DCT

2:25-cv-00658

Fleet Connect Solutions LLC v. PACCAR Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00658, E.D. Tex., 06/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business in the district, transacts business there, and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicle fleet management, diagnostics, and tracking systems infringe eight patents related to wireless communication, data packet generation, and vehicle communication systems.
  • Technical Context: The technology at issue falls within the domain of vehicle telematics, which involves the integration of telecommunications and informatics for vehicles, a market driven by regulatory mandates for electronic logging and commercial demand for fleet efficiency.
  • Key Procedural History: The complaint does not reference prior litigation, Inter Partes Review (IPR) proceedings, or specific licensing history concerning the asserted patents.

Case Timeline

Date Event
1999-09-10 Priority Date for ’270 and ’723 Patents
2001-09-21 Priority Date for ’040 and ’845 Patents
2003-04-28 Priority Date for ’153 Patent
2003-11-11 ’270 Patent Issued
2004-07-20 Priority Date for ’388 Patent
2006-06-06 ’040 Patent Issued
2006-08-15 ’723 Patent Issued
2007-08-21 ’153 Patent Issued
2009-08-25 Priority Date for ’581 Patent
2010-01-29 Priority Date for ’053 Patent
2010-02-02 ’845 Patent Issued
2010-06-22 ’388 Patent Issued
2011-08-23 ’053 Patent Issued
2013-07-23 ’581 Patent Issued
2025-06-24 Complaint Filed

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 communication systems, such as Bluetooth and IEEE 802.11 Wi-Fi, operate simultaneously in the same unlicensed frequency band (e.g., 2.4 GHz) and in close proximity (’040 Patent, col. 1:26-34). This interference can cause the destruction of data bits and degrade network performance (Id., col. 1:35-41).
  • The Patented Solution: The invention proposes a method to manage this interference by using a time-division multiple access (TDMA) scheme. The method involves computing shared time-slot channels, allocating specific slots to each communication medium, and instructing the respective transceivers to transmit only within their assigned slots (’040 Patent, col. 2:3-12; Fig. 1A). This coordination is intended to prevent simultaneous transmissions that would otherwise interfere with each other.
  • Technical Importance: The solution provides a method for enabling the coexistence of different, popular wireless standards in crowded, unlicensed radio spectrum, which is critical for maintaining reliable performance in devices that incorporate multiple wireless technologies.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶31).
  • The essential elements of independent claim 1 are:
    • A method for data transmission over first and second media that overlap in frequency.
    • Computing one or more TDMA time-slot channels to be shared between the media.
    • Allocating one or more time-slots to the first medium.
    • Allocating one or more of the remaining time-slots to the second medium.
    • Dynamically adjusting the number of time-slots assigned to one of the media during transmission to maintain a desired level of service.
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’040 Patent.

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method And Apparatus Providing Extended Range And Extended Rate Across Imperfectly Estimated Channels"

  • Issued: August 21, 2007

The Invention Explained

  • Problem Addressed: The patent describes a problem in Multiple-Input Multiple-Output (MIMO) wireless systems where imperfect estimation of the communication channel leads to "cross-talk interference" between the multiple data sub-streams that are transmitted in parallel (’153 Patent, col. 3:42-49). This cross-talk degrades the signal-to-noise ratio and undermines the performance benefits of MIMO technology (Id., col. 4:9-15).
  • The Patented Solution: The invention provides a method for improving MIMO performance by first evaluating the quality of the communication channel using specific "Channel Matrix Metrics." Based on these metrics, the channel is classified as "Good" or "Bad." If a channel is "Bad," a "Pre-Equalizer" operator is calculated and applied to transform the channel into a "Good" one with more favorable characteristics, thereby reducing cross-talk and improving the reliability and data rate of the communication link (’153 Patent, col. 4:38-54).
  • Technical Importance: This technology aims to make high-speed MIMO wireless systems, which are foundational to modern standards like Wi-Fi and 5G, more robust against the real-world challenge of imperfect channel conditions, allowing them to achieve performance closer to their theoretical potential.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶40).
  • The essential elements of independent claim 1 are:
    • A method for evaluating a MIMO wireless communication channel.
    • Defining a "channel matrix metric," which is a predefined function of the channel's singular values and provides a measure of cross-talk signal-to-noise ratio.
    • Obtaining an estimated channel matrix.
    • Performing a singular value decomposition (SVD) on the estimated channel matrix to obtain estimated channel singular values.
    • Calculating a respective crosstalk measure for each data sub-stream from the channel matrix metric and the estimated singular values.
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’153 Patent.

