DCT

2:25-cv-00616

Fleet Connect Solutions LLC v. Eroad Ltd

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Fleet Connect Solutions LLC (Texas)
- Defendant: EROAD Limited (New Zealand) and Coretex Limited (New Zealand)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
Case Identification: 2:25-cv-00616, E.D. Tex., 06/10/2025
Venue Allegations: Venue is asserted under 28 U.S.C. § 1391(c)(3), which permits suit against a non-U.S. resident in any judicial district, as both Defendants are organized under the laws of New Zealand.
Core Dispute: Plaintiff alleges that Defendants’ fleet management platforms, vehicle telematics hardware, and associated software infringe fourteen U.S. patents related to wireless communication, data processing, and navigation technologies.
Technical Context: The lawsuit targets the fleet telematics industry, a sector focused on vehicle tracking, diagnostics, and fleet management, which relies heavily on the integration of GPS, cellular, and short-range wireless communication technologies.
Key Procedural History: The complaint notes that Defendant EROAD Limited acquired Defendant Coretex Limited in July 2021, an event described as enabling faster growth in the North American market. No other significant procedural events, such as prior litigation or administrative patent challenges, are mentioned in the complaint.

Case Timeline

Date	Event
2000-09-11	Priority Date: U.S. Patent No. 6,647,270
2001-02-21	Priority Date: U.S. Patent No. 6,549,583
2001-08-21	Priority Date: U.S. Patent No. 6,633,616
2001-09-17	Priority Date: U.S. Patent No. 6,961,586
2001-09-21	Priority Date: U.S. Patent No. 7,058,040
2002-11-04	Priority Date: U.S. Patent No. 7,206,837
2003-04-15	Issue Date: U.S. Patent No. 6,549,583
2003-04-28	Priority Date: U.S. Patent No. 7,260,153
2003-10-06	Priority Date: U.S. Patent No. 7,092,723
2003-10-14	Issue Date: U.S. Patent No. 6,633,616
2003-11-11	Issue Date: U.S. Patent No. 6,647,270
2005-07-20	Priority Date: U.S. Patent No. 7,742,388
2005-10-31	Priority Date: U.S. Patent No. 7,593,751
2005-11-01	Issue Date: U.S. Patent No. 6,961,586
2006-04-11	Priority Date: U.S. Patent No. 7,656,845
2006-06-06	Issue Date: U.S. Patent No. 7,058,040
2006-08-15	Issue Date: U.S. Patent No. 7,092,723
2007-04-17	Issue Date: U.S. Patent No. 7,206,837
2007-08-21	Issue Date: U.S. Patent No. 7,260,153
2008-06-20	Priority Date: U.S. Patent No. 7,741,968
2009-08-25	Priority Date: U.S. Patent No. 8,494,581
2009-09-29	Issue Date: U.S. Patent No. 7,593,751
2010-01-29	Priority Date: U.S. Patent No. 8,005,053
2010-02-02	Issue Date: U.S. Patent No. 7,656,845
2010-06-22	Issue Date: U.S. Patent No. 7,742,388
2010-06-22	Issue Date: U.S. Patent No. 7,741,968
2011-08-23	Issue Date: U.S. Patent No. 8,005,053
2013-07-23	Issue Date: U.S. Patent No. 8,494,581
2021-07-14	EROAD Limited acquires Coretex Limited
2025-06-10	Complaint Filing Date

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

U.S. Patent No. 7,058,040 - "Channel Interference Reduction," issued June 6, 2006

