DCT
2:25-cv-00626
Context Directions LLC v. Peters Chevrolet Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Context Directions LLC (Delaware)
- Defendant: Peters Chevrolet, Inc. (Texas)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 2:25-cv-00626, E.D. Tex., 06/12/2025
- Venue Allegations: Venue is asserted based on Defendant's alleged place of business within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that various Ford and Toyota vehicles equipped with advanced driver-assistance systems, sold by Defendant, infringe two patents related to methods and systems for detecting a device's context using hierarchically organized groups of sensors.
- Technical Context: The technology concerns energy-efficient context awareness for mobile devices, such as detecting movement in a vehicle, by using low-power sensors to trigger higher-power sensors in a tiered, adaptive system.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement for both patents-in-suit on October 31, 2023. The '791 Patent is a continuation of the application that matured into the '564 Patent. U.S. Patent No. 10,142,791 was the subject of an ex parte reexamination, with a certificate issued on November 5, 2021, confirming the patentability of asserted claim 1, among others.
Case Timeline
| Date | Event |
|---|---|
| 2012-02-17 | Priority Date for '564 and '791 Patents |
| 2017-10-31 | U.S. Patent No. 9,807,564 Issued |
| 2018-11-27 | U.S. Patent No. 10,142,791 Issued |
| 2021-11-05 | Reexamination Certificate Issued for U.S. Patent No. 10,142,791 |
| 2023-10-31 | Alleged Written Notice of Infringement Sent to Defendant |
| 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 challenge with prior art mobile devices: determining the user's context (e.g., being in a moving vehicle) either relied on power-intensive sensors like GPS, which drained battery life, or less precise methods like cell tower triangulation, which were slow and prone to error (Compl. ¶12; ’564 Patent, col. 2:6-22).
- The Patented Solution: The invention proposes a method using hierarchically arranged groups of sensors. A first, lower-power sensor group is used to make an initial, less-certain context assessment. If a potential context is detected, a second, higher-power and more accurate sensor group is activated. The results from the higher-level group are then used to "adapt the configuration" of the classifier for the lower-level group, making the system more efficient and accurate over time (’564 Patent, Abstract; col. 4:1-19).
- Technical Importance: This hierarchical and adaptive approach was designed to improve the energy efficiency of context-aware applications on mobile devices, a critical factor for extending battery life (’564 Patent, col. 2:10-15).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 23 (Compl. ¶14). Claim 23 is a method claim.
- The essential elements of independent claim 23 include:
- Assigning a plurality of sensors to a plurality of sensor groups.
- Arranging the sensor groups according to a hierarchy.
- Activating a classification by a classifier for a second (higher-level) sensor group after a result from a classifier for a first (lower-level) sensor group.
- Adapting a configuration of the classifier for the first sensor group based on a result from the classifier for the second sensor group.
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 complaint notes that the ’791 Patent shares an identical specification with the ’564 Patent, thereby addressing the same technical problem of energy-inefficient context detection in mobile devices (Compl. ¶26; ’791 Patent, col. 1:58 - col. 2:22).
- The Patented Solution: As a continuation, the '791 Patent discloses the same hierarchical and adaptive sensor group architecture to solve the problem of balancing context-detection accuracy with power consumption (’791 Patent, Abstract; col. 4:1-19).
- Technical Importance: The invention provides a system-level solution to the battery life limitations that constrained the performance of early context-aware personal electronics (’791 Patent, col. 2:10-15).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶27). Claim 1 is a device claim.
- The essential elements of independent claim 1 include:
- A mobile device comprising a plurality of sensors and sensor groups arranged in a hierarchy, along with a plurality of classifiers.
- The mobile device is configured to activate a classifier for a first (lowest-level) sensor group.
- It is further configured to activate a classifier for a second sensor group after a result from the first.
- It is also configured to adapt the configuration of the classifier for the first group based on a result from the classifier for the second group.
III. The Accused Instrumentality
Product Identification
- A wide range of used Ford and Toyota vehicles from model years 2015-2025 are identified as the "Accused Products" or "Accused Instrumentalities" (Compl. ¶¶ 14, 27).
Functionality and Market Context
- The complaint alleges these vehicles contain advanced driver-assistance systems (ADAS), such as "pre-collision system with pedestrian detection, dynamic radar cruise control, lane departure alert with steering assist, and lane tracing assist" (Compl. ¶17). These systems are alleged to use a suite of sensors—including cameras, radar, and sensors for steering, braking, and speed—to monitor the vehicle's environment and control its movement (Compl. ¶15). The complaint alleges these features are advertised to customers to explain their use (Compl. ¶20).
IV. Analysis of Infringement Allegations
The complaint alleges that the ADAS in the accused vehicles function as the claimed "mobile device" and that its sensors are organized into the claimed hierarchical groups. No probative visual evidence provided in complaint.