U.S. Patent No. 8,005,053 - "Channel Interference Reduction"

  • Issued: August 23, 2011
  • Technology Synopsis: As a continuation of the application leading to the ’040 Patent, this patent also addresses RF interference between co-located wireless systems operating in overlapping frequency bands. The solution involves selecting one of the media as a "common medium" and routing all data transmission through it to avoid interference (Compl. ¶¶ 46, 47; ’053 Patent, Abstract).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶49).
  • Accused Features: The complaint alleges that Defendant’s products, which use multiple wireless standards operating in overlapping frequency bands (e.g., Bluetooth and Wi-Fi), infringe by managing interference between these standards (Compl. ¶¶ 18-21).

U.S. Patent No. 7,656,845 - "Channel Interference Reduction"

  • Issued: February 2, 2010
  • Technology Synopsis: As a continuation of the application leading to the ’040 Patent, this patent also describes methods for mitigating RF interference between co-located wireless systems. The claims relate to allocating TDMA time slots between different media to prevent simultaneous, interfering transmissions (’845 Patent, Abstract; Compl. ¶55).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶58).
  • Accused Features: The infringement allegations target the functionality within Defendant’s products that manages coexistence between different wireless protocols operating in the same frequency bands (Compl. ¶¶ 18-21).

U.S. Patent No. 7,742,388 - "Packet Generation Systems And Methods"

  • Issued: June 22, 2010
  • Technology Synopsis: This patent discloses methods for increasing the data rate of a packet in a digital communication system, such as a wireless local area network. The invention involves increasing the standard size of a data packet by adding subcarriers to it, thereby creating an "extended data signal" that carries more information (’388 Patent, Abstract; Compl. ¶64).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶67).
  • Accused Features: The complaint alleges that the Accused Products, which employ Orthogonal Frequency-Division Multiplexing (OFDM) methods, generate and process packets in a manner that infringes the patent (Compl. ¶¶ 20, 21).

U.S. Patent No. 6,647,270 - "VehicleTalk"

  • Issued: November 11, 2003
  • Technology Synopsis: The patent describes a communication system for mobile units (vehicles) that enables them to exchange information. Each mobile unit is equipped with a broadband RF transceiver, a GPS receiver, and a microprocessor to construct and transmit data packets containing information such as the vehicle's position, speed, and direction (’270 Patent, Abstract; Compl. ¶80).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶83).
  • Accused Features: The Accused Products are alleged to infringe by tracking and reporting vehicle location and other data, and by enabling communication between a vehicle and a remote system administrator (Compl. ¶22).

U.S. Patent No. 8,494,581 - "System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices"

  • Issued: July 23, 2013
  • Technology Synopsis: This patent relates to systems for managing mobile field assets using wireless handheld devices. It describes bi-directional data delivery and synchronization between enterprise servers and field devices to support logistics, personnel management, and data collection based on geographical location (’581 Patent, Abstract; Compl. ¶89).
  • Asserted Claims: At least claims 21 and 22 are asserted (Compl. ¶92).
  • Accused Features: The complaint targets Defendant's fleet management platforms that provide, process, and display routing, diagnostic, and location information for vehicles, allegedly infringing the patented methods (Compl. ¶¶ 18, 22).

