DCT
2:25-cv-00350
Fleet Connect Solutions LLC v. CalAmp Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fleet Connect Solutions LLC (Texas)
- Defendant: CalAmp Corp. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00350, E.D. Tex., 04/07/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district, specifically a facility in Richardson, Texas, and has committed acts of patent infringement there. The complaint also notes that Defendant did not contest venue in prior litigation in the same district.
- Core Dispute: Plaintiff alleges that Defendant’s fleet management and asset tracking products infringe eight patents related to wireless communication protocols, dynamic vehicle routing, and mobile data management for field operations.
- Technical Context: The technologies at issue concern fleet telematics and wireless data systems, which are foundational to modern logistics, commercial transportation, and mobile asset management industries.
- Key Procedural History: The complaint references two Certificates of Correction issued for U.S. Patent No. 7,450,955. No other significant procedural events, such as inter partes review proceedings or prior litigation between the parties, are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2000-09-18 | U.S. Patent No. 6,961,586 Priority Date |
| 2000-09-18 | U.S. Patent No. 8,862,184 Priority Date |
| 2001-02-21 | U.S. Patent No. 6,549,583 Priority Date |
| 2001-02-21 | U.S. Patent No. 6,633,616 Priority Date |
| 2002-01-10 | U.S. Patent No. 6,941,223 Priority Date |
| 2002-11-04 | U.S. Patent No. 7,206,837 Priority Date |
| 2003-04-15 | U.S. Patent No. 6,549,583 Issue Date |
| 2003-10-14 | U.S. Patent No. 6,633,616 Issue Date |
| 2005-09-06 | U.S. Patent No. 6,941,223 Issue Date |
| 2005-11-01 | U.S. Patent No. 6,961,586 Issue Date |
| 2006-09-20 | U.S. Patent No. 7,450,955 Priority Date |
| 2007-04-17 | U.S. Patent No. 7,206,837 Issue Date |
| 2008-06-20 | U.S. Patent No. 7,741,968 Priority Date |
| 2008-11-11 | U.S. Patent No. 7,450,955 Issue Date |
| 2010-06-22 | U.S. Patent No. 7,741,968 Issue Date |
| 2014-10-14 | U.S. Patent No. 8,862,184 Issue Date |
| 2025-04-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,549,583 - Optimum Phase Error Metric For OFDM Pilot Tone Tracking In Wireless LAN
The Invention Explained
- Problem Addressed: The patent’s background section describes how in wireless communication systems using Orthogonal Frequency Division Multiplexing (OFDM), phase noise generated by local oscillators in the radio components can corrupt the signal, leading to high error rates, particularly when using complex, high-data-rate modulation schemes like 64-QAM (’583 Patent, col. 1:16-43). Building highly stable, low-noise radios on a single integrated chip is described as difficult and costly (’583 Patent, col. 1:56-62).
- The Patented Solution: The invention proposes a method to compensate for this radio-level phase noise using digital signal processing in the baseband portion of the receiver. It determines "pilot reference points" from a known part of the wireless signal (the preamble) and then estimates the "aggregate phase error" for subsequent data symbols by comparing them to these reference points. This estimation is performed using a "maximum likelihood-based" approach, which combines information from all available pilot tones to generate a more robust estimate of the phase error (’583 Patent, Abstract; col. 2:5-16).
- Technical Importance: This signal processing solution allows for the use of less expensive, lower-performance radio hardware in wireless devices while still supporting high-data-rate communications, a key enabler for cost-effective mass-market products like Wi-Fi devices (’583 Patent, col. 1:53-62).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶29).
- Claim 1 is a method claim comprising the elements of:
- determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform;
- estimating an aggregate phase error of a subsequent OFDM data symbol relative to the pilot reference points using complex signal measurements from the pilots of that data symbol; and
- wherein the estimation step involves performing a maximum likelihood-based estimation using those complex signal measurements.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 6,633,616 - OFDM Pilot Tone Tracking for Wireless LAN
The Invention Explained
- Problem Addressed: This patent addresses a related problem: the processing delay inherent in the Fast Fourier Transform (FFT) block of a conventional OFDM receiver. This delay limits the bandwidth of the phase error tracking loop, making it less effective at correcting rapid phase variations or phase noise at higher frequency offsets (’616 Patent, col. 17:5-20).
