Minotaur Systems LLC v. Stellantis

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Minotaur Systems LLC (New York / Delaware)
  • Defendant: Stellantis (Netherlands)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00640, E.D. Tex., 06/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the Eastern District of Texas and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s vehicles equipped with the uConnect 5 infotainment system infringe a patent related to power management for in-vehicle communication systems.
• Technical Context: The technology concerns methods for intelligently managing power states in vehicle electronics, seeking to conserve battery life while ensuring that communication and infotainment systems remain responsive to user presence and commands.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,652,023 - “Power management system”

• Patent Identification: U.S. Patent No. 9,652,023, “Power management system,” issued May 16, 2017.

The Invention Explained

• Problem Addressed: The patent’s background section notes that while power management systems are used to prolong battery life, a "positive user experience requires that power saving measures are minimally intrusive" (’971 Patent, col. 1:12-15). The technical problem is balancing the need for energy conservation in a vehicle with the user’s expectation of immediate system responsiveness.
• The Patented Solution: The invention describes a control unit for a vehicle communication system that operates in distinct power states: ON, OFF, and a LOW POWER state (’971 Patent, col. 1:22-23). A "power management module" commands the control unit to transition from the LOW POWER state to the full ON state in response to various triggers, including vehicle-related events (e.g., ignition) and "environmental stimuli" (e.g., sound or light changes) (’971 Patent, Abstract; Fig. 2). This allows the system to conserve significant energy while "waking up" intelligently when user activity is detected or anticipated.
• Technical Importance: The described technology provides a method for in-vehicle systems to offer near-instantaneous connectivity upon a driver entering a vehicle, without requiring the continuous power draw that would otherwise be necessary to maintain such readiness (’971 Patent, col. 9:44-48, col. 10:50-56).

Key Claims at a Glance

• The complaint does not specify which claims it asserts, referring only to "Exemplary '023 Patent Claims" (Compl. ¶11). Independent claims 1 and 18 are representative of the patent's scope.
• Independent Claim 1 recites a system including a control unit with a power management module that commands the unit to enter the ON state in response to each of:
  • a vehicle ignition event
  • a vehicle running condition
  • an incoming wireless command signal
  • environmental stimuli
• Independent Claim 18 recites a similar system, but requires the power management module to command the unit to enter the ON state in response to at least one of the same list of triggers.
• The complaint does not explicitly reserve the right to assert dependent claims, but its general allegations could be interpreted to do so.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as vehicles manufactured by Stellantis brands—including Maserati, Jeep, Fiat, Chrysler, Dodge, and RAM—that are equipped with the "uConnect 5" system (Compl. ¶3). These are referred to as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint alleges that these products practice the technology claimed by the ’971 Patent (Compl. ¶16). However, the complaint does not describe the specific technical operation of the uConnect 5 system’s power management features. Instead, it incorporates by reference claim charts from an external "Exhibit 2" that was not included with the filed complaint (Compl. ¶17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference an infringement analysis in an external document, Exhibit 2, which was not provided with the publicly filed document. The complaint’s narrative theory alleges that the accused uConnect 5 system contains a power management system that practices the claimed invention and satisfies all elements of the asserted claims (Compl. ¶16). Without the specific mappings in Exhibit 2, a detailed element-by-element analysis is not possible from the complaint alone.

Identified Points of Contention

• Scope Questions: A central dispute may involve the scope of the term "environmental stimuli." The patent specification provides examples such as a "sudden change in light intensity" or "human speech" (’971 Patent, col. 10:5-9, 10:55-56). A question for the court will be whether triggers allegedly used by the accused system, such as the opening of a car door or detection of a key fob, fall within the construed scope of this term.
• Technical Questions: The complaint's infringement theory rests on the allegation that the uConnect 5 system has distinct "ON" and "LOW POWER" states as defined by the patent. A key technical question will be what evidence demonstrates that the accused system transitions between these specific states in response to the claimed triggers, as opposed to operating in conventional "sleep" or "standby" modes that may function differently. The distinction between claim 1's requirement for a response to "each of" the triggers versus claim 18's "at least one of" will be a critical point requiring distinct factual proof.

V. Key Claim Terms for Construction

• The Term: "LOW POWER state"

• Context and Importance: The existence of and transition from a "LOW POWER state" is a foundational element of the independent claims. The definition of this term is critical to determining whether the accused uConnect 5 system, which likely has its own power-saving modes, practices this specific claimed limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims themselves distinguish the "LOW POWER state" from the "ON state" and "OFF state," which may support an interpretation that any intermediate power state between fully on and fully off meets the limitation (’971 Patent, col. 12:15-18).
  • Evidence for a Narrower Interpretation: The specification describes a specific embodiment of the LOW POWER state where a particular subset of modules remains ON (e.g., "power management module 52, Bluetooth modules 40, microphone module 56, accelerometer module 58, and GPS module 60 light sensor 62 and vehicle power analysis module 64") while other components are "turned OFF" (e.g., "host processor 54") (’971 Patent, col. 9:36-48). This detailed description could be used to argue for a narrower construction that requires this specific modular activity profile.

• The Term: "environmental stimuli"

• Context and Importance: This term defines one of the four categories of events that can trigger the system to enter the ON state. Its breadth will directly impact the scope of infringement, as it is a less-defined category than "vehicle ignition event" or "incoming wireless command signal."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent uses the phrase "e.g., sudden light change, noise such as human speech," suggesting the list of examples is not exhaustive (’971 Patent, col. 10:55-56). This supports a construction covering other environmental inputs that indicate a user's presence or intent.
  • Evidence for a Narrower Interpretation: The specification explicitly links the detection of environmental stimuli to specific disclosed hardware: a "light sensor 62" and a "microphone 17" (’971 Patent, col. 10:3-9). An argument could be made that the term should be limited to the types of stimuli detectable by the disclosed sensor hardware.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users to operate the products in a manner that infringes the ’971 Patent (Compl. ¶14-15).

Willful Infringement

The complaint bases its willfulness allegation on post-suit conduct. It asserts that the filing of the complaint provides Defendant with "actual knowledge" of infringement, and that any continued infringing activities thereafter are willful (Compl. ¶13-14).

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

• A core issue will be one of definitional scope: can the term "LOW POWER state," as described in the patent with a specific configuration of active and inactive modules, be construed to read on the particular power-saving modes implemented in the accused uConnect 5 system?
• A second pivotal issue will be one of evidentiary proof: what technical evidence will be required to show that the accused system is triggered by "environmental stimuli" as claimed, and does this require proof of specific sensors disclosed in the patent or can it cover other user-presence indicators?
• Finally, the outcome may hinge on a claim scope distinction: should the case proceed on claims like Claim 1, Plaintiff will bear the significant burden of proving the accused system is triggered by all four enumerated event types, whereas claims like Claim 18 require proof of only one, presenting a much lower evidentiary bar for infringement.