DCT
2:25-cv-00528
Hayden Ai Tech Inc v. Fleetmind Seon Solutions Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hayden AI Technologies, Inc. (Delaware)
- Defendant: Fleetmind Seon Solutions Inc. (Canada)
- Plaintiff’s Counsel: White & Case LLP
- Case Identification: 2:25-cv-00528, E.D. Tex., 05/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation subject to suit in any judicial district. The complaint also asserts the district is convenient, citing the location of potential witnesses and evidence.
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle automated bus lane enforcement system infringes a patent related to a behind-the-windshield camera assembly designed for autonomous traffic violation detection.
- Technical Context: The technology at issue involves vehicle-mounted, AI-powered camera systems for automated traffic enforcement, a market driven by municipalities seeking to improve public transit efficiency and street safety.
- Key Procedural History: The complaint notes that Defendant actively prosecutes its own U.S. patents relating to similar technology, including LPR cameras for automated bus lane enforcement systems. No prior litigation or post-grant proceedings involving the patent-in-suit are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2022-11-16 | ’787 Patent Priority Date (Provisional Filing) |
| 2023-04-26 | Alleged first offer for sale of Accused Product by Defendant |
| 2023-06-01 | Alleged demonstration of Accused Product by Defendant |
| 2023-06-27 | ’787 Patent Issue Date |
| 2023-07-01 | Alleged date of Defendant's knowledge of the ’787 Patent |
| 2025-05-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,689,787 - "Behind the windshield camera-based perception system for autonomous traffic violation detection"
- Patent Identification: U.S. Patent No. 11,689,787, "Behind the windshield camera-based perception system for autonomous traffic violation detection," issued June 27, 2023. (Compl. ¶1, 55).
The Invention Explained
- Problem Addressed: The patent addresses challenges with mounting automated traffic enforcement cameras inside a vehicle. While interior mounting protects equipment from the elements, vehicle windshields often block infrared (IR) light required for night vision and can reflect both ambient and IR light, causing image-degrading glare and interference for the camera system. (Compl. ¶50-52; ’787 Patent, col. 2:6-22).
- The Patented Solution: The invention is a camera assembly featuring a specially designed "skirt" that protrudes from the camera housing toward the windshield. The skirt is engineered to block interfering light sources from inside the vehicle and prevent the camera from capturing IR light that reflects off the windshield. (’787 Patent, Abstract). The patent describes a specific two-part structure, comprising an inner and outer skirt whose dimensions are geometrically optimized based on the camera’s angle to the windshield to manage these optical problems. (’787 Patent, col. 26:35-col. 28:42, Fig. 9).
- Technical Importance: This design purports to enable reliable, automated violation detection from an interior-mounted camera across various lighting conditions, which was a persistent challenge for prior art systems. (Compl. ¶54; ’787 Patent, col. 2:32-41).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶85).
- The essential elements of independent claim 1 are:
- A license plate recognition (LPR) camera assembly.
- An LPR camera housing containing one or more LPR cameras.
- An LPR camera mount configured to attach the housing to a vehicle’s interior at an angle relative to the windshield.
- A plurality of infrared (IR) lights to illuminate an event scene.
- At least one LPR camera skirt protruding from the housing, configured to prevent reflected IR light from interfering with the captured videos.
- The skirt comprises an outer LPR camera skirt and an inner LPR camera skirt, which is at least partially shrouded by the outer skirt.
- The outer skirt comprises a first and second lateral side.
- The inner skirt comprises a first and second lateral side.
- The length of at least one of the inner skirt's lateral sides is determined based on an angle formed by the outer skirt's second lateral side and the vehicle's windshield.
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant's "Interior Bus Camera Assembly" and its "ClearLane" automated bus lane enforcement (ABLE) system, which incorporates the camera assembly. (Compl. ¶4).
Functionality and Market Context
- The accused ClearLane system is described as an "ALPR camera behind the windshield" used for automated, camera-based enforcement of bus priority lanes and bus stops. (Compl. ¶72).
- The complaint alleges the system is marketed and sold to municipal transit authorities, placing it in direct competition with Plaintiff's own ABLE system. (Compl. ¶66, 69). The complaint includes a figure from Defendant's technical materials, described as a "carefully designed camera hood" intended to solve problems of "windshield glare, reflections, [and] blocked IR." (Compl. ¶72, ¶74). The complaint provides a design drawing from what it alleges are Defendant's materials for a bid to the Los Angeles County Metropolitan Transportation Authority. (Compl. ¶74).