The Invention Explained

Problem Addressed: The patent addresses radio frequency (RF) interference that occurs when multiple wireless standards, such as Bluetooth (a wireless personal area network, or PAN) and IEEE 802.11 (a wireless local area network, or LAN), operate in close proximity within the same unlicensed 2.4 GHz radio band (’040 Patent, col. 1:4-25). The patent notes that because both standards use frequency hopping, but at different rates, there is a strong potential for one system to jam the other, degrading performance (’040 Patent, col. 1:39-44).
The Patented Solution: The invention proposes a method to manage this interference by coordinating transmissions between the two different wireless media. The solution involves computing time division multiple access (TDMA) time-slots that can be shared, allocating specific slots to each medium, and instructing the respective transceivers to transmit only during their assigned time-slots (’040 Patent, Abstract). This time-sharing approach prevents simultaneous transmissions that would otherwise cause interference. The patent further describes dynamically adjusting the allocation of these time-slots to meet a "desired level of service" (’040 Patent, col. 2:19-24).
Technical Importance: This method provided a framework for enabling the coexistence of distinct and independently developed wireless protocols in the increasingly crowded unlicensed spectrum, a critical challenge for device interoperability (’040 Patent, col. 1:19-25).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶35).
Claim 1 is a method claim with the following essential elements:
- computing one or more time division multiple access (TDMA) time-slot channels to be shared between the first and second media for data transmission;
- allocating one or more time-slot channels to the first medium for data transmission;
- allocating one or more of the remaining time-slot channels to the second medium for data transmission; and
- dynamically adjusting a number of time-slot channels assigned to one of the first and second media during the data transmission to remain within limits of a desired level of service.

U.S. Patent No. 7,742,388 - "Packet Generation Systems and Methods," issued June 22, 2010

The Invention Explained

Problem Addressed: The patent background describes the persistent demand for higher data rates and more efficient use of bandwidth in digital communication systems, particularly within established standards like IEEE 802.11a (’388 Patent, col. 1:46-54).
The Patented Solution: The invention discloses a method for increasing the data rate of a communication packet by adding subcarriers to the standard packet structure defined by a given protocol. In the context of an Orthogonal Frequency Division Multiplexed (OFDM) system, this involves populating additional frequency bins during the IFFT process to create an "extended data signal" with a greater payload capacity than a standard packet (’388 Patent, Abstract; col. 6:1-12). The method also details how the packet's preamble is modified to signal the presence of these extra subcarriers to a compatible receiver.
Technical Importance: The solution enables higher data throughput for next-generation devices while retaining a degree of compatibility with legacy devices operating under the original protocol, facilitating incremental improvements to wireless standards (’388 Patent, col. 2:5-11).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶44).
Claim 1 is a method claim with the following essential elements:
- generating a packet with a size corresponding to a protocol used for a network transmission, wherein the packet comprises a preamble having a first training symbol and a second training symbol;
- increasing the size of the packet by adding subcarriers to the second training symbol of the packet to produce an extended packet, wherein a quantity of subcarriers of the second training symbol is greater than a quantity of subcarriers of the first training symbol; and
- transmitting the extended packet from an antenna.

U.S. Patent No. 8,005,053 - "Channel Interference Reduction," issued August 23, 2011

Technology Synopsis: This patent, related to the ’040 Patent, discloses a method for mitigating interference between two different communication media that overlap in frequency. The solution involves selecting one medium as a "common medium" and routing data transmission for both systems through it, thereby avoiding simultaneous transmissions on different protocols.
Asserted Claims: At least independent claim 1 (Compl. ¶60).
Accused Features: The complaint alleges that the Accused Products, which employ multiple wireless protocols like Bluetooth and Wi-Fi, infringe by performing methods to reduce channel interference (Compl. ¶24, ¶59).

U.S. Patent No. 7,656,845 - "Channel Interference Reduction," issued February 2, 2010

Technology Synopsis: This patent, also related to the ’040 Patent, describes a method for managing interference by bonding a short-range radio channel (e.g., Bluetooth) with cellular frequency channels to increase bandwidth, suggesting a coordination scheme between disparate wireless technologies.
Asserted Claims: At least independent claim 1 (Compl. ¶69).
Accused Features: The Accused Products are alleged to infringe by performing wireless communications with mobile units in a manner that reduces interference (Compl. ¶24, ¶68).

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range," issued August 21, 2007

Technology Synopsis: The patent describes a method to solve cross-talk interference in a Multi-Input Multi-Output (MIMO) wireless system. The solution is intended to provide robust and predictable extended communication range and data rates, particularly when propagation channels are imperfectly estimated.
Asserted Claims: At least independent claim 1 (Compl. ¶78).
Accused Features: The Accused Products are alleged to infringe by performing wireless communications that generate and transmit packets using a plurality of wireless transceivers (Compl. ¶25, ¶77).

