DCT
2:23-cv-00458
AutoBrilliance LLC v. Hyundai Motor Group
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AutoBrilliance, LLC (Texas)
- Defendant: Hyundai Motor Group, Hyundai Motor Company, and Kia Motors Corporation (Republic of Korea)
- Plaintiff’s Counsel: Rubino Law LLC; Truelove Law Firm, PLLC
- Case Identification: 2:23-cv-00458, E.D. Tex., 10/02/2023
- Venue Allegations: Venue is alleged to be proper because Defendants are not U.S. residents and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendants’ vehicles equipped with advanced driver-assistance systems infringe a patent related to the dynamic alignment of vehicle sensors.
- Technical Context: The technology involves methods for automatically calibrating on-board vehicle sensors, such as cameras and radar, to ensure the accuracy of safety and driver-assistance features.
- 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 | U.S. Patent No. 7,337,650 Priority Date |
| 2008-03-04 | U.S. Patent No. 7,337,650 Issued |
| 2023-10-02 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 7,337,650, “System and Method for Aligning Sensors on a Vehicle,” issued March 4, 2008.
The Invention Explained
- Problem Addressed: The patent describes that next-generation automotive systems like collision avoidance and adaptive cruise control rely on multiple sensors (e.g., radar, cameras) that must be precisely aligned with each other and with the vehicle's body. Traditional alignment requires costly external tools during production or repair and does not account for misalignment that occurs over time due to "normal wear and tear." (’650 Patent, col. 2:32 - col. 3:14).
- The Patented Solution: The invention proposes a system that uses on-board inertial sensors to dynamically and automatically align the vehicle's sensors. By attaching a "micro-inertial device" to a primary sensor (e.g., a camera) and a separate one to the vehicle's body, the system can measure and compare their respective acceleration and rotation as the vehicle moves. A processor uses the differences in these measurements to calculate the angular misalignment between the sensor and the vehicle body, and then computationally applies a correction to the sensor's data, ensuring its output is always aligned with the vehicle's reference frame. (’650 Patent, Abstract; col. 4:41-65).
- Technical Importance: This method allows for continuous, real-time sensor calibration without requiring external equipment or manual intervention, thereby improving the long-term reliability and accuracy of advanced driver-assistance systems. (’650 Patent, col. 3:4-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶15).
- Independent Claim 1 requires:
- A sensor mounted on a vehicle for gathering target data using optical information.
- A micro inertial sensor "included with the 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 misalignment between the two reference frames and aligns the sensor's target data with the vehicle body reference frame based on that misalignment.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Accused Hyundai-Kia Vehicles," which are vehicles equipped with the "Hyundai SmartSense System and/or Kia Drive Wise System." (Compl. ¶¶10, 14).
Functionality and Market Context
- The accused systems are suites of advanced driver-assistance systems (ADAS) that include features such as Forward Collision-Avoidance Assist (FCA), Lane Keeping Assist (LKA), and Smart Cruise Control (SCC). (Compl. pp. 4-6). The complaint alleges these systems use multiple sensors, including a front-view camera and front radar, to perceive the vehicle's surroundings. (Compl. ¶10). A diagram from a vehicle owner's manual identifies the location of the "Front view camera" and "Front radar" used by the accused systems. (Compl. p. 12). The complaint alleges these systems "utilize systems which use multiple sensors which establish a vehicle body reference frame, a sensor reference frame, and processor to determine misalignment." (Compl. ¶14).
- The complaint highlights features like the "Surround View Monitor," which uses four exterior-mounted cameras to create a composite 360-degree view, suggesting the use of data from multiple, spatially distinct sensors. (Compl. p. 7).
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 Kia Stinger is equipped with a mounted sensor for gathering target data around the vehicle using optical information. | ¶16 | col. 7:59-61 |
| 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 Kia Stinger's system comprises 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. 8:1-5 |
| 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 Kia Stinger's system 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. 8:6-9 |
| 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. | The Kia Stinger's system comprises a processor for determining an amount of misalignment between the reference frames and aligning the sensor target data with the vehicle body reference frame based on that misalignment. | ¶16 | col. 8:10-15 |
Identified Points of Contention
- Scope Questions: The complaint's allegations for infringement of claim 1 track the claim language very closely. (Compl. ¶16). A central question will be whether discovery reveals that the accused systems actually contain the specific two-part inertial sensor architecture required by the claim: one inertial sensor "included with" the optical sensor and a "separate micro inertial sensor independently mounted on the vehicle."
