DCT

2:25-cv-00046

Fleet Connect Solutions LLC v. AutoZone Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00046, E.D. Tex., 01/16/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established and regular place of business in the Eastern District of Texas and has committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s use of Trimble fleet management platforms and telematics devices infringes twelve U.S. patents related to logistics systems, wireless communications, and mobile asset management.
  • Technical Context: Fleet management and telematics technologies are central to modern logistics, enabling companies to track vehicles, monitor maintenance schedules, and optimize routing for large commercial fleets.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the Asserted Patents. Certificates of Correction have been issued for several of the asserted patents, which may be relevant to claim construction.

Case Timeline

Date Event
2000-02-01 Priority Date for U.S. Patent No. 6,429,810
2000-09-11 Priority Date for U.S. Patent No. 6,647,270
2001-08-21 Priority Date for U.S. Patent No. 6,633,616
2001-09-17 Priority Date for U.S. Patent No. 6,961,586
2002-08-06 U.S. Patent No. 6,429,810 Issues
2003-01-10 Priority Date for U.S. Patent No. 6,941,223
2003-10-14 U.S. Patent No. 6,633,616 Issues
2003-11-11 U.S. Patent No. 6,647,270 Issues
2005-09-06 U.S. Patent No. 6,941,223 Issues
2005-11-01 U.S. Patent No. 6,961,586 Issues
2006-09-20 Priority Date for U.S. Patent No. 7,463,896
2006-09-20 Priority Date for U.S. Patent No. 7,450,955
2008-01-23 Priority Date for U.S. Patent No. 7,536,189
2008-06-20 Priority Date for U.S. Patent No. 7,701,360
2008-11-11 U.S. Patent No. 7,450,955 Issues
2008-12-09 U.S. Patent No. 7,463,896 Issues
2009-02-19 Priority Date for U.S. Patent No. 7,599,715
2009-05-19 U.S. Patent No. 7,536,189 Issues
2009-10-06 U.S. Patent No. 7,599,715 Issues
2010-01-29 Priority Date for U.S. Patent No. 8,005,053
2010-04-20 U.S. Patent No. 7,701,360 Issues
2011-08-23 U.S. Patent No. 8,005,053 Issues
2013-06-24 Priority Date for U.S. Patent No. 8,862,184
2014-10-14 U.S. Patent No. 8,862,184 Issues
2020-05-31 Date of Trimble case study regarding AutoZone's use of Accused Products
2025-01-16 Complaint Filing Date

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

U.S. Patent No. 6,429,810 - “Integrated Air Logistics System,” issued August 6, 2002.

The Invention Explained

  • Problem Addressed: The patent’s background section describes that tracking freight is a difficult and labor-intensive process, often complicated by the involvement of multiple independent companies, last-minute shipping changes, and a reliance on manual data entry that can be incorrect or delayed (’810 Patent, col. 1:23-68).
  • The Patented Solution: The invention proposes an autonomous cargo tracking system featuring a position sensing and communication (PSC) unit affixed to a shipping container. This unit uses a GPS satellite constellation to determine its location and a communication satellite constellation to report that location to a ground system, which can then make status information available to users via an Internet web site (’810 Patent, Abstract; col. 2:17-34).
  • Technical Importance: The technology aimed to provide shippers and forwarders with more accurate and timely cargo status by automating the tracking process, reducing reliance on human operators and manual scans (’810 Patent, col. 2:11-15).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶26).
  • Claim 1 is a method for providing container status information to a user, comprising the essential elements of:
    • attaching an electronic communications unit to a shipping container;
    • generating a transaction identification code specific to the container and a user transaction;
    • initiating a status inquiry by a user with that code;
    • receiving the inquiry at a ground communications system;
    • transmitting the inquiry from the ground system to the electronic unit;
    • obtaining a status information response from the electronic unit;
    • transmitting the response from the electronic unit back to the ground system; and
    • forwarding the response from the ground system to the user.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,005,053 - “Channel Interference Reduction,” issued August 23, 2011.

