DCT
2:25-cv-00624
Context Directions LLC v. Patterson Motors Of Kilgore Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Context Directions LLC (Delaware)
- Defendant: Patterson Motors of Kilgore, Inc., et al. (Texas)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 2:25-cv-00624, E.D. Tex., 06/12/2025
- Venue Allegations: Venue is asserted based on Defendants maintaining regular and established places of business within the Eastern District of Texas where alleged acts of infringement have occurred.
- Core Dispute: Plaintiff alleges that advanced driver-assistance systems in certain vehicles sold by Defendants infringe patents related to a hierarchical, power-saving method for detecting a mobile device's context.
- Technical Context: The technology addresses the challenge of enabling continuous context awareness (e.g., detecting if a device is in a moving vehicle) on battery-powered devices without excessive energy consumption.
- Key Procedural History: The complaint alleges Plaintiff provided Defendants with written notice of infringement for both asserted patents on October 26, 2023. U.S. Patent No. 10,142,791 underwent an ex parte reexamination, with a certificate issued on November 5, 2021, confirming the patentability of asserted independent claim 1, among others.
Case Timeline
| Date | Event |
|---|---|
| 2012-02-17 | Earliest Priority Date ('564 & '791 Patents) |
| 2017-10-31 | '564 Patent Issued |
| 2018-11-27 | '791 Patent Issued |
| 2021-11-05 | '791 Patent Reexamination Certificate Issued |
| 2023-10-26 | Alleged Written Notice of Infringement to Defendants |
| 2025-06-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,807,564: "Method for Detecting Context of a Mobile Device and a Mobile Device with a Context Detection Module" (Issued Oct. 31, 2017)
The Invention Explained
- Problem Addressed: The patent identifies a need for mobile devices to determine their "context," such as being located in a moving vehicle (Compl. ¶17). Prior methods that relied on GPS or cellular signals were described as either too power-intensive, leading to unacceptable battery drain, or too inaccurate, resulting in frequent false classifications (’564 Patent, col. 2:5-22).
- The Patented Solution: The invention proposes a power-efficient system where sensors are organized into a hierarchy of groups (’564 Patent, col. 4:6-10). A lower-level, low-power group is activated first to perform a preliminary check. Only if a potential context is detected does the system activate a higher-level, more power-hungry (but more accurate) sensor group for confirmation (’564 Patent, col. 10:55-67; Fig. 3). This tiered activation conserves energy by avoiding constant use of all sensors.
- Technical Importance: This hierarchical approach to sensor management allows for more robust and continuous context-awareness on battery-powered devices than was previously practical (’564 Patent, col. 2:60-67).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 23 (Compl. ¶20).
- Independent Claim 1 (Device Claim) Essential Elements:
- A mobile device comprising a plurality of sensors and sensor groups arranged in a hierarchy.
- A plurality of classifiers, each assigned to a sensor group.
- A context detection module configured to:
- activate a first classification by a classifier of a first, lowest-level sensor group;
- activate a second classification by a classifier of a second sensor group after a result from the first; and
- adapt a configuration of the first classifier based on a result from the second classifier.
U.S. Patent No. 10,142,791: "Method and System for Context Awareness of a Mobile Device" (Issued Nov. 27, 2018)
The Invention Explained
- Problem Addressed: The ’791 Patent shares an identical specification with the ’564 Patent and therefore addresses the same technical problem of power-inefficient context detection in mobile devices (Compl. ¶32; ’791 Patent, col. 2:5-22).
- The Patented Solution: The solution is substantively identical to that described in the ’564 Patent, utilizing a hierarchical arrangement of sensor groups and classifiers to manage power consumption while detecting a device's context (’791 Patent, Abstract). The system activates sensor groups sequentially from lower-power to higher-power based on classification results (’791 Patent, col. 4:1-19).
- Technical Importance: As with the parent patent, the technical contribution is a method for enabling sophisticated context detection on energy-constrained devices (’791 Patent, col. 2:60-67).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶33).
