Context Directions LLC v. Peltier Enterprises Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Context Directions LLC (Delaware)
  • Defendant: Peltier Enterprises, Inc. (Texas)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 2:25-cv-00419, E.D. Tex., 04/18/2025
• Venue Allegations: Venue is asserted based on Defendant maintaining multiple established places of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that infotainment and mobile connectivity systems in a wide range of vehicles sold by Defendant infringe three patents related to power-efficient methods for detecting a mobile device's context.
• Technical Context: The technology addresses the challenge of enabling mobile devices to be aware of their surroundings (e.g., being in a moving vehicle) without rapidly draining their batteries.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement for all three patents-in-suit on October 31, 2023. The patents share a common specification and claim a shared priority date. U.S. Patent No. 10,142,791 underwent an ex parte reexamination where the patentability of asserted claim 1, among others, was confirmed. This reexamination history may inform arguments regarding the patent's validity.

Case Timeline

Date	Event
2012-02-17	Earliest Priority Date for '564, '791, and '738 Patents
2017-01-01	Approximate Launch of Earliest Accused Products (2017 Model Year)
2017-10-31	'564 Patent Issue Date
2018-11-27	'791 Patent Issue Date
2021-07-06	'738 Patent Issue Date
2021-11-05	'791 Patent Ex Parte Reexamination Certificate Issued
2023-10-31	Plaintiff's Alleged Written Notice of Infringement to Defendant
2025-04-18	Complaint Filing Date

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

U.S. Patent No. 9,807,564 - "Method for Detecting Context of a Mobile Device and a Mobile Device with a Context Detection Module"

• Patent Identification: U.S. Patent No. 9,807,564, "Method for Detecting Context of a Mobile Device and a Mobile Device with a Context Detection Module," issued October 31, 2017.

The Invention Explained

• Problem Addressed: The patent describes a technical challenge with mobile devices: determining the user's "context" (e.g., being in a moving vehicle) in a power-efficient manner. Prior methods using cell tower triangulation were slow and inaccurate, while methods using GPS were accurate but consumed significant battery power, reducing the device's operating time (Compl. ¶12; '564 Patent, col. 1:58 - col. 2:21).
• The Patented Solution: The invention proposes a hierarchical, multi-stage system for context detection. It organizes a device's sensors into different groups, typically from low-power/low-accuracy to high-power/high-accuracy ('564 Patent, col. 4:39-49). A low-power sensor group is used for an initial, energy-efficient check. If this first stage detects a potential context, it triggers the activation of a higher-power sensor group for more definitive classification. The system also includes a feedback loop where results from the higher-level, more accurate classification are used to "adapt the configuration" of the lower-level classifier, improving its future performance ('564 Patent, Abstract).
• Technical Importance: This tiered approach sought to provide reliable context-awareness, a key feature for smart devices, without imposing the prohibitive battery drain associated with continuous high-power sensor operation ('564 Patent, col. 2:61-67).

Key Claims at a Glance

• The complaint asserts independent claims 1 (a device claim) and 23 (a method claim) (Compl. ¶14).
• Claim 1 recites a mobile device comprising: a hierarchy of sensor groups; a plurality of classifiers assigned to the groups; and a context detection module configured to (1) activate a first, lowest-level classifier, (2) activate a second, higher-level classifier based on the first's result, and (3) adapt the configuration of the first classifier based on the second's result.
• Claim 23 recites a corresponding method of arranging sensor groups in a hierarchy, activating a higher-level classification after a lower-level one, and adapting the lower-level classifier's configuration based on the higher-level result.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,142,791 - "Method and System for Context Awareness of a Mobile Device"

• Patent Identification: U.S. Patent No. 10,142,791, "Method and System for Context Awareness of a Mobile Device," issued November 27, 2018.

