Fleet Connect Solutions LLC v. UAB Gurtam

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fleet Connect Solutions LLC (Texas)
  • Defendant: UAB Gurtam (Lithuania)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:25-cv-00661, E.D. Tex., 06/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is not a resident of the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management and tracking platforms infringe seven patents related to mobile communications, vehicle tracking, field data management, and trip status notification.
• Technical Context: The lawsuit concerns technology in the vehicle telematics and fleet management sector, a market focused on providing location, status, and communication services for commercial vehicles and mobile assets.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the asserted patents.

Case Timeline

Date	Event
1999-09-10	Priority Date for ’270 and ’723 Patents
2000-09-18	Priority Date for ’586, ’751, and ’581 Patents
2002-11-04	Priority Date for ’837 Patent
2003-11-11	’270 Patent Issued
2005-11-01	’586 Patent Issued
2006-08-15	’723 Patent Issued
2007-04-17	’837 Patent Issued
2008-06-20	Priority Date for ’968 Patent
2009-09-29	’751 Patent Issued
2010-06-22	’968 Patent Issued
2013-07-23	’581 Patent Issued
2025-06-25	Complaint Filed

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

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification"

Issued April 17, 2007

The Invention Explained

• Problem Addressed: The patent describes the process of a user in transit estimating their time of arrival as an "inconvenient and cumbersome task," particularly when it needs to be recalculated periodically during a trip (’837 Patent, col. 1:33-40).
• The Patented Solution: The invention automates this process by providing a method that receives a mobile device's current location and uses calendrical time (i.e., time and date) and "historical travel time data" to estimate one or more "time-of-arrival metrics" (e.g., expected, earliest, or latest arrival time). These estimates are then sent to the user's mobile device (’837 Patent, Abstract; col. 2:26-38).
• Technical Importance: The solution aims to improve the accuracy of ETA calculations by incorporating historical data, which can account for predictable variations in travel time (e.g., rush hour, holidays) that simple distance-and-speed calculations might miss (’837 Patent, col. 2:4-15).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶28).
• The essential elements of claim 1 include:
  • Receiving a location of a mobile communications device that is in transit to a destination.
  • Estimating the time-of-arrival bounds for the device at the destination for a confidence interval.
  • Basing the estimate on the device's location and "at least one historical travel time statistic."
  • Sending the time-of-arrival bounds to the mobile communications device.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices"

Issued September 29, 2009

The Invention Explained

• Problem Addressed: The patent family addresses the problem that field personnel (e.g., in construction, HVAC) often lack efficient access to critical information, guidance, or expert support while on-site, which can lead to inaccurate assessments or bids (’586 Patent, col. 1:20-30, 48-52).
• The Patented Solution: The invention is a method for managing data during a field operation using a handheld device. The device is configured with a specific data management program, GPS for location and directions, a user interface for data entry, and a wireless module for real-time communication with a remote server to transfer data, receive instructions, and access third-party information from the Internet (’751 Patent, col. 14:1-17:66).
• Technical Importance: This technology integrates handheld computing, GPS, and real-time wireless data communication into a comprehensive tool for mobile workers, aiming to improve the efficiency and accuracy of data collection and decision-making in the field (’586 Patent, col. 1:52-56).

Key Claims at a Glance

• The complaint asserts at least independent claim 6 (Compl. ¶39).
• The essential elements of method claim 6 include:
  • Providing a handheld field data management device to a user.
  • The device includes a memory with a program module, a microprocessor, a GPS positioning module, a display, a user interface, and a wireless communication module.
  • Enabling the user to access instructions and mapped directions to find a field operation location.
  • Enabling the user to access instructions to assist in collecting industry-specific data.
  • Enabling the user to access instructions to assist in communicating with a remote server before, during, and after data collection.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices"

Issued November 1, 2005

• Technology Synopsis: This patent, from the same family as the ’751 patent, describes a method for conducting field assessments (e.g., construction analysis, HVAC troubleshooting) using a handheld device. The method involves providing a user with an industry-specific software module to execute the assessment, provide required information, and retrieve supporting data (Compl. ¶51).
• Asserted Claims: At least claim 9 (Compl. ¶50).
• Accused Features: The complaint alleges that Gurtam’s fleet management platforms, ELD solutions, and driver apps perform the claimed method of conducting field assessments (Compl. ¶¶43, 51).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices"

Issued July 23, 2013

• Technology Synopsis: Also in the family of the ’751 patent, this patent claims an apparatus with means-plus-function limitations for managing field data. It describes means for establishing a two-way communication channel between a server and a remote handheld device, accessing a program on the server, managing collected data, and determining the device's geographic location (Compl. ¶¶62-63).
• Asserted Claims: At least claims 21 and 22 (Compl. ¶61).
• Accused Features: The complaint alleges that Gurtam’s fleet management platforms and related products comprise an apparatus with the claimed means for managing mobile field assets (Compl. ¶¶54, 62-63).

