DCT
2:25-cv-00660
Motedata Corp v. UAB Xirgo Global
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Motedata Corporation (Delaware)
- Defendant: UAB Xirgo Global (Lithuania)
- Plaintiff’s Counsel: Bruster PLLC
- Case Identification: 2:25-cv-00660, E.D. Tex., 06/25/2025
- Venue Allegations: Plaintiff alleges that because Defendant is not a resident of the United States, venue is proper in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
- Core Dispute: Plaintiff alleges that Defendant’s fleet management software platform and associated tracking devices infringe three patents related to systems and methods for storing, retrieving, and managing data from tags associated with physical objects.
- Technical Context: The technology at issue involves aggregating data from various sources associated with tagged assets, such as vehicles in a fleet, to enable centralized monitoring, tracking, and analysis.
- Key Procedural History: The complaint alleges that Defendant has had knowledge of the patents-in-suit since at least May 17, 2024, based on a separate lawsuit Plaintiff filed against Track What Matters, LLC. The ’742 Patent is subject to a patent term extension, while the ’520 and ’118 Patents are subject to terminal disclaimers. The complaint also notes a patent license agreement with GPS Insight, Inc. and excludes products sold to that entity from its infringement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2003-10-30 | Earliest Priority Date for all Asserted Patents |
| 2003-Fall | Motedata company formed by inventors |
| 2011-06-07 | ’742 Patent Issued |
| 2015 | Launch of Accused Xirgo Global Fleet Web App |
| 2015-12-22 | ’520 Patent Issued |
| 2021-08-24 | ’118 Patent Issued |
| 2024-05-17 | Alleged Date of Defendant's Knowledge of Patents |
| 2025-06-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,956,742 - "Method and System for Storing, Retrieving, and Managing Data for Tags"
- Patent Identification: U.S. Patent No. 7,956,742, titled “Method and System for Storing, Retrieving, and Managing Data for Tags,” issued June 7, 2011 (’742 Patent).
The Invention Explained
- Problem Addressed: The patent addresses the need for a system to manage data for any type of tag (e.g., RFID) associated with any type of object, where the relevant data may be spread across numerous, disparate data repositories (’742 Patent, col. 1:30-37, col. 3:49-56).
- The Patented Solution: The invention describes a system that aggregates data from these various repositories through a "Crawling Subsystem," reorganizes it into new data structures, and allows a user to query the aggregated data through a "Query Processing Subsystem" (’742 Patent, Abstract; Fig. 14). This allows data from different points in an object's lifecycle (e.g., manufacturing, distribution, use) to be linked by a common tag identifier and analyzed together (’742 Patent, col. 21:5-18).
- Technical Importance: This approach enables complex queries across previously siloed datasets, providing a unified view of a tagged object by combining information that would otherwise be difficult to correlate (’742 Patent, col. 22:46-54).
Key Claims at a Glance
- The complaint asserts infringement of claims 1, 2, 3, 5, 6, and 8–11 (Compl. ¶63). Claim 1 is the sole independent claim asserted.
- The essential elements of independent claim 1 include:
- A method for accessing data associated with tagged entities from one or more repositories.
- Accessing data associated with the tags themselves from one or more repositories.
- Linking the entity data and the tag data together using tag identifiers.
- Receiving a query or keyword search.
- Retrieving data that matches the query from the repositories.
- Determining the tag identifier associated with the matching data.
- Retrieving additional data associated with that determined tag identifier.
- The complaint also asserts dependent claims, which add limitations related to, among other things, posting responses on a web page and the use of standing queries (’742 Patent, cls. 2, 7).
U.S. Patent No. 9,218,520 - "Method and System for Storing, Retrieving, and Managing Data for Tags"
- Patent Identification: U.S. Patent No. 9,218,520, titled “Method and System for Storing, Retrieving, and Managing Data for Tags,” issued December 22, 2015 (’520 Patent).
The Invention Explained
- Problem Addressed: Like its parent, the ’520 Patent addresses the problem of managing and querying data for tagged objects where that data resides in different repositories (’520 Patent, col. 1:29-37).
- The Patented Solution: The invention claims a method of linking entity data with tag data that specifically includes location information, thereby providing the location of the entity via its tag (’520 Patent, cl. 1). A key feature of the claimed method is the step of "ranking" the determined tag identifiers based on "tag references," which relate to the hierarchical relationships between tagged objects and their component parts (’520 Patent, Abstract; col. 25:1-20).
- Technical Importance: The claimed ranking mechanism provides a method for organizing query results to surface the most relevant tagged entities from a large, aggregated dataset, potentially improving the utility of the system for complex asset tracking (’520 Patent, col. 22:50-58).