U.S. Patent No. 6,633,616 - "OFDM Pilot Tone Tracking for Wireless LAN," issued October 14, 2003

Technology Synopsis: This patent discloses a pilot phase tracking loop for an Orthogonal Frequency Division Multiplexed (OFDM) receiver. The system uses a pilot phase error metric to determine a phase error estimate, which is then used to adjust the phase of subsequent incoming symbols, reducing the effects of phase noise from the radio.
Asserted Claims: At least independent claim 12 (Compl. ¶87).
Accused Features: The Accused Products are alleged to infringe by performing various methods of processing OFDM symbols in their wireless communications (Compl. ¶26, ¶86).

U.S. Patent No. 6,549,583 - "Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN," issued April 15, 2003

Technology Synopsis: The patent details a method for pilot phase error estimation in an OFDM receiver. It uses a maximum likelihood-based estimation based on complex signal measurements from multiple pilot tones to compensate for poor local oscillator performance and improve signal tracking in low signal-to-noise conditions.
Asserted Claims: At least independent claim 1 (Compl. ¶96).
Accused Features: The Accused Products are alleged to infringe by performing or causing to be performed error estimation in OFDM receivers (Compl. ¶26, ¶95).

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification," issued April 17, 2007

Technology Synopsis: This patent describes a method for providing periodic trip status information to a user in transit. The system estimates time-of-arrival metrics based on a variety of data inputs, including the user's current location, the time and date, historical travel statistics, and current and forecasted weather and traffic conditions.
Asserted Claims: At least independent claim 1 (Compl. ¶105).
Accused Features: The Accused Products, as fleet management and tracking solutions, are alleged to provide trip status notifications that infringe the patent (Compl. ¶23, ¶104).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices," issued September 29, 2009

Technology Synopsis: The patent discloses a system for using handheld devices to conduct field operations. It includes features for data synchronization with a remote server, real-time access to programs and data, and management of field assessments and data collection via the handheld device.
Asserted Claims: At least independent claim 1 (Compl. ¶114).
Accused Features: The mobile applications and handheld devices within the Accused Products, used for fleet management, are alleged to infringe (Compl. ¶23, ¶113).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices," issued November 1, 2005

Technology Synopsis: This patent, related to the ’751 patent, describes a method for conducting field assessments with a handheld device. It emphasizes providing access to industry-specific program modules on the device and retrieving data to support the assessment, with wireless capabilities enabling data synchronization.
Asserted Claims: At least independent claim 9 (Compl. ¶123).
Accused Features: The handheld data management and mobile application components of the Accused Products are alleged to infringe (Compl. ¶23, ¶122).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices," issued July 23, 2013

Technology Synopsis: The patent covers a system for managing mobile assets (such as personnel and equipment) in the field using wireless handheld devices. The system focuses on collecting and communicating field data based on geographical location to support dispatch, data synchronization, and logistics.
Asserted Claims: At least independent claims 21 and 22 (Compl. ¶132).
Accused Features: The asset tracking and management features of the Accused Products are alleged to infringe (Compl. ¶23, ¶131).

U.S. Patent No. 6,647,270 - "Vehicletalk," issued November 11, 2003

Technology Synopsis: The patent discloses a system for communication between mobile units, such as vehicles. Each unit is equipped with a broadband RF transceiver, a GPS receiver, and a microprocessor, allowing vehicles to transmit and receive packets containing information like their position, speed, and direction.
Asserted Claims: At least independent claim 1 (Compl. ¶141).
Accused Features: The tracking and communication functionalities of the Accused Products, which are used in vehicles, are alleged to practice the claimed invention (Compl. ¶23, ¶140).

