DCT
2:25-cv-00169
Lexidine LLC v. Ford Motor Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lexidine, LLC (Oklahoma)
- Defendant: Ford Motor Company (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00169, E.D. Tex., 02/12/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Ford has committed acts of infringement in the district and maintains a regular and established place of business there, identified as its "Central Market Area Office" in Plano, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Center High-Mounted Stop Lamp Cameras, integrated into various Ford vehicles, infringe a patent related to concealing a camera within a vehicle's external light housing.
- Technical Context: The technology concerns the integration of vehicle-mounted cameras, such as backup cameras, into existing lighting fixtures to make them less visually obtrusive and easier to retrofit.
- Key Procedural History: The sole asserted patent, U.S. Patent No. 7,609,961, was the subject of an ex parte reexamination initiated in 2020. A Reexamination Certificate issued in 2022, which confirmed the patentability of original claims 19-22, found original claim 1 patentable as amended, and confirmed patentability for dependent claims 2-11 and new claims 24-80. This proceeding may affect the scope of the asserted claims and strengthens the patent's presumption of validity against the art considered during reexamination.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-11 | ’961 Patent Priority Date |
| 2009-10-27 | ’961 Patent Issue Date |
| 2020-02-20 | Ex Parte Reexamination of ’961 Patent Requested |
| 2022-08-22 | Ex Parte Reexamination Certificate for ’961 Patent Issued |
| 2025-02-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,609,961 - “VEHICLE CAMERA”
The Invention Explained
- Problem Addressed: The patent’s background section identifies that prior art vehicle cameras are often "obtrusive in appearance," which detracts from a vehicle's original styling and makes them a more probable target for theft (’961 Patent, col. 1:37-41). Furthermore, retrofitting these cameras often requires "drilling a hole in the vehicle or otherwise creating a mounting point" (’961 Patent, col. 1:43-44).
- The Patented Solution: The invention solves this problem by integrating a camera assembly entirely within the housing of an existing vehicle light, such as a brake light or marker light (’961 Patent, col. 2:58-62). As illustrated in the exploded view of Figure 2 and the cross-section of Figure 3, a camera body (111) is mounted inside a vehicle lens (120) and has a viewing axis that passes through an opening (124) in that lens. This design aims to conceal the camera and allow for easier retrofitting (’961 Patent, col. 1:52-56).
- Technical Importance: This design provides a method for adding camera functionality to a vehicle in a way that is "unobtrusive in appearance" and can be "readily retrofitted" without permanent modification to the vehicle's bodywork (’961 Patent, col. 1:52-56).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1, as amended by the ex parte reexamination certificate (Compl. ¶2, ¶28-29).
- Essential elements of amended independent claim 1 include:
- A vehicle lens of an external light, having an internal reflector surface, a translucent area of a predetermined color, and an opening in the translucent area.
- The vehicle lens having a slanted surface in close proximity to the opening.
- A camera body within the vehicle lens with a viewing axis through the opening.
- A base attached to the vehicle lens, with the viewing axis at an angle between 15-75 degrees relative to the plane of the base.
- A camera assembly including the camera body, a camera lens, and a transparent camera lens cover.
- The camera body houses optoelectronic components.
- At least a portion of the camera assembly is outside the opening in the vehicle lens.
- The camera assembly and camera body are fixed in position with respect to the vehicle lens.
- The complaint does not explicitly reserve the right to assert dependent claims, but the prayer for relief requests judgment on "one or more claims" (Compl. ¶(a) at p. 14).
III. The Accused Instrumentality
Product Identification
The accused products are the "Center High-Mounted Stop Lamp Cameras" ("CHMSL Cameras") that are sold as OEM or replacement parts and installed as standard or optional equipment on various Ford vehicles (Compl. ¶19).
Functionality and Market Context
The CHMSL Cameras are integrated into the vehicle's high-mounted stop light assembly, located at the top-rear of the vehicle cab (Compl. ¶19, Fig. 1). Figure 1 shows the location of the CHMSL Camera assembly on a Ford F-150 Lightning truck, circled in red. The complaint provides several images of the accused product, including an image of the complete assembly removed from a vehicle, which shows the brake light, cargo lights, and the centrally located camera lens (Compl. Fig. 5). A close-up image shows the camera lens itself, positioned within the larger housing (Compl. Fig. 7). The function is to provide the driver with a video feed of the area behind the vehicle, particularly for monitoring the truck bed or assisting with trailer hitching. The complaint does not contain specific allegations regarding the product's market positioning beyond its inclusion in Ford's vehicle lineup (Compl. ¶19, Ex. B).