Key Claims at a Glance
- The complaint asserts infringement of claims 1, 3, 4, 6–11, and 15–20 (Compl. ¶70). Claims 1 and 16 are independent.
- The essential elements of independent claim 1 include:
- Accessing data associated with tagged entities from repositories.
- Accessing data associated with the tags themselves, which includes location information.
- Linking the data to provide the location of the entities.
- Receiving a query or keyword search.
- Determining two or more tag identifiers that satisfy the query.
- Ranking the determined tag identifiers based on their tag references.
- The complaint also asserts dependent claims, which add limitations such as representing data with a physical markup language and crawling repositories (’520 Patent, cls. 3, 11).
U.S. Patent No. 11,100,118 - "Method and System for Storing, Retrieving, and Managing Data for Tags"
- Patent Identification: U.S. Patent No. 11,100,118, titled “Method and System for Storing, Retrieving, and Managing Data for Tags,” issued August 24, 2021 (’118 Patent) (Compl. ¶18).
- Technology Synopsis: The ’118 Patent describes a system where a tag, equipped with a sensor and wireless transceiver, transmits data to a central authority. This central authority organizes the data, generates alerts, and responds to queries by determining and ranking tag identifiers based on their "tag references" to other tags (’118 Patent, Abstract; cl. 1).
- Asserted Claims: The complaint asserts infringement of claims 1–4, 6–11, 13–17, and 19–20 (Compl. ¶77). Claims 1 and 15 are independent.
- Accused Features: The complaint alleges that the Xirgo FMP, in conjunction with its sensor-equipped GNSS devices that transmit data to Xirgo's central system for organization and retrieval, infringes the ’118 Patent (Compl. ¶¶ 49, 78).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the Xirgo Global Fleet Management Software platform (the “Xirgo FMP”), used in conjunction with Xirgo Global GNSS tracking devices (Compl. ¶¶ 47, 49).
Functionality and Market Context
- The Xirgo FMP is a software and hardware system designed for managing fleets of vehicles, including light vehicles, trucks, and agricultural machinery (Compl. ¶48). The software platform is accessible on Windows, web browsers, and mobile devices, and provides functions such as real-time tracking, geo-fencing, fuel monitoring, and reporting (Compl. ¶¶ 48, 50). The system uses GNSS devices installed in vehicles, which the complaint characterizes as "tags," to collect and transmit data including vehicle location, battery status, temperature, and CAN-BUS data (Compl. ¶¶ 49, 52). Each tag is associated with a unique identifier and linked to a particular vehicle, person, or piece of equipment (Compl. ¶54). The complaint includes a screenshot of the accused product's interface showing a map with vehicle locations and a historical data graph, illustrating the system's function of associating tag data with entities and presenting it to users (Compl. p. 14).
IV. Analysis of Infringement Allegations
’742 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| accessing data associated with one or more entities, said entities associated with one or more tags having one or more identifiers, said data being stored in one or more data repositories... | The Xirgo FMP accesses data about vehicles ("entities") that are equipped with Xirgo GNSS devices ("tags") having unique identifiers. | ¶54 | col. 23:5-9 |
| accessing data associated with one or more tags having one or more identifiers, said data associated with the one or more tags being stored in one or more data repositories... | The Xirgo FMP accesses data from the GNSS devices themselves, such as car location, battery status, and temperature. | ¶52 | col. 23:10-14 |
| linking the accessed data associated with the one or more entities together with the accessed data associated with the one or more tags using said one or more tag identifiers... | The Xirgo FMP platform associates the vehicle data with the data from its corresponding GNSS device using the device's unique identifier. | ¶54 | col. 23:15-19 |
| receiving at least one query or at least one keyword search... | The Xirgo FMP provides user interfaces (Windows, web, mobile) that allow customers to view reports and historical data, which constitutes receiving queries for tag-related data. | ¶53 | col. 23:20-21 |
| retrieving data that matches said at least one query... determining at least one tag identifier... and retrieving additional data that is associated with said at least one determined tag identifier... | When a user requests to view a vehicle's status or history, the system retrieves matching data by determining the vehicle's associated tag identifier and retrieving the various data types (e.g., location, CAN-BUS) linked to it. | ¶¶52, 53 | col. 23:22-29 |
’520 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| accessing data associated with one or more entities, the entities associated with one or more tags having one or more tag identifiers... | The Xirgo FMP accesses data for vehicles ("entities") that are associated with uniquely identified GNSS devices ("tags"). | ¶54 | col. 25:12-15 |
| accessing data associated with one or more tags... and includes location information... | The system accesses data from the GNSS devices, which inherently includes car location information for real-time tracking. A visual on page 15 of the complaint highlights "Accurate tracking of your vehicle." | ¶¶49, 52, p. 15 | col. 25:16-19 |
| linking the accessed data associated with the one or more entities... to provide location information of the one or more entities using the location information of the one or more tags... | The platform links the location data from the GNSS tag to the corresponding vehicle entity to display the vehicle's location on a map. | ¶¶52, 53 | col. 25:20-24 |
| determining two or more tag identifiers that satisfy the query or keyword search... | A user query for a fleet's status or a report covering multiple vehicles would require the system to determine the tag identifiers for each of those vehicles. | ¶48 | col. 25:27-29 |
| ranking the determined two or more tag identifiers based on tag references of the determined two or more tag identifiers. | The complaint alleges infringement of this claim but does not provide specific facts detailing how the Xirgo FMP performs a "ranking" function based on "tag references." | ¶71 | col. 25:30-33 |
Identified Points of Contention
- Technical Questions: A primary point of contention for the ’520 Patent will likely be the "ranking" limitation. The complaint does not describe how the accused Xirgo FMP performs a function that meets the claim’s requirement to "rank" tag identifiers "based on tag references." The evidence presented focuses on data collection and display, raising the question of whether any ranking, as contemplated by the patent, actually occurs.