The Invention Explained

  • Problem Addressed: The patent addresses radio frequency (RF) interference that occurs when multiple wireless technologies, such as Bluetooth and IEEE 802.11 (Wi-Fi), operate simultaneously in the same unlicensed radio band, like 2.4 GHz (’053 Patent, col. 1:12-20, 1:39-42).
  • The Patented Solution: The invention describes an apparatus containing at least two different wireless transceivers. A controller selects one of the transceivers to handle communications and avoids interference by encoding data from the unselected transceiver’s protocol into the data format of the selected transceiver’s protocol for transmission, rather than transmitting on both simultaneously (’053 Patent, Abstract; col. 2:4-14).
  • Technical Importance: This approach provides a method for enabling the coexistence of different wireless standards within a single device, a significant challenge as more wireless technologies share the same frequency spectrums (’053 Patent, col. 1:21-26).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶36).
  • Claim 1 is an apparatus claim comprising the essential elements of:
    • a first wireless transceiver for a first wireless protocol;
    • a second wireless transceiver for a different, second wireless protocol;
    • a controller that selects one of the transceivers to communicate data of both protocols;
    • wherein the apparatus is configured to encode data of the unselected protocol into data of the selected protocol.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 8,862,184 - “System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices,” issued October 14, 2014.

  • Technology Synopsis: The patent addresses limitations in collecting field data for assessments, which can be inefficient and lack access to critical information (’184 Patent, col. 1:21-30). The invention provides a system where a field assessment program is downloaded from a server to a handheld device, allowing a user to collect job-related data, which is then combined with location information and rendered on the device (’184 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶46).
  • Accused Features: The complaint alleges that the Accused Products perform a method of downloading a field assessment program to a handheld device, executing it to collect job data, obtaining location information, and rendering an assessment (Compl. ¶47).

U.S. Patent No. 6,941,223 - “Method And System For Dynamic Destination Routing,” issued September 6, 2005.

  • Technology Synopsis: The patent describes a system for dynamic vehicle routing that addresses the need for route recommendations to remain optimal during a drive (’223 Patent, col. 1:38-41). The solution involves determining an initial optimal route based on static information, receiving additional information during the drive, and determining a new optimal route if a comparison shows the current route is no longer optimal (’223 Patent, Abstract).
  • Asserted Claims: At least claim 19 (Compl. ¶56).
  • Accused Features: The complaint alleges the Accused Products perform a method of determining an optimal route, receiving additional information, comparing real travel parameters to the route's parameters, and determining a new optimal route if the original is no longer optimal (Compl. ¶57).

U.S. Patent No. 6,961,586 - “Field Assessments Using Handheld Data Management Devices,” issued November 1, 2005.

  • Technology Synopsis: The patent addresses the problem that field personnel may lack access to specialized information needed to conduct accurate assessments (’586 Patent, col. 1:29-35). The invention is a method where a handheld device provides a user with access to an industry-specific field assessment program module (e.g., for construction or HVAC analysis) to execute the assessment and retrieve relevant data (’586 Patent, Abstract).
  • Asserted Claims: At least claim 9 (Compl. ¶65).
  • Accused Features: The complaint alleges the Accused Products perform a method of providing a user access to an industry-specific field assessment program module on a handheld device to execute assessments such as project management and equipment troubleshooting (Compl. ¶66).

U.S. Patent No. 6,633,616 - “OFDM Pilot Tone Tracking For Wireless LAN,” issued October 14, 2003.

  • Technology Synopsis: This patent addresses performance issues in Orthogonal Frequency Division Multiplexed (OFDM) systems caused by phase noise in local oscillators, which is critical when using complex signal constellations (’616 Patent, col. 1:36-44). The invention is a method for pilot phase error estimation in an OFDM receiver that processes a preamble waveform and subsequent symbols in parallel paths to determine a phase error estimate, completing this determination before the processing of the subsequent symbol is finished (’616 Patent, Abstract).
  • Asserted Claims: At least claim 12 (Compl. ¶76).
  • Accused Features: The complaint alleges the Accused Products, which use protocols like IEEE 802.11, perform a method of pilot phase error estimation in an OFDM receiver by processing preamble and subsequent symbols in parallel paths (Compl. ¶¶16, 77).