The Invention Explained

• Problem Addressed: The complaint states that the ’791 Patent shares an identical specification with the '564 Patent, and therefore addresses the same problem of the trade-off between context-detection accuracy and power consumption in mobile devices (Compl. ¶21, incorporating ¶¶11-13).
• The Patented Solution: As the specification is shared, the proposed solution is the same: a hierarchical sensor activation and classification system designed to minimize power use ('791 Patent, Abstract). A low-power sensor group performs an initial check, and if a relevant context is potentially identified, a more power-intensive group is activated for confirmation. The architecture further includes a mechanism for the lower-level classifier to adapt based on results from the higher-level classifier, as depicted in the patent's logical diagrams ('791 Patent, Fig. 2).
• Technical Importance: The invention provides a framework for making sensor-rich mobile devices "smarter" and more responsive to their environment in a sustainable, energy-efficient way ('791 Patent, col. 2:61-67).

Key Claims at a Glance

• The complaint asserts independent claim 1 (a device claim) (Compl. ¶22).
• Claim 1 recites a mobile device with a hierarchy of sensor groups and associated classifiers. The device is configured to: (1) activate a first, lowest-level classification; (2) activate a second, higher-level classification after a result from the first; and (3) adapt the configuration of the first classifier based on the result from the second.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,057,738 - "Adaptive Context Detection in Mobile Devices"

• Patent Identification: U.S. Patent No. 11,057,738, "Adaptive Context Detection in Mobile Devices," issued July 6, 2021.

Multi-Patent Capsule

• Technology Synopsis: This patent shares the same specification as the other asserted patents and is directed to the same core technology (Compl. ¶29). It describes a system and method for power-efficient context detection in a mobile device using a hierarchical arrangement of sensor groups. The system activates progressively more power-intensive sensors only as needed and uses the results from higher-level classifications to adapt and improve the performance of lower-level classifiers (Compl. ¶29, incorporating ¶¶11-13).
• Asserted Claims: Independent claims 1 (a device claim) and 28 (a method claim) are asserted (Compl. ¶30).
• Accused Features: The complaint alleges that the context-aware systems within the accused vehicles, which contain various sensors, infringe by employing the patented hierarchical classification and adaptation method (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

• The accused products are a wide range of used vehicles from manufacturers including Chrysler, Jeep, Toyota, and Mazda, with model years from 2017 to 2024 (Compl. ¶14, ¶22, ¶30). The infringing functionalities are presumably located within the vehicles' infotainment, navigation, or mobile connectivity systems.

Functionality and Market Context

• The complaint does not provide specific technical details about the operation of the accused vehicle systems. It alleges that these systems perform context detection, such as determining that the vehicle is in motion, and that in doing so, they practice the patented methods (Compl. ¶14, ¶22, ¶30). The defendant, Peltier Enterprises, Inc., is a used car dealership that sells and offers for sale these vehicles in Texas (Compl. ¶2, ¶6).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits B-O) that are not included in the provided filing. Therefore, a tabular analysis is not possible. The infringement theory is summarized below in prose.

No probative visual evidence provided in complaint.

'564 Patent Infringement Allegations

The complaint alleges that the accused vehicles' systems infringe at least claims 1 and 23 of the '564 Patent (Compl. ¶14). The narrative theory of infringement suggests these systems function as a "mobile device" containing sensors (e.g., GPS, accelerometers) organized into a "hierarchy" of groups. To determine a context like vehicle movement, the systems allegedly first activate a lower-power sensor group. Based on that result, they activate a higher-power group for confirmation. Finally, the systems are alleged to "adapt a configuration" of the lower-level classifier based on the feedback from the higher-level classification, thereby meeting the core limitations of the asserted claims (Compl. ¶14).

'791 Patent Infringement Allegations

The complaint alleges that the same accused vehicle systems infringe at least claim 1 of the ’791 Patent (Compl. ¶22). The infringement theory is substantively identical to that for the '564 Patent. It centers on the allegation that the accused systems employ a hierarchical, multi-stage process for context detection, wherein a lower-level classification result triggers a higher-level classification, and the result of the higher-level process is used to adapt the lower-level classifier (Compl. ¶22).