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 application leading to the ’270 patent, this invention also pertains to a system for communication among mobile vehicles. It describes generating communication packets from data fields that include sender and receiver information, enabling the exchange of vehicle status data like speed, direction, and position (’723 Patent, Abstract; Compl. ¶98).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶101).
  • Accused Features: Infringement is alleged based on the Accused Products' functionality for tracking, analyzing, and reporting vehicle maintenance needs, warnings, and locations, and facilitating communication between a vehicle and a remote administrator (Compl. ¶22).

III. The Accused Instrumentality

Product Identification

The complaint broadly identifies the "Accused Products" as Defendant's fleet management platforms, diagnostic platforms, tracking solutions, and vehicles incorporating such systems (Compl. ¶18). Specific examples include Peterbilt's SmartLINQ, ConnectedFleet®, and Virtual Vehicle™ systems and platforms (Compl. ¶18(1)).

Functionality and Market Context

  • The Accused Products are alleged to be on-board diagnostic systems, connected vehicle systems, and Electronic Logging Device (ELD) systems that communicate with in-cab or remote devices using a variety of wireless protocols, including Bluetooth, 802.11 (Wi-Fi), GNSS/GPS, and cellular (LTE/5G) (Compl. ¶18(1)).
  • Their functions include tracking, routing, monitoring, maintenance, messaging, and compliance for vehicles and other assets (Compl. ¶18(2)). They are also alleged to provide and display diagnostic, location, status, and alert information to drivers or fleet managers via software, applications, or web portals (Compl. ¶18(3)). The complaint notes that ELDs are mandated by the U.S. Department of Transportation for commercial motor vehicle operators (Compl. ¶18(1)).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent but does not include these exhibits in the filing (Compl. ¶¶ 31, 40, 49, 58, 67, 83, 92, 101). Accordingly, the narrative infringement theories are summarized below.

'040 Patent Infringement Allegations

  • The complaint alleges that the Accused Products perform wireless communications using multiple protocols that operate in overlapping frequencies, such as Bluetooth and IEEE 802.11 (Compl. ¶19). To enable coexistence, these systems must manage potential interference. The complaint contends that this management of overlapping communications constitutes infringement of the claimed method of computing and allocating TDMA time-slots to different media and dynamically adjusting those allocations (Compl. ¶¶ 23, 28, 31).
  • Identified Points of Contention:
    • Technical Questions: A central technical question will be whether the coexistence mechanisms employed by the Accused Products (which may use standardized techniques like Adaptive Frequency Hopping for Bluetooth) perform the specific steps of "computing one or more time division multiple access (TDMA) time-slot channels to be shared" and "allocating" them as required by claim 1. The analysis will focus on whether there is a fundamental mismatch between the claimed TDMA-based approach and the actual operation of the accused systems.
    • Scope Questions: The dispute may turn on the construction of "dynamically adjusting a number of time-slot channels." The question for the court will be what level and type of adjustment meets this limitation and whether the accused systems perform such an adjustment to maintain a "desired level of service."

'153 Patent Infringement Allegations

  • The complaint asserts that the Accused Products utilize modern wireless standards like IEEE 802.11n or 5G, which employ MIMO technology to achieve high data rates (Compl. ¶¶ 19, 20). The complaint alleges that to function correctly, these MIMO systems must perform channel estimation and adapt their transmissions to mitigate interference, and that this process infringes the claimed method of defining a "channel matrix metric," performing an SVD, and calculating a "crosstalk measure" (Compl. ¶¶ 23, 37, 40).
  • Identified Points of Contention:
    • Technical Questions: A key evidentiary question will be what proof exists that the accused MIMO systems calculate and apply the specific "channel matrix metric" as defined in the patent. The analysis will probe whether the channel quality indicators and adaptation algorithms used in the accused standards-based products are technically equivalent to the claimed method.
    • Scope Questions: The construction of "channel matrix metric" will be critical. The court will need to determine if this term is limited to the specific formulation in the patent's disclosure or if it can be construed more broadly to cover other forms of channel quality assessment used in modern MIMO systems.