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

Issued November 11, 2003

• Technology Synopsis: This patent describes a system for communication between multiple remote units (e.g., vehicles). Each unit contains a memory for a unique identifier, a transceiver, a GPS receiver, and a microprocessor that constructs data packets including sender information (ID and position) and receiver information (address of the desired remote unit) (’270 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶73).
• Accused Features: The complaint alleges that Defendant's Accused Products, including vehicle trackers and telematics devices, comprise the claimed system for transmitting data packets between remote units (Compl. ¶¶66, 74).

U.S. Patent No. 7,092,723 - "System and Method for Communicating Between Mobile Units"

Issued August 15, 2006

• Technology Synopsis: A continuation of the ’270 patent, this patent claims a vehicle configured for voice or data communications. The vehicle includes a GPS receiver and a remote unit with a memory, transceiver, and microprocessor for generating data packets that include the sender's unique ID, position information, and the address of a desired remote unit (Compl. ¶85).
• Asserted Claims: At least claim 1 (Compl. ¶84).
• Accused Features: The complaint alleges that Defendant's Accused Products comprise a vehicle configured with the claimed communication system (Compl. ¶¶77, 85).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group"

Issued June 22, 2010

• Technology Synopsis: This patent describes a method for tracking a group of individuals using a portable hand-held device. The method involves receiving location data for each individual at the device, displaying it, sending "converging instructions" to at least one individual to allow them to converge with the handheld device, and generating ETAs for the convergence (Compl. ¶96).
• Asserted Claims: At least claim 4 (Compl. ¶95).
• Accused Features: The complaint alleges that Defendant’s fleet management and mobile applications perform the claimed method of tracking groups (Compl. ¶¶88, 96).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the “Gurtam” fleet management platform and tracking solutions. This includes the Wialon Fleet Management Solution and its various modules (e.g., Fleet Maintenance, Delivery, Driver Behavior Monitoring), associated mobile and web applications (e.g., Wialon, Logistics Mobile), vehicle trackers, and the GPS-Trace Platform (Compl. ¶¶18, 21).

Functionality and Market Context

The accused products are alleged to provide fleet management and tracking functionalities. The complaint's infringement allegations suggest these functionalities include receiving the location of mobile devices, estimating time-of-arrival, and providing tools for managing data during field operations via handheld devices (Compl. ¶¶29, 40). Based on the product names, the platform appears to be marketed to commercial sectors such as logistics, transportation, and agriculture (Compl. ¶18). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’837 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method comprising: (i) receiving a location of a mobile communications device that is in transit to a destination;	Defendant's accused products allegedly perform a method that involves receiving the location of a mobile device in transit.	¶29	col. 6:49-51
(ii) estimating the time-of-arrival bounds for said mobile communications device at said destination for a confidence interval based on: (a) said location, and (b) at least one historical travel time statistic;	The accused products allegedly estimate time-of-arrival bounds for the mobile device based on its location and historical travel time data.	¶29	col. 6:52-57
and (iii) sending the time-of-arrival bounds to said mobile communications device.	The accused products allegedly send the calculated time-of-arrival bounds back to the mobile device.	¶29	col. 6:64-66

’751 Patent Infringement Allegations

Claim Element (from Independent Claim 6)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
providing a handheld field data management device to a user...said handheld field data management device includes: a memory...a microprocessor...a positioning module including GPS...a display...a user interface...and a wireless communication module...	The accused products allegedly involve providing a user with a handheld device (e.g., a smartphone or tablet running Gurtam software) containing the specified hardware and software components.	¶40	col. 15:5-30
enabling the user to access instructions including mapped directions from at least one of said field data management program and said remote sever to assist the user in finding a field operation location...	Defendant's products allegedly enable users to access mapped directions to find a field location.	¶40	col. 16:21-26
enabling the user to access instructions from said at least one field data management program to assist the user in collecting industry-specific data at the field operation location;	Defendant's products allegedly provide instructions to help users collect "industry-specific data."	¶40	col. 16:27-30
and enabling the user to access instructions from said at least one field data management program to assist the user in communicating with a remote server...before, during and after the collection of industry-specific data...	Defendant's products allegedly provide instructions to assist with communication with a remote server throughout the data collection process.	¶40	col. 16:31-36