'564 Patent Infringement Allegations
| Claim Element (from Independent Claim 23) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| assigning the plurality of sensors to a plurality of sensor groups... | The vehicle's steering, braking, and speed sensors are assigned to a "Group 1," while the camera and radar sensors are assigned to a "Group 2." | ¶16 | col. 7:41-54 |
| arranging the sensor groups according to a hierarchy; | The groups are hierarchical because Group 1 sensors are activated first to enable vehicle movement, and Group 2 sensors are activated second to monitor the moving environment. | ¶17 | col. 9:16-24 |
| activating a classification by a classifier assigned to a second sensor group after a result of a classification by a classifier assigned to a first sensor group... | The camera and radar (Group 2) are activated to monitor objects after the steering, braking, and speed sensors (Group 1) are active and the vehicle is in a moving state. | ¶18 | col. 10:55-61 |
| adapting 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 the camera and radar (Group 2) "teaches" or controls the steering, braking, and speed sensors (Group 1) to perform actions like changing lanes or adjusting speed. | ¶19 | col. 13:3-12 |
'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 accused vehicle is the "mobile device," and its sensors (steering, braking, speed, camera, radar) are organized into hierarchical groups. | ¶¶ 15-17 (incorporated by reference at ¶26) | col. 7:41-54 |
| wherein the mobile device is configured to: activate a classification by a classifier assigned to a first sensor group...at a lowest level...; | The vehicle's ADAS is configured to first activate the "Group 1" sensors (steering, braking, speed) to control the vehicle's basic moving state. | ¶17 (incorporated by reference at ¶26) | col. 14:56-59 |
| 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; | The system is configured to activate the camera and radar sensors (Group 2) once the vehicle is in motion. | ¶18 (incorporated by reference at ¶26) | col. 14:60-63 |
| 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. | The system is configured to use data from the camera and radar (Group 2) to control the behavior of the steering, braking, and speed sensors (Group 1). | ¶19 (incorporated by reference at ¶26) | col. 14:64-65 |
Identified Points of Contention
- Scope Questions: A primary issue may be whether a modern automobile qualifies as a "mobile device" as that term is used in the patents. The specifications of both patents repeatedly reference personal, battery-powered electronics like "mobile phones, laptops, PDAs, tablets, watches," where energy conservation is a paramount design constraint (’564 Patent, col. 1:30-32, col. 2:10-22). This raises the question of whether the patent’s scope extends to a vehicle powered by an engine and alternator.
- Technical Questions: The infringement theory hinges on whether the ADAS feedback mechanism constitutes "adapting a configuration of the classifier" as claimed. The complaint alleges that when camera/radar data "teach" the steering/speed sensors, this meets the limitation (Compl. ¶19). However, this raises the technical question of whether this is a direct, real-time control signal or if it involves modifying an underlying classification model (e.g., a "set of positive patterns" as described in the patent) as required for "adaptation" (’791 Patent, Fig. 5; col. 13:3-12).
V. Key Claim Terms for Construction
The Term: "mobile device"
- Context and Importance: This term's construction is foundational to the entire case. If a vehicle is determined not to be a "mobile device" within the meaning of the patents, the infringement claims may fail.
- Intrinsic Evidence for a Broader Interpretation: The term itself is general. The specification provides a non-exhaustive list of examples, including "satellite navigation devices," which are commonly found in vehicles (’564 Patent, col. 1:31-32).
- Intrinsic Evidence for a Narrower Interpretation: The patent’s background and problem statement are consistently framed around the challenge of limited battery capacity in personal electronics, stating that high power consumption "significantly reduces the operating time of the mobile device using battery, often to such levels that are unacceptable to the user" (’564 Patent, col. 2:11-14). This context may support an interpretation limited to devices with similar power constraints.
The Term: "adapting a configuration of the classifier"
- Context and Importance: This term distinguishes the claimed invention from a simple, non-adaptive feedback system. Whether the accused ADAS performs "adaptation" or merely "reaction" will be a critical point of dispute.
- Intrinsic Evidence for a Broader Interpretation: The complaint's theory suggests any instance where a higher-level sensor's output modifies the behavior of a lower-level sensor system could be considered "adapting" its configuration (Compl. ¶19).
- Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific adaptive mechanism where a classifier's internal logic is changed. For example, a "features vector" is added to or removed from a "set of positive patterns" or a "set of negative patterns" based on feedback from a higher-level classifier (’791 Patent, col. 13:3-12; Fig. 5). This suggests a form of machine learning, which may be narrower than the simple reactive control alleged in the complaint.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by providing the accused vehicles and advertising their ADAS features, which allegedly instructs customers on how to use the infringing systems (Compl. ¶¶ 15, 20).
- Willful Infringement: The willfulness claim is based on alleged continued infringement after Plaintiff provided written notice to Defendant on or about October 31, 2023 (Compl. ¶¶ 20, 28).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: can the term "mobile device", described in the patent in the context of battery-constrained personal electronics, be construed to cover a modern automobile, which operates under a vastly different power paradigm?
- A key evidentiary question will be one of technical operation: does the accused vehicles' ADAS merely implement a reactive command-and-control loop, or does it perform the specific "adapting a configuration of the classifier" taught by the patent, which involves modifying an underlying classification model as described in the specification?
- The dispute may also turn on the interpretation of "hierarchy": does the sequential activation of vehicle systems (e.g., propulsion first, then cruise control) constitute the specific, power-saving hierarchical classification scheme claimed by the patents, or is it a functional necessity of vehicle operation that falls outside the patented method?