- Independent Claim 1 (Device Claim) Essential Elements:
- A mobile device comprising a plurality of sensors and sensor groups arranged in a hierarchy.
- A plurality of classifiers, each assigned to a sensor group.
- The mobile device is configured to:
- activate a classification by a classifier of a first, lowest-level sensor group;
- activate a classification by a classifier of a second sensor group after a result from the first; and
- adapt a configuration of the first classifier based, at least in part, on a result from the second classifier.
III. The Accused Instrumentality
Product Identification
- The complaint identifies a range of Mazda and Toyota vehicles from model years 2018 through 2025 as the "Accused Instrumentality" (Compl. ¶20, ¶33).
Functionality and Market Context
- The allegations focus on the vehicles' advanced driver-assistance systems (ADAS), which include features like "pre-collision system with pedestrian detection, dynamic radar cruise control, lane departure alert with steering assist, and lane tracing assist" (Compl. ¶23). The complaint alleges that the vehicle itself, with its integrated sensors (camera, radar, steering, braking, speed) and software modules, functions as the claimed "mobile device" (Compl. ¶21). These sensors are alleged to work in a hierarchical sequence to monitor the vehicle's surroundings and control its movement, thereby detecting the vehicle's context relative to its environment (Compl. ¶21, ¶23). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’564 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A mobile device, comprising: a plurality of sensors... | The Accused Instrumentality (vehicle) comprises sensors including a camera, radar, steering, braking, and speed sensor. | ¶21 | col. 7:54-63 |
| ...and a plurality of sensor groups, wherein each of the sensor groups is assigned at least one of the sensors, and wherein the sensor groups are arranged according to a hierarchy; | Sensors are assigned to hierarchical groups: Group 1 (steering, braking, speed) is activated first, and Group 2 (camera, radar) is activated second. | ¶22, ¶23 | col. 4:6-10 |
| ...a plurality of classifiers, wherein each classifier is assigned to a sensor group... | The vehicle's software modules function as classifiers, with software module 1 assigned to Group 1 and software module 2 assigned to Group 2. | ¶24, ¶25 | col. 4:3-6 |
| ...activate a classification by a classifier assigned to a first sensor group... | Software module 1 for Group 1 (steering, braking, speed sensors) is executed first to control the moving vehicle. | ¶23, ¶24 | col. 14:56-62 |
| ...activate a classification by a classifier assigned to a second sensor group after a result of the classification by the classifier assigned to the first sensor group... | After Group 1 is active (vehicle is moving), software module 2 for Group 2 (camera, radar) is activated to monitor surrounding objects. | ¶23, ¶24 | col. 14:62-65 |
| ...adapt a configuration of the classifier assigned to the first sensor group based, at least in part, on a result of the classification by the classifier assigned to the second sensor group. | Information from Group 2's classification (e.g., detecting a nearby car) "teaches" or modifies the operation of Group 1's sensors and classifier to control motion (e.g., change lane or speed). | ¶25 | col. 14:65-col. 15:2 |
’791 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A mobile device, comprising: a plurality of sensors and a plurality of sensor groups... arranged according to a hierarchy... | The allegations for the '791 patent are substantively identical to those for the '564 patent, citing the vehicle's sensors (camera, radar, etc.) arranged in hierarchical groups. | ¶21-23, ¶33 | col. 7:40-52 |
| ...a plurality of classifiers, wherein each classifier is assigned to a sensor group... | The vehicle's software modules are alleged to be classifiers for the sensor groups. | ¶24, ¶33 | col. 8:14-16 |
| ...wherein the mobile device is configured to: activate a classification by a classifier assigned to a first sensor group... | The ADAS is configured to activate the classifier for Group 1 (steering, braking, speed) first. | ¶23, ¶24 | col. 14:51-57 |
| activate a classification by a classifier assigned to a second sensor group after a result of the classification... | The ADAS activates the classifier for Group 2 (camera, radar) once the vehicle is in a moving state. | ¶24 | col. 14:57-62 |
| adapt a configuration of the classifier assigned to the first sensor group based, at least in part, on a result of the classification by the classifier assigned to the second sensor group. | Data from the camera and radar group is used to modify the behavior of the steering and speed control systems. | ¶25 | col. 14:62-col. 15:2 |
- Identified Points of Contention:
- Scope Question: A primary issue for the court will be whether a vehicle's integrated ADAS qualifies as a "mobile device" under the patents. The specifications of both patents repeatedly provide examples of personal electronics like "mobile phones, laptops, PDAs, tablets, watches" (’791 Patent, col. 1:30-32), which may raise the question of whether the claimed invention was intended to cover an entire automobile.
