DCT
2:25-cv-00429
Vision Works IP Corp v. Suzuki Motor Corp
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vision Works IP Corp. (Washington)
- Defendant: Suzuki Motor Corporation (Japan)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00429, E.D. Tex., 12/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant conducts substantial business in the district, including through a network of authorized dealerships that advertise and sell the accused products.
- Core Dispute: Plaintiff alleges that Defendant’s electronic vehicle control systems, incorporated into certain Suzuki motorcycles, infringe three U.S. patents related to using acceleration sensors to monitor and control vehicle performance.
- Technical Context: The technology at issue involves advanced vehicle dynamics control, where sensors detect forces such as lateral acceleration to actively adjust systems like suspension, which is a key component of modern vehicle stability and performance systems.
- Key Procedural History: The filing is a First Amended Complaint. The complaint alleges that Defendant has had knowledge of the asserted patents since at least the date the original complaint in the matter was served, which forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2004-10-05 | Priority Date for ’769, ’558, and ’989 Patents |
| 2012-11-20 | U.S. Patent No. 8,315,769 Issued |
| 2014-03-25 | U.S. Patent No. 8,682,558 Issued |
| 2019-08-27 | U.S. Patent No. 10,391,989 Issued |
| 2025-12-19 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,315,769 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
The Invention Explained
- Problem Addressed: The patent describes a problem with prior art anti-collision systems that use simple accelerometers to detect deceleration. Such systems can be unreliable because they struggle to distinguish true deceleration from the effects of gravity when a vehicle is on an incline or a banked curve, leading to false warnings or missed detections of subtle but important events like coasting. (’769 Patent, col. 2:5-41).
- The Patented Solution: The invention proposes a method to more reliably detect deceleration by using data from a vehicle speed sensor (VSS). By monitoring changes in the VSS signal over time, the system can calculate the vehicle's actual acceleration or deceleration, independent of gravitational forces that can corrupt simple accelerometer readings. This data is then used to control vehicle systems. (’769 Patent, col. 7:51-61; Fig. 9).
- Technical Importance: This approach enables the detection of earlier, more subtle indicators of a potential stop, such as a driver disengaging the throttle, which allows for earlier warnings to following vehicles and may help prevent rear-end collisions. (’769 Patent, col. 2:42-53).
Key Claims at a Glance
- The complaint asserts independent claim 21. (Compl. ¶30).
- Claim 21 includes the following essential elements:
- A method for controlling vehicle performance characteristics.
- Sensing the vehicle's lateral acceleration.
- Sending a signal to a plurality of control devices based on the lateral acceleration.
- Adjusting a suspension characteristic of the vehicle based on the lateral acceleration.
U.S. Patent No. 8,682,558 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
The Invention Explained
- Problem Addressed: Similar to the ’769 Patent, this patent addresses the technical challenge of using accelerometers in moving vehicles where the force of gravity can be misinterpreted as acceleration or deceleration, particularly on slopes. (’558 Patent, col. 2:5-41).
- The Patented Solution: The invention discloses a system that uses a combined "accelerometer-gyroscopic sensor." The gyroscope measures the vehicle's orientation (e.g., its pitch and roll), which allows the system to calculate and subtract the component of gravity being measured by the accelerometer. The result is a gravity-compensated or "absolute" acceleration signal, which reflects the true motion of the vehicle. (’558 Patent, col. 5:1-12, Fig. 3A).
- Technical Importance: By providing a more accurate "absolute" acceleration measurement, the invention allows for more precise and reliable control over vehicle performance systems, such as anti-rollover and dynamic suspension adjustments, that must react to real forces acting on the vehicle. (’558 Patent, col. 8:16-24).
Key Claims at a Glance
- The complaint asserts independent claim 21. (Compl. ¶50).
- Claim 21 includes the following essential elements:
- A system for monitoring and controlling vehicle performance characteristics.
- An accelerometer-gyroscope for sensing an absolute acceleration of the vehicle.
