¶66).

Asserted Claims

Claim 1 (Compl. ¶229).

Accused Features

The complaint accuses Honda vehicles with a 4G LTE modem, which allegedly uses different resources for the Physical Uplink Control Channel (PUCCH) and the Physical Uplink Shared Channel (PUSCH) and transmits control information and data on these separate channels in different time intervals according to 3GPP standards (Compl. ¶¶231-236).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are various Honda and Acura automotive vehicles, including but not limited to the Honda Odyssey, Passport, Pilot, Accord, Civic, CR-V, and Acura MDX and RDX models (Compl. ¶¶68, 83, 98, 115, 130, 143, 156, 172, 191, 207, 228). The specific accused technologies are the embedded systems within these vehicles, such as the Honda Infotainment system, HondaLink®, Honda Navigation System, Mobile Hotspot System, and Surround-View camera systems (Compl. ¶¶70, 85, 100, 132, 146).

Functionality and Market Context

The complaint alleges these systems provide core connectivity and user-facing features in modern Honda vehicles. Functionally, these systems are alleged to perform a wide range of tasks:

  • In-Vehicle Networking: The Honda Infotainment system is alleged to use the MOST (Media Oriented Systems Transport) network, a data bus that connects components like the tuner, amplifier, and display unit (Compl. ¶¶70, 71). A system diagram from a Honda service manual shows the interconnection of these components via the MOST bus (Compl. p. 25).
  • External Connectivity: The Telematics systems are alleged to communicate with external cellular networks to provide services, and in doing so, are assigned an address by that external network (Compl. ¶¶74, 75). A diagram in the complaint illustrates the Telematics Control Unit connecting to a cellular network and the Honda Server (Compl. p. 27).
  • Navigation and Search: The Honda Navigation System is alleged to allow users to search for points of interest by category (a user preference) and near a specific location, displaying matching results on the screen (Compl. ¶¶87, 89). A screenshot of the navigation interface shows a user selecting "Barbecue" from a list of categories to search nearby (Compl. p. 31).
  • Wireless Hotspot: The Mobile Hotspot System is alleged to provide in-vehicle Wi-Fi by using a 4G LTE modem for a long-range Internet connection and an 802.11 access point for short-range communication with user devices (Compl. ¶¶133-135).
  • The complaint frames these features as integral to the functionality and marketability of the accused Honda and Acura models (Compl. ¶33).

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... Honda Count I Automobiles include a first network of components in a data bus system using, for example, MOST networks. ¶71 col. 1:16-21
...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... The MOST network uses a NetworkMaster to generate a Central Registry during initialization, which stores the logical node address and function blocks of each device. ¶73 col. 1:22-24
...wherein at least one particular component of the first network communicates with a second network, said one component, when dialling [sic] into the second network, is assigned a second address by the second network... The vehicle's Infotainment, HondaLink, or Telematics systems communicate with external networks (e.g., cellular) and are assigned a second address by that second network. ¶¶74, 75 col. 2:25-32
...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. On the application level, a MOST device contains multiple components called function blocks (FBlocks), such as a tuner or amplifier, which are addressed based on their function. ¶72 col. 2:33-40

Identified Points of Contention

  • Scope Questions: A central question may be whether the term "central register" as described in the patent, which was filed in 2001, can be read to cover the "Central Registry" generated by the "NetworkMaster" in the more recent MOST protocol. The defense may argue these are distinct technical concepts.
  • Technical Questions: The complaint alleges the component is "assigned a second address by the second network" (Compl. ¶75). A key factual question will be what evidence demonstrates that an external cellular network actually "assigns" an address to the in-vehicle Telematics unit in the manner required by the claim, as opposed to the unit merely initiating a standard data connection.

U.S. Patent No. 9,602,608 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A electronic computer implemented method for matching users with information, comprising: receiving a first user preference, a location of a mobile device of the first user, and a geographic area limitation; The Honda Navigation System is capable of receiving a user preference (e.g., by selecting a category like "Restaurants" or "Barbecue") and a location (e.g., "Where I Am Now"). ¶87 col. 2:4-7
storing, for a plurality of objects, a set of attributes of each corresponding object, and a location of the corresponding object; The system is capable of storing a database of objects (e.g., restaurants) with corresponding attributes (e.g., style) and locations. ¶88 col. 2:8-11
determining an object of the plurality of objects that matches the first user based on at least: (a) the set of attributes for the object satisfies the first user preference, and (b) the distance between the received location of the mobile device of the first user and the object is within the geographic area limitation; The system determines matching restaurants based on the user's selected category and the restaurant's proximity to the vehicle's current location. A screenshot shows a search for "Barbecue" near Signal Hill, CA (Compl. p. 33). ¶89 col. 2:12-18
sending to the first user, in response to a positive outcome of the determining, information about the matching object; and The system displays a list of matching objects (e.g., "Big Hawaiian Bbq") to the user on the navigation screen. ¶90 col. 2:19-21
wherein the matching object is a person, place and/or thing. The matching objects are places, specifically restaurants. ¶90 col. 2:22-23

