DCT
2:24-cv-01013
Vision Works IP Corp v. Jaguar Land Rover Automotive
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vision Works IP Corp. (Washington)
- Defendant: Jaguar Land Rover Automotive PLC (United Kingdom)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:24-cv-01013, E.D. Tex., 12/09/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant conducts substantial business in the district, has committed and continues to commit acts of infringement there, and ships, distributes, and sells the accused products through authorized dealerships within the district.
- Core Dispute: Plaintiff alleges that Defendant’s vehicle control systems, including the JLR Integrated Chassis Control System, InControl Remote Climate feature, and Country Road Assist, infringe six U.S. patents related to the use of acceleration sensors for vehicle performance, safety, and efficiency.
- Technical Context: The technology at issue involves advanced automotive systems that use sensor data to actively manage vehicle dynamics, fuel consumption, and collision avoidance, representing a significant area of innovation and competition in the modern automotive market.
- Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the patents-in-suit, or any prior licensing history.
Case Timeline
| Date | Event |
|---|---|
| 2004-10-05 | Earliest Priority Date for all Patents-in-Suit |
| 2012-11-20 | U.S. Patent No. 8,315,769 Issues |
| 2013-05-07 | U.S. Patent No. 8,437,935 Issues |
| 2014-03-25 | U.S. Patent No. 8,682,558 Issues |
| 2017-11-28 | U.S. Patent No. 9,830,821 Issues |
| 2019-09-10 | U.S. Patent No. 10,410,520 Issues |
| 2019-10-08 | U.S. Patent No. 10,436,125 Issues |
| 2024-12-09 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,315,769 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 8,315,769, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued November 20, 2012. (Compl. ¶16).
The Invention Explained
- Problem Addressed: The patent family addresses the limitations of prior art accelerometer-based systems, which struggle to precisely distinguish gravitational forces (e.g., from hills or banked curves) from a vehicle's true acceleration or deceleration. This ambiguity complicates the reliable detection of subtle changes in motion necessary for early-warning safety and performance systems (’520 Patent, col. 2:1-20).
- The Patented Solution: The invention claims a method for controlling vehicle performance by sensing the vehicle's lateral acceleration and, based on that signal, sending a signal to control devices that adjust a suspension characteristic. (Compl. ¶17, ¶22). This use of sensor data allows for real-time adjustments to optimize vehicle handling, particularly during cornering (’769 Patent, Abstract).
- Technical Importance: This approach allows for more dynamic and responsive vehicle suspension systems, moving beyond static setups to systems that adapt to immediate driving conditions. (Compl. ¶17).
Key Claims at a Glance
- The complaint asserts Claims 21-25, with Claim 21 being the sole independent claim asserted. (Compl. ¶22).
- Independent Claim 21 (Method):
- A method of controlling the performance characteristics of a vehicle.
- Sensing a lateral acceleration of the vehicle at the vehicle.
- Sending a signal to a plurality of control devices based upon the lateral acceleration of the vehicle.
- Adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle.
- The complaint does not explicitly reserve the right to assert other claims, but standard practice allows for amending such contentions.
U.S. Patent No. 8,437,935 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 8,437,935, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued May 7, 2013. (Compl. ¶36).
The Invention Explained
- Problem Addressed: The patent addresses fuel waste and pollution caused by motor vehicles remaining in an "idling" state while parked or not in use, which is a target of environmental regulations. (’520 Patent, col. 2:64-col. 3:12).
- The Patented Solution: The invention provides a method to automatically shut down an idling engine to conserve fuel and reduce emissions. (Compl. ¶37). The system senses that a vehicle is stationary, activates a timer for a "deactivation time window," confirms the vehicle's transmission is in park, and then sends a signal to turn off the engine. (Compl. ¶42; ’935 Patent, Fig. 11).
- Technical Importance: The technology provides an automated solution to comply with anti-idling laws and improve vehicle fuel efficiency without requiring driver intervention. (Compl. ¶37).
Key Claims at a Glance
- The complaint asserts Claims 1, 3, 4, 5, 6, 10, 11, 12, and 14, with Claim 1 being the lead independent claim. (Compl. ¶42).
- Independent Claim 1 (Method):
- A method of automatically turning off an idling engine of a vehicle.
- Sensing a stationary status of the vehicle.
- Activating an idling timer with a deactivation time window.
- Detecting a transmission park-status of the vehicle.
- Wherein if the vehicle is stationary, the idling timer is activated and configured to send a de-activation signal to turn off the engine once the deactivation time window has expired and the transmission park-status of the vehicle is confirmed.
- The complaint asserts several dependent claims alongside the independent claim. (Compl. ¶42).
U.S. Patent No. 8,682,558 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 8,682,558, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued March 25, 2014. (Compl. ¶56).
