DCT

2:25-cv-00429

Vision Works IP Corp v. Suzuki Motor Corp

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00429, E.D. Tex., 01/16/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Suzuki conducts substantial business in the district, including through an authorized dealer network that advertises and sells the accused products to Texas consumers.
  • Core Dispute: Plaintiff alleges that Defendant’s motorcycle electronic control systems, specifically the Suzuki Advanced Electronic Suspension and Suzuki Intelligent Ride System, infringe three patents related to using sensor data to monitor and control vehicle dynamics.
  • Technical Context: The technology at issue involves advanced driver-assistance systems (ADAS) for motorcycles, which use accelerometers and gyroscopes to sense vehicle motion and actively adjust suspension or provide safety warnings.
  • Key Procedural History: The asserted patents claim priority to a 2004 provisional application and have an extensive prosecution history involving multiple continuation, continuation-in-part, and divisional applications, which may give rise to questions regarding claim scope and prosecution history estoppel.

Case Timeline

Date Event
2004-10-05 Earliest Patent Priority Date (’769, ’558, ’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 Model Year Accused Product Model Year Mentioned
2026-01-16 Complaint Filing Date

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

U.S. Patent No. 8,315,769 - *"Absolute Acceleration Sensor For Use Within Moving Vehicles"*

  • Patent Identification: U.S. Patent No. 8,315,769, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued November 20, 2012 (Compl. ¶62).

The Invention Explained

  • Problem Addressed: The patent's background describes how prior art vehicle safety systems that used accelerometers were often ineffective (Compl. ¶27). These systems struggled to distinguish between true vehicle deceleration and the effects of gravity when a vehicle travels on hills or banked curves, which could lead to false warnings or require desensitizing the system to a point where its warnings were delayed and less useful ('769 Patent, col. 2:3-12).
  • The Patented Solution: The invention proposes a system using an "accelerometer-gyroscope" to sense "absolute" acceleration, which decouples the measurement from gravitational forces (Compl. ¶¶36, 42). By providing a cleaner signal representing the vehicle's actual lateral motion, the system can more reliably control vehicle components, such as adjusting individual suspension systems during cornering to counteract rollover forces ('769 Patent, col. 4:11-15, Fig. 4). The complaint references Figure 4 from the patent, a schematic of an anti-rollover system, to illustrate how the sensor's detection of "Absolute Lateral Acceleration" is used to activate individual suspension system controllers (Compl. ¶44, p. 19).
  • Technical Importance: This approach enabled the development of more sophisticated and reliable active vehicle safety systems by providing more accurate real-time data on vehicle dynamics, uncorrupted by road geometry ('769 Patent, col. 1:34-38).

Key Claims at a Glance

The complaint alleges infringement of one or more claims, focusing on method claim 21 while also reciting independent device and system claims 1 and 9 (Compl. ¶¶69, 83-84).

  • Independent Claim 1 (Device): A device comprising:
    • an accelerometer-gyroscope for sensing an absolute lateral acceleration;
    • a suspension selector; and
    • a plurality of controllers for individually controlling one or more suspension systems.
  • Independent Claim 9 (System): A system comprising:
    • an accelerometer-gyroscope for sensing an absolute lateral acceleration;
    • a suspension selector that receives a signal from the sensor;
    • a plurality of controllers that receive a signal from the selector; and
    • one or more suspension systems individually activated by the controllers.
  • Independent Claim 21 (Method): A method comprising:
    • sensing a lateral acceleration of the vehicle at the vehicle;
    • sending a signal to a plurality of control devices based upon the lateral acceleration; and
    • adjusting a suspension characteristic based upon the lateral acceleration.

U.S. Patent No. 8,682,558 - *"Absolute Acceleration Sensor For Use Within Moving Vehicles"*

  • Patent Identification: U.S. Patent No. 8,682,558, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued March 25, 2014 (Compl. ¶98).

The Invention Explained

  • Problem Addressed: As a continuation of the patent family that includes the ’769 Patent, the ’558 patent addresses the same technical problem: the unreliability of simple accelerometer-based systems due to their inability to compensate for gravitational forces on varied terrain (Compl. ¶107; ’558 Patent, col. 2:3-12).
  • The Patented Solution: The solution claimed in the ’558 Patent integrates an "accelerometer-gyroscope" with a "vehicle computer unit" (VCU) ('558 Patent, Claim 1). The sensor provides absolute acceleration data to the VCU, which then processes the signal to operate vehicle performance systems or issue warnings to the driver ('558 Patent, col. 8:49-60). The complaint references Figure 9 from the patent's specification, which illustrates a system where a vehicle speed sensor and acceleration computer provide a deceleration signal to a control device (Compl. ¶45, p. 19).
  • Technical Importance: This patent focuses on the system-level integration of purified sensor data with a vehicle's centralized processing unit to enable intelligent control, diagnostics, and warnings related to vehicle performance and safety (Compl. ¶102).

