Haley IP LLC v. Harman Intl Industries Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Haley IP LLC (Texas)
  • Defendant: Harman Intl Industries, Inc (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:25-cv-00577, E.D. Tex., 05/22/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant having committed acts of infringement and maintaining a regular and established place of business in the Eastern District of Texas, as well as conducting substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s driver monitoring systems infringe a patent related to detecting driver inattention by analyzing eye movement and reporting the data.
• Technical Context: The technology concerns advanced driver-assistance systems (ADAS), specifically those designed to enhance safety by monitoring driver alertness and behavior, a market of increasing importance in the automotive industry.
• Key Procedural History: Plaintiff states it is a non-practicing entity and has previously entered into settlement licenses concerning its patents with other entities. The complaint notes these licenses did not involve admissions of infringement or obligations to produce a patented article, which Plaintiff argues is relevant to statutory marking requirements.

Case Timeline

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

U.S. Patent No. 9,311,544 - Teleproctor Reports Use Of A Vehicle And Restricts Functions Of Drivers Phone, issued April 12, 2016

• The Invention Explained:

  • Problem Addressed: The patent addresses the desire of insurance companies, employers, and parents to monitor driver behavior—such as speed, location, and visual attentiveness—to assess risk and encourage safety. A key technical challenge is to provide this monitoring in a way that cannot be easily bypassed by the driver ('544 Patent, col. 1:11-19).
  • The Patented Solution: The invention is a vehicle-installed monitoring device, or "teleproctor," that uses a camera and image processing to automatically detect when a driver's eyes are "not on the road for longer than a glance" ('544 Patent, Abstract). The system is designed to capture and report various driving metrics and includes features to detect its own removal or de-powering to prevent subterfuge ('544 Patent, col. 2:57-64). The components, including a camera (29), image processor (28), and radio transceiver (30), are illustrated in the patent's Figure 2.
  • Technical Importance: The technology aims to automate the process of driver-gaze monitoring, which the patent contrasts with prior art systems that required human review of images, and to create a robust system that reports tampering ('544 Patent, col. 1:40-45; col. 8:36-52).

• Key Claims at a Glance:

  • The complaint asserts claims 1-20 of the '544 Patent (Compl. ¶9, ¶11). Independent claim 1 is a system claim.
  • Independent Claim 1 requires:
    • A camera adapted for installation in a vehicle aimed at a driver's typical location.
    • An image processor circuit coupled to the camera that (i) identifies human eyes, (ii) records a usual appearance of the eyes in an "eyes-on-the-road" position, and (iii) determines when the eyes are diverted from that position by "determining ellipticity of dark parts of eyes contrasted with surrounding whites of eyes."
    • A radio communications circuit for reporting data to a wide area radio network.
    • A speed determining circuit.
    • Means for the components to report incidents of "eyes-off-the-road" to a server when the vehicle is moving above a threshold speed.
  • Plaintiff reserves the right to amend its infringement contentions (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

• The complaint identifies Defendant's "Pupil-Based Driver Monitoring System and related systems" as the accused instrumentality (Compl. ¶12).

Functionality and Market Context

• The complaint alleges that the accused system is used for "determining when a driver of a vehicle is not maintaining a proper lookout" (Compl. ¶8). Plaintiff points to Defendant's website, specifically a factsheet for a product named "Ready Care," as providing instructions for use that allegedly cause infringement (Compl. ¶11). The allegations frame the accused product as a system that monitors driver behavior, a function central to modern automotive safety technology. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain an element-by-element infringement chart, instead referring to a forthcoming "exhibit B" (Compl. ¶10). The infringement theory is based on allegations that Defendant's "Pupil-Based Driver Monitoring System" performs the patented method (Compl. ¶8, ¶12). A summary of the apparent infringement theory for claim 1 is presented below based on the complaint's narrative allegations.

’544 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A central question will be whether Defendant's "Pupil-Based" system actually performs the specific function of "determining ellipticity of dark parts of eyes" as required by the claim. The complaint lacks specific factual allegations on the precise algorithm or method used by the accused system, creating a potential mismatch in technical operation that will be a focus of discovery.
  • Scope Questions: The complaint's infringement theory appears to rest heavily on the name of the accused product. The court will need to determine whether the evidence shows that the accused system's functionality, regardless of its name, falls within the scope of the patent's claims.

V. Key Claim Terms for Construction

• The Term: "determines when the eyes are diverted... by determining ellipticity of dark parts of eyes contrasted with surrounding whites of eyes" (Claim 1)

• Context and Importance: This term recites a specific technical mechanism for detecting eye diversion. The outcome of the infringement analysis may depend entirely on whether the accused system uses this particular method. Practitioners may focus on this term because it is a functional limitation that appears to define the core of the inventive concept over prior art.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party might argue that this language should cover any image analysis technique that measures changes in the shape or orientation of the pupil relative to the sclera to infer gaze direction.
  • Evidence for a Narrower Interpretation: The patent provides a detailed "Method of Computing Eye Direction Metrics" in Appendix A, which describes a multi-step process for identifying pupils and analyzing "rays" extending from the pupil center ('544 Patent, col. 11:21-58). A party could argue this detailed disclosure limits the claim scope to this specific implementation or very close equivalents.

• The Term: "a usual appearance of eyes of a driver in an eyes-on-the-road position" (Claim 1)

• Context and Importance: This term requires the system to establish a baseline for what constitutes normal, attentive driving for a specific driver. Infringement will depend on whether the accused system performs this "recording" or "training" step.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue this term is met by any system that establishes a baseline gaze position, even if it is done dynamically or without an explicit, one-time setup process.
  • Evidence for a Narrower Interpretation: The specification describes a specific setup process where a driver "clicks a button, then looks straight ahead at the road as if driving" to capture an image and save "data characteristics of this face and these eyes" ('544 Patent, col. 4:40-46). This could support an argument that the term requires a distinct, initial calibration step.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant "actively encouraged or instructed others" on how to use its products in an infringing manner, citing a "factsheet" on Defendant's website as evidence of such instructions (Compl. ¶11). Contributory infringement is also alleged on the basis that the accused system's "only reasonable use is an infringing use" and is not a staple commercial product (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’544 patent "from at least the issuance of the patent" or, alternatively, from the filing of the lawsuit (Compl. ¶11, ¶12).

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

1. A core issue will be one of claim scope: can the phrase "determining ellipticity of dark parts of eyes," as described in the patent, be construed to read on the specific technical method of gaze detection employed by Harman’s "Pupil-Based Driver Monitoring System"? The resolution will depend on how narrowly the court defines this functional language in light of the patent's specification.

2. A key evidentiary question will be one of technical proof: what evidence will emerge in discovery to show that the accused system actually performs the claimed steps of recording a "usual appearance" of eyes and then detecting deviations using the specific "ellipticity" method? The complaint's current lack of detailed technical allegations makes this a central point of future contention.

3. The case may also raise questions of indirect infringement: does the material on Defendant's website, such as the "factsheet," constitute sufficient instruction or encouragement to actively induce customers to use the system in a way that directly infringes all limitations of an asserted claim?