DCT

2:25-cv-00122

OBD Sensor Solutions LLC v. UAB Xirgo Global

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00122, E.D. Tex., 02/03/2025
  • Venue Allegations: Plaintiff alleges that venue is proper because Defendant is a foreign entity and may be sued in any judicial district pursuant to the alien venue statute.
  • Core Dispute: Plaintiff alleges that Defendant’s plug-in GPS vehicle trackers, which connect to a vehicle's on-board diagnostic port, infringe a patent related to monitoring and processing vehicle operating data.
  • Technical Context: The technology resides in the field of vehicle telematics and on-board diagnostics (OBD), where electronic devices access and analyze data from a vehicle's internal computer systems for purposes such as fleet management, usage-based insurance, and diagnostics.
  • Key Procedural History: The complaint asserts that Plaintiff is the exclusive licensee of the patent-in-suit, granting it the sole and exclusive right to enforce the patent. No prior litigation or post-grant proceedings are mentioned.

Case Timeline

Date Event
2001-06-18 Priority Date for U.S. Patent No. 7,146,346
2006-12-05 U.S. Patent No. 7,146,346 Issues
2025-02-03 Complaint Filed

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

U.S. Patent No. 7,146,346 - "Fuzzy-Logic On Board Device For Monitoring And Processing Motor Vehicle Operating Data"

  • Patent Identification: U.S. Patent No. 7,146,346, “Fuzzy-Logic On Board Device For Monitoring And Processing Motor Vehicle Operating Data,” issued December 5, 2006.

The Invention Explained

  • Problem Addressed: The patent describes a need in the automotive field for on-board systems that can effectively collect and process vehicle operating data. It notes that prior systems were often inefficient, requiring dedicated sensors, having limited processing capability, and continuously recording redundant data, which increased cost and complexity (ʼ346 Patent, col. 1:15-36).
  • The Patented Solution: The invention is an electronic device designed to connect to a vehicle’s existing internal network (e.g., via the OBD port) to access data from on-board sensors and electronic control units (ECUs). The device comprises a central processing unit and integrated storage to autonomously process this data, perform analysis, and store the results, thereby creating a "statistic parameter array" characterizing the vehicle's usage pattern without requiring extensive vehicle modification ('346 Patent, col. 1:51-62; Fig. 1).
  • Technical Importance: The described technology aimed to provide a more intelligent and self-contained data management capability that could be added to a vehicle to analyze its operation in real-time ('346 Patent, col. 2:19-27).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶26).
  • The essential elements of independent claim 1 include:
    • An electronic device for monitoring and processing vehicle data comprising a central processing unit, integrated data storage, and a network connector.
    • The network connector is configured to connect to a vehicle's inner network via a diagnostic connector (e.g., OBD).
    • The device is a "stand-alone device" that cooperates with the vehicle's ECUs to process data received from the inner network.
    • The processing includes a "performed analysis" that is stored in the integrated storage.
    • The device includes an interface connector for connecting to a radio transmitter or a wireless unit.
    • The device includes a front-end device and buses connecting the network connector, CPU, and storage.
    • The device is coupled via its on-board network connector with an OBD- or EOBD-type connector.
  • The prayer for relief seeks judgment on "one or more claims," but the infringement count specifically identifies only claim 1 (Compl. ¶¶26, 31(a)).

III. The Accused Instrumentality

Product Identification

The complaint identifies "one or more Plug-In GPS Vehicle Tracker products and solutions, e.g., XT2600" as the Accused Products (Compl. ¶17).

Functionality and Market Context

The Accused Products are described as devices that plug into a vehicle's OBD-II port to "monitor and process information and/or data related to the use and functioning of motor vehicles" (Compl. ¶17). Marketing materials cited in the complaint describe the XT2600 as a "Vehicle trip logger using OBD2" that communicates vehicle information such as fuel level, odometer reading, and driver behavior via cellular networks (Compl., Fig. 2). A screenshot of the product specifications for the XT2600 lists features including an integrated GPS receiver, cellular connectivity, and an accelerometer (Compl., Fig. 1).