- Technology Synopsis: The patent describes a system that uses measurements of a vehicle's absolute acceleration to control its performance systems. (Compl. ¶57). It employs an accelerometer-gyroscope to sense acceleration and a computer unit to operate vehicle systems based on those sensor signals. (Compl. ¶62).
- Asserted Claims: At least Claim 21 (independent system claim). (Compl. ¶62).
- Accused Features: The JLR Integrated Chassis Control system is accused of infringing this patent. (Compl. ¶61).
U.S. Patent No. 9,830,821 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 9,830,821, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued November 28, 2017. (Compl. ¶76).
- Technology Synopsis: The patent discloses a vehicle safety system that communicates information about the vehicle's speed and its distance to a nearby object. (Compl. ¶77). It provides for a "safe-zone threshold" that increases as the vehicle's speed increases, creating a dynamic safety buffer. (Compl. ¶82).
- Asserted Claims: Claims 12, 13, 14, 15, 17, and 18 (Claim 12 is independent). (Compl. ¶82).
- Accused Features: The JLR Country Road Assist feature is accused of infringing this patent. (Compl. ¶81).
U.S. Patent No. 10,410,520 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 10,410,520, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued September 10, 2019. (Compl. ¶96).
- Technology Synopsis: Similar to the ’821 Patent, this patent relates to a vehicle safety system for communicating speed and distance to a nearby vehicle. (Compl. ¶97). It describes determining a safe distance by calculating the distance to an object and comparing it to a constant value defined according to the vehicle's speed. (Compl. ¶102).
- Asserted Claims: Claims 1, 2, 3, 5, 9, 10, 12, 13, 14, 16, 20, 21, 22, and 23 (Claim 1 is independent). (Compl. ¶102).
- Accused Features: The JLR Country Road Assist feature is accused of infringing this patent. (Compl. ¶101).
U.S. Patent No. 10,436,125 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
- Patent Identification: U.S. Patent No. 10,436,125, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued October 8, 2019. (Compl. ¶116).
- Technology Synopsis: This patent describes a method for saving fuel and reducing emissions by automatically shutting down an idling engine. (Compl. ¶117). The method includes detecting that a vehicle has stopped, detecting a non-drive transmission status, and activating a shutdown timer. (Compl. ¶122).
- Asserted Claims: Claims 1, 7, and 11 (Claim 1 is independent). (Compl. ¶122).
- Accused Features: The JLR InControl Remote Climate feature is accused of infringing this patent. (Compl. ¶121).
III. The Accused Instrumentality
Product Identification
- The complaint identifies three accused instrumentalities: the JLR Integrated Chassis Control System, the JLR InControl Remote Climate feature, and the JLR Country Road Assist. (Compl. ¶14).
Functionality and Market Context
- JLR Integrated Chassis Control System: This system is alleged to control vehicle performance by sensing lateral acceleration and adjusting suspension characteristics accordingly. (Compl. ¶22). It is also alleged to use an accelerometer-gyroscope to sense absolute acceleration to operate one or more performance systems. (Compl. ¶62).
- JLR InControl Remote Climate feature: This feature is alleged to provide a method for automatically shutting down an idling engine by sensing a stationary status, activating a timer, and confirming a "park" or "non-drive" transmission status before deactivating the engine. (Compl. ¶42, ¶122).
- JLR Country Road Assist: This feature is alleged to be a safety system that calculates the distance to an object and determines if the vehicle is within a safe-zone threshold that is dynamically set based on the vehicle's speed. (Compl. ¶82, ¶102).
- The complaint alleges these features are offered in premium vehicles manufactured by Defendant, but provides limited detail on their specific market penetration or commercial success beyond being a "source of revenue and a business focus." (Compl. ¶28, ¶48).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
8,315,769 Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of controlling the performance characteristics of a vehicle, comprising: sensing a lateral acceleration of the vehicle at the vehicle; | The JLR Integrated Chassis Control System provides a method for controlling vehicle performance by sensing its lateral acceleration. | ¶22 | col. 26:21-23 |
| sending a signal to a plurality of control devices based upon the lateral acceleration of the vehicle; | The system sends a signal to a plurality of control devices based upon the vehicle's lateral acceleration. | ¶22 | col. 26:24-26 |
| and adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle. | The system adjusts a suspension characteristic of the vehicle based upon the lateral acceleration. | ¶22 | col. 26:27-29 |
8,437,935 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of automatically turning off an idling engine of a vehicle, comprising: sensing a stationary status of the vehicle; | The JLR InControl Remote Climate feature provides a method for automatically turning off an idling engine by sensing a stationary status of the vehicle. | ¶42 | col. 28:51-52 |
| activating an idling timer with a deactivation time window; | The system activates an idling timer with a deactivation time window. | ¶42 | col. 28:53-54 |
| and detecting a transmission park-status of the vehicle, | The system detects a transmission park-status of the vehicle. | ¶42 | col. 28:55-56 |
| wherein if the vehicle is stationary, the idling timer is activated and is configured to send a de-activation signal to turn off the engine once the deactivation time window has expired and the transmission park-status of the vehicle is confirmed. | If the vehicle is stationary, the idling timer is activated and sends a de-activation signal to turn off the engine once the deactivation time window has expired and the transmission park-status is confirmed. | ¶42 | col. 28:57-62 |
- Identified Points of Contention:
- Direct vs. Indirect Infringement: Both the ’769 and ’935 patents have method claims asserted. The complaint accuses Defendant of direct infringement by its "provision" of the systems, and also pleads indirect infringement theories based on customer use. (Compl. ¶22-27, ¶42-47). A potential point of contention is whether Defendant, as the system provider, can be held liable for directly performing the steps of the claimed methods, which may be fully executed only when the vehicle is in operation by an end-user.