- A vehicle computer unit that receives a signal from the accelerometer-gyroscope based on the absolute acceleration.
- The computer unit operates one or more vehicle performance systems based on the absolute acceleration.
U.S. Patent No. 10,391,989 - "Absolute Acceleration Sensor For Use Within Moving Vehicles"
Technology Synopsis
The patent addresses the challenge of creating effective vehicle feedback systems by accurately measuring vehicle motion. It describes a system that monitors a vehicle's lateral acceleration and, upon detecting that the acceleration exceeds a predefined threshold, automatically reduces the vehicle's speed to enhance stability, for example during aggressive cornering. (’989 Patent, col. 2:5-14, col. 4:10-18).
Asserted Claims
The complaint asserts independent claim 9. (Compl. ¶70).
Accused Features
The complaint alleges that Defendant's Suzuki Intelligent Ride System (S.I.R.S.) infringes this patent. (Compl. ¶¶69-70).
III. The Accused Instrumentality
Product Identification
The complaint identifies the Suzuki Advanced Electronic Suspension (SAES) and the Suzuki Intelligent Ride System (S.I.R.S.) as the accused instrumentalities. (Compl. ¶22).
Functionality and Market Context
These systems are alleged to be incorporated into certain Suzuki motorcycle models, including the GSX-S1000GT and GSX-S1000GX. (Compl. ¶¶15, 30 n.5).
Based on marketing materials cited in the complaint, SAES is a feature that "offers a broad range of versatile settings" to deliver a "smoother, more consistent and more stable ride." (Compl., Fig. 2). The S.I.R.S. is described as a broader collection of "advanced electronic rider assist functions," which includes "Active Damping Control" and "Suzuki Road Adaptive Stabilization (SRAS)." (Compl., Fig. 2). A screenshot from Suzuki's website shows a diagram of the Automatic Rear Suspension Modes, illustrating the system's dynamic adjustment capabilities. (Compl., Fig. 2 at p. 5).
The complaint positions these features as key technologies on modern, high-performance Suzuki motorcycles, suggesting they are commercially significant and central to the products' marketing. (Compl. ¶¶15-16, Fig. 2).
IV. Analysis of Infringement Allegations
'769 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for controlling the performance characteristics of a vehicle by sensing its lateral acceleration at the vehicle, | The complaint alleges the Suzuki Advanced Electronic Suspension (SAES) provides a method for controlling vehicle performance by sensing its lateral acceleration. | ¶30 | col. 15:1-3 |
| sending a signal to a plurality of control devices based upon the vehicle's lateral acceleration, | It is alleged that the SAES system sends a signal to control devices based on the vehicle's lateral acceleration. | ¶30 | col. 15:3-5 |
| and adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle. | The SAES system is alleged to adjust a suspension characteristic based on the lateral acceleration. This is supported by cited marketing materials describing "Active Damping Control" and "versatile settings" that provide a "more stable ride." (Compl., Fig. 2). | ¶30 | col. 15:6-8 |
'558 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for monitoring and controlling the performance characteristics of a vehicle including an accelerometer-gyroscope for sensing an absolute acceleration of the vehicle, | The complaint alleges that the SAES system provides for monitoring and controlling vehicle performance and includes an "accelerometer-gyroscope for sensing an absolute acceleration of the vehicle." | ¶50 | col. 16:35-39 |
| a vehicle computer unit that receives a signal from the accelerometer-gyroscope based upon the absolute acceleration of the vehicle | The SAES system allegedly contains a vehicle computer unit that receives a signal from the aforementioned accelerometer-gyroscope. | ¶50 | col. 16:39-42 |
| and operates one or more vehicle performance systems based upon the absolute acceleration of the vehicle. | The SAES is alleged to operate one or more vehicle performance systems (such as the suspension itself) based on the absolute acceleration signal. Marketing materials describe SAES as enabling "seamless switching between settings that emphasize responsiveness" and those that "better smooth out bumps." (Compl., Fig. 2). | ¶50 | col. 16:42-45 |
Identified Points of Contention
- Scope Questions: For the ’769 Patent, the term "plurality of control devices" may become a point of contention. The analysis may raise the question of whether a single integrated electronic control unit (ECU) that sends signals to multiple suspension actuators meets this limitation, or if the claim requires multiple distinct processing units.