U.S. Patent No. 7,463,896 - “System And Method For Enforcing A Vehicle Code,” issued December 9, 2008.

  • Technology Synopsis: The patent describes a system for communication between mobile vehicles to improve safety and the driving experience (’896 Patent, col. 2:42-48). The invention is a method where a first mobile unit receives a wireless signal from a second mobile unit associated with a vehicle, determines the vehicle's ID and GPS position, and allows a system administrator to determine the vehicle's status for code enforcement purposes (’896 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶86).
  • Accused Features: The complaint alleges the Accused Products perform a method for enforcing a vehicle code by receiving a wireless signal at a first mobile unit from a second, determining vehicle ID and GPS position, and allowing a system administrator to determine vehicle status (Compl. ¶87).

U.S. Patent No. 6,647,270 - “Vehicle Talk,” issued November 11, 2003.

  • Technology Synopsis: This patent discloses a system for providing a communication link among a plurality of mobile units (’270 Patent, Abstract). Each remote unit includes a memory, transceiver, GPS receiver, and microprocessor to construct and transmit data packets containing sender information (unique ID, position) and receiver information (address of desired unit) (’270 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶96).
  • Accused Features: The complaint alleges the Accused Products are a system for transmitting data packets between remote units, each having a memory, transceiver, GPS, and microprocessor to construct data packets with sender and receiver information (Compl. ¶97).

U.S. Patent No. 7,450,955 - “System And Method For Tracking Vehicle Maintenance Information,” issued November 11, 2008.

  • Technology Synopsis: This patent discloses a method for tracking vehicle maintenance information via a wireless system (’955 Patent, Abstract). A system administrator identifies a vehicle, determines an associated warning, and generates a data packet containing the warning, which is transmitted to a receiving mobile unit in the vehicle; a confirmation of receipt is then sent back (’955 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶106).
  • Accused Features: The complaint alleges the Accused Products are used to perform a method of tracking vehicle maintenance where a system administrator identifies a vehicle, determines a warning, generates and transmits a data packet with the warning, and receives a confirmation of receipt (Compl. ¶107).

U.S. Patent No. 7,536,189 - “System And Method For Sending Broadcasts In A Social Network,” issued May 19, 2009.

  • Technology Synopsis: This patent discloses a method for a system administrator to broadcast an advisory communication to remote units (’189 Patent, Abstract). The method involves accessing a website to input a communication, filtering a plurality of remote units to select recipients, assembling a data or voice packet, and forwarding it for transmission (’189 Patent, Abstract).
  • Asserted Claims: At least claim 1 (Compl. ¶116).
  • Accused Features: The complaint alleges the Accused Products perform a method for broadcasting an advisory communication by accessing a website, filtering remote units, assembling a data/voice packet, and forwarding it for transmission (Compl. ¶117).

U.S. Patent No. 7,599,715 - “System And Method For Matching Wireless Devices,” issued October 6, 2009.

  • Technology Synopsis: This patent describes a method for tracking vehicle maintenance information using a wireless communication system (’715 Patent, Abstract). The system receives a signal from a vehicle's mobile unit containing a vehicle identifier and status, stores it in a log, determines associated maintenance information, constructs and forwards a communication packet over the Internet, and stores it in a second log (’715 Patent, Abstract).
  • Asserted Claims: At least claim 31 (Compl. ¶127).
  • Accused Features: The complaint alleges the Accused Products perform a method of tracking vehicle maintenance by receiving a signal from a vehicle, storing it, determining maintenance info, constructing and transmitting a packet over the Internet, and storing it in a second log (Compl. ¶128).

U.S. Patent No. 7,701,360 - “System And Method For Selective Navigation Tracking,” issued April 20, 2010.

  • Technology Synopsis: The patent discloses systems and methods for displaying navigational routing information overlaid with environmental data (’360 Patent, Abstract). A navigation display receives data from a remote environmental sensor (e.g., weather, traffic), including its geographical position, and overlays this environmental data onto the displayed navigation route at the appropriate point (’360 Patent, Abstract).
  • Asserted Claims: At least Claim 1 (Compl. ¶137).
  • Accused Features: The complaint alleges the Accused Products perform a method of displaying a navigation route and overlaying it with received environmental and geographical position data from a remote sensor (Compl. ¶138).

