DCT
2:24-cv-00685
Longhorn Automotive Group LLC v. Mitsubishi Motors Corp
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Longhorn Automotive Group LLC (Texas)
- Defendant: Mitsubishi Motors Corporation (Japan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:24-cv-00685, E.D. Tex., 07/30/2025
- Venue Allegations: Venue is alleged to be proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s vehicles and associated automotive subsystems—specifically adaptive headlights, telematics platforms, direct-injection engines, and driver-assistance systems—infringe four U.S. patents.
- Technical Context: The asserted patents cover a range of technologies central to modern automotive design, including advanced driver-assistance systems (ADAS), vehicle-to-cloud connectivity, and engine efficiency.
- Key Procedural History: This analysis is based on the Plaintiff's First Amended Complaint for Patent Infringement. The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2003-10-01 | ’353 Patent Priority Date |
| 2003-10-29 | ’238 Patent Priority Date |
| 2003-11-26 | ’002 Patent Priority Date |
| 2007-11-12 | ’803 Patent Priority Date |
| 2009-04-07 | ’238 Patent Issued |
| 2011-07-26 | ’002 Patent Issued |
| 2012-09-11 | ’353 Patent Issued |
| 2014-08-19 | ’803 Patent Issued |
| 2018-02-09 | My Mitsubishi Connect App Released |
| 2025-07-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,810,803 - "Lens System"
The Invention Explained
- Problem Addressed: The patent's background describes an issue where computer vision systems that rely on projected light patterns can fail to reliably detect objects if the pattern is too regular, as this can cause the object's texture to "disappear" relative to the background at certain distances (’803 Patent, col. 1:20-30).
- The Patented Solution: The invention proposes a system to project a complex, semi-random or random light pattern. It consists of a light source with multiple emitters (e.g., an LED array), a "cluster of lenses" that focuses and projects the light from the emitters in many directions, and an optional "condenser lens" positioned between the source and the lens cluster to concentrate the light ('803 Patent, col. 1:40-67; FIG. 1). This creates a dense, aperiodic pattern that provides robust texture for computer vision systems, allowing for more accurate object tracking ('803 Patent, col. 2:24-35).
- Technical Importance: This approach provided a method for generating structured light patterns with high spatial complexity, enhancing the reliability of 3D object detection for computer vision applications.
Key Claims at a Glance
- The complaint asserts independent claim 15 of the ’803 Patent (Compl. ¶22).
- The essential elements of claim 15 are:
- A light source including a plurality of emitters configured to emit light.
- A cluster of lenses, with each lens configured to receive the emitted light from each of the plurality of emitters.
- A condenser lens located between the light source and the cluster of lenses, configured to concentrate light from each of the emitters towards a center of the cluster of lenses.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 7,987,002 - "Arrangement for Distributed Measurement System for Measurement and Simulation in Distributed Control Systems"
The Invention Explained
- Problem Addressed: The patent background explains the complexity of measuring, analyzing, and monitoring distributed control systems, such as those in modern vehicles. These tasks often require separating processor-intensive analysis from real-time data collection and managing different communication protocols, which can be difficult with monolithic systems (’002 Patent, col. 1:36-54).
- The Patented Solution: The patent describes a modular architecture separating a high-level "tool arrangement" (e.g., a PC or PDA, the "complex monitoring unit") from a lower-level interface unit (the "basic monitoring unit" or interface) that connects directly to the distributed control system (e.g., a vehicle's CAN bus) ('002 Patent, Abstract; col. 2:15-32). The complex unit communicates with the interface using a "first protocol" (e.g., USB), while the interface communicates with the vehicle's system using a "second protocol" (e.g., CAN). The complex unit can generate instructions for the basic unit, which in turn retrieves specific data from the control system, thereby decoupling complex analysis from low-level data acquisition ('002 Patent, col. 2:15-32).
- Technical Importance: This architecture enables flexible and powerful diagnostic and control systems by allowing sophisticated software on general-purpose computers or mobile devices to interact with specialized, embedded vehicle networks without requiring a fully integrated, single-purpose device.
Key Claims at a Glance
- The complaint asserts independent claim 15 of the ’002 Patent (Compl. ¶37).
- The essential elements of claim 15 are:
- A plurality of monitoring units (comprising at least one complex and one basic unit) configured to communicate with at least one interface unit using a first protocol.
- The interface unit is communicably connected to a distributed control system and receives data values from it using a second protocol.
- The complex monitoring unit is configured to receive data values from the interface unit (via the first protocol) and generate programmatic instructions for the basic monitoring unit.
- The basic monitoring unit is configured to receive the programmatic instructions and, in response, receive a subset of the data values from the interface unit (via the first protocol).
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 7,513,238 - "Directly Injecting Internal Combustion Engine"
- Technology Synopsis: The patent describes a piston for a direct-injection engine designed to optimize fuel-air mixture for both early (homogeneous) and late (stratified) injection timings ('238 Patent, col. 1:11-43). The solution is a piston recess with a specific geometry—a central elevation and an adjoining, substantially planar surface connected via a radius—that directs the fuel jet to ensure proper distribution and mixing regardless of when injection occurs ('238 Patent, Abstract).
