Context Directions LLC v. Wagner Cadillac Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Context Directions LLC (Texas)
  • Defendant: Wagner Cadillac Company, Ltd. (Texas)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 2:25-cv-00627, E.D. Tex., 06/12/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining a regular and established place of business within the Eastern District of Texas and having committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s sale of used vehicles equipped with advanced driver-assistance systems infringes two patents related to methods for detecting a mobile device’s context using a hierarchical and adaptive arrangement of sensors.
• Technical Context: The technology concerns energy-efficient context awareness for mobile devices, a critical function in applications like modern automotive advanced driver-assistance systems (ADAS) that must balance performance with system resources.
• Key Procedural History: Plaintiff alleges it provided Defendant with written notice of infringement for both patents-in-suit on October 31, 2023. U.S. Patent No. 10,142,791, one of the patents-in-suit, successfully underwent an ex parte reexamination where the patentability of several claims, including asserted independent claim 1, was confirmed. The '791' patent is also subject to a terminal disclaimer.

Case Timeline

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

U.S. Patent No. 9,807,564

• Patent Identification: 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 October 31, 2017.
• The Invention Explained:
  • Problem Addressed: The patent describes a technical challenge with mobile devices: determining the device's "context" (e.g., whether it is in a moving vehicle) without either suffering from inaccuracy, as with cell tower positioning, or consuming excessive power, as with continuous GPS use (Compl. ¶12; '564' Patent, col. 2:5-22).
  • The Patented Solution: The invention proposes a hierarchical system of sensor groups to solve this problem. A low-power, "lowest level" group of sensors is used to make an initial context assessment. If this assessment indicates a possible context of interest, a "higher level" group containing more power-intensive but more accurate sensors is activated to confirm the context. Crucially, the system then uses the result from the higher-level group to "adapt the configuration" of the lower-level group's classifier, theoretically making the low-power group "smarter" and more efficient over time ('564' Patent, Abstract; col. 4:1-19). This hierarchical activation and adaptation is illustrated in the patent's Figures 2 and 3 ('564' Patent, Figs. 2-3).
  • Technical Importance: This method of hierarchical, adaptive sensing offers a pathway to achieve accurate, real-time context awareness in mobile devices without the prohibitive energy costs associated with continuously operating high-power sensors (Compl. ¶13; '564' Patent, col. 6:44-54).
• Key Claims at a Glance:
  • The complaint asserts independent claims 1 (a device claim) and 23 (a method claim) (Compl. ¶14).
  • The essential elements of independent claim 1 include:
    • A plurality of sensors arranged into a hierarchical plurality of sensor groups.
    • A plurality of classifiers, each assigned to a sensor group.
    • A context detection module configured to:
      • activate a classification by a classifier for a "first sensor group" at the lowest level;
      • activate a classification by a classifier for a "second sensor group" based on the first group's result; and
      • "adapt a configuration" of the first group's classifier based on the second group's result.
  • The prayer for relief reserves the right to assert additional claims (Compl. p. 9, ¶a).

U.S. Patent No. 10,142,791

• Patent Identification: U.S. Patent No. 10,142,791, "Method and System for Context Awareness of a Mobile Device," issued November 27, 2018.
• The Invention Explained:
  • Problem Addressed: The complaint states that the ’791 Patent shares an identical specification with the ’564 Patent; therefore, it addresses the same technical problem of balancing accuracy and power consumption in mobile device context detection (Compl. ¶26; ’791 Patent, col. 2:5-22).
  • The Patented Solution: As the specification is identical to that of the ’564 Patent, the proposed solution is the same hierarchical and adaptive sensor group architecture, where lower-power sensors trigger higher-power sensors, and the results from the latter are used to refine the former (’791 Patent, Abstract; col. 4:1-19).
  • Technical Importance: The technical contribution is identical to that described for the ’564 Patent (Compl. ¶26; ’791 Patent, col. 6:44-54).
• Key Claims at a Glance:
  • The complaint asserts independent claim 1 (a device claim) (Compl. ¶27).
  • The essential elements of independent claim 1 include:
    • A plurality of sensors and hierarchical sensor groups.
    • A plurality of classifiers assigned to the sensor groups.
    • A configuration wherein the mobile device activates a classifier for a "first sensor group" (lowest level), then activates a classifier for a "second sensor group" based on the first result, and finally "adapt[s] a configuration" of the first classifier based on the second result.
  • The prayer for relief reserves the right to assert additional claims (Compl. p. 10, ¶b).