U.S. Patent No. 7,092,723 - "System and Method for Communicating Between Mobile Units," issued August 15, 2006

Technology Synopsis: As a continuation of the ’270 patent, this patent further details a system for communication between mobile units. It focuses on the composition of communication packets, including fields for sender/receiver information, administrative data like security and priority, and sender data derived from GPS.
Asserted Claims: At least independent claim 1 (Compl. ¶150).
Accused Features: The packet generation and communication methods of the Accused Products are alleged to infringe (Compl. ¶23, ¶149).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group," issued June 22, 2010

Technology Synopsis: This patent describes a system for permissive navigational tracking, where a "master" portable device can establish a communication link with a group of other devices. The master device maintains and displays the geographic positions of all devices in the group, allowing for centralized tracking and coordination.
Asserted Claims: At least independent claim 4 (Compl. ¶159).
Accused Features: The group tracking and fleet management functionalities of the Accused Products are alleged to infringe the patent (Compl. ¶23, ¶158).

III. The Accused Instrumentality

Product Identification: The complaint identifies the accused instrumentalities as the "EROAD" and/or "Coretex" fleet management platform and tracking solutions (Compl. ¶23). This includes a broad range of products: software applications (MyEROAD, Coretex360), mobile apps (EROAD Assist, Coretex Drive), and hardware such as electronic logging devices (ELDs), asset tracking gateways, dashcams, and various wireless sensors (Compl. ¶23).
Functionality and Market Context: The Accused Products provide enterprise-grade telematics solutions for vehicle fleets of various sizes (Compl. ¶7, ¶9). Their core technical functionality, as alleged in the complaint, involves performing wireless communications using multiple standard protocols including Bluetooth, IEEE 802.11, and LTE (Compl. ¶24). The complaint alleges these products generate and transmit data packets using multiple wireless transceivers (Compl. ¶25) and perform complex signal processing, including error estimation in Orthogonal Frequency Division Multiplexed ("OFDM") receivers and processing of OFDM symbols (Compl. ¶26). These functions are central to vehicle tracking, asset management, and driver monitoring services offered to customers in North America, Australia, and New Zealand (Compl. ¶7-¶9).

IV. Analysis of Infringement Allegations

The complaint references Exhibits A through R as "Evidence of Use Regarding Infringement" for each asserted patent but does not include these exhibits in the filing (Compl. ¶23, ¶35, ¶44). In the absence of these claim-chart exhibits, the following analysis is based on the narrative infringement theories presented in the body of the complaint.

'040 Patent Infringement Allegations

The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’040 Patent (Compl. ¶35). The infringement theory appears to be based on the fact that the accused hardware utilizes multiple radios operating in overlapping frequency bands, such as Wi-Fi and Bluetooth (Compl. ¶24). The complaint alleges that in operating these multiple protocols, the Accused Products necessarily practice methods for reducing channel interference that meet the limitations of the asserted claims (Compl. ¶27).
Identified Points of Contention:
- Scope Question: A potential dispute may arise over whether the accused products' method for radio co-existence, which may be based on standard industry protocols, constitutes "computing . . . TDMA time-slot channels" and "allocating" them as specifically required by the claim language.
- Evidentiary Question: The complaint does not specify the mechanism by which the Accused Products allegedly "dynamically adjust" transmission opportunities based on a "desired level of service." A key question will be what evidence demonstrates this specific adaptive functionality, as opposed to a static or pre-configured co-existence scheme.

'388 Patent Infringement Allegations

The complaint alleges that Defendants directly infringe at least claim 1 of the ’388 Patent (Compl. ¶44). The theory appears to rest on the Accused Products’ use of wireless protocols such as IEEE 802.11n, which operate at higher data rates than earlier standards like 802.11a/g (Compl. ¶24). Plaintiff alleges that such protocols achieve higher rates by using packets with more subcarriers than the legacy standards, thereby practicing the claimed method of "increasing the size of the packet by adding subcarriers" (Compl. ¶27, ¶41, ¶44).
Identified Points of Contention:
- Scope Question: The central issue may be whether implementing a newer, distinct wireless standard (e.g., 802.11n) that is defined to use more subcarriers than an older standard constitutes "increasing the size of the packet by adding subcarriers." Defendants may argue this language requires an active modification of a base packet, not simply the use of a different, pre-defined packet structure.
- Technical Question: What evidence does the complaint provide that the preamble of the transmitted packets in the Accused Products maps to the claim's specific structure of a "first training symbol" and a "second training symbol" where the second contains more subcarriers than the first?

