Fleet Connect Solutions LLC v. UAB Gurtam

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fleet Connect Solutions LLC (Texas)
  • Defendant: Remote Asset Management Limited and RAM Tracking Acquisition Limited (England and Wales)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:25-cv-00661, E.D. Tex., 11/28/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants are not residents of the United States and may therefore be sued in any judicial district under the alien-venue rule.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management and vehicle tracking products infringe five patents related to mobile asset management, intelligent trip notification, and group navigation tracking.
• Technical Context: The technologies at issue relate to fleet telematics and mobile workforce management, a market focused on using GPS, wireless communication, and software to monitor and coordinate vehicles and personnel in the field.
• Key Procedural History: The complaint does not specify any significant procedural events such as prior litigation, licensing history, or post-grant proceedings involving the asserted patents.

Case Timeline

Date	Event
2000-09-18	Priority Date for ’751, ’586, and ’581 Patents
2002-11-04	Priority Date for ’837 Patent
2005-08-10	Priority Date for ’968 Patent
2005-11-01	Issue Date for U.S. Patent No. 6,961,586
2007-04-17	Issue Date for U.S. Patent No. 7,206,837
2009-09-22	Issue Date for U.S. Patent No. 7,593,751
2010-06-22	Issue Date for U.S. Patent No. 7,741,968
2013-07-23	Issue Date for U.S. Patent No. 8,494,581
2025-11-28	Complaint Filing Date

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’s background section describes the problem that, at the time of the invention, navigation systems could not automatically provide users with updated time-of-arrival estimates as a trip progressed (’837 Patent, col. 1:26-57). Manually performing these estimations while driving was described as inconvenient, distracting, and potentially dangerous (’837 Patent, col. 1:44-55).
• The Patented Solution: The invention is an automated method to overcome these issues by enabling a user to "automatically receive trip status information while in transit to a destination" (’837 Patent, col. 1:56-62). As illustrated in a flowchart (FIG. 2) provided in the complaint, the method involves a mobile device that receives its location, looks up historical travel time data based on the "calendrical time (i.e., the time and date)," and estimates time-of-arrival metrics, which are then sent to the user's device (Compl. p. 11; ’837 Patent, col. 2:4-6).
• Technical Importance: This approach automated a complex, error-prone, and distracting manual task for drivers by integrating location data with historical and time-based travel statistics (’837 Patent, col. 1:44-55).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶51).
• The essential elements of Claim 1 are:
  • 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 based on: (a) the device's location, and (b) at least one historical travel time statistic; and
  • Sending the time-of-arrival bounds to the mobile communications device.

U.S. Patent No. 7,593,751 - “Conducting Field Operations Using Handheld Data Management Devices,” Issued September 22, 2009

The Invention Explained

• Problem Addressed: The patent family addresses limitations in managing mobile field assets (e.g., personnel, equipment) where remote work is required (’751 Patent, col. 1:25-30). These problems included less experienced personnel being tasked with data collection for senior decision-makers and experienced professionals lacking access to critical information while in the field (’751 Patent, col. 1:32-43).
• The Patented Solution: The patented solution enables "targeted real-time communication and data synchronization between enterprise servers and handheld devices in the field" (’751 Patent, col. 3:27-31). The complaint includes several figures from the patent illustrating the system, including a diagram of a PDA-like device (FIG. 1), its internal components (FIG. 2), and its ability to communicate with remote servers over a network (FIG. 3) (Compl. p. 25). This connectivity allows field operators to access supplemental information and expert assistance, improving efficiency (’751 Patent, col. 3:45-12:47).
• Technical Importance: This technology aimed to improve the accuracy and efficiency of field operations by connecting mobile workers with centralized data and remote expertise, reducing the need to deploy senior personnel for on-site tasks (Compl. ¶75).

Key Claims at a Glance

• The complaint asserts at least independent claim 6 (Compl. ¶82).
• The essential elements of Claim 6 are:
  • Providing a handheld field data management device to a user, where the device includes a memory, microprocessor, positioning module (GPS), display, user interface, and wireless communication module;
  • Enabling the user to access instructions from the device's program or a remote server to find a field operation location;
  • Enabling the user to access instructions from the program to assist in collecting industry-specific data at the location; and
  • Enabling the user to access instructions from the program to assist in communicating with a remote server before, during, and after the data collection.

