DCT

2:24-cv-00877

AutoConnect Holdings LLC v. General Motors LLC

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: AutoConnect Holdings LLC (Delaware)
- Defendant: General Motors LLC (Delaware)
- Plaintiff’s Counsel: Avantech Law, LLP; Miller Fair Henry PLLC
Case Identification: 2:24-cv-00877, E.D. Tex., 10/30/2024
Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established business presences in the district, including in Roanoke, Texas, has committed acts of infringement in the district, and has previously consented to venue in this district in other litigation.
Core Dispute: Plaintiff alleges that Defendant’s vehicle infotainment systems, including those enabling Apple CarPlay, Android Auto, and Google built-in, infringe ten patents related to in-vehicle connectivity, application management, and user profile portability.
Technical Context: The technology relates to the integration of personal electronics and cloud-based services with vehicle computer systems, a central feature in the modern automotive market for enhancing driver and passenger experience.
Key Procedural History: The complaint alleges extensive pre-suit communications beginning in December 2023, where Plaintiff provided Defendant with notice and infringement claim charts for a majority of the asserted patents. It further alleges Defendant responded with general invalidity and non-infringement positions. Several of the asserted patents are also alleged to have been cited during the prosecution of Defendant's own patent applications, a fact which may be relevant to pre-suit knowledge and willfulness.

Case Timeline

Date	Event
2011-11-16	Earliest Priority Date for ’491, ’786, ’560, ’100, and '764 Patents
2012-10-15	Earliest Priority Date for ’367 Patent
2013-04-15	Earliest Priority Date for ’239, ’297, '153, and '243 Patents
2015-04-28	U.S. Patent No. 9,020,491 Issues
2015-07-14	U.S. Patent No. 9,082,239 Issues
2015-08-04	U.S. Patent No. 9,098,367 Issues
2015-08-25	U.S. Patent No. 9,116,786 Issues
2015-09-22	U.S. Patent No. 9,140,560 Issues
2015-09-29	U.S. Patent No. 9,147,297 Issues
2015-10-27	U.S. Patent No. 9,173,100 Issues
2016-01-01	Alleged Launch of Accused Products for multiple patents (Model Year 2016)
2016-03-22	U.S. Patent No. 9,290,153 Issues
2017-01-01	Alleged Launch of Accused Products for multiple patents (Model Year 2017)
2020-12-08	U.S. Patent No. 10,862,764 Issues
2022-01-01	Alleged Launch of Accused '239 Products (Model Year 2022)
2023-12-01	Plaintiff first contacts Defendant regarding patent portfolio
2024-05-01	Defendant provides formal response to Plaintiff's letter
2024-06-14	Plaintiff responds to Defendant's letter
2024-07-16	U.S. Patent No. 12,039,243 Issues
2024-10-25	Plaintiff sends follow-up letter with additional claim charts
2024-10-30	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,020,491 - "Sharing Applications/Media Between Car and Phone (Hydroid)"

The Invention Explained

Problem Addressed: The patent describes a disconnect between a person's digital life (e.g., on mobile devices) and their in-vehicle experience, noting that vehicle manufacturers have traditionally built comfort "around a vehicle" rather than building a vehicle "around comfort," failing to fully consider the vehicle as an integrated "ecosystem." (’491 Patent, col. 2:1-2).
The Patented Solution: The invention proposes a vehicle communication system that creates a "universal bus and hotspot," allowing devices within the vehicle to connect, create a network, and share applications, data, and multimedia. (’491 Patent, Abstract; col. 3:9-25). This aims to create a seamless, intuitive environment that integrates the user's personal devices with the vehicle's systems. (’491 Patent, col. 3:9-25).
Technical Importance: This approach addresses the growing consumer expectation for seamless connectivity between their personal devices and their environment, a key trend in both consumer electronics and the automotive industry during the relevant time period. (Compl. ¶¶ 2, 8).

Key Claims at a Glance

The complaint asserts independent method claim 11 and independent system claim 16. (Compl. ¶43).
Essential elements of independent claim 11 (a method) include:
- Receiving a signal at a vehicle communication system from a device.
- Automatically determining if the signal originates from inside the vehicle.
- If the signal originates from inside, communicatively connecting the system to the device.
- Providing the device with access to a vehicle bus.
Essential elements of independent claim 16 (a system) include:
- Two or more BLUETOOTH transceivers.
- A communication system with two or more communication modules and a signal processor.
- The signal processor is operable to perform the steps of receiving a signal, determining its origin relative to the vehicle, and, if internal, connecting to the device and providing bus access.
The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,082,239 - "Intelligent Vehicle for Assisting Vehicle Occupants"