IV. Analysis of Infringement Allegations

’346 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An electronic device for monitoring and processing information data related to the use and functioning of motor vehicles through an inner network connecting vehicle sensors... The Accused Products are electronic devices that monitor and process motor vehicle data through the vehicle's inner sensor network (Compl. ¶17). ¶27 col. 6:8-11
said device comprising, a central processing unit; an integrated data storage connected to the central processing unit; and a network connector... configured to be connected to an inner network of a motor vehicle through a connector used by motor vehicle makers... The Accused Products are alleged to contain a central processing unit, integrated data storage, and a network connector for interfacing with a vehicle’s OBD port. ¶27 col. 6:12-19
said device being a stand-alone device cooperating with the vehicle electronic dedicated control units, via said network connector and through said inner network, and processing information data... The Accused Products are alleged to be stand-alone devices that cooperate with the vehicle's control units to process data received from the inner network. ¶27 col. 6:19-25
said data received through said inner network being processed by said central processing unit and performed analysis being stored into said storage; The Accused Products allegedly process data using their central processing unit and store the performed analysis in their storage. ¶27 col. 6:29-32
an interface connector providing connection to one of a radio transmitter and a wireless unit; The Accused Products allegedly include an interface for connection to a wireless unit for cellular communication (Compl. Fig. 1). ¶27 col. 6:33-35
a front-end device and a bus connecting said network connector to said central processing unit; and a further bus connecting said central processing unit to said storage... The Accused Products are alleged to contain a front-end device and internal buses connecting the processor, storage, and network connector. ¶27 col. 6:36-41
wherein said device is coupled, through said on-board network connector, with one of an OBD- and an EOBD connector for interfacing the motor vehicle inner networks with an outside network of said motor vehicle. The Accused Products are alleged to couple with a vehicle’s OBD or EOBD connector. The complaint includes a screenshot describing the XT2600 as a "Vehicle trip logger using OBD2" (Compl., Fig. 2). ¶27 col. 6:42-47

Identified Points of Contention

  • Scope Questions: A potential dispute may arise over the meaning of "stand-alone device cooperating with the vehicle electronic dedicated control units." The defense may argue that the accused trackers are primarily data-pass-through devices for a remote server, rather than "stand-alone" devices performing the claimed functions. The nature of the required "cooperation" will also be at issue.
  • Technical Questions: Claim 1 requires that a "performed analysis" be stored on the device. The complaint does not specify what analysis the Accused Products perform on-board. A key technical question will be whether the processing conducted by the accused device rises to the level of "analysis" as contemplated by the patent, or if it is limited to data collection, formatting, and transmission. The patent specification describes a sophisticated "fuzzy logic" and "genetic algorithm construction" analysis ('346 Patent, col. 3:60-64), which is not explicitly recited in Claim 1, raising the question of how much processing is sufficient to meet the "analysis" limitation.

V. Key Claim Terms for Construction

The Term: "performed analysis being stored into said storage"

  • Context and Importance: The definition of this term is critical to determining the scope of infringement. The dispute will likely focus on whether the on-board data handling in the Accused Products constitutes "analysis" or is merely preparatory data transmission. Practitioners may focus on this term because the patent's specification describes a specific, complex "fuzzy-logic" analysis, while the claim language is more general.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself does not import the "fuzzy-logic" or "DNA" terminology from the specification. A party could argue that "analysis" should be given its plain and ordinary meaning, which could encompass any processing that derives meaning or categorizes data, however simple.
    • Evidence for a Narrower Interpretation: The specification heavily details a particular type of analysis: creating "statistic index arrangements" using "fuzzy-logic principles" to generate a vehicle "DNA" ('346 Patent, col. 1:56-62, col. 4:1-11). A party could argue that these detailed descriptions inform the proper construction of "analysis" and limit the term to these more complex operations, which were presented as the solution to the prior art's problems.

The Term: "stand-alone device"

  • Context and Importance: This term distinguishes the claimed invention from a component that is merely an integrated part of a larger system. The infringement question may turn on whether the accused tracker, which relies on a cellular network and likely a remote server, qualifies as "stand-alone."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is used in the claim in contrast to the vehicle's own "electronic dedicated control units," suggesting "stand-alone" means it is a physically separate, add-on module rather than a deeply integrated vehicle component ('346 Patent, col. 6:20-22). Figure 4 shows the device (1) as separate from the vehicle's ECU network (35).
    • Evidence for a Narrower Interpretation: The requirement that the device "cooperat[es] with the vehicle electronic dedicated control units" ('346 Patent, col. 6:20-22) may suggest a degree of dependency that could be used to argue against an overly broad interpretation of "stand-alone."

VI. Other Allegations

Indirect Infringement

The complaint alleges Defendant provides "materials instructing its customers to perform infringing activities" (Compl. ¶12) and controls a website that "educates customers about its products" (Compl. ¶11). These allegations form the basis for a potential claim of induced infringement, although the facts are not detailed in a separate count.

Willful Infringement

The complaint does not explicitly allege willful infringement or plead facts indicating Defendant had pre-suit knowledge of the '346 patent. The prayer for relief includes a request for attorneys' fees pursuant to 35 U.S.C. § 285, which requires a finding that the case is "exceptional" (Compl. ¶31(e)).

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

  • A core issue will be one of definitional scope: can the term "performed analysis," which the patent specification illustrates with complex "fuzzy-logic" and "genetic algorithm" examples, be construed to cover the on-board data processing functions of the accused GPS trackers? The outcome may depend on whether the claims are limited to the sophisticated analysis described as the invention's key advantage.
  • A key evidentiary question will be one of technical operation: what specific processing and analysis functions are actually performed on the accused device itself before data is transmitted wirelessly? Discovery will likely focus on the architecture of the Accused Products to determine whether they are simply data conduits for a remote server or if they are, in fact, "stand-alone" devices performing and storing an "analysis" as claimed.