DCT
2:24-cv-00933
Longhorn Automotive Group LLC v. Volkswagen AG
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Longhorn Automotive Group LLC (Texas)
- Defendant: Volkswagen AG (Germany) and Audi AG (Germany)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:24-cv-00933, E.D. Tex., 04/18/2025
- Venue Allegations: Venue is alleged to be proper because Defendants are not U.S. residents and thus may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that a wide range of Volkswagen and Audi vehicles, along with their associated components and services, infringe five patents related to adaptive headlights, vehicle monitoring systems, direct injection engines, driver assistance sensors, and GPS data security.
- Technical Context: The technologies at issue represent key areas of innovation in the modern automotive market, including advanced driver-assistance systems (ADAS), connected vehicle services, and powertrain efficiency.
- Key Procedural History: The filing is an Amended Complaint for Patent Infringement, indicating it follows an original complaint and potentially a responsive pleading or court order that prompted the amendment.
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 |
| 2005-09-06 | ’192 Patent Priority Date |
| 2007-11-12 | ’803 Patent Priority Date |
| 2009-04-07 | U.S. Patent No. 7,513,238 Issued |
| 2011-07-26 | U.S. Patent No. 7,987,002 Issued |
| 2011-12-27 | U.S. Patent No. 8,085,192 Issued |
| 2012-09-11 | U.S. Patent No. 8,265,353 Issued |
| 2014-08-19 | U.S. Patent No. 8,810,803 Issued |
| 2020-10-14 | Audi announces Digital Matrix LED headlights for 2021 e-tron models |
| 2025-04-18 | Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,810,803 - "Lens System"
- Patent Identification: U.S. Patent No. 8,810,803, "Lens System," issued August 19, 2014.
The Invention Explained
- Problem Addressed: The patent describes a problem in computer vision systems where regular, repeating light patterns projected onto a scene can make it difficult to reliably detect objects, as the pattern can appear to match the background at certain distances (’803 Patent, col. 1:20-30).
- The Patented Solution: The invention proposes a system to create a complex, semi-random dot pattern of light. It uses a light source with multiple emitters (e.g., LEDs) arranged in a pattern, an optional condenser lens to concentrate the light, and a "cluster of lenses" that focuses and projects the light from the emitters in numerous directions (’803 Patent, Abstract; col. 2:38-50). This projected texture allows a computer vision system to uniquely identify different parts of an object, improving depth perception and object tracking (’803 Patent, col. 2:28-34).
- Technical Importance: This approach provides a method for generating robust, non-repeating textures on surfaces, which is a critical need for stereo vision and structured light 3D scanning systems to function accurately.
Key Claims at a Glance
- The complaint asserts at least independent claim 15 (Compl. ¶25).
- Claim 15 requires:
- 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 emitters.
- A condenser lens located between the light source and the lens cluster, configured to concentrate light from 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"
- Patent Identification: U.S. Patent No. 7,987,002, "Arrangement for Distributed Measurement System for Measurement and Simulation in Distributed Control Systems," issued July 26, 2011.
The Invention Explained
- Problem Addressed: The patent addresses the complexity of measuring, analyzing, and monitoring distributed control systems, such as the network of electronic control units (ECUs) in a modern vehicle. These systems often use specialized protocols (like CAN bus), making it difficult to interface with standard tools (like a PC or PDA) that use different protocols (like USB or Bluetooth) (’002 Patent, col. 1:31-48).
- The Patented Solution: The invention describes a hierarchical monitoring architecture. An "interface unit" connects directly to the vehicle's internal control system using a "second protocol" (e.g., CAN). A "plurality of monitoring units" then communicate with this interface unit using a "first protocol" (e.g., a wireless protocol like cellular or Bluetooth). These monitoring units are divided into at least one "complex" unit (e.g., a remote server) that can receive a wide range of data and generate instructions, and at least one "basic" unit (e.g., a user's PDA or smartphone) that receives instructions from the complex unit and accesses a smaller "subset" of the vehicle data (’002 Patent, Abstract; claim 15).
- Technical Importance: This system provides a flexible framework for remote diagnostics and telematics, allowing different levels of users and systems to access vehicle data over standard communication channels without needing direct, physical access to the vehicle's internal network.
Key Claims at a Glance
- The complaint asserts at least independent claim 15 (Compl. ¶39).
- Claim 15 requires:
- A plurality of monitoring units communicating with an interface unit using a first protocol.
- The interface unit is connected to a distributed control system and receives data from it using a second protocol.
- The monitoring units include at least one complex unit and at least one basic unit.
- The complex unit receives data from the interface unit and generates programmatic instructions for the basic unit.
- The basic unit receives the instructions and, in response, receives a subset of data from the interface unit.
- 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"
- Patent Identification: U.S. Patent No. 7,513,238, "Directly Injecting Internal Combustion Engine," issued April 7, 2009.