The Invention Explained

Problem Addressed: The patent addresses the need for a vehicle to be more than a simple conveyance, instead acting as an "intelligent system" that can understand and assist its occupants, thereby enhancing safety, comfort, and productivity. (’239 Patent, col. 1:49-55).
The Patented Solution: The invention describes a computer-implemented method where the vehicle determines a "persona" of an occupant (based on biometrics, historical data, etc.) and determines the vehicle's state. Based on this information, the system provides assistance, which can include modifying vehicle operations or providing a recommendation to the occupant. (’239 Patent, Abstract; col. 27:3-25).
Technical Importance: This technology represents a shift toward proactive, context-aware vehicle systems that personalize the driving experience and provide intelligent assistance, a foundational concept for modern advanced driver-assistance systems (ADAS) and integrated vehicle AI. (Compl. ¶¶ 2, 8).

Key Claims at a Glance

The complaint asserts independent claims 1, 8, and 15. (Compl. ¶62).
Essential elements of independent claim 1 (a method) include:
- Maintaining a persona of a selected vehicle occupant.
- Determining vehicle-related information comprising one or more of vehicle context, surroundings, location, and path of travel.
- Determining, based on the persona and vehicle-related information, a type of assistance to provide.
- Performing an action assisting the occupant.
Essential elements of independent claim 8 (a vehicle) include:
- A microprocessor executable persona identification module.
- A microprocessor executable vehicle control system operable to determine vehicle-related information and an action assisting the occupant.
Essential elements of independent claim 15 (a non-transitory computer readable medium) include:
- Instructions that, when executed, cause a microprocessor to perform a method of assisting an occupant based on a persona and vehicle-related information.
The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,098,367 - "Self-configuring Vehicle Console Application Store"

Technology Synopsis: This patent addresses the technical challenge of managing software applications in a vehicle. It describes a system for an on-board "application store" that determines which applications are compatible with the vehicle's current hardware and software configuration and presents a curated list to the user, thereby ensuring stability and proper functionality. (’367 Patent, Abstract).
Asserted Claims: Independent claims 1, 10, and 17. (Compl. ¶81).
Accused Features: Infotainment systems in GM vehicles from the 2017 model year to the present that enable an in-vehicle application store or catalog. (Compl. ¶80).

U.S. Patent No. 9,116,786 - "On Board Vehicle Networking Module"

Technology Synopsis: The technology relates to a microprocessor-executable remote control module within a vehicle. This module can receive commands from a remote, authenticated owner to configure, alter, or determine the state of a vehicle component, providing a secure method for remote vehicle management. (’786 Patent, Abstract).
Asserted Claims: Independent claim 23. (Compl. ¶100).
Accused Features: Vehicle systems in GM vehicles from the 2016 model year to the present that enable Apple CarPlay and/or Android Auto. (Compl. ¶99).

U.S. Patent No. 9,140,560 - "In-Cloud Connection for Car Multimedia"

Technology Synopsis: This patent describes a vehicle communication system that connects to the cloud to manage multimedia. The system is designed to determine which devices are inside the vehicle and create a universal bus or hotspot to share data and resources between the vehicle, the cloud, and the occupants' devices. (’560 Patent, Abstract).
Asserted Claims: Independent claims 11 and 16. (Compl. ¶119).
Accused Features: In-vehicle multimedia systems in GM vehicles from the 2016 model year to the present that enable Apple CarPlay and/or Android Auto. (Compl. ¶118).

U.S. Patent No. 9,147,297 - "Infotainment System Based on User Profile"

Technology Synopsis: The technology concerns an infotainment system that adjusts its configuration based on a user profile. The system detects a user's presence and identity and modifies vehicle settings based on stored preferences in that user's profile, creating a personalized in-vehicle environment. (’297 Patent, Abstract).
Asserted Claims: Independent claims 1, 9, and 15. (Compl. ¶138).
Accused Features: Infotainment systems in GM vehicles from the 2017 model year to the present that enable user device profiles. (Compl. ¶137).

U.S. Patent No. 9,173,100 - "On board Vehicle Network Security"

Technology Synopsis: This patent describes a network security system for a vehicle's internal network. It discloses a microprocessor-executable network controller that can detect a security breach and isolate the affected on-board component to prevent the breach from affecting other components on the network. (’100 Patent, Abstract).
Asserted Claims: Independent claims 1, 9, and 17. (Compl. ¶157).
Accused Features: Hardware and software in GM vehicles from the 2017 model year to the present that enable security measures. (Compl. ¶156).

