DCT
2:22-cv-00338
AutoBrilliance LLC v. Honda Motor Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AutoBrilliance, LLC (Texas)
- Defendant: Honda Motor Co. Ltd. (Japan)
- Plaintiff’s Counsel: RUBINO LAW LLC; TRUELOVE LAW FIRM, PLLC
- Case Identification: 2:22-cv-00338, E.D. Tex., 08/31/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is not a resident of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s automotive safety and driver-assistance systems, such as the "Honda Sensing" suite, infringe a patent related to the dynamic alignment and calibration of vehicle-mounted sensors.
- Technical Context: The technology concerns methods for ensuring that data from various advanced driver-assistance system (ADAS) sensors (e.g., cameras, radar) remain accurately oriented relative to the vehicle's frame of reference, even after experiencing physical shifts from use.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2004-11-09 | '650 Patent Priority Date |
| 2008-03-04 | '650 Patent Issue Date |
| 2016-01-01 | Alleged launch of infringing Honda Civic |
| 2022-08-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,337,650 - System and Method for Aligning Sensors on a Vehicle
Issued March 4, 2008 (’650 Patent)
The Invention Explained
- Problem Addressed: The patent addresses the problem that sensors for automotive safety systems (e.g., cameras, radar) can become physically misaligned from the vehicle's body over time due to normal wear and tear. This misalignment can lead to inaccurate sensor data, compromising the safety system's function, and traditionally required costly, complex recalibration procedures with specialized tools (ʼ650 Patent, col. 3:1-14).
- The Patented Solution: The invention describes a system that can dynamically determine and compensate for this misalignment without external equipment. One described method involves placing a "micro-inertial sensor" (e.g., an accelerometer/gyroscope) with the primary sensor (like a camera) and a separate micro-inertial sensor on the vehicle's body. By comparing the forces and rotations measured by both inertial sensors as the vehicle moves, a processor can calculate the angular difference, or misalignment, between the primary sensor and the vehicle. This misalignment value is then used to mathematically "align" the sensor's data to the vehicle's true frame of reference (ʼ650 Patent, Abstract; col. 4:41-65). The patent also describes optical methods, such as using a camera to view the vehicle's own hood line to calculate misalignment (ʼ650 Patent, col. 6:14-35).
- Technical Importance: This technology enables automated, continuous self-calibration for vehicle sensor systems, which may enhance the reliability and reduce the long-term maintenance costs of advanced driver-assistance systems (ADAS) (ʼ650 Patent, col. 3:4-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶15).
- The essential elements of independent claim 1 are:
- A sensor mounted on a vehicle for gathering target data using optical information.
- A micro inertial sensor included with the optical sensor that measures rotation and acceleration to establish a "sensor reference frame."
- A separate micro inertial sensor independently mounted on the vehicle that measures rotation and acceleration to establish a "vehicle body reference frame."
- A processor that determines the amount of misalignment between the sensor reference frame and the vehicle body reference frame, and aligns the sensor's target data accordingly.
- The complaint does not explicitly reserve the right to assert dependent claims, but the prayer for relief is broad (Compl. ¶a, p. 10).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Accused Honda Vehicles," which include numerous models such as the Honda Civic, Accord, CR-V, and Pilot, equipped with the "Honda Sensing" and "Honda Lane Watch" systems (Compl. ¶9, ¶10).
Functionality and Market Context
- The "Honda Sensing" system is described as a suite of safety and driver-assistance technologies, including a Collision Mitigation Braking System (CMBS), Road Departure Mitigation System (RDM), Adaptive Cruise Control (ACC), and Lane Keeping Assist System (LKAS) (Compl. ¶9). The complaint alleges these systems employ "sensor fusion" technology, which combines data from a millimeter-wave radar and a monocular camera to detect objects and maintain the vehicle's position (Compl. p. 6). The Lane Keeping Assist System, for example, is alleged to rely on dash-mounted cameras to sense lane markings (Compl. p. 9). The complaint provides an image from Honda's marketing materials illustrating how the Lane Keeping Assist System (LKAS) "adjusts steering to help you keep centered in a detected lane" (Compl. p. 4, fig. 4).