- Technology Synopsis: The patent describes a technical problem of optimizing fuel-air mixture in direct-injection engines that need to operate in different combustion modes (e.g., early vs. late injection) (’238 Patent, col. 1:25-48). The purported solution is a piston with a specially shaped recess, including a central elevation and a surface contoured to ensure the fuel jet is properly distributed within the combustion chamber regardless of the injection timing, thereby improving combustion efficiency and reducing emissions (’238 Patent, Abstract).
- Asserted Claims: At least independent claim 1 (Compl. ¶54).
- Accused Features: The complaint accuses Volkswagen and Audi's FSI Direct Injection engines, as used in vehicles like the Audi Q7. The infringement theory focuses on the physical geometry of the engine's pistons, alleging that the shape of the piston recess matches the features required by the patent's claims (Compl. ¶55, ¶57).
U.S. Patent No. 8,265,353 - "Method of Reconstructing an Image Acquired Using Several Imagery Modes"
- Patent Identification: U.S. Patent No. 8,265,353, "Method of Reconstructing an Image Acquired Using Several Imagery Modes," issued September 11, 2012.
- Technology Synopsis: The patent, rooted in medical imaging, addresses the challenge of creating a clear image of a moving object when using multiple imaging types (’353 Patent, col. 1:4-8). The solution is a method where one imaging technique that is effective at capturing motion (e.g., an attenuation scan) is used to calculate a "displacement field," which quantifies the object's movement. This displacement data is then used to correct and enhance the images from a second, different imaging technique (e.g., an emission scan), resulting in a clearer final image (’353 Patent, Abstract).
- Asserted Claims: At least independent claim 1 (Compl. ¶70).
- Accused Features: The complaint targets VW's IQ.Drive and Audi's Pre Sense driver assistance systems, which rely on a central controller (zFAS) to process sensor data. The infringement theory alleges these systems practice the patented method by obtaining data from a first set of sensors (e.g., 360-degree cameras and ultrasonic sensors) and a second, independent set of sensors (e.g., front camera and radar), and fusing this data to form a comprehensive image of the vehicle's surroundings (Compl. ¶71-76).
U.S. Patent No. 8,085,192 - "Device, System and Method for Controlling and Storing Sensitive Information on a GPS Device"
- Patent Identification: U.S. Patent No. 8,085,192, "Device, System and Method for Controlling and Storing Sensitive Information on a GPS Device," issued December 27, 2011.
- Technology Synopsis: The patent addresses the privacy risk of sensitive information (e.g., home address, route history) stored on GPS devices (’192 Patent, col. 1:35-43). The invention is a GPS device with an encryption module to secure location data, a storage module (which can be removable like an SD card) to hold the encrypted data, and a processing module that controls access based on a user-provided code string (’192 Patent, Abstract).
- Asserted Claims: At least independent claim 1 (Compl. ¶88).
- Accused Features: The complaint accuses VW and Audi infotainment and navigation systems (e.g., MIB 3 in the Audi A3). The infringement theory points to the system's use of a GPS for location data, data encryption features, a removable SD card for storage, and a processor that sends and retrieves encrypted information to and from the SD card (Compl. ¶89-94).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are broadly defined to include numerous Volkswagen and Audi vehicle models, as well as specific subsystems like headlight systems, internal combustion engines, driver assistance systems (IQ.Drive, Audi Pre Sense), connected vehicle platforms (Volkswagen Car-Net, Audi Connect), and infotainment systems (MIB 3) (Compl. ¶15). The complaint identifies specific exemplary vehicles for each patent, including the Audi e-tron Sportback 55 quattro, Audi A8, Audi Q7, and Audi A3 (Compl. ¶24, ¶40, ¶53, ¶70, ¶87).
Functionality and Market Context
- The accused functionalities represent high-value features in modern vehicles. The Digital Matrix LED headlights are alleged to use 1.3 million micromirrors per headlight to project adaptable light patterns onto the road (Compl. p. 9). The Audi Connect system is alleged to provide remote access to vehicle data and functions (e.g., location, status, locking) via the myAudi smartphone app, which communicates with the vehicle's internal network through a telematics control unit and a remote server platform (Compl. ¶41-42). These features are marketed as providing enhanced safety, convenience, and performance.
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 accused headlight system includes LED lights as the light source, which comprise multiple emitters. | ¶27 | col. 2:39-41 |
| 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 | The accused headlight contains a projector lens system ("Projektionslinse") that receives light from the LED emitters. | ¶28 | col. 2:42-44 |
| and 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 | The system includes a "primary optic with a mirror" positioned between the LED light source and the projection lens cluster, which allegedly concentrates the light. A cutaway diagram illustrates this light path (Compl. p. 14, fig. 14). | ¶29 | col. 2:56-59 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused "primary optic with a mirror" (Compl. ¶29) constitutes a "condenser lens" as that term is used in the patent. The analysis will likely focus on whether this component performs the claimed function of "concentrating light... towards a center of the cluster of lenses."
- Technical Questions: The complaint states the accused headlights use a digital micromirror device (DMD) with 1.3 million mirrors to create the final light pattern (Compl. p. 9). A point of contention could be whether the claimed lens system is the primary component forming the pattern, or if the DMD technology, which is not recited in the claim, is performing the essential function, potentially suggesting a mismatch between the claim and the accused product's operation.