U.S. Patent No. 9,290,153 - "Vehicle-Based Multimode Discovery"

Technology Synopsis: The technology relates to a system for discovering and connecting to computational devices within or near a vehicle. A "discovery daemon" identifies devices, determines their location relative to the vehicle, and applies rules to permit or deny access to the vehicle's network and communication subsystem based on that location. (’153 Patent, Abstract).
Asserted Claims: Independent claims 1, 11, and 12. (Compl. ¶176).
Accused Features: Communication systems in GM vehicles from the 2016 model year to the present that enable Apple CarPlay and/or Android Auto. (Compl. ¶175).

U.S. Patent No. 10,862,764 - "Universal Console Chassis for the Car"

Technology Synopsis: This patent describes a physical "universal chassis" for a vehicle's head unit designed to accept interchangeable modules. This modular hardware approach allows for easier upgrades and configuration of the vehicle's infotainment and control systems by allowing different functional modules to be inserted into a common chassis form factor. (’764 Patent, Abstract).
Asserted Claims: Independent claim 1. (Compl. ¶195).
Accused Features: In-vehicle multimedia systems in GM vehicles from the 2016 model year to the present that enable Apple CarPlay and/or Android Auto. (Compl. ¶194).

U.S. Patent No. 12,039,243 - "Access and Portability of User Profiles Stored as Templates"

Technology Synopsis: The technology concerns a system for accessing and editing portable user profiles that govern vehicle functions. The system uses biometric or device identification to verify a user's authority to access a profile, which can be stored in the vehicle, in the cloud, or on a communications device, and allows the user to edit their preferences. (’243 Patent, Abstract).
Asserted Claims: Independent claims 1 and 11. (Compl. ¶214).
Accused Features: Mobile applications and in-vehicle systems in GM vehicles from the 2017 model year to the present that enable user profiles. (Compl. ¶213).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are broadly defined as certain General Motors vehicles, vehicle communication systems, and in-vehicle multimedia systems from model years 2016 to the present. (Compl. ¶¶ 42, 61, 80, 99, 118, 137, 156, 175, 194, 213). The complaint specifically identifies vehicles that enable smartphone integration platforms such as Apple CarPlay and Android Auto, as well as vehicles with the more deeply integrated "Google built-in" system and those that support user profiles via mobile apps like myChevrolet. (Compl. ¶¶ 42, 61, 80, 137, 213).

Functionality and Market Context

The accused functionalities fall into two main categories. The first is smartphone projection (Apple CarPlay, Android Auto), where a connected phone's interface is mirrored on the vehicle's central display, allowing control of phone applications through the car's native inputs. (Compl. ¶42). The second is a fully integrated infotainment OS ("Google built-in"), where applications like Google Maps and Google Assistant run directly on the vehicle's hardware, independent of a connected phone, but linked to a user's cloud-based account. (Compl. ¶61). These systems are central to the modern in-vehicle user experience and are a significant point of product differentiation and marketing for automakers. (Compl. ¶¶ 2, 8).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,020,491 Infringement Allegations

The complaint alleges that GM's infotainment systems enabling Apple CarPlay and/or Android Auto meet the limitations of exemplary claims 11 and 16. (Compl. ¶¶ 42-43). The complaint references an infringement chart attached as Exhibit A3, which is not provided. The narrative infringement theory suggests that by providing the hardware and software for these platforms, GM's systems establish a "communication session" between a user's phone and the vehicle, creating a "universal bus" that allows access to the vehicle's systems and data, thereby practicing the claimed invention. (Compl. ¶¶ 42-43).

Identified Points of Contention:
- Scope Questions: A central issue may be whether the term "universal bus," as defined and used in the patent, can be construed to cover the specific software-based communication protocols of Apple CarPlay and Android Auto. The defense may argue that the patent teaches a specific type of vehicle-centric hardware or network architecture, whereas the accused systems are largely software protocols dependent on the phone's operating system.
- Technical Questions: The analysis may turn on how the accused systems "provide access to the vehicle bus" as required by claim 11. A question for the court will be what level of access and control CarPlay/Android Auto provides to the vehicle's core bus (e.g., CAN bus) versus a more limited, sandboxed connection to only the infotainment head unit.

U.S. Patent No. 9,082,239 Infringement Allegations

The complaint alleges that GM's "Google built-in" systems infringe exemplary claims 1, 8, and 15 of the ’239 Patent. (Compl. ¶¶ 61-62). An infringement chart is referenced as Exhibit B3 but is not provided. The complaint's theory is that these integrated systems collect vehicle data (e.g., location, speed) and user data (via a logged-in Google account) to create a "persona" and provide "assistance" in the form of navigation, alerts, and other contextual suggestions, thereby meeting the claim limitations for an "intelligent vehicle." (Compl. ¶¶ 61-62).