III. The Accused Instrumentality

• Product Identification: The complaint identifies a range of used vehicles from model years 2018-2023, including Jeep, Toyota, and RAM models, sold by the Defendant (Compl. ¶14, ¶27). These are collectively termed the "Accused Instrumentalities."
• Functionality and Market Context: The complaint alleges that the Accused Instrumentalities are equipped with advanced driver-assistance systems (ADAS) that perform the patented method. These systems allegedly comprise a "plurality of sensors" such as cameras, radar, and sensors for steering, braking, and speed (Compl. ¶15). Plaintiff alleges these sensors are organized into hierarchical "sensor groups" (e.g., Group 1: steering, braking, speed; Group 2: camera, radar) that are activated sequentially to detect the vehicle's context and enable features like pre-collision systems, dynamic radar cruise control, and lane tracing assist (Compl. ¶16-¶17). The complaint posits that software modules within the vehicles' operating systems function as the claimed "classifiers" that control the sensors and vehicle movement (Compl. ¶15, ¶18).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'564 Patent Infringement Allegations

'791 Patent Infringement Allegations

The complaint incorporates the infringement allegations from paragraphs 15-19 for its infringement theory of the ’791 Patent (Compl. ¶26). The specific claim chart exhibits cited in the complaint were not provided. The infringement theory appears identical to that for the ’564 Patent.

• Identified Points of Contention:
  • Scope Questions: The complaint alleges that an entire vehicle is a "mobile device" (Compl. ¶15). The patent specifications, however, primarily provide examples of personal electronics like "mobile phones, laptops, PDAs, tablets, watches" ('564' Patent, col. 2:30-32). This raises the question of whether the term "mobile device" as used in the claims can be properly construed to encompass a vehicle, or if it is limited by the specification's disclosure to portable consumer electronics.
  • Technical Questions: The complaint alleges that the ADAS systems "adapt" the configuration of the first classifier by using data from the second group's sensors to "teach" the first group's sensors how to control the car (Compl. ¶19). The patent, in contrast, describes an adaptation mechanism involving updating sets of "positive patterns" and "negative patterns" ('564' Patent, FIG. 5; col. 13:1-15). A key technical question is what evidence the complaint provides that the accused real-time vehicle control loop performs the specific function of "adapting a configuration of the classifier" as required by the claims, rather than operating as a conventional feedback control system.

V. Key Claim Terms for Construction

• The Term: "mobile device"

  • Context and Importance: The applicability of the patents to the accused vehicles hinges on the construction of this term. A narrow construction limited to personal electronics could be dispositive of non-infringement. Practitioners may focus on this term because the specification's explicit examples appear to differ significantly from the accused instrumentality.
  • Intrinsic Evidence for a Broader Interpretation: The plain meaning of "mobile device" could reasonably include a vehicle. The claims themselves do not contain language limiting the term to a specific size or type, such as "handheld" or "portable." The specification lists "satellite navigation devices" and "cameras" as examples of mobile devices, both of which are commonly integrated into vehicles ('564' Patent, col. 2:32).
  • Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly frames the invention in the context of personal electronics, listing "mobile phones, laptops, PDAs, tablets, watches, music players" ('564' Patent, col. 2:30-32). The background section focuses on detecting if a device is in a vehicle, which suggests a distinction between the device and the vehicle ('564' Patent, col. 2:46-48). This context may support an interpretation that the claimed "mobile device" is an item separate from the vehicle itself.

• The Term: "adapt a configuration of the classifier"

  • Context and Importance: This term describes the core "learning" element of the patented invention. The infringement analysis will likely turn on whether the accused ADAS functionality meets this limitation.
  • Intrinsic Evidence for a Broader Interpretation: The term "adapt" could be broadly construed to mean any adjustment or modification. The complaint's allegation that the second sensor group "teaches" the first sensor group to control the vehicle's motion could be argued to fall within a broad definition of adaptation (Compl. ¶19).
  • Intrinsic Evidence for a Narrower Interpretation: The specification discloses a specific method for adaptation, wherein the classifier's configuration is adapted by adding or removing "features vector[s]" to or from a "set of positive patterns" and a "set of negative patterns" ('564' Patent, col. 13:3-15; Fig. 5). An argument could be made that "adapt a configuration" should be limited to this disclosed mechanism of updating the classifier's underlying pattern-matching rules, rather than encompassing the real-time operational feedback that is common in control systems.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement to infringe, stating that Defendant "induces others" (e.g., customers) to perform the patented methods by providing the Accused Instrumentalities and advertising their infringing features and use (Compl. ¶15, ¶20).
• Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It explicitly states that Plaintiff provided written notice of infringement to Defendant on October 31, 2023, and that Defendant's allegedly infringing activities continued after receiving this notice (Compl. ¶20, ¶28).

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

The resolution of this case may depend on the court's determination of several key questions:

1. A core issue will be one of definitional scope: can the term "mobile device", rooted in the patent's context of personal, battery-powered electronics, be construed to cover an entire vehicle as the complaint alleges?
2. A key evidentiary question will be one of technical mechanism: does the accused ADAS's use of sensor data for real-time vehicle control constitute "adapting a configuration of the classifier" as claimed, or is there a fundamental mismatch between the accused feedback system and the specific adaptive learning process described in the patents?
3. A significant procedural and substantive question will be the impact of the '791' patent's reexamination: how will the USPTO's confirmation of the patentability of asserted claim 1 over prior art challenges influence the Defendant's available invalidity arguments and the court's view of the patent's strength?