- The Patented Solution: The invention proposes a receiver architecture where phase error estimation is performed in a "parallel path" to the main data processing path that contains the FFT. By using a separate, dedicated processing block for the pilot tones (e.g., a discrete Fourier transform portion), the phase error estimate can be determined and applied to correct the signal before the main FFT has finished processing the data symbol (’616 Patent, Abstract; col. 19:48-61). This reduction in processing latency allows the tracking loop to operate at a higher bandwidth, improving its performance.
- Technical Importance: This parallel architecture improves the receiver's ability to track and cancel phase noise, enhancing signal integrity and enabling more reliable high-speed wireless communication without requiring more expensive radio hardware (’616 Patent, col. 18:5-12).
Key Claims at a Glance
- The complaint asserts at least independent claim 12 (Compl. ¶39).
- Claim 12 is a method claim comprising the elements of:
- determining pilot reference points from an OFDM preamble waveform;
- processing the preamble in a parallel path with a fast Fourier transform;
- determining a phase error estimate of a subsequent OFDM symbol;
- processing the subsequent symbol in the parallel path with the fast Fourier transform; and
- wherein the step of determining the phase error estimate is completed prior to the completion of the processing of the subsequent OFDM symbol with the fast Fourier transform.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 6,941,223 - Method And System For Dynamic Destination Routing
- Technology Synopsis: The patent describes a method for vehicle navigation that begins by determining an "optimal route" based on static information. During travel, the system receives additional information and compares "real travel parameters" of the vehicle (e.g., travel time, distance) against the parameters of the planned route to determine if it remains optimal, calculating a new route if necessary (Compl. ¶50).
- Asserted Claims: At least claim 19 is asserted (Compl. ¶49).
- Accused Features: The complaint accuses Defendant's products that perform destination routing for a vehicle (Compl. ¶50).
U.S. Patent No. 6,961,586 - Field Assessments Using Handheld Data Management Devices
- Technology Synopsis: The patent discloses a method for conducting field assessments using a handheld device. The method involves providing a user with access to an "industry-specific field assessment program module" (e.g., for construction or HVAC), executing that module to conduct an assessment, and providing and retrieving data in support of that assessment (Compl. ¶59).
- Asserted Claims: At least claim 9 is asserted (Compl. ¶58).
- Accused Features: The complaint accuses Defendant's products that perform methods of conducting field assessments using handheld devices (Compl. ¶59).
U.S. Patent No. 7,206,837 - Intelligent Trip Status Notification
- Technology Synopsis: The patent relates to a method for providing trip status. The method comprises receiving the location of a mobile device in transit and estimating "time-of-arrival bounds" for its destination based on its current location and "at least one historical travel time statistic." These bounds are then sent to the mobile device (Compl. ¶70).
- Asserted Claims: At least claim 1 is asserted (Compl. ¶69).
- Accused Features: The complaint accuses Defendant's products that perform methods for estimating time-of-arrival (Compl. ¶70).
U.S. Patent No. 7,450,955 - System And Method For Tracking Vehicle Maintenance Information
- Technology Synopsis: The patent describes a system for communicating vehicle maintenance warnings. A system administrator identifies a vehicle and an associated warning, generates a data packet including unique identifiers for the transmitting and receiving mobile units, upconverts the data to radio frequency, transmits it to the vehicle, and receives a confirmation of receipt (Compl. ¶80).
- Asserted Claims: At least claim 1 is asserted (Compl. ¶79).
- Accused Features: The complaint accuses Defendant's products that track vehicle maintenance information and communicate warnings (Compl. ¶80).
U.S. Patent No. 7,741,968 - System And Method For Navigation Tracking Of Individuals In A Group
- Technology Synopsis: The patent covers a method for tracking a group of individuals with a portable hand-held device. The method includes receiving and displaying the geographic location of individuals in the group, sending "converging instructions" to at least one individual to facilitate a rendezvous with the hand-held device, and generating ETAs for that convergence (Compl. ¶90).
