Peregrine Data LLC v. Brigade Electronics

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (NM)
  • Defendant: Brigade Electronics (UK)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00508, E.D. Tex., 05/07/2025
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s unidentified vehicle vision systems infringe a patent related to multi-camera recording methods for automobiles.
• Technical Context: The technology involves perimeter vehicle camera systems that continuously record imagery for evidentiary purposes, a domain relevant to automotive safety, insurance, and liability documentation.
• Key Procedural History: The asserted patent claims priority to a 2004 provisional application. The patent’s front page indicates it is subject to a terminal disclaimer, which may tie its enforceability and term to that of another patent not identified in the complaint.

Case Timeline

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

U.S. Patent No. 8,319,619 - "Stored vision for automobiles"

• Patent Identification: U.S. Patent No. 8,319,619, issued November 27, 2012.

The Invention Explained

• Problem Addressed: The patent’s background section identifies the difficulty of obtaining reliable, objective evidence following vehicle accidents or crimes, noting the fallibility of eyewitness testimony and the danger of distracting a driver who tries to manually monitor or record events (’619 Patent, col. 1:15-44). Existing systems are described as insufficient for capturing all surrounding activity (’619 Patent, col. 1:48-52).
• The Patented Solution: The invention proposes a method and system where multiple cameras are placed around a vehicle's periphery to continuously and automatically record a 360-degree view (’619 Patent, col. 2:19-23). The image data is transmitted to a central digital recorder, and the system is preferably inaccessible to the driver during operation to prevent distraction, allowing for later “off line recovery” of recorded events for evidentiary use (’619 Patent, col. 2:16-19, col. 2:54-58; Fig. 1).
• Technical Importance: The described approach provides for comprehensive, continuous, and automatic perimeter surveillance, contrasting with earlier systems that may have been limited to forward-facing views, manual activation, or event-based triggers like G-force sensors (’619 Patent, col. 2:23-28).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," with analysis logically centering on the sole independent claim, Claim 1.
• Independent Claim 1 recites a method with the following key steps:
  • Placing a plurality of cameras in circumferentially spaced positions around the vehicle’s periphery “at about the middle of its vertical height” and fixedly securing them.
  • Activating all cameras upon starting a trip to operate continuously throughout the trip.
  • Recording images acquired by each camera in a “corresponding separate file.”
  • Using “separate node files to provide eight separate files of real-time recorded data” obtained from the cameras.
  • Using the cameras as a “set, not a combination,” with each operating separately and individually.
  • Locating the apparatus so it is “inaccessible to a driver” throughout the trip.
• The complaint’s reference to "Exemplary '619 Patent Claims" suggests it may assert dependent claims as well (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any of the accused instrumentalities by name. It refers to them generally as “Exemplary Defendant Products” and states they are identified in claim charts attached as Exhibit 2 (Compl. ¶¶11, 13). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint alleges that the accused products are vehicle camera systems that practice the technology claimed in the ’619 Patent (Compl. ¶13). It further alleges that Defendant’s employees directly infringe by internally testing and using these products (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the products' specific functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges infringement by incorporating claim charts from an external exhibit that was not provided with the public filing (Compl. ¶14). Therefore, a detailed element-by-element analysis based on the complaint's allegations is not possible.

The narrative infringement theory is that Defendant makes, uses, sells, or imports products that perform the method of the ’619 Patent (Compl. ¶11). This method, as outlined in Claim 1, involves using a vehicle-mounted, multi-camera system to continuously record perimeter views into separate files for later retrieval. The complaint asserts that the accused products "satisfy all elements of the Exemplary '619 Patent Claims" (Compl. ¶13).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: Claim 1 requires placing cameras "at about the middle of [the vehicle's] vertical height." A potential dispute is whether accused products with cameras placed in other locations, such as high on a commercial truck's cab or low in a car's bumper, meet this limitation. The interpretation of "about the middle" will be critical.
  • Technical Questions: Claim 1(d) recites a specific data architecture: "using separate node files to provide eight separate files of real-time recorded data." This raises the evidentiary question of whether the accused systems create exactly eight files in this manner, or if they use a different number of files, a single multiplexed data stream, or another storage method. The specificity of this limitation may be a focal point of the technical dispute.

V. Key Claim Terms for Construction

• The Term: "at about the middle of its vertical height" (Claim 1(a))

• Context and Importance: The construction of this spatial term will be central to determining the scope of infringement. A narrow interpretation could exclude many common camera placements on modern vehicles. Practitioners may focus on this term because its ambiguity could be a significant non-infringement defense.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's stated objective is to "capture all activity around a vehicle for extended periods of time" (’619 Patent, col. 2:6-7). This purpose might support a functional definition where any placement achieving effective perimeter viewing qualifies as "about the middle," rather than a strict geometric one.
  • Evidence for a Narrower Interpretation: The specification suggests placement in "previously existing corner or side electrical housings" such as "headlight, brake light, and/or side marker electrical housings" (’619 Patent, col. 4:47-52), which on a typical automobile are located in the vertical middle of the main body. This could support a narrower construction tied to these specific examples.

• The Term: "inaccessible to the driver" (Claim 1(f))

• Context and Importance: This term is tied to the patent's stated goal of avoiding driver distraction. Its definition is crucial for infringement, as it addresses the degree of user interaction permitted by the claimed method.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification repeatedly emphasizes that the system should not distract the driver and is "preferably inacessible to the driver while driving the vehicle" (’619 Patent, col. 2:56-57). This could support a reading that requires the entire apparatus to be physically beyond the driver's reach or control during operation.
  • Evidence for a Narrower Interpretation: The patent’s core concern is preventing distraction from the "main priority—which is DRIVING THE VEHICLE CORRECTLY AND SAFELY" (’619 Patent, col. 2:14-16). This focus could support an interpretation where "inaccessible" means the core recording functions cannot be disrupted, even if non-distracting controls (e.g., a display toggle) are available to the driver.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege indirect infringement (inducement or contributory infringement). Allegations are limited to direct infringement by the Defendant and its employees (Compl. ¶¶11-12).
• Willful Infringement: The complaint does not explicitly allege willful infringement. However, the prayer for relief requests a judgment that the case be declared "exceptional" under 35 U.S.C. § 285, which would permit an award of attorney's fees (Compl. ¶E.i). The complaint does not plead any specific facts, such as pre-suit knowledge of the patent, to support this request.

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

• A central issue will be one of claim scope: can the specific limitations of Claim 1, such as placing cameras "at about the middle of [the vehicle's] vertical height" and recording into exactly "eight separate files," be read to cover the design and operation of Defendant's modern vehicle camera systems? The resolution of this question will depend heavily on claim construction.
• A second key issue will be one of evidentiary proof: given the complaint's lack of specific factual allegations, the case will hinge on whether discovery produces evidence that the accused products' technical operations, particularly their data storage protocols and file structures, map directly onto the precise method steps recited in the asserted patent claims.