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 myAudi app and the Audi Connect Server Platform (monitoring units) communicate with the vehicle's telematics control unit (TCU) (interface unit) using a cellular network (first protocol). | ¶41, ¶42 | col. 16:16-18 |
| wherein the at least one interface unit is communicably connected to a distributed control system, and the at least one interface unit 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) via a CAN bus (distributed control system) and receives data using CAN communication (second protocol). A wiring diagram shows this connection (Compl. p. 27, fig. 32). | ¶41 | col. 16:19-23 |
| wherein the plurality of monitoring units comprises at least one complex monitoring unit and at least one basic monitoring unit | The system is alleged to comprise the Audi Connect Server Platform as the complex unit and the myAudi app as the basic unit. | ¶42 | col. 16:24-26 |
| wherein the at least one complex monitoring unit is configured to receive a plurality of data values from the at least one interface unit...and to generate programmatic instructions for the at least one basic monitoring unit | The Audi Connect Server Platform is alleged to receive data like engine performance and vehicle speed from the TCU and generate programmatic instructions for the myAudi app. | ¶43 | col. 16:27-31 |
| 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 myAudi app allegedly receives instructions and, in response, receives a subset of data (e.g., vehicle status) from the TCU over the cellular network. | ¶44 | col. 16:32-36 |
- Identified Points of Contention:
- Scope Questions: The dispute may turn on the meaning of "generate programmatic instructions." The question will be whether the accused server platform is merely relaying user requests from the app to the vehicle, or if it is actively generating new instructions for the app to execute, as required by the claim.
- Technical Questions: The complaint alleges the basic unit (myAudi app) receives data "from the at least one interface unit" (the vehicle's TCU). A factual question will be whether the app communicates directly with the TCU or if all data is routed through and mediated by the server (the complex unit). The specific data flow architecture of the Audi Connect system will be critical to this analysis.
V. Key Claim Terms for Construction
’803 Patent
- The Term: "condenser lens"
- Context and Importance: The infringement case for the '803 patent hinges on this term, as the complaint maps it to the accused "primary optic with a mirror" (Compl. ¶29). The construction of "condenser lens" will determine whether this alleged equivalent structure falls within the scope of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional definition, stating the component "concentrates light" and lists multiple possible structures, including "one or more prisms" ('803 Patent, col. 3:39-45). This may support an argument that any component performing the light-concentrating function, including one with a mirror, meets the definition.
- Evidence for a Narrower Interpretation: The patent figures depict the condenser lens as a transmissive optical element (e.g., Fig. 4, element 120). A defendant may argue that the term should be limited to such refractive lenses and does not encompass reflective optical components like a mirror.
’002 Patent
- The Term: "generate programmatic instructions"
- Context and Importance: This term defines the core function of the "complex monitoring unit." Practitioners may focus on this term because infringement depends on whether the Audi Connect Server Platform's role transcends that of a simple data relay and involves the active creation of instructions for the myAudi app.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent discusses modifying modules "by means of instructions for special tasks and measurement configurations," which are "downloaded to the PDA in configuration files" (’002 Patent, col. 7:49-53, col. 14:47-49). This could support a broad reading where "programmatic instructions" include configuration data or high-level commands that direct the behavior of the basic unit.
- Evidence for a Narrower Interpretation: A defendant could argue that "generate" implies the creation of new, executable code or detailed command sequences, rather than simply passing along pre-defined requests initiated by the user via the basic unit (the app).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The allegations are based on Defendants supplying the Accused Products to customers with instructions on how to use the infringing features, such as through owner's manuals, websites, and other product literature (Compl. ¶31, ¶46, ¶62, ¶80, ¶97).
- Willful Infringement: Willfulness is alleged based on a theory of willful blindness. The complaint asserts that Defendants have a policy of not reviewing the patents of others, and that there was a high probability they would have learned of their infringement, but remained willfully blind, starting from the issue date of each respective patent (Compl. ¶30, ¶46, ¶61, ¶79, ¶96). Post-suit knowledge is established by reference to the "Original Complaint" (Compl. ¶30).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents a broad challenge to core technologies in modern Volkswagen and Audi vehicles. The outcome will likely depend on the court's resolution of several key questions:
- A primary issue will be one of structural and functional equivalence: For the '803 patent, can a "primary optic with a mirror" in an advanced DMD headlight be construed as the claimed "condenser lens," and does the claimed lens system, rather than the unmentioned DMD technology, perform the primary pattern-forming function?
- A second core issue will be one of definitional scope and system architecture: For the '002 patent, does the accused server platform's function in the connected vehicle system meet the claim requirement of "generat[ing] programmatic instructions" for the mobile app, or does it operate as a simpler data intermediary?
- A recurring question across multiple patents will be one of technological application: Can claims drafted in one technological context (e.g., medical imaging for the '353 patent) be read to cover the distinct operations of a modern automotive driver-assistance system that fuses data from disparate sensors like cameras and radar?