- Technical Scope: For the ’769 Patent, a question may arise as to whether the accused "Integrated Chassis Control System" constitutes the claimed "plurality of control devices" or if the claim requires physically distinct controllers. For the ’935 Patent, the analysis may focus on what evidence demonstrates the accused feature uses an "idling timer with a deactivation time window" as claimed, rather than a more generic engine management process that achieves a similar result.
V. Key Claim Terms for Construction
’769 Patent, Claim 21
- The Term: "plurality of control devices"
- Context and Importance: The infringement theory hinges on mapping the allegedly singular "JLR Integrated Chassis Control System" onto this claim element. Practitioners may focus on this term because its construction will determine whether a single, integrated software-based controller can satisfy a limitation that, on its face, suggests multiple hardware components.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification may describe "control devices" in functional terms, potentially encompassing different software modules within a single ECU that control various aspects of the vehicle, which could support a broader reading.
- Evidence for a Narrower Interpretation: The patent’s detailed description and figures may exclusively depict embodiments with separate, physically distinct controllers for different parts of the suspension system (e.g., one for each wheel), which could support a narrower construction requiring multiple hardware units. (’769 Patent, Fig. 4, showing separate controls 431, 441, 451, 461).
’935 Patent, Claim 1
- The Term: "deactivation time window"
- Context and Importance: The complaint alleges the accused feature operates for a "predetermined period of time." (Compl. ¶42). The key dispute will be whether this is synonymous with the claimed "deactivation time window." The definition is critical, as a "window" could imply a period with distinct start and end conditions beyond a simple countdown.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification might use terms like "period," "time," and "window" interchangeably, suggesting the patentee did not intend a specific technical meaning distinct from a predetermined duration. (’935 Patent, col. 28:53-54).
- Evidence for a Narrower Interpretation: The prosecution history of the patent family may reveal distinctions made between a "period of time" and a "time window" to overcome prior art. For instance, the related ’125 Patent claims a "shutdown timer configured to shutdown the vehicle after a predetermined period of time," suggesting the patentees used different phrasing for what may be distinct concepts.
VI. Other Allegations
- Indirect Infringement: For all six patents-in-suit, the complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant instructs customers on how to use the accused features through websites, brochures, and promotional materials. (Compl. ¶24-26, ¶44-46, ¶64-66, ¶84-86, ¶104-106, ¶124-126). Contributory infringement is based on allegations that the accused systems have special features specifically designed for infringing use and are not staple articles of commerce with substantial non-infringing uses. (Compl. ¶27, ¶47, ¶67, ¶87, ¶107, ¶127).
- Willful Infringement: The complaint alleges willfulness on two grounds for each patent. First, it alleges post-suit willfulness based on Defendant's continued infringement despite having knowledge of the patents since at least the filing of the complaint. (Compl. ¶32, ¶52, ¶72, ¶92, ¶112, ¶132). Second, it alleges pre-suit willfulness by asserting that Defendant has a policy or practice of not reviewing the patents of others, constituting willful blindness. (Compl. ¶30, ¶50, ¶70, ¶90, ¶110, ¶130).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of direct infringement for method claims: can Plaintiff establish that Defendant, by providing integrated vehicle systems, is directly performing the steps of the asserted methods, or will liability depend entirely on proving indirect infringement through the actions of vehicle operators?
- A key battleground will be claim construction: can terms rooted in an earlier technological context, such as "plurality of control devices" and "idling timer," be construed to cover the integrated, software-driven architecture of modern automotive systems, or is there a fundamental mismatch in scope?
- A central question for damages will be willfulness: beyond the standard allegation of post-suit willfulness, can Plaintiff substantiate its claim that Defendant maintained a pre-suit policy of "willful blindness," which would significantly elevate the risk of enhanced damages?