V. Key Claim Terms for Construction

"dynamically adjusting a number of time-slot channels" ('040 Patent, claim 1)

  • Context and Importance: This term is central to the infringement analysis for the ’040 Patent. The plaintiff's theory appears to depend on mapping the coexistence features of modern wireless protocols to this claimed step. Practitioners may focus on this term because its construction will determine whether protocols that manage interference through means other than explicit TDMA time-slot allocation (e.g., frequency hopping or listen-before-talk mechanisms) fall within the scope of the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism or algorithm for the adjustment, only that it is done "dynamically...during the data transmission to remain within limits of a desired level of service" (’040 Patent, col. 10:26-30). This may support an argument that any real-time adaptation of channel access qualifies.
    • Evidence for a Narrower Interpretation: The patent's specification is grounded in TDMA systems, describing how "a single mobile station can transmit on multiple time slots of the same TDMA frame" and how "uplink and downlink are allocated separately" (’040 Patent, col. 4:27-35). Figure 1E explicitly illustrates TDMA frames and time slots. This context suggests the "adjusting" is specific to the allocation of discrete TDMA time slots, not other forms of channel access management.

"channel matrix metric" ('153 Patent, claim 1)

  • Context and Importance: The definition of this term is crucial for the ’153 Patent, as the entire claimed evaluation method depends on it. The dispute will likely center on whether the channel quality assessment methods used in the Accused Products meet this definition. Practitioners may focus on this term because it appears to be a patentee-coined phrase whose scope will be determined almost entirely from the intrinsic evidence.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim defines the term functionally as a "predefined function of channel matrix singular values" that "provides a measure of cross-talk signal to noise ratio" (’153 Patent, col. 16:47-52). An argument could be made that any function that uses SVD outputs to quantify crosstalk meets this definition, regardless of its specific mathematical form.
    • Evidence for a Narrower Interpretation: The specification describes using these metrics to classify channels into "Good" and "Bad" categories based on whether they fall within a specific region of "Singular Values Feature Space" defined by "Discriminant Functions" (’153 Patent, col. 8:36-54; Fig. 2). This may support a narrower construction requiring a metric that performs this specific classification function, rather than any general measure of crosstalk.

VI. Other Allegations

Indirect Infringement

For U.S. Patent No. 7,742,388, the complaint alleges both induced and contributory infringement (Compl. ¶¶ 69, 71). Inducement is alleged based on Defendant providing the Accused Products and distributing instructions that guide customers and end-users to use them in an infringing manner (Compl. ¶¶ 69-70). Contributory infringement is alleged on the basis that the Accused Products have "special features that are specially designed to be used in an infringing way" and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶71).

Willful Infringement

Willfulness is alleged for the ’388 Patent based on knowledge obtained "at least as of the date when it received this Complaint" (Compl. ¶68). The complaint further alleges Defendant has a "policy or practice of not reviewing the patents of others" and has been "willfully blind" to Plaintiff's patent rights, constituting objectively reckless conduct (Compl. ¶¶ 72-74).

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

This case presents a broad assertion of eight patents against complex, multi-component telematics systems. The outcome will likely depend on the court's resolution of several core technical and legal questions:

  • A central issue will be one of technical mechanism: For the channel interference patents (’040, ’845, ’053), does the method of interference mitigation used in modern, standards-based wireless systems (e.g., adaptive frequency hopping, carrier sensing) operate in the same way as the claimed method of computing and allocating discrete TDMA time-slots, or is there a fundamental mismatch in their technical operation?
  • A key question will be one of definitional scope: Can terms rooted in specific technical disclosures, such as the "VehicleTalk" system (’270, ’723) and the "channel matrix metric" (’153), be construed broadly enough to read on the accused fleet management architecture and the standardized MIMO adaptation algorithms it employs?
  • A third critical question will be one of evidentiary proof: Given the breadth of the accused instrumentalities, what specific evidence can Plaintiff produce to show that any particular component of the SmartLINQ, ConnectedFleet®, or Virtual Vehicle™ systems performs every step of any single asserted claim? The resolution may depend on detailed analysis of the accused products' hardware, software, and adherence to various communication standards.