- Technical Question: The infringement theory hinges on whether the accused ADAS performs the specific function of "adapting a configuration of the classifier" as claimed. The complaint alleges that feedback from the second group "teaches" the first group (Compl. ¶25). This raises the question of whether the accused system performs the specific adaptation described in the patent (e.g., modifying sets of "positive patterns" and "negative patterns" as shown in '791 Patent, Fig. 5), or if it merely uses a conventional feedback control loop.
V. Key Claim Terms for Construction
The Term: "mobile device"
- Context and Importance: This term's construction is foundational to the dispute. If a vehicle's integrated ADAS is not a "mobile device," there can be no direct infringement of the asserted claims.
- Intrinsic Evidence for a Broader Interpretation: The term itself is not explicitly defined. A party might argue that its plain and ordinary meaning is not limited and can encompass any device that is mobile, including a vehicle equipped with the described sensor and processor functionality.
- Intrinsic Evidence for a Narrower Interpretation: The patent specification consistently frames the invention in the context of personal, portable electronics. The background section lists "mobile phones, laptops, PDAs, tablets, watches, music players, satellite navigation devices, cameras" as exemplary devices (’791 Patent, col. 1:30-32). This repeated use of handheld examples may support an interpretation that limits the term's scope to such devices.
The Term: "adapt a configuration of the classifier"
- Context and Importance: This term is critical for distinguishing the claimed invention from a static, non-learning hierarchical system. Practitioners may focus on this term because infringement depends on whether the accused ADAS performs a specific type of learning or adaptation, rather than simple sensor-based feedback.
- Intrinsic Evidence for a Broader Interpretation: The complaint alleges this element is met when information collected by the camera and radar "teaches" the steering and speed sensors to control the car's motion (Compl. ¶25). A party could argue this functional description of one system part influencing another falls within a broad reading of "adapt a configuration."
- Intrinsic Evidence for a Narrower Interpretation: The specification details a specific adaptation mechanism where the classifier is modified by adding or removing "features vector[s]" to or from a "set of positive patterns" and a "set of negative patterns" (’791 Patent, col. 13:3-15; Fig. 5). A party could argue this detailed disclosure limits the claim term to this specific machine-learning-style adaptation, excluding conventional real-time control logic.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants induce infringement by providing the Accused Instrumentality (the vehicles) to end-users, thereby causing them to use the patented methods (Compl. ¶21-25).
- Willful Infringement: Willfulness is alleged based on Defendants' continued infringement after receiving alleged written notice on October 26, 2023, which identified the patents-in-suit and the accused products (Compl. ¶26, ¶34).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may turn on two central questions:
- A core issue will be one of definitional scope: can the term "mobile device", which the patents describe in the context of personal electronics like phones and watches, be construed to encompass a modern vehicle's entire integrated driver-assistance system?
- A key evidentiary question will be one of technical operation: does the accused ADAS perform the specific "adaptation of a classifier" as taught in the patent's specification—which describes a learning process of modifying pattern sets—or is the interaction between its sensor groups a form of conventional, non-infringing feedback control?