- Asserted Claims: Independent claim 1 (Compl. ¶53).
- Accused Features: The 2.4L MIVEC 4-cylinder direct-injection engine used in Mitsubishi vehicles, which allegedly includes a piston with the claimed recess geometry (Compl. ¶¶52, 56-57). The complaint provides a diagram of an accused piston to support this allegation (Compl. p. 58, fig. 70).
U.S. Patent No. 8,265,353 - "Method of Reconstructing an Image Acquired Using Several Imagery Modes"
- Technology Synopsis: The patent discloses a method for improving image reconstruction of a moving object when data is gathered from two different, independent sensor systems ('353 Patent, Abstract). The method involves synchronizing the measurements from both systems, estimating movement based on each, and using the more precise movement data from the first system (e.g., a camera) to correct and enhance the image constructed from the data of the second system (e.g., radar), thereby compensating for motion blur and distortion ('353 Patent, col. 2:5-18).
- Asserted Claims: Independent claim 1 (Compl. ¶68).
- Accused Features: The Mitsubishi MI-PILOT Assist system, which allegedly performs a method of forming an image of a mobile object by obtaining and associating data from a "first imaging technique" (Multi-View Camera System using sonar sensors) and a "second imaging technique" (front camera using radar sensors) (Compl. ¶¶67, 70, 72, 74). A system configuration diagram shows a camera and radar feeding data to a driver-assistance ECU (Compl. p. 66, fig. 81).
III. The Accused Instrumentality
Product Identification
- The Accused Products include Mitsubishi vehicles such as the Outlander PHEV, Eclipse Cross, and Outlander Sport, along with specific subsystems: adaptive headlight systems ("Automatic High Beam" or "AHB"), the Mitsubishi Connect telematics system and My Mitsubishi Connect App, 2.4L MIVEC direct-injection engines, and the MI-PILOT Assist driver-assistance system (Compl. ¶¶13-17).
Functionality and Market Context
- The AHB system is alleged to use a "Driver Assistance Camera" to detect vehicles and automatically switch between high and low beams to enhance nighttime driving safety (Compl. ¶¶23, 26). A promotional video screenshot shows this camera mounted on the vehicle (Compl. p. 9, fig. 6).
- The Mitsubishi Connect system provides telematics services through an embedded Telematics Control Unit (TCU) with a cellular modem that connects to the vehicle's internal CAN bus network (Compl. ¶39). This TCU communicates with the "My Mitsubishi Connect App" on a user's smartphone, enabling remote services like vehicle status checks, remote start, and parental controls (Compl. ¶¶38, 39). A block diagram provided in the complaint illustrates the TCU connecting to a "Telematics Cloud Server" and a "Mobile App" (Compl. p. 34, fig. 39). The accused functionality represents a key feature in the connected-car market.
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,810,803 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a light source including a plurality of emitters configured to emit light | The LED headlights, which include multiple LED emitters for high beam and low beam functionality. | ¶24 | col. 1:42-43 |
| a cluster of lenses, each lens included in the cluster of lenses being configured to receive the emitted light from each of the plurality of emitters | Lenses positioned in front of the LEDs, which may be spread out across or combined as layers within the headlight assembly. | ¶25 | col. 1:44-45 |
| a condenser lens located between said light source and said cluster of lenses, the condenser lens concentrating light from each of the plurality of emitters towards a center of the cluster of lenses | A projector lens or other lens located between the LED light sources and the outer cluster of lenses, which concentrates light from the emitters. | ¶26 | col. 1:55-59 |
Identified Points of Contention:
- Scope Questions: A potential dispute may arise over the interpretation of "cluster of lenses" and "condenser lens." The infringement theory identifies two distinct components within the accused headlight assembly. The question for the court may be whether a modern, integrated vehicle headlamp, which may use a complex single optical body, can be said to contain both a structurally separate "condenser lens" and a "cluster of lenses" as claimed, or if it constitutes a single, different optical system.
