DCT
2:22-cv-00124
OBD Sensor Solutions LLC v. Track What Matters
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: OBD Sensor Solutions LLC (Texas)
- Defendant: Track What Matters, L.L.C. d/b/a Rhino Fleet Tracking (Texas)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:22-cv-00124, E.D. Tex., 06/29/2022
- Venue Allegations: Venue is alleged based on Defendant’s residence in Texas, its maintenance of established and regular places of business within the district, and its commission of alleged acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Plug-in OBDII" vehicle tracking devices and associated systems infringe a patent related to an on-board device for monitoring and processing motor vehicle operating data.
- Technical Context: The technology involves on-board diagnostic (OBD) port devices that connect to a vehicle's internal network to collect, process, and transmit data for applications such as fleet management and vehicle health monitoring.
- Key Procedural History: This filing is a First Amended Complaint. The complaint alleges that Defendant’s knowledge of the asserted patent for the purposes of willful and indirect infringement dates from at least the service of the original complaint in this action.
Case Timeline
| Date | Event |
|---|---|
| 2001-06-18 | ’346 Patent Priority Date |
| 2002-06-14 | ’346 Patent Application Filing Date |
| 2006-12-05 | ’346 Patent Issue Date |
| 2022-06-29 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,146,346 - “Fuzzy-Logic On Board Device For Monitoring And Processing Motor Vehicle Operating Data,” issued December 5, 2006
The Invention Explained
- Problem Addressed: The patent describes a need in the motor vehicle field for on-board systems that can collect and process operating data to optimize vehicle design, monitor component aging, and analyze usage patterns. It notes that prior systems had drawbacks, including low processing capability, a need for many dedicated sensors, the recording of redundant data, and high cost. (’346 Patent, col. 1:15-46).
- The Patented Solution: The invention is an electronic on-board device that connects to a vehicle’s internal network (e.g., via the OBD port) to autonomously collect and analyze data from the vehicle's existing sensors and electronic control units (ECUs). The device uses a microprocessor and "fuzzy-logic principles" to process the data and derive statistical profiles, referred to as a vehicle "DNA," which characterize the vehicle's usage pattern without requiring continuous transmission of raw data. (’346 Patent, Abstract; col. 1:56-62; col. 2:21-26).
- Technical Importance: The described approach seeks to provide a more intelligent, autonomous, and cost-effective method for on-board vehicle data analysis, moving beyond simple data logging to create synthesized, high-level summaries of vehicle operation. (’346 Patent, col. 1:50-55).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶28).
- Claim 1 of the ’346 Patent recites an electronic device comprising:
- a central processing unit;
- an integrated data storage connected to the CPU;
- a network connector configured to connect to a vehicle's inner network via a diagnostic connector (e.g., OBD);
- the device being a "stand-alone device cooperating with the vehicle electronic dedicated control units" to process data from vehicle sensors;
- the received data is processed by the CPU and the "performed analysis" is stored in the data storage;
- an interface connector for connection to a radio transmitter or wireless unit;
- a front-end device and a bus connecting the network connector to the CPU; and
- a further bus connecting the CPU to the data storage.
- The complaint does not explicitly reserve the right to assert dependent claims but references "one or more claims" in its prayer for relief. (Compl. ¶49a).
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are Defendant’s "Plug-in OBDII" vehicle tracking devices and associated software and applications. (Compl. ¶18). A product image is provided in the complaint, showing a small device labeled "RHINO" designed to plug into a vehicle's diagnostic port. (Compl. p. 7).
Functionality and Market Context
- The complaint alleges the accused devices are used to "monitor and process information and/or data related to the use and functioning of motor vehicles." (Compl. ¶18). The devices are alleged to include a central processing unit, internal data storage, and an OBD connector to interact with a vehicle to "gather and process vehicle diagnostic information and code alerts." (Compl. ¶31-33). The devices are further alleged to use GSM/GPRS or other wireless units to transmit data to external systems, such as those used by a fleet manager. (Compl. ¶36).