Identified Points of Contention

  • Scope Questions: The claim recites receiving the "location of a mobile device of the first user." A potential point of contention is whether the location of the vehicle itself, as determined by its integrated GPS, constitutes the location of a "mobile device of the user" as contemplated by the patent, which could be interpreted as referring to a personal, portable device like a smartphone.
  • Technical Questions: The claim requires determining a match where the object's attributes "satisfy" the user preference. A factual question will be what level of attribute matching the accused system performs beyond simple category selection, and whether this functionality meets the claim requirement as defined by the patent's specification.

V. Key Claim Terms for Construction

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

  • The Term: "function-specific address components"
  • Context and Importance: This term is the core of the invention's approach to addressing within the vehicle network. Its construction will be critical to determining infringement. Honda will likely argue for a narrow definition tied to the patent's specific examples, while Intellectual Ventures will argue for a broader, functional definition that covers the "Function Blocks" (FBlocks) used in the accused MOST protocol.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary states that "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" ('283 Patent, col. 2:33-40), suggesting the term describes the functional outcome rather than a specific hardware structure.
    • Evidence for a Narrower Interpretation: The detailed description provides specific examples, such as a control device having "two function blocks 8, 9 which are functionally addressed by means of a function-specific address component 0x51 and 0x06, respectively" ('283 Patent, col. 6:50-54). A party could argue this ties the term to these specific hexadecimal address component examples.

U.S. Patent No. 9,602,608

  • The Term: "mobile device of the first user"
  • Context and Importance: The infringement allegation centers on the vehicle's built-in navigation system. The definition of this term will determine whether an integrated vehicle system falls within the scope of the claim. Practitioners may focus on this term because the patent's 2002 priority date predates the ubiquity of modern integrated infotainment systems, and the language could be argued to contemplate a personal device (like a PDA or early smartphone) distinct from the vehicle itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims use the general term "mobile device" without further limitation to a handheld or personal device. A party could argue that a vehicle, being mobile, and its navigation system, being a device used by the user, meets the plain meaning of the term.
    • Evidence for a Narrower Interpretation: The patent lacks a detailed specification, but a court may look to the ordinary meaning of the term at the time of the invention. A party could argue that in 2002, a "mobile device" in the context of user-specific preferences would have been understood by a person of ordinary skill in the art to mean a personal, portable device rather than a component integrated into a vehicle's dashboard.

VI. Other Allegations

Indirect Infringement

For each asserted patent, the complaint alleges that Honda induces infringement by "providing and promoting the described hardware and/or software components and features" and by "providing its customers instructions on how to use its products and services" in an infringing manner (e.g., Compl. ¶¶79, 94). Contributory infringement is also alleged, on the basis that the accused components have no substantial non-infringing uses or are especially adapted for an infringing use (e.g., Compl. ¶¶80, 95).

Willful Infringement

For each asserted patent, the complaint alleges that Honda "knew of the ['XXX] Patent, or should have known," but bases its claim of actual knowledge on a letter dated October 18, 2021, which was received by Honda on the same day (e.g., Compl. ¶¶78, 93). This timing suggests the willfulness claim is primarily directed at post-notice conduct.

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

  • A core issue will be one of technological translation and scope: can claim terms from patents with priority dates in the early 2000s, such as "function-specific address components" ('283 Patent) and "mobile device of the first user" ('608 Patent), be construed to cover modern, integrated automotive systems that rely on industry standards (e.g., MOST, 3GPP), or are they limited to the specific, and potentially distinct, technological context in which they were originally described?
  • A central evidentiary question will be one of system-level functionality: given the assertion of eleven distinct patents against multifaceted automotive platforms like HondaLink®, what level of technical proof will be required to demonstrate that the accused systems perform the specific, and often granular, steps recited in each individual claim, from managing data packet queues in a Wi-Fi hotspot ('318 Patent) to scheduling uplink resources in an LTE modem ('466 Patent)?
  • A key legal question will concern damages and apportionment: if infringement is found, how will damages be calculated across eleven different patents covering a wide array of features within a single vehicle? This raises the question of whether a reasonable royalty can be apportioned to the specific contribution of each patented technology without stacking royalties to an unreasonable level for the product as a whole.