U.S. Patent No. 7,987,002 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of monitoring units configured to communicate with at least one interface unit using a first protocol... | The My Mitsubishi Connect App and the Mitsubishi services platform (monitoring units) communicate with the vehicle's Telematics Control Unit (TCU) (interface unit) using a first protocol (e.g., TCP/IP over a cellular network). | ¶39, ¶40 | col. 2:15-24 |
| wherein the at least one interface unit is communicably connected to a distributed control system, and...is further configured to receive data values from the distributed control system using a second protocol | The TCU is connected to the vehicle's electronic control modules (ECUs) (distributed control system) and receives data (e.g., tire pressure) via a second protocol (CAN communication). A technical diagram illustrates this CAN communication link (Compl. p. 31, fig. 36). | ¶39 | col. 2:17-21 |
| wherein the plurality of monitoring units comprises at least one complex monitoring unit and at least one basic monitoring unit | The My Mitsubishi Connect App is identified as the "complex monitoring unit," and the Mitsubishi services platform is identified as the "basic monitoring unit." | ¶40 | col. 2:22-24 |
| wherein the at least one complex monitoring unit is configured to receive a plurality of data values from the at least one interface unit using the first protocol and to generate programmatic instructions for the at least one basic monitoring unit | The App receives vehicle data (e.g., temperature, tire pressure) from the TCU and generates programmatic instructions (e.g., commands for controlling vehicle features) for the services platform. | ¶42 | col. 2:25-29 |
| wherein the at least one basic monitoring unit is configured to receive the programmatic instructions and in response thereto to receive a subset of the plurality of data values from the at least one interface unit using the first protocol | The services platform receives commands from the App and, in response, receives a subset of data values from the TCU via the first protocol. | ¶42 | col. 2:30-34 |
Identified Points of Contention:
- Technical Questions: The case may turn on the factual and technical mapping of the accused system onto the claimed architecture. A key question will be whether the "Mitsubishi services platform" (a cloud-based server system) functions as the claimed "basic monitoring unit." The claim requires this basic unit to receive instructions and, in response, receive data from the interface unit. The actual data flow—whether the server pulls data from the TCU on command from the app, or if the TCU pushes data that the server then forwards—will be a critical technical inquiry.
V. Key Claim Terms for Construction
’803 Patent, Claim 15
- The Term: "condenser lens"
- Context and Importance: Practitioners may focus on this term because the infringement allegation relies on identifying this as a distinct component separate from the "cluster of lenses." Defendant may argue that the accused headlamp uses a single, integrated lens system that does not have a separate "condenser lens," making the term's structural and functional requirements central to the dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the condenser lens functionally as hardware "capable of concentrating and/or redirecting light" (’803 Patent, col. 3:33-35), which may support an interpretation covering any component within the optical path that performs this function, even if integrated with others.
- Evidence for a Narrower Interpretation: The figures consistently depict the "condenser lens" (120) as a discrete element structurally positioned between the "lighting source" (110) and the "lens cluster" (130) (’803 Patent, FIG. 1, FIG. 4). This could support a narrower construction requiring a physically separate component.
’002 Patent, Claim 15
- The Term: "basic monitoring unit"
- Context and Importance: The claim's architecture is defined by the specific roles of and interactions between the "complex" and "basic" monitoring units. Plaintiff identifies the "basic" unit as a cloud platform (Compl. ¶40, ¶42). Practitioners may focus on this term because the patent's specification often describes the unit directly interfacing with the vehicle's protocol (a "first unit") as a hardware device like a "PC interface" (’002 Patent, col. 4:1-3, FIG. 1). Whether a remote, server-side software platform can be a "basic monitoring unit" will be a central construction question.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim is written in functional terms, requiring the unit to perform the steps of receiving instructions and then receiving a data subset. This language may not inherently limit the unit to a specific physical location or hardware implementation.
- Evidence for a Narrower Interpretation: The specification's description of the "first unit" (which corresponds to the "interface unit" and/or "basic monitoring unit" roles) as a module that "transforms...the first protocol...to a second protocol" suggests a gateway or hardware-level function, which could argue against a remote cloud platform qualifying ('002 Patent, col. 2:19-24).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all patents, stating that Mitsubishi provides the Accused Products to customers with owner's manuals and other instructional materials that encourage and direct users to operate the products in an infringing manner (e.g., Compl. ¶¶29, 45, 60, 78). For the ’002 Patent, the complaint specifically notes that providing the My Mitsubishi Connect App for download and use with the vehicle system induces infringement (Compl. ¶43).
- Willful Infringement: The complaint alleges that Mitsubishi had knowledge of the patents at least as of the date of the original complaint. It further alleges, in the alternative, that Mitsubishi has been willfully blind by maintaining a policy of not reviewing the patents of others, despite a high probability that its activities were infringing (e.g., Compl. ¶¶28, 44, 59, 77).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural and architectural mapping: does the physical design of Mitsubishi’s integrated headlight and engine components, and the data-flow architecture of its software-driven telematics and ADAS platforms, align with the specific, multi-part component structures and process flows required by the respective patent claims?
- A related central question will be one of definitional scope, particularly for the '803 and '002 patents: can the term "condenser lens," depicted in the patent as a discrete optical element, be construed to read on an integrated feature of a modern headlamp assembly? Similarly, can the "basic monitoring unit," described in the patent as a hardware-level interface, be construed to cover a remote, cloud-based software platform?
- A key evidentiary question will concern functional operation: for the '353 patent, does the MI-PILOT Assist system actually perform the claimed method of using movement data derived from one sensor system (e.g., sonar) to correct and form an image based on data from a second, independent sensor system (e.g., radar), or is the association between the sensor data more simplistic than what the claim requires?