Key Claims at a Glance

The complaint alleges infringement of one or more claims, focusing on method claim 21 while also reciting independent device and system claims 1 and 11 (Compl. ¶¶105, 119-120).

  • Independent Claim 1 (Device): A device comprising:
    • an accelerometer-gyroscope;
    • a vehicle computer unit; and
    • an internal warning system, wherein the sensor sends a signal to the computer unit, which operates one or more vehicle performance systems.
  • Independent Claim 11 (System): A system comprising:
    • an accelerometer-gyroscope for sensing an absolute acceleration;
    • a vehicle computer unit that receives a signal from the sensor and operates one or more vehicle performance systems based on it.
  • Independent Claim 21 (Method): A method comprising:
    • sensing an absolute acceleration of the vehicle;
    • sending a signal to a vehicle computer unit based upon the absolute acceleration; and
    • operating one or more vehicle performance systems based upon the absolute acceleration.

U.S. Patent No. 10,391,989 - *"Absolute Acceleration Sensor For Use Within Moving Vehicles"*

  • Patent Identification: U.S. Patent No. 10,391,989, "Absolute Acceleration Sensor For Use Within Moving Vehicles," issued August 27, 2019 (Compl. ¶134).
  • Technology Synopsis: This patent is directed to a vehicle monitoring system for preventing rollovers. It claims a system that detects lateral acceleration and, if that acceleration exceeds a threshold, a control device sends a signal to reduce the vehicle's speed. The decision logic is distinct in that it is "based on a heading of the vehicle," allowing the system to differentiate between normal cornering and dangerous lateral movements that risk instability (Compl. ¶¶138, 141; '989 Patent, col. 4:9-15).
  • Asserted Claims: The complaint asserts at least method claim 9 and also recites system claims 1 and 20 (Compl. ¶¶141, 150).
  • Accused Features: The complaint alleges that the "Suzuki Intelligent Ride System (S.I.R.S.)" infringes this patent (Compl. ¶¶60, 149).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are two integrated electronic systems on Suzuki motorcycles: the "Suzuki Advanced Electronic Suspension" (SAES) and the "Suzuki Intelligent Ride System" (S.I.R.S.) (Compl. ¶60). These systems are allegedly incorporated into models such as the 2025 Suzuki GSX-S1000GT+ (Compl. ¶15, Fig. 1).

Functionality and Market Context

  • The complaint presents a screenshot from Suzuki's marketing materials describing the SAES as a system that "offers a broad range of versatile settings that ably support everything from aggressive sport riding to long-distance touring while delivering a smoother, more consistent and more stable ride" (Compl. ¶16, Fig. 2).
  • The S.I.R.S. is described as a broader collection of "advanced electronic rider assist functions," which includes the SAES as well as traction control and other features (Compl. ¶16, Fig. 2).
  • The complaint alleges that these systems are promoted and sold through Suzuki's U.S. dealer network, including dealerships located in the Eastern District of Texas (Compl. ¶¶14-16). A screenshot from a Plano, Texas dealer's website is provided as evidence of these products being offered for sale in the district (Compl. ¶16, Fig. 1).

IV. Analysis of Infringement Allegations

'769 Patent Infringement Allegations

Claim Element (from Independent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
sensing a lateral acceleration of the vehicle at the vehicle; The Suzuki Advanced Electronic Suspension allegedly includes sensors that detect the motorcycle's lateral acceleration during operation. ¶84 col. 5:20-26
sending a signal to a plurality of control devices based upon the lateral acceleration of the vehicle; The SAES allegedly processes the sensed lateral acceleration signal and transmits it to controllers that manage the vehicle's suspension system. ¶84 col. 8:1-12
adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle. The SAES allegedly uses the signal to actively modify suspension settings to enhance stability during cornering or other maneuvers. ¶84 col. 4:11-15