Identified Points of Contention

• Scope Questions: A primary question may be whether a vehicle's integrated infotainment system, powered by the vehicle's electrical system, qualifies as a "mobile device" under the patents. The specifications appear to focus on solving battery-life problems in small, personally-carried electronics like smartphones ('791 Patent, col. 2:13-21).
• Technical Questions: The infringement case may hinge on the "adapt a configuration of the classifier" limitation. A key factual question is what evidence demonstrates that the accused systems dynamically reconfigure their lower-level classification algorithms, as opposed to simply making a final decision based on a static combination of inputs from different sensor tiers. Proving this specific adaptive behavior will be critical.

V. Key Claim Terms for Construction

For U.S. Patent 9,807,564 and U.S. Patent 10,142,791

• The Term: "mobile device"

• Context and Importance: This term's construction is central because the accused instrumentalities are vehicles, while the patents' examples are personal electronics. The definition will determine if the patents can read on the accused products at all. Practitioners may focus on this term because the patent's stated problem—conserving battery life—is a defining characteristic of personal mobile devices but is a different consideration for a vehicle with an alternator.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of examples: "mobile phones, laptops, PDAs, tablets, watches, music players, satellite navigation devices, cameras" ('791 Patent, col. 1:30-33). This list could be argued to support a broad definition covering any movable electronic system with sensors, including a vehicle's infotainment unit.
  • Evidence for a Narrower Interpretation: The background section repeatedly frames the technical problem in terms of limited battery capacity, stating that power consumption can reduce operating time "to such levels that are unacceptable to the user" ('791 Patent, col. 2:13-17). This context may support a narrower construction limited to battery-powered, personal devices where such constraints are paramount.

• The Term: "adapt a configuration of the classifier"

• Context and Importance: This term describes a sophisticated feedback mechanism. The dispute will likely focus on whether the accused systems perform a function that meets this specific limitation, which goes beyond simply using multiple data points.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that the lower-level classifier "'learns' from the higher level group classifier" ('791 Patent, col. 11:7-9). This could be argued to cover any process where the behavior of the first stage is modified by the outcome of the second stage, even if the underlying algorithm is not completely rewritten.
  • Evidence for a Narrower Interpretation: The detailed description and FIG. 5 illustrate a specific adaptation mechanism involving adding and removing "features vector" patterns from positive and negative sets ('791 Patent, col. 13:3-14:1). This may support a narrower interpretation requiring a demonstrable modification of the classifier's underlying data model or parameters, not just a change in its output based on new data.

VI. Other Allegations

• Indirect Infringement: The complaint includes allegations of indirect infringement for all three patents but does not plead specific facts to support the knowledge and intent elements beyond asserting Defendant had "full knowledge" from a notice letter (Compl. ¶15, ¶23, ¶31).
• Willful Infringement: Willfulness is alleged for all three patents. The basis for the allegation is Defendant's continued sale of the accused vehicles after receiving alleged written notice of infringement from Plaintiff on or about October 31, 2023 (Compl. ¶15, ¶23, ¶31).

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

• A core issue will be one of definitional scope: can the term "mobile device," rooted in the specification's context of battery-constrained personal electronics, be construed to cover an infotainment system integrated into and powered by a motor vehicle?
• A key evidentiary question will be one of technical operation: does the Plaintiff possess evidence to show that the accused vehicle systems perform the specific, active step of "adapting a configuration" of a lower-level classifier, or do the systems simply use a static, multi-input logic to determine context?
• A final question relates to patent strength and litigation strategy: how will the successful ex parte reexamination of the '791 patent, which confirmed the patentability of asserted claim 1, influence the parties' settlement posture and the court's view of the overall strength of the asserted patent portfolio?