- Scope Questions: For the ’742 Patent, a potential issue is the scope of the multi-step retrieval process claimed ("retrieving... determining... retrieving additional data"). The dispute may center on whether the routine data lookup and display function in the accused product meets the specific sequence and structure of these claim steps, or if the patent requires a more complex, multi-stage retrieval operation not present in the accused system.
V. Key Claim Terms for Construction
- The Term: "linking... together" (’742 Patent, cl. 1)
- Context and Importance: This term is fundamental to the patent's data aggregation concept. Its construction will determine whether simply associating related data in a user interface is sufficient for infringement, or if a more complex backend process of creating new, combined data structures is required. Practitioners may focus on this term because the patent's detailed description illustrates a "Data Reorganization System" that creates "Reorganized Data" (’742 Patent, Fig. 14), which could suggest a narrower meaning than what the complaint alleges as the infringing functionality.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests linking can be a logical association, stating that logical associations may include information in a database table that "may establish a correspondence between one or more tags and one or more objects" (’742 Patent, col. 6:40-45).
- Evidence for a Narrower Interpretation: Figure 14 and the accompanying text describe a distinct "Data Reorganizer" (1440) that processes data from a "Data Space" (1430) to create "Reorganized Data" (1450), suggesting a specific architectural component and process that goes beyond simple correspondence (’742 Patent, col. 19:15-26).
- The Term: "ranking" (’520 Patent, cl. 1)
- Context and Importance: This term is a critical limitation in an independent claim and a likely focus of non-infringement arguments, given the lack of specific factual allegations in the complaint about how the accused system performs this function. The case may turn on whether "ranking" is given its plain and ordinary meaning (e.g., any ordering) or a more technical one tied to the patent's disclosure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "ranking," which could support an argument that the term should be given its plain meaning of arranging items in a particular order.
- Evidence for a Narrower Interpretation: The specification discusses ranking in the context of "keyword queries" that "respond with tag data that is highly ranked with respect to the keywords" and mentions a "ranking algorithm may be a pluggable attribute" (’520 Patent, col. 22:23-44). This context may support a narrower construction requiring a specific algorithmic sorting based on relevance criteria, not just any display order.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement for all three patents. The basis for this allegation is that Defendant provides the Xirgo FMP and associated devices to its customers with the knowledge and intent that the customers' use of the system will directly infringe the asserted patents (Compl. ¶¶ 65, 72, 79).
- Willful Infringement: Willfulness is alleged for all three patents. The complaint bases this allegation on Defendant having had knowledge of the patents-in-suit since at least May 17, 2024, the date Plaintiff filed a lawsuit against an unrelated third party, Track What Matters, LLC (Compl. ¶¶ 60, 68, 75, 82).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional scope, particularly concerning the ’520 Patent: does the accused Xirgo FMP’s generation of reports or display of fleet vehicles constitute "ranking the determined... tag identifiers based on tag references" as required by the claim? The complaint’s lack of specific factual allegations for this element suggests this will be a central point of dispute over whether there is a fundamental mismatch in technical operation.
- A second key question will be one of claim construction: can the term "linking... together" in the ’742 Patent be construed to cover the dynamic association and presentation of data from different sources, as performed by the accused product, or does it require the creation of new, persistent, reorganized data structures as depicted in the patent’s specification?
- Finally, a key evidentiary question for willfulness will be whether Plaintiff’s lawsuit against a different company is sufficient to establish that Defendant had the requisite pre-suit knowledge of the patents to have acted in an objectively reckless manner.