'558 Patent Infringement Allegations

Claim Element (from Independent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
sensing an absolute acceleration of the vehicle at the vehicle; The Suzuki Advanced Electronic Suspension allegedly senses the "absolute acceleration" of the motorcycle, which the patent distinguishes from acceleration affected by gravity. ¶120 col. 7:31-33
sending a signal to a vehicle computer unit based upon the absolute acceleration of the vehicle; The SAES allegedly sends the processed sensor signal to a central computer unit within the motorcycle's electronics system. ¶120 col. 8:49-54
operating one or more vehicle performance systems based upon the absolute acceleration of the vehicle. The central computer unit allegedly uses the signal to operate the SAES, which is identified as the "vehicle performance system." ¶120 col. 9:27-30
  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern whether the integrated Inertial Measurement Unit (IMU) sensor package used in modern motorcycles constitutes the claimed "accelerometer-gyroscope." Similarly, questions may arise as to whether the motorcycle's general Electronic Control Unit (ECU) meets the definition of the "vehicle computer unit" as recited in the ’558 Patent.
    • Technical Questions: For the ’769 Patent, a factual question will be whether the SAES architecture uses a "plurality of control devices" to adjust suspension, or if a single controller manages multiple suspension components. For the ’558 Patent, the analysis may turn on whether the accused system performs the claimed method step of "operating" a performance system, which may require a specific command-and-control relationship between the computer unit and the suspension.

V. Key Claim Terms for Construction

  • The Term: "accelerometer-gyroscope" (’769 and ’558 Patents)
    • Context and Importance: This term is foundational to the independent claims of the lead patents. Practitioners may focus on this term because its construction will determine whether a modern, integrated multi-axis sensor (like an IMU), which was not common in 2004, falls within the claim scope. The defendant may argue the term requires two distinct components or a specific type of integrated sensor disclosed in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discusses the functions of sensing acceleration and orientation in combination, which could support a functional definition (i.e., a system that provides both data streams, regardless of physical integration) (e.g., ’769 Patent, col. 1:36-37).
      • Evidence for a Narrower Interpretation: The hyphenated term itself, along with figures labeling a single box as the "Accelerometer-Gyroscopic Sensor" (e.g., ’769 Patent, Fig. 3A), could support an argument that the claim requires a single, combined physical device as it was understood at the time of invention.
  • The Term: "vehicle computer unit" (VCU) (’558 Patent)
    • Context and Importance: This term is critical to the ’558 patent’s system claims. The dispute may center on whether a general-purpose ECU found in a modern motorcycle is equivalent to the claimed "VCU," or if the claim requires a more specialized processor as described in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claims define the VCU functionally: it "receives a signal" from the sensor and "operates" a performance system based on that signal ('558 Patent, Claim 11). This functional language could support a broad interpretation covering any processor performing those steps.
      • Evidence for a Narrower Interpretation: The patent's figures depict distinct VCUs for specific subsystems, such as the "Vehicle Computer Unit (Engine Monitor)" or "(Suspension)" ('558 Patent, Figs. 5, 6). This could support a narrower construction requiring a dedicated controller rather than a general-purpose one.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Suzuki encourages and instructs customers on how to use the accused SAES and S.I.R.S. features through marketing materials, information brochures, and other sales and support activities (Compl. ¶¶86-88, 124, 154).
  • Willful Infringement: Plaintiff claims willful infringement based on Defendant's alleged knowledge of the patents since at least the filing date of the original complaint in the matter. The complaint further alleges that Suzuki has a "policy or practice of not reviewing the patents of others" and has thus been willfully blind to Plaintiff's patent rights (Compl. ¶¶90, 92, 126, 128, 156, 158).

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

  • A core issue will be one of definitional scope: can the term "accelerometer-gyroscope," rooted in the patent’s 2004 priority date, be construed to cover the modern, highly integrated Inertial Measurement Units (IMUs) used in the accused Suzuki motorcycle systems?
  • A key evidentiary question will be one of architectural mapping: does the specific electronic architecture of the accused SAES and S.I.R.S. map onto the patent's claimed structures, such as the "plurality of control devices" required by the '769 patent or the specific functions of the "vehicle computer unit" recited in the '558 patent?
  • A central legal question, foreshadowed by the complaint's extensive arguments, will be subject matter eligibility: are the claims directed to a specific, concrete technical improvement in vehicle sensor technology (i.e., isolating acceleration data from gravitational noise), or are they directed to the abstract idea of using environmental data to control a vehicle's mechanical systems?