IV. Analysis of Infringement Allegations
’787 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an LPR camera mount coupled to the LPR camera housing and configured to mount the LPR camera housing to an interior of a carrier vehicle at an angle with respect to a windshield... | The accused system is advertised as an "ALPR camera behind the windshield," mounted to a bus interior at an angle. (Compl. ¶71-72). | ¶71, ¶72 | col. 30:60-65 |
| a plurality of infrared (IR) lights configured to illuminate an event scene... | The accused assembly includes IR lights for nighttime and low-light conditions, as required by bid specifications. (Compl. ¶73). | ¶73 | col. 31:1-3 |
| at least one LPR camera skirt coupled to... the LPR camera housing... configured to prevent reflected IR light from interfering with the videos... | Defendant's marketing materials allegedly state problems with reflections and blocked IR are "solved by adding a carefully designed camera hood." The complaint provides a technical drawing of this feature. (Compl. ¶72, 74). | ¶72, ¶74 | col. 31:4-8 |
| wherein the at least one LPR camera skirt comprises an outer LPR camera skirt and an inner LPR camera skirt at least partially shrouded or surrounded by the outer LPR camera skirt... | The complaint alleges on information and belief that the accused assembly's skirt includes an outer LPR camera skirt and an inner LPR camera skirt. (Compl. ¶74). | ¶74 | col. 31:9-13 |
| wherein the length of at least one of the second inner camera skirt lateral side and the first inner camera skirt lateral side is determined based on an angle... | The complaint alleges on information and belief that the length of the accused skirt's components is determined based on the angle made by the outer skirt and the windshield. (Compl. ¶75). | ¶75 | col. 31:17-23 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis may focus on the structural requirements of the "LPR camera skirt." A central question will be whether Defendant’s "camera hood" (Compl. ¶72) constitutes the claimed two-part structure of an "outer LPR camera skirt and an inner LPR camera skirt." The complaint’s own evidence depicts the accused feature as a "Boot" (Compl. p. 19), raising the question of whether this is structurally equivalent to the claimed nested-skirt configuration.
- Technical Questions: A key technical question is whether the dimensions of the accused product's components satisfy the specific geometric relationship recited in claim 1. The claim requires that the length of the inner skirt is "determined based on an angle made by the second outer camera skirt lateral side and a windshield." The complaint alleges this in a conclusory manner (Compl. ¶75), but does not provide evidence showing that the accused product was designed according to this specific method or that its final form meets this precise geometric constraint.
V. Key Claim Terms for Construction
The Term: "at least one LPR camera skirt"
Context and Importance: This term is the central feature of the invention, designed to solve the problem of light interference. The complaint alleges Defendant's "camera hood" (Compl. ¶72) is the infringing feature. Practitioners may focus on this term because its construction will determine whether a single-component "hood" or "boot" can meet the limitations of a multi-component "skirt" as defined in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification at one point refers to "a context camera skirt 116 or camera hood" (’787 Patent, col. 12:61-62), which could suggest the terms are interchangeable and that a single-piece structure might suffice.
- Evidence for a Narrower Interpretation: Claim 1 itself explicitly requires the "skirt" to comprise "an outer LPR camera skirt and an inner LPR camera skirt" with a specific shrouded relationship. The detailed description and Figure 9 heavily detail this two-part structure and its geometric optimization, which may support an interpretation that limits the term "skirt" to this specific, complex embodiment. (’787 Patent, col. 21:1-col. 22:23).
The Term: "wherein the length of...the...inner camera skirt lateral side is determined based on an angle..."
Context and Importance: This limitation defines a specific functional or design relationship between the components, rather than merely their final shape. It is a likely focal point for a non-infringement defense, as proving that a competitor's design process followed this exact methodology presents a high evidentiary hurdle.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff may argue that the claim is to an apparatus, not a method. Therefore, if the final dimensions of the accused product are consistent with what would result from such a determination, it infringes, regardless of the actual design process used by the defendant.
- Evidence for a Narrower Interpretation: The patent specification provides extensive detail, including mathematical equations, on how to perform this determination. (’787 Patent, col. 27:21-col. 28:22). This emphasis may support a narrower construction requiring proof that the accused product's dimensions are a direct and intended result of this specific angular relationship, not just an incidental alignment.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting Defendant directs and encourages its affiliates and customers (e.g., transit authorities) to assemble and use the infringing system. (Compl. ¶96-97). It further alleges contributory infringement by supplying components (the Interior Bus Camera Assembly) that are a material part of the invention, are specially adapted for infringing use, and have no substantial non-infringing uses. (Compl. ¶92-93).
- Willful Infringement: The complaint alleges Defendant had knowledge of the ’787 Patent as of July 2023, just one month after its issuance, based on "extensive monitoring of Hayden" and specific internal employee communications that "expressed concern" about infringement. (Compl. ¶83, 95). It further alleges that Defendant sought legal advice but "chose to proceed...without obtaining an opinion, in reckless disregard of the ’787 Patent." (Compl. ¶98).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural equivalence: Does the accused product's "camera hood" or "boot" (Compl. ¶72, p. 19) embody the specific, two-part "inner skirt" and "outer skirt" configuration that is explicitly recited in Claim 1, or is it a structurally distinct design?
- A key evidentiary question will be one of design intent versus final form: To prove infringement, must the plaintiff show that the dimensions of the accused product were actively "determined based on" the complex geometric relationship to the windshield angle as the claim recites, or is it sufficient to show that the final product's dimensions merely conform to that relationship?
- A significant question for the potential remedy will be the viability of the willfulness claim: The complaint's specific allegations of early, post-issuance knowledge, internal expressions of concern, and a deliberate choice to proceed without an opinion of counsel (Compl. ¶95, ¶98) lay a strong foundation for a finding of willful infringement and enhanced damages if substantiated during discovery.