- Asserted Claims: At least claim 4 is asserted (Compl. ¶89).
- Accused Features: The complaint accuses Defendant's products that perform methods of keeping track of a group of individuals (Compl. ¶90).
U.S. Patent No. 8,862,184 - System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices
- Technology Synopsis: The patent describes a method for managing mobile field assets. The method includes downloading a "field assessment program" from a remote server to a handheld device, executing the program to assess a job, collecting data, obtaining job location information, and rendering the assessment on the device (Compl. ¶105).
- Asserted Claims: At least claim 1 is asserted (Compl. ¶104).
- Accused Features: The complaint accuses Defendant's products that perform methods of downloading and executing field assessment programs on handheld devices (Compl. ¶105).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are a broad range of CalAmp’s fleet management and asset tracking products and solutions. This includes software platforms such as CalAmp Fleet Telematics Application, FleetOutlook, CalAmp iOn, and various hardware devices identified by model numbers (e.g., LMU-series, TTU-series, ATU-series) (Compl. ¶17).
Functionality and Market Context
- The complaint alleges that the Accused Products provide fleet management and tracking solutions to customers (Compl. ¶17). The relevant technical functionalities alleged include performing wireless communications via protocols such as IEEE 802.11 and LTE, which utilize OFDM technology (Compl. ¶¶18-19). The products are also alleged to provide functionalities for tracking vehicle location and maintenance needs, generating driver warnings, enabling communication between a system administrator and remote units, and performing dynamic routing and field assessments (Compl. ¶¶20, 50, 59, 105). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
U.S. Patent No. 6,549,583 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [A] method of pilot phase error estimation in an orthogonal frequency division multiplexed (OFDM) receiver comprising: determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform; | Defendant's Accused Products perform a method that includes determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform. | ¶30 | col. 2:9-12 |
| and estimating an aggregate phase error of a subsequent OFDM data symbol relative to the pilot reference points using complex signal measurements corresponding to each of the plurality of pilots of the subsequent OFDM data symbol and the pilot reference points; | The method performed by the Accused Products includes estimating an aggregate phase error of a subsequent OFDM data symbol relative to the pilot reference points using complex signal measurements corresponding to each of the plurality of pilots of the subsequent OFDM data symbol and the pilot reference points. | ¶30 | col. 2:12-16 |
| wherein the estimating step comprises performing a maximum likelihood-based estimation using the complex signal measurements corresponding to each of the plurality of pilots of the subsequent OFDM data symbol and the pilot reference points. | The estimating step performed by the Accused Products comprises performing a maximum likelihood-based estimation using the complex signal measurements corresponding to each of the plurality of pilots of the subsequent OFDM data symbol and the pilot reference points. | ¶30 | col. 2:12-16 |
- Identified Points of Contention:
- Technical Question: The complaint’s allegations mirror the claim language without detailing how the accused products perform the claimed steps. A central technical question will be what specific algorithm the accused OFDM receivers use for phase error estimation. The case may turn on whether the evidence shows that this algorithm is, in fact, a "maximum likelihood-based estimation" as required by the claim, or a different, non-infringing type of estimation algorithm (e.g., a simple averaging method).
U.S. Patent No. 6,633,616 Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [A] method of pilot phase error estimation...comprising: determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform; | The accused method includes determining pilot reference points corresponding to a plurality of pilots of an OFDM preamble waveform. | ¶40 | col. 3:39-42 |
| processing, in a parallel path to the determining step, the OFDM preamble waveform with a fast Fourier transform; | The accused method includes processing, in a parallel path to the determining step, the OFDM preamble waveform with a fast Fourier transform. | ¶40 | col. 3:40-42 |
| determining a phase error estimate of a subsequent OFDM symbol relative to the pilot reference points; | The accused method includes determining a phase error estimate of a subsequent OFDM symbol relative to the pilot reference points. | ¶40 | col. 3:42-45 |
| and processing, in the parallel path to the determining step, the subsequent OFDM symbol with the fast Fourier transform; | The accused method includes processing, in the parallel path to the determining step, the subsequent OFDM symbol with the fast Fourier transform. | ¶40 | col. 3:45-48 |
| wherein the determining the phase error estimate step is completed prior to the completion of the processing of the subsequent OFDM symbol with the fast Fourier transform in the parallel path. | The determining of the phase error estimate step is completed prior to the completion of the processing of the subsequent OFDM symbol with the fast Fourier transform in the parallel path. | ¶40 | col. 3:45-48 |
- Identified Points of Contention:
- Scope Question: The dispute may focus on the architectural requirement of a "parallel path." A key question of scope will be whether this term requires physically separate processing hardware or if it can be read on a software implementation where pilot-related calculations are scheduled to occur concurrently with and finish before the main data FFT processing is complete.