Identified Points of Contention

• Evidentiary Questions: The complaint's infringement allegations for both patents consist of conclusory statements that largely mirror the language of the asserted claims. A central question for the court will be whether discovery produces specific evidence showing that the accused products actually perform the claimed functions. For example, what evidence demonstrates that Gurtam's ETA calculations use a "historical travel time statistic" (’837 Patent) rather than exclusively real-time data, or that its apps provide instructions for collecting "industry-specific data" (’751 Patent) as opposed to generic telematics data.
• Scope Questions: The dispute over the ’751 patent may raise questions about the scope of its method steps. For instance, the parties may dispute what constitutes "enabling the user to access instructions...to assist" in performing a task, and whether simply providing a software tool meets this limitation without more explicit guidance or prompts.

V. Key Claim Terms for Construction

For the ’837 Patent

• The Term: "historical travel time statistic"
• Context and Importance: This term is the central technical limitation distinguishing the claimed invention from a simple ETA calculation based on current speed and distance. The infringement analysis will depend on whether Defendant's ETA feature uses data that meets this definition. Practitioners may focus on this term because modern GPS systems often rely heavily on real-time traffic data, and the nature of the data used by the accused product will be dispositive.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the data could come from a variety of sources and be organized in different ways, stating the database could contain data for "various combinations of start and destination locations, modes of travel, and calendrical time categories (e.g., rush hour, holiday, off-peak, etc.)" ('837 Patent, col. 3:39-44). This may support a broad definition that includes any stored data about past travel.
  • Evidence for a Narrower Interpretation: The patent emphasizes the importance of "calendrical time" for making accurate estimates and provides examples like "4:00 PM on the Wednesday before Thanksgiving" ('837 Patent, col. 2:15-16). This could support an argument that the "statistic" must be tied to specific, recurring temporal patterns, not just a raw collection of past travel times.

For the ’751 Patent

• The Term: "industry-specific data"
• Context and Importance: This term defines the type of data the claimed method helps a user collect. Infringement may turn on whether the data collected using Defendant's products (e.g., driver hours, fuel levels, delivery status) qualifies as "industry-specific" or is considered generic telematics data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim itself is not limited to any particular industry. A party could argue that any data collected in the course of a commercial enterprise (e.g., trucking, delivery) is by definition "industry-specific."
  • Evidence for a Narrower Interpretation: The specification of the parent ’586 patent, incorporated by reference, provides specific examples of field assessments, such as "construction industry project analysis, HVAC system analysis; project management, equipment readiness, system and equipment troubleshooting," and "conducting legal investigations" (’586 Patent, claim 9). This may support a narrower construction requiring data tailored to the unique requirements of a particular trade or profession beyond general logistics.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced and contributory infringement only for the ’968 Patent. The inducement allegation is based on Defendant allegedly advising customers, providing instructions, and offering technical support with the intent to cause infringement (Compl. ¶¶98-99). The contributory infringement allegation claims the accused products have special features that are a material part of the invention and not staple articles of commerce (Compl. ¶100). Both allegations are based on knowledge "since at least the time of receiving the complaint" (Compl. ¶¶98, 100).

Willful Infringement

Willfulness is alleged only for the ’968 Patent. The allegation is based on knowledge of the patent "at least as of the date Defendant was notified of the filing of this action" and an alleged "policy or practice of not reviewing the patents of others" constituting willful blindness (Compl. ¶¶97, 101, 103).

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

• A core issue will be one of evidentiary sufficiency: The complaint provides infringement contentions that recite the elements of the asserted claims without offering specific, publicly available evidence (such as technical documents or product screenshots) mapping those elements to the accused products. A central question for the litigation will be whether discovery uncovers technical facts sufficient to support these allegations, particularly for nuanced limitations like the use of a "historical travel time statistic" or the collection of "industry-specific data."
• A second key question will be one of claim construction and scope: The asserted patents have priority dates from the advent of widespread mobile data and GPS technology. The case may turn on whether the scope of the claims, when construed in light of their specifications, is broad enough to read on the functionality of Defendant’s modern, integrated fleet management platform, or if there are fundamental mismatches in the claimed technology and the accused system's architecture and operation.
• For the ’581 patent specifically, a dispositive issue will be the application of means-plus-function analysis: The infringement case for this patent will require identifying the specific structures disclosed in the specification corresponding to the claimed "means" and then determining whether the accused products employ identical or equivalent structures to perform the claimed functions.