III. The Accused Instrumentality

Product Identification

  • The Accused Products include Trimble fleet management platforms, telematics devices, and related software and hardware, specifically including the "web-based TMT Fleet Maintenance platform," Trimble telematics devices such as the TAG 200, and third-party tablets such as the Samsung Tab Active5 (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges that Defendant AutoZone uses the Accused Products to manage its private fleet of approximately 360 trucks and 800 trailers (Compl. ¶6). The functionality of the Trimble TMT Fleet Maintenance platform is described as a solution for the trucking industry to track and report fleet data, manage maintenance, and gain insights into costs (Compl. ¶15; Compl. Fig. 2). A screenshot from a Trimble case study provided in the complaint states AutoZone uses the platform to track repair history, manage preventive maintenance intervals, and track operating costs (Compl. Fig. 2, Fig. 3, p. 6-7).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,429,810 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method of providing container status information to a user, the method comprising of the steps of: attaching an electronic communications unit to a shipping container; Defendant uses the Accused Products, which include telematics devices (electronic communications units) attached to its trucks and trailers (shipping containers). ¶27 col. 3:7-9
generating a transaction identification code, wherein said transaction identification code is specific to said shipping container and specific to at least one user transaction; The Accused Products allegedly generate a transaction ID code specific to the shipping container and a user transaction. ¶27 col. 5:1-3
initiating a status inquiry utilizing said transaction identification code, wherein said user performs said initiating step; A user, via the Accused Products' interface, initiates a status inquiry for a specific vehicle using its identifier. ¶27 col. 8:12-18
receiving said status inquiry by a ground communications system; The ground system component of the Accused Products receives the user's inquiry. ¶27 col. 8:15-18
transmitting said status inquiry to said electronic communications unit by said ground communications system; The ground system transmits the inquiry to the specific telematics device on the vehicle. ¶27 col. 8:65-68
obtaining a status information response by said electronic communications unit; The telematics device obtains status information, such as its GPS location. ¶27 col. 9:2-4
transmitting said status information response to said ground communications system by said electronic communications unit; and The telematics device transmits its status information back to the ground system. ¶27 col. 9:4-6
forwarding said status information response to said user by said ground communications system. The ground system forwards the status information to the user, for example, via a web-based platform. ¶27 col. 9:8-10

Identified Points of Contention

  • Scope Questions: A primary question may be whether the term "shipping container" in the context of an "Integrated Air Logistics System" can be construed to read on the ground-based trucks and trailers operated by AutoZone. Similarly, the interpretation of "ground communications system" will be relevant to whether the web-based platforms and cellular networks used by the Accused Products fall within the claim scope.
  • Technical Questions: The complaint does not specify how the Accused Products generate a "transaction identification code" that is specific to both the vehicle and the "user transaction." A point of contention may be whether a simple vehicle identifier satisfies this dual-specificity requirement of the claim.

U.S. Patent No. 8,005,053 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
an apparatus comprising: a first wireless transceiver configured to communicate data according to a first wireless protocol; The Accused Products allegedly include hardware with a first wireless transceiver, for example, for cellular (LTE) communication. ¶¶16, 37 col. 2:4-6
a second wireless transceiver configured to communicate data according to a second wireless protocol that is different from the first wireless protocol; The Accused Products allegedly include a second wireless transceiver for a different protocol, for example, for Wi-Fi or Bluetooth. ¶¶16, 37 col. 2:6-8
and a controller configured to select one of the first and second wireless transceivers to communicate data of both the first and second wireless protocols, A controller within the Accused Products allegedly selects one of the available transceivers (e.g., cellular) to communicate data. ¶37 col. 2:8-10
wherein the apparatus is configured to encode data of the wireless protocol for the unselected transceiver into data of the wireless protocol for the selected transceiver. The apparatus allegedly encodes data from the unselected protocol (e.g., Wi-Fi) into the selected protocol's format (e.g., cellular) for transmission. ¶37 col. 2:10-14

Identified Points of Contention

  • Technical Questions: The central point of contention will likely be the "encode" limitation. The complaint alleges the Accused Products use multiple wireless protocols (Compl. ¶16), but it provides no specific facts explaining how or if they perform the claimed step of encoding data from one protocol into another. A key question for the court will be whether the Accused Products simply route traffic over an available connection or if they perform the specific data transformation required by the claim.