IV. Analysis of Infringement Allegations
’961 Patent Infringement Allegations
| Claim Element (from Independent Claim 1, as amended) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a vehicle lens of an external light for a vehicle light, the vehicle lens having an internal reflector surface and a translucent area of a predetermined color...and having an opening in the translucent area of the vehicle lens | The Accused Products comprise a vehicle lens for an external vehicle light, which has an internal reflector surface, a translucent area, and an opening in that area. | ¶29 | col. 6:42-49; Reexam Cert. C1, col. 1:24-30 |
| the vehicle lens having a slanted surface in close proximity to the opening in the vehicle lens | The Accused Products comprise a vehicle lens with a slanted surface near the opening. | ¶29 | Reexam Cert. C1, col. 1:31-33 |
| a camera body within the vehicle lens having a viewing axis through the opening | The Accused Products comprise a camera body located within the vehicle lens, with a viewing axis that passes through the opening. | ¶29 | col. 6:50-52; Reexam Cert. C1, col. 1:34-36 |
| a base attached to the vehicle lens, wherein the viewing axis is at an angle between about 15 to 75 degrees with respect to a plane of the base | The Accused Products comprise a base attached to the lens, where the viewing axis is angled between 15 and 75 degrees relative to the base's plane. | ¶29 | col. 6:53-56; Reexam Cert. C1, col. 1:37-40 |
| a camera assembly that includes at least the camera body, a camera lens, and a transparent camera lens cover | The Accused Products comprise a camera assembly that includes a camera body, a camera lens, and a transparent camera lens cover. | ¶29 | Reexam Cert. C1, col. 1:41-43 |
| wherein the camera body houses a camera comprised of optoelectronic components | The camera body of the Accused Products houses a camera with optoelectronic components. | ¶29 | Reexam Cert. C1, col. 1:44-46 |
| wherein at least a portion of the camera assembly is outside the opening in the vehicle lens | At least a portion of the camera assembly in the Accused Products is located outside the opening in the vehicle lens. | ¶29 | Reexam Cert. C1, col. 1:47-49 |
| wherein the camera assembly and camera body are fixed in position with respect to the vehicle lens | The camera assembly and body in the Accused Products are fixed in position relative to the vehicle lens. | ¶29 | Reexam Cert. C1, col. 2:5-7 |
Identified Points of Contention
- Scope Questions: A central dispute may concern the construction of "within the vehicle lens." The parties may contest whether this requires the camera body to be fully encapsulated by the lens material itself, or merely housed within the cavity defined by the lens housing. The complaint's visual evidence, such as Figure 5 showing the integrated but distinct components, will be central to this analysis.
- Technical Questions: A key evidentiary question will be whether the accused CHMSL camera assembly features a "slanted surface in close proximity to the opening" as required by the amended claim. The complaint alleges this feature exists but does not provide specific technical details, diagrams, or measurements to substantiate how the geometry of the Ford product meets this limitation (Compl. ¶29).
V. Key Claim Terms for Construction
The Term: "within the vehicle lens"
Context and Importance: This term is fundamental to the patent's core concept of concealing the camera. Its interpretation will determine whether the accused products, which integrate a camera module into a larger stop lamp housing, fall under the claim's scope. Practitioners may focus on this term because the physical relationship between the camera body and the lens housing is a primary point of the invention.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the "camera assembly 110" being "attached within the vehicle lens 120" (’961 Patent, col. 2:61-62). Figures 3 and 5 show the camera body (111, 211) as a distinct component that is mounted inside the larger lens housing (120, 220), which may support an interpretation that "within" refers to being contained in the housing's interior space.
- Evidence for a Narrower Interpretation: The specification also states that the "camera body [is] mounted completely within the vehicle lens" (’961 Patent, col. 2:12-13; see also col. 8:7). This language could be argued to require a more integrated, or even encapsulated, arrangement than what is depicted in the accused product.
The Term: "slanted surface"
Context and Importance: This term was added during reexamination, suggesting it was critical for establishing patentability over prior art. Its construction will be vital to the infringement analysis, as the complaint makes a conclusory allegation about its presence without providing supporting detail (Compl. ¶29).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "slanted." A party might argue for its plain and ordinary meaning, covering any surface that is not perpendicular or parallel to the base plane.
- Evidence for a Narrower Interpretation: The specification describes one embodiment where the vehicle lens has a "slanted top surface 221" and a "concave portion 222 that can have the same inclination as the slanted top surface" (’961 Patent, col. 4:55-58). This specific example could be used to argue that "slanted surface" should be construed in the context of this specific geometry, potentially limiting its scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating Ford provides instructions, advertising, and directs personnel and customers to use the Accused Products in a manner that infringes (Compl. ¶30). The complaint also alleges contributory infringement, asserting the Accused Products contain "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶31).
- Willful Infringement: Willfulness is alleged based on Ford's knowledge of the ’961 patent "at least as of the date it was notified of the filing of this action" (Compl. ¶32). The complaint further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural definition: can the claim term "within the vehicle lens," which was central to the patent's novelty, be construed to read on the accused Ford products where the camera is a distinct module integrated into a larger stop lamp assembly, rather than being encapsulated by the lens material itself?
- A key evidentiary question will be one of geometric proof: what evidence will Plaintiff present to demonstrate that the accused Ford CHMSL camera assembly possesses the specific "slanted surface in close proximity to the opening" that was added during reexamination to secure the patent's validity, and will that evidence be sufficient to meet the claim limitation as construed by the court?