- Technical Questions: For the ’558 Patent, a central technical question will be whether the accused SAES calculates "absolute acceleration" in the manner required by the patent. The patent specification heavily details the need to use gyroscopic data to correct for gravitational forces. Evidence will be needed to determine if Suzuki's system performs this specific gravity-compensation step or uses a different method to measure acceleration.
V. Key Claim Terms for Construction
The Term: "absolute acceleration" (’558 Patent, Claim 21)
- Context and Importance: This term is critical because the patent's background distinguishes the invention from prior art by its ability to provide a gravity-compensated, or "absolute," measurement. The infringement analysis for the ’558 patent will likely depend on whether the accused system's calculation of acceleration meets the specific definition of "absolute acceleration" as taught in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is not explicitly defined with a single sentence. A party might argue for a broader meaning, suggesting it covers any processed acceleration signal that is more refined than a raw sensor output.
- Evidence for a Narrower Interpretation: The specification repeatedly contrasts its invention with systems that are confused by "gravitational acceleration artifacts." (’558 Patent, col. 2:33-35). It describes the solution as using a gyroscope to measure orientation, which enables the system to account for gravity and derive the vehicle's true motion. (’558 Patent, col. 5:1-12). This context suggests "absolute acceleration" is a term of art within the patent that requires compensation for gravitational forces.
The Term: "plurality of control devices" (’769 Patent, Claim 21)
- Context and Importance: The infringement finding for the ’769 patent may hinge on the architecture of the accused SAES. Practitioners may focus on this term because modern vehicle systems often use a centralized ECU to manage multiple components, raising the question of what constitutes a "device."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide a specific definition. A party could argue that the term's plain and ordinary meaning includes a system where a single processor sends distinct commands to multiple actuators (e.g., front and rear suspension controllers), with each actuator or its local controller constituting a "device."
- Evidence for a Narrower Interpretation: A party could point to figures in the patent family, such as Figure 4, which depicts separate "Control" blocks for each quadrant of the suspension system. (’769 Patent, Fig. 4). This may support an interpretation that "plurality of control devices" requires multiple, functionally distinct controllers, not just actuators receiving signals from one central unit.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is predicated on Suzuki allegedly instructing customers on the use of the accused SAES and S.I.R.S. features through user manuals and promotional materials. (Compl. ¶¶32-34, 52-54, 72-74). Contributory infringement is based on allegations that the accused systems contain special features designed for infringement with no substantial non-infringing uses. (Compl. ¶¶35, 55, 75).
Willful Infringement
The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents since at least the date the original complaint was served. (Compl. ¶¶40, 60, 80). The plaintiff further alleges a "policy or practice of not reviewing the patents of others," suggesting a theory of willful blindness. (Compl. ¶¶38, 58, 78).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope and technical operation: Can the term "absolute acceleration," which the '558 patent specification frames as a gravity-compensated measurement, be construed to read on the method of acceleration sensing used in Suzuki’s SAES? The case will likely require a deep dive into whether Suzuki's system uses gyroscopic data to correct for gravity, as taught by the patent.
- A key question of claim construction will concern the ’769 patent's term "plurality of control devices." The outcome may depend on whether this term is interpreted to require multiple independent processing units or if it can encompass a modern architecture where a central ECU directs multiple suspension system actuators.
- An overarching evidentiary question will be one of technical proof: Plaintiff's allegations are based on publicly available information, and the case will turn on what discovery reveals about the precise hardware, software, and algorithms operating within the accused Suzuki Advanced Electronic Suspension and Intelligent Ride System products.