IV. Analysis of Infringement Allegations
’346 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a central processing unit (3); | The "Plug-in OBDII" device includes a central processing unit that interacts with a vehicle to gather and process vehicle diagnostic information and code alerts. | ¶31 | col. 3:15-21 |
| an integrated data storage (4) connected to the central processing unit; | The device includes internal data storage, such as a memory unit, connected to the CPU to aid in gathering and processing vehicle information. | ¶32 | col. 3:21-24 |
| a network connector (8) operatively connected to the central processing unit and configured to be connected to an inner network of a motor vehicle through a connector (40) used by motor vehicle makers for accessing a vehicle on-board electric system with a diagnostic unit, | The device includes a network connector, such as an OBD connector, that is operatively connected to the CPU and configured to connect to a motor vehicle's inner network. A complaint visual shows the device being plugged into a vehicle's OBD port. | ¶33, p. 8 | col. 3:12-14 |
| said device being a stand-alone device cooperating with the vehicle electronic dedicated control units, via said network connector and through said inner network, and processing information data... | The accused devices are alleged to be stand-alone devices that cooperate with vehicle ECUs to receive and process data from connected vehicle sensors. | ¶34 | col. 5:19-25 |
| said data received through said inner network being processed by said central processing unit and performed analysis being stored into said storage (4); | Diagnostic and other information received from the vehicle's inner network is processed by the device's CPU, and the resulting analysis is stored in the device's memory. | ¶35 | col. 5:26-29 |
| an interface connector (2) providing connection to one of a radio transmitter (6) and a wireless unit; | The device uses GSM/GPRS and/or other wireless/radio units to transmit data, and these units are alleged to be interface connectors. | ¶36 | col. 3:15-16 |
| a front-end device (6) and a bus (13) connecting said network connector (8) to said central processing unit; and | The OBD network connector is allegedly connected to the CPU through a front-end device and a bus to facilitate information transfer. | ¶37 | col. 3:40-41 |
| a further bus (14) connecting said central processing unit to said storage (4), | The device includes busses that are described as "connections necessary to connect components of computer systems." | ¶38 | col. 3:41-44 |
| wherein said device is coupled, through said on-board network connector (8), with one of an OBD- and an EOBD connector (40)... | The device is alleged to be coupled via its on-board network connector with an OBD- or EOBD-type connector. | ¶39 | col. 5:39-44 |
Identified Points of Contention
- Technical Question: The claim requires that "performed analysis" be stored on the device. The patent's specification describes this analysis in terms of "fuzzy-logic," "clustering," and the creation of a vehicle "DNA." (’346 Patent, col. 1:58-62, col. 4:46-48). The complaint alleges the accused device performs "analysis" by processing "diagnostic information and code alerts." (Compl. ¶31, 35). This raises the question of whether the accused device's processing meets the level of "analysis" described and claimed in the patent, or if a court may find a mismatch in the complexity and nature of the processing.
- Scope Question: The claim recites a "stand-alone device cooperating with the vehicle electronic dedicated control units." The patent specification suggests this cooperation can include providing analyses back to the ECUs to "take required strategic decisions" or to "change the motor vehicle engine control procedures." (’346 Patent, col. 5:35-38, 50-54). The complaint alleges the device "cooperat[es]" (Compl. ¶34), but the supporting allegations focus on receiving data from the vehicle. This raises the question of whether merely reading data from ECUs constitutes "cooperating" as the term is used in the patent, or if a more interactive, two-way functionality is required.
V. Key Claim Terms for Construction
"performed analysis"
- Context and Importance: The definition of this term is critical because it goes to the core function of the claimed device. The dispute may center on whether the "analysis" performed by the accused product—allegedly processing "diagnostic information and code alerts" (Compl. ¶31)—is coextensive with the "analysis" disclosed in the patent. Practitioners may focus on this term because the patent specification heavily details a specific type of fuzzy-logic-based analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly limit "analysis" to a specific algorithm, which may support a construction covering any form of data processing beyond raw logging.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the analysis as being based on "fuzzy-logic principles" to derive "statistic index arrangements" and a vehicle "DNA." (’346 Patent, col. 1:58-62; col. 2:23-26). The detailed description of the "genetic algorithm construction" and filtering process (FIG. 2; col. 4:1-6) could be used to argue that "analysis" requires this specific, sophisticated methodology.
"cooperating with the vehicle electronic dedicated control units"
- Context and Importance: This term defines the relationship between the claimed stand-alone device and the vehicle's native systems. The infringement analysis may depend on whether the accused device's one-way data gathering is sufficient to meet this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "cooperating" simply means working in conjunction with, which could include passively receiving data that the ECUs make available on the vehicle's network.
- Evidence for a Narrower Interpretation: The specification provides examples of a more active cooperation, where the device provides its "performed analyses to the other ECU's to take required strategic decisions" or is used to "change the motor vehicle engine control procedures." (’346 Patent, col. 5:35-38, 50-54). This language may support an interpretation that requires a more interactive or influential relationship than just data monitoring.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement on the basis that Defendant provides customers with "instructions that guide users to use the Accused Instrumentalities in an infringing manner" and advertises and promotes such use with the specific intent to cause infringement. (Compl. ¶40).
- Willful Infringement: The willfulness allegation is based on Defendant’s alleged knowledge of the ’346 Patent "at least as of the date when it was notified of the filing of the Original Complaint." (Compl. ¶41). The complaint further alleges willful blindness, stating on information and belief that Defendant has a "policy or practice of not reviewing the patents of others." (Compl. ¶42).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical scope: does the accused device's processing of "diagnostic information and code alerts" constitute the specific "fuzzy-logic" based "analysis" that the patent describes for creating a vehicle's operational "DNA," or is there a fundamental mismatch in the level and nature of the data processing performed by the device itself?
- A second key issue will be one of functional definition: can the term "cooperating with," in the context of the patent, be met by a device that primarily reads data from a vehicle's network, or does the claim require a more interactive function where the device provides analytical output back to the vehicle's control units to influence their behavior?
- An evidentiary question will be what proof exists that the accused device performs "analysis" on-board and stores the results locally before transmission, as required by the claim, versus simply acting as a conduit for streaming raw or minimally processed data to a remote server where the primary analysis occurs.