V. Key Claim Terms for Construction

For the '040 Patent

The Term: "dynamically adjusting" (from claim 1)
Context and Importance: The construction of this term is critical to the infringement analysis. Infringement may depend on whether the Accused Products' alleged interference management is adaptive and responsive to performance needs, as "dynamically adjusting" suggests, or if it is a static, pre-set allocation of resources.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's general goal is to "effectively relax the phase noise performance requirements of the radio portion" by coordinating the radio and baseband processing portions, which might support construing any non-static coordination as "dynamic" (’040 Patent, col. 3:45-53).
- Evidence for a Narrower Interpretation: The claim links the adjustment to remaining "within limits of a desired level of service," which suggests a specific feedback mechanism tied to quality-of-service metrics, potentially narrowing the term to exclude adjustments made for other reasons or based on a fixed schedule (’040 Patent, col. 2:22-24).

For the '388 Patent

The Term: "increasing the size of the packet by adding subcarriers" (from claim 1)
Context and Importance: This term is the core of the infringement theory. Its construction will determine whether simply operating on a newer standard with a larger, pre-defined packet structure falls within the claim scope, or if the claim requires an affirmative act of modifying a smaller, base packet.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Summary of the Invention describes systems and methods for "increasing data rate of a packet" to produce an "extended data signal," language which could be argued to generally cover the use of higher-throughput packets like those in 802.11n relative to its predecessors (’388 Patent, col. 2:15-20).
- Evidence for a Narrower Interpretation: The claim language recites an active step of "increasing the size ... by adding subcarriers," which may imply a process of modification rather than the generation of a packet that is natively defined by a different standard. The detailed description illustrates this as a modification process, showing subcarriers being "added" to a baseline configuration (’388 Patent, FIG. 6).

VI. Other Allegations

Indirect Infringement: The complaint pleads induced and contributory infringement for U.S. Patent Nos. 7,742,388 and 7,741,968. The allegations state that Defendants induce infringement by providing customers with instructions, advertising, and technical support that direct the use of the Accused Products in an infringing manner (Compl. ¶47, ¶162). Contributory infringement is alleged on the basis that the Accused Products contain "special features" that are not substantial non-infringing articles of commerce (Compl. ¶48, ¶163).
Willful Infringement: Willfulness is alleged for the ’388 and ’968 patents. The allegations are based on knowledge of the patents at least from the filing of the complaint (Compl. ¶45, ¶160). The complaint further alleges Defendants have a "policy or practice of not reviewing the patents of others" and are therefore "willfully blind," constituting objectively reckless conduct (Compl. ¶49-¶50, ¶164-¶165).
No probative visual evidence provided in complaint.

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

Question of Coexistence vs. Patented Method: A central issue for the patents on channel interference reduction (e.g., the ’040 patent) will be one of technical implementation: Do the Accused Products’ methods for managing co-located radios (e.g., Bluetooth and Wi-Fi) merely implement standard industry coexistence protocols, or do they practice the specific, claimed method of computing, allocating, and "dynamically adjusting" TDMA-style time-slots based on a "desired level of service"?
Question of Standardization vs. Active Modification: For patents related to packet generation (e.g., the ’388 patent), a key dispute will be one of definitional scope: Does implementing a newer wireless standard (like 802.11n) that uses more subcarriers than an older standard (like 802.11a) constitute "increasing the size of the packet by adding subcarriers," as claimed, or does the claim require a non-standard modification of a base packet structure not contemplated by the protocol itself?
Portfolio Breadth and Evidentiary Burden: Given the assertion of fourteen patents covering a wide range of technologies—from RF-level interference management to application-level group navigation—a key procedural and evidentiary question will be how the plaintiff will marshal evidence to prove infringement across such a broad technical and product spectrum, and whether the case will be narrowed to focus on a few core technologies as litigation proceeds.