- Technical Question: Factually, the case will question whether the accused devices are architected in a way that allows the phase error estimate to be calculated and available before the main FFT block has finished its computation for a given data symbol, as required by the final limitation of the claim.
V. Key Claim Terms for Construction
For the ’583 Patent
- The Term: "maximum likelihood-based estimation"
- Context and Importance: This term defines the specific mathematical nature of the claimed invention. The infringement analysis will depend entirely on whether the accused devices' phase estimation algorithm falls within the scope of this term. Practitioners may focus on this term because it distinguishes the invention from simpler, potentially non-infringing techniques like averaging or tracking only the strongest pilot signal.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the goal as producing "an estimate of the aggregate phase error of the current OFDM data symbol" by processing "complex signal measurements for all of the pilots" (’583 Patent, col. 5:24-29). A party could argue that any method that mathematically combines data from all pilots to find the statistically most probable phase error meets the definition.
- Evidence for a Narrower Interpretation: The detailed description provides specific mathematical formulas for the estimator (e.g., Eqs. 13 and 14) (’583 Patent, col. 10:11-42). A party could argue the term should be limited to these specific equations or structures that are mathematically equivalent, thereby excluding other forms of multi-pilot estimation.
For the ’616 Patent
- The Term: "processing, in a parallel path"
- Context and Importance: This phrase describes the core architectural innovation of the patent—performing pilot tracking separately from and concurrently with the main data processing. The infringement question will turn on whether the accused systems have such a parallel architecture.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that "processing the baseband signal...in parallel paths, shown as path A and path B, with the FFT 304 is unique" (’616 Patent, col. 19:57-60). This could support a construction that covers any system where pilot processing is not strictly in series with (i.e., dependent on the output of) the main data FFT.
- Evidence for a Narrower Interpretation: Figure 8 of the patent depicts a distinct "Pilot Phase Error Metric" block (808) that receives its input signal in parallel with the "Cyclic Prefix Removal" block (802), which feeds the main FFT (304). This could support a narrower construction requiring a physically or logically distinct processing pipeline for the pilot tones that does not wait for the output of the main FFT.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement with respect to the ’968 patent. The inducement claim is based on Defendant allegedly providing instructions, advertising, and technical support that guide end-users to use the Accused Products in an infringing manner (Compl. ¶¶91-92). The contributory infringement claim alleges the Accused Products contain "special features" that are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶93).
- Willful Infringement: Willfulness is alleged for the ’968 patent, based on the assertion that Defendant's infringement was "intentional, deliberate, or in conscious disregard of Fleet Connect's rights" and "at least objectively reckless" (Compl. ¶¶94-95). The complaint does not specify facts supporting pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical implementation: Do the accused CalAmp products, which operate in the complex domain of wireless communications and fleet logistics, actually practice the specific technical methods claimed in the patents? For example, do they utilize the "maximum likelihood-based estimation" of the ’583 patent and the "parallel path" architecture of the ’616 patent, or do they employ different, non-infringing technical solutions to similar problems?
- A second core issue will be one of definitional scope: Can the claim terms from the diverse portfolio of asserted patents, ranging from specific signal processing techniques ("maximum likelihood-based estimation") to broader application-level concepts ("field assessment program"), be construed to cover the integrated, multi-functional software and hardware platforms of the Defendant?
- A key evidentiary question for the indirect and willful infringement claims will be one of knowledge and intent: Beyond the general operation of its products, what specific evidence will be presented to show that Defendant knew of the ’968 patent and actively intended for its customers to use its products in a manner that directly infringed the patent's claims?