IV. Analysis of Infringement Allegations
’650 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sensor mounted on an automotive vehicle for gathering target data around the vehicle using optical information | The complaint alleges the Honda Civic's Lane Keeping Assist System comprises a "mounted sensor for gathering target data around the vehicle using optical information" (e.g., a dash-mounted camera) (Compl. p. 9, fig. 11). | ¶16 | col. 15:58-61 |
| a micro inertial sensor included with the sensor that measures rotation rate and acceleration along two or more axes of the sensor for the establishment of a sensor reference frame | The complaint alleges the Honda Civic's system includes a "micro inertial sensor included with the sensor that measures rotation rate and acceleration along two or more axes of the sensor for the establishment of a sensor reference frame." | ¶16 | col. 15:62-65 |
| a separate micro inertial sensor independently mounted on the vehicle that measures rotation rate and acceleration along two or more axes of the vehicle for the establishment of a vehicle body reference frame | The complaint alleges the Honda Civic's system "further comprises a separate micro inertial sensor mounted on the vehicle that measures rotation rate and acceleration along two or more axes of the vehicle for the establishment of a vehicle body reference." | ¶16 | col. 16:1-4 |
| a processor for determining an amount of misalignment of the sensor reference frame with the vehicle body reference frame and aligning the sensor target data with the vehicle body reference frame according to the amount of misalignment | Upon information and belief, the complaint alleges the Honda Civic's system "comprises a processor for determining an amount of misalignment" and "aligning the sensor target data with the vehicle body reference frame according to the amount of misalignment." | ¶16 | col. 16:5-10 |
- Identified Points of Contention:
- Technical Questions: A central question will be whether the accused Honda systems actually contain the specific three-part hardware architecture required by claim 1: (1) an optical sensor, (2) an inertial sensor physically associated with it, and (3) a separate inertial sensor elsewhere on the vehicle body. The complaint alleges this architecture exists in the Honda Civic (Compl. ¶16), but the basis for the processor's function is "upon information and belief." Discovery will be needed to determine if the accused vehicles use two distinct inertial sensors in the manner claimed for the purpose of sensor alignment, or if their inertial sensors serve other functions (e.g., vehicle stability control) and alignment is achieved through different means.
- Scope Questions: The case may turn on the functional meaning of "aligning the sensor target data." The patent describes specific methods for using calculated misalignment angles to rotate sensor data into the vehicle's reference frame (ʼ650 Patent, col. 6:43-55). A dispute could arise over whether the accused "sensor fusion" technology (Compl. p. 6) performs this specific claimed function of "aligning," or if it combines data using a different, non-infringing process.
V. Key Claim Terms for Construction
The Term: "micro inertial sensor"
Context and Importance: This term is recited twice in claim 1, defining two separate components of the claimed system. Its definition is critical because the infringement theory rests on the existence of two distinct such sensors performing different roles (one establishing the sensor's reference frame, the other establishing the vehicle's). Practitioners may focus on this term to determine if the components in the accused systems, which may be standard accelerometers or gyroscopes used for various vehicle functions, meet the specific requirements of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional, requiring a device that "measures rotation rate and acceleration along two or more axes" ('650 Patent, col. 15:62-64). This could arguably encompass a wide range of common automotive sensors.
- Evidence for a Narrower Interpretation: The specification refers to a "gyro triad or micro-inertial device" when discussing sensing the vehicle's angular rotation ('650 Patent, col. 5:10-12). Defendant may argue that the term implies a more sophisticated device than a simple accelerometer, or one specifically configured for the alignment task described.
The Term: "aligning the sensor target data"
Context and Importance: This term captures the ultimate function of the claimed processor and is the final step of the claimed invention. The dispute will likely center on what specific action constitutes "aligning."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue this term should be given its plain and ordinary meaning, covering any process that corrects or adjusts sensor data to account for physical misalignment.
- Evidence for a Narrower Interpretation: The specification provides detailed flow charts and mathematical descriptions of how misalignment angles are calculated and then "used to rotate the sensor target data into the vehicle body frame" ('650 Patent, col. 6:43-44; Fig. 10). Defendant may argue that "aligning" is not merely correcting, but is limited to this specific act of rotational transformation based on a comparison of two inertial reference frames.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Honda induces infringement by "providing these products to end-users for use in an infringing manner" (Compl. ¶18). The complaint also references marketing materials, such as a visual depicting the Adaptive Cruise Control system maintaining a following interval, which may be presented as evidence of instruction (Compl. p. 4, fig. 3).
- Willful Infringement: The complaint does not include a separate count for willfulness but alleges that Defendant has knowledge of its infringement "at least as of the date of this Complaint" (Compl. ¶18). This allegation forms a basis for potential post-suit willful infringement. The prayer for relief also seeks a finding that the case is "exceptional," which could lead to an award of attorney fees (Compl. ¶d, p. 10).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of factual correspondence: Does discovery reveal that the accused Honda Sensing systems contain the specific hardware configuration of Claim 1—namely, an optical sensor with its own co-located inertial sensor, a separate vehicle-body inertial sensor, and a processor that uses data from both inertial sensors to perform the alignment function? The complaint's conclusory allegations on this point will need to be substantiated with technical evidence.
A second key issue will be one of functional scope: What does it mean to "align" sensor data in the context of the '650 patent? The case may depend on whether the term is construed narrowly to mean the specific rotational compensation method detailed in the patent's embodiments, or more broadly to cover any form of data fusion or correction that accounts for misalignment, which might be found in the accused systems.