- Technical Questions: What evidence demonstrates that the accused systems' processors perform alignment by calculating misalignment between two distinct, inertially-derived reference frames (one for the sensor, one for the vehicle body) as claimed, rather than using other known calibration techniques? The complaint provides screenshots from owner's manuals describing system functions like "Forward Collision-Avoidance Assist (FCA) - (Sensor Fusion)," but does not detail the underlying alignment methodology. (Compl. p. 10).
V. Key Claim Terms for Construction
The Term: "micro inertial sensor"
- Context and Importance: This term appears twice in claim 1 and is fundamental to the claimed invention. The case may turn on whether the inertial measurement units (IMUs) or other components within the accused vehicles qualify as a "micro inertial sensor." Practitioners may focus on this term because the patent does not provide an explicit definition, leaving its precise structural and functional scope open to interpretation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims require the sensor to measure "rotation rate and acceleration along two or more axes," which could be argued to cover any modern, multi-axis IMU used in automotive applications. ('650 Patent, col. 8:2-4). The specification repeatedly refers to the component as a "micro-inertial device," suggesting the terms are interchangeable. ('650 Patent, col. 5:12).
- Evidence for a Narrower Interpretation: The term "micro" could be interpreted to imply a specific manufacturing technology (e.g., MEMS) or size limitation that was notable at the time of the invention. The consistent use of "micro inertial" rather than a more generic term like "inertial measurement unit" may suggest a specific meaning was intended.
The Term: "included with the sensor"
- Context and Importance: Claim 1 distinguishes between a micro inertial sensor "included with the sensor" and a "separate micro inertial sensor independently mounted." The physical and functional relationship between the optical sensor and its associated inertial sensor is therefore a critical limitation. Infringement will depend on the degree of integration required to be "included with" the sensor.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: This phrase could be argued to mean co-packaged in the same housing or module, even if the components are on different circuit boards. The overall system diagram in Figure 10 shows "Sensor Aperture" and "Micro-inertial Device" as separate but closely linked blocks. ('650 Patent, Fig. 10).
- Evidence for a Narrower Interpretation: The direct contrast with the "independently mounted" sensor could support an interpretation requiring a higher level of integration, such as being on the same substrate or printed circuit board. This distinction is central to the claimed architecture, suggesting the two phrases are intended to have distinct, non-overlapping meanings.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants supply the Accused Hyundai-Kia Vehicles with instructions, such as Owner's Manuals, that guide end-users on how to operate the vehicles in an infringing manner. (Compl. ¶19).
- Willful Infringement: The complaint alleges that Defendants had knowledge of infringement "at least as of the date of this Complaint." (Compl. ¶18). It further alleges inducement with the "intent to cause infringing acts" or, alternatively, with "willful[] blind[ness] to the infringement." (Compl. ¶19). The prayer for relief requests a finding that the case is "exceptional" and an award of attorney fees under 35 U.S.C. § 285. (Compl. Prayer ¶d).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of architectural correspondence: do the accused Hyundai SmartSense and Kia Drive Wise systems in fact employ the specific two-part hardware architecture recited in claim 1, namely one "micro inertial sensor" that is "included with" an optical sensor and a second, "separate micro inertial sensor" that is "independently mounted" on the vehicle?
- A central legal question will be one of claim scope: what is the proper construction of the term "micro inertial sensor"? The outcome of this construction will determine whether the components used in Defendants' vehicles fall within the scope of the claims.
- A dispositive technical question will be one of functional operation: do the accused systems' processors "align" sensor data by calculating misalignment between two distinct, inertially-derived reference frames (one for the sensor and one for the vehicle body) as taught by the patent, or do they achieve sensor calibration through a fundamentally different technical method?