V. Key Claim Terms for Construction

The Term: "shipping container" (’810 Patent, Claim 1)

  • Context and Importance: This term's construction is critical because the ’810 Patent is titled "Integrated Air Logistics System" and its specification heavily emphasizes air cargo. The accused infringement involves ground-based trucks and trailers. The dispute will question whether the claim scope is limited by the specification's context or if the term should be given a broader, ordinary meaning.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is not limited to air transport. The specification refers to the PSC unit being attached to a "cargo container or other freight" and later mentions transit by "truck, train, ship, and/or airline," which may support application beyond just air logistics (’810 Patent, col. 3:8-9; col. 4:61-62).
    • Evidence for a Narrower Interpretation: The patent title, abstract, and background repeatedly frame the invention in the context of "air cargo," "air transit," and solving problems specific to air freight, which could be used to argue for a narrower construction limited to that field of use (’810 Patent, Abstract; col. 1:19; col. 5:10-12).

The Term: "encode data" (’053 Patent, Claim 1)

  • Context and Importance: This term is the central technical limitation of claim 1 of the ’053 Patent. Its definition will determine whether the claim covers systems that simply select one available communication channel over another (e.g., routing data over cellular instead of Wi-Fi) or if it requires a specific technical process of transforming the data structure of the unselected protocol into the data structure of the selected one.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract states the controller is configured to "select one of the first and second wireless transceivers to communicate data of both the first and second wireless protocols," which could be argued to broadly cover any method of channeling all communications through a single active transceiver (’053 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The word "encode" implies a specific technical transformation. The patent's summary describes the apparatus as being "configured to encode data of the wireless protocol for the unselected transceiver into data of the wireless protocol for the selected transceiver," suggesting a conversion of data formats, not merely a re-routing of a data payload through a different channel (’053 Patent, col. 2:10-14).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced and contributory infringement for U.S. Patent No. 7,701,360 only. Inducement is alleged based on Defendant providing the Accused Products and taking active steps with the specific intent to cause infringement by end-users, including distributing instructions (Compl. ¶139). Contributory infringement is alleged on the basis that the Accused Products have special features designed for infringement that are not staple articles of commerce (Compl. ¶140).
  • Willful Infringement: The complaint alleges willful infringement for the ’360 Patent only, based on knowledge acquired "since at least the time it received notice of the filing of this action" (Compl. ¶141). It further alleges that Defendant has a "policy or practice of not reviewing the patents of others" and has thus been "willfully blind" to Plaintiff's rights (Compl. ¶142).

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

  • A core issue will be one of definitional scope: can terms like "shipping container," which are rooted in the patent's disclosure of an "air logistics system," be construed broadly enough to cover the ground-based trucks and trailers in AutoZone's fleet management system? This question of applying claim language from one technical context to another will likely recur across multiple asserted patents.
  • A key evidentiary question will be one of technical operation: does the complaint provide sufficient factual support that the Accused Products perform the specific technical functions required by the claims? For instance, with respect to the ’053 patent, the central dispute will be whether the Trimble devices merely switch between wireless networks or perform the specific "encoding" of data from one protocol into another as claimed. The complaint's conclusory allegations on these technical points suggest this will be a significant area of contention.
  • A threshold question may be one of pleading sufficiency: the complaint asserts twelve patents, often reciting claim elements and alleging they are met without providing detailed, non-conclusory factual allegations to support how the accused system's complex operations map to those elements. This raises the possibility of early disputes over whether the complaint meets the plausibility standards for pleading patent infringement for each of the numerous and diverse technologies asserted.