Identified Points of Contention:
- Scope Questions: A key question will be the scope of "persona" and "assisting the vehicle occupant." The defense may argue that these terms, in the patent's context, require a more sophisticated level of vehicle-specific intelligence and autonomous action than what is performed by the accused systems, which largely provide conventional infotainment and navigation functions tied to a general-purpose Google account.
- Technical Questions: A factual dispute may arise over whether the accused "Google built-in" system actually "perform[s] an action assisting the selected vehicle occupant" that goes beyond merely presenting information. The analysis will likely focus on evidence of the system's ability to modify vehicle operations or make intelligent inferences based on the combination of the occupant's persona and real-time vehicle data, as claimed.

V. Key Claim Terms for Construction

For the ’491 Patent:
- The Term: "universal bus"
- Context and Importance: This term is central to both asserted independent claims (11 and 16). Its construction will determine whether the software-based connectivity protocols of CarPlay and Android Auto fall within the scope of what the patent claims. Practitioners may focus on this term because its definition could distinguish between a specific hardware implementation and a more conceptual, protocol-agnostic communication link.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification describes the bus as a "subsystem that transfers information and/or data between various components" and notes it can be for a "wired network... or wireless network." (’491 Patent, col. 4:11-19). This language may support a broader construction covering various forms of data transfer links.
  - Evidence for a Narrower Interpretation: The detailed description refers to the bus in the context of specific vehicle network architectures like the CAN bus and linkages to the vehicle's "head unit." (’491 Patent, col. 4:40-57). This could support a narrower interpretation tied more closely to the vehicle's integrated hardware rather than a temporary, phone-driven software link.
For the ’239 Patent:
- The Term: "persona of a selected vehicle occupant"
- Context and Importance: This term appears in all asserted independent claims (1, 8, and 15) and is foundational to the patent's concept of an "intelligent vehicle." The case may turn on whether a standard Google user account, with its associated general data (e.g., calendar, search history), constitutes the claimed "persona," which the patent links to vehicle-specific context and assistance.
- Intrinsic Evidence for Interpretation:
  - Evidence for a Broader Interpretation: The specification states the persona may be based on "biometrics, personal information, driving history, historical information... user settings and feature preferences," which is a broad definition that could encompass data stored in a Google account. (’239 Patent, col. 24:1-20).
  - Evidence for a Narrower Interpretation: The patent repeatedly links the "persona" to a "vehicle ecosystem" and describes its use in providing vehicle-specific assistance. For example, the specification describes using the persona to determine an "emotional state" and provide an "automated vehicle response." (’239 Patent, col. 12:1-12; col. 22:50-53). This may support a narrower construction requiring a deeper, more vehicle-centric profile than a general-purpose cloud account.

VI. Other Allegations

Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is primarily based on allegations that Defendant provides instructions, user manuals, and promotional materials that encourage and instruct customers on how to use the accused systems in an infringing manner. (Compl. ¶¶ 45-46, 64-65, 83-84). Contributory infringement is based on allegations that Defendant sells and supplies key software components that are a material part of the claimed inventions, are not staple articles of commerce, and are known to be especially made for an infringing use. (Compl. ¶¶ 49, 68, 87).
Willful Infringement: Willfulness is alleged for all asserted patents. The claims are based on alleged pre-suit knowledge from at least two sources: (1) Defendant's alleged encounters with the asserted patents and related applications during the prosecution of its own patents (Compl. ¶¶ 47, 66, 85); and (2) direct notice from Plaintiff via a letter and claim charts sent in December 2023, followed by several months of correspondence before the suit was filed (Compl. ¶¶ 34-38, 52-53, 71-72). The complaint also alleges that Defendant has not taken any affirmative steps to avoid infringement since learning of the patents. (Compl. ¶¶ 54, 73).

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

A core issue will be one of technological scope: The asserted patents claim inventions conceived between 2011 and 2021 related to vehicle ecosystems, intelligent assistance, and application management. A central question for the court will be whether the language of these patents, interpreted in light of their specifications, can be construed broadly enough to read on the specific, and rapidly evolving, software implementations of Apple CarPlay, Android Auto, and Google built-in.
A second key issue will be one of knowledge and intent: The complaint alleges extensive pre-suit notice, including detailed claim charts, and further alleges that Defendant encountered the patented technology during its own patent prosecution activities. The court will need to resolve factual questions regarding the timing and sufficiency of this notice to determine whether Defendant’s alleged infringement was willful, which could expose Defendant to enhanced damages.
A final question will be one of patent-by-patent functionality: With ten patents asserted against overlapping sets of vehicle features, the case will likely require a detailed technical analysis to determine whether the distinct functions of each accused system (e.g., smartphone projection vs. embedded OS) map to the specific solutions claimed in each distinct patent (e.g., a "universal bus," an "intelligent assistant," a "self-configuring app store").