U.S. Patent No. 6,961,586 - “Field Assessments Using Handheld Data Management Devices,” Issued November 1, 2005

• Technology Synopsis: As part of the same family as the ’751 patent, this patent addresses the challenges of managing mobile field assets. It claims a handheld device comprising specific hardware components (memory, microprocessor, user interface) and software ("field assessment program" with at least one "template") along with a "synchronization means" for communicating with remote resources to support various field tasks like construction analysis or inventory tracking (’586 Patent, Claim 1).
• Asserted Claims: At least independent claim 9 is asserted (Compl. ¶101).
• Accused Features: The complaint alleges that Defendants’ RAM Tracking fleet management platform and its associated functionalities for managing field operations infringe this patent (Compl. ¶17, ¶100).

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: This patent, also in the same family as the ’751 patent, addresses mobile asset management problems. It claims an apparatus using "means-plus-function" language, reciting 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 (’581 Patent, Claim 18).
• Asserted Claims: At least claims 21 and 22, which depend from independent claim 18, are asserted (Compl. ¶120).
• Accused Features: The complaint accuses Defendants’ fleet management platform and its features for communication, data management, and location tracking of infringement (Compl. ¶17, ¶119).

U.S. Patent No. 7,741,968 - “System and Method for Navigation Tracking of Individuals in a Group,” Issued June 22, 2010

• Technology Synopsis: The patent addresses the inability of prior art systems to allow a user to electronically share their location with a selected device and receive navigational assistance in return (’968 Patent, col. 1:37-42). The claimed solution is a method for a "master" device to track a group by receiving current geographic location data from each individual, displaying that data, sending "converging instructions" to at least one individual, and generating ETAs for convergence (’968 Patent, Claim 4). The complaint includes a figure (FIG. 1) from the patent showing two mobile devices exchanging location and ETA information via a central control network (Compl. p. 58).
• Asserted Claims: At least independent claims 4 and 7 are asserted (Compl. ¶143, ¶146).
• Accused Features: The group tracking and navigation features of the Defendants' RAM Tracking platform are accused of infringement (Compl. ¶17, ¶145).

III. The Accused Instrumentality

Product Identification

The accused products are the "Ram Tracking fleet management platform and tracking solutions" (the "Accused Products") (Compl. ¶17). This includes, but is not limited to, software and applications such as GPS Fleet Tracking, Job Scheduling and Tracking App, Ram Tracking ELD, and Ram Assist, as well as associated hardware like GPS Tracking devices and Dash cams (Compl. ¶17).

Functionality and Market Context

The complaint describes the Accused Products as a platform for fleet management that performs wireless communications and implements methods for tracking and managing mobile assets (Compl. ¶17-18). The functionality is alleged to include generating and transmitting data packets, processing location information, and facilitating communication between mobile units and central resources, consistent with the features required by the asserted patents (Compl. ¶19-20). The complaint does not provide specific details on the market positioning of the Accused Products beyond identifying them as a "fleet management platform" (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of at least one claim of each of the five asserted patents but states that the detailed infringement theories are contained in Exhibits A-E (Compl. ¶51, ¶82, ¶101, ¶120, ¶146). As these exhibits were not attached to the publicly filed complaint, a tabular claim chart summary cannot be constructed. The complaint’s narrative sections for each patent focus almost exclusively on subject matter eligibility and do not contain sufficient detail to summarize a specific infringement theory for the Accused Products.

Identified Points of Contention

• ’837 Patent: A potential point of contention may be whether the Accused Products' ETA calculations meet the specific claim requirement of "estimating the time-of-arrival bounds for said mobile communications device at said destination for a confidence interval based on...at least one historical travel time statistic." This raises the technical question of whether the defendants' system calculates a statistical "confidence interval" or merely an estimated time window, and the legal question of whether its use of real-time traffic data qualifies as a "historical travel time statistic" under the patent's definition.
• ’751 Patent: For Claim 6, a central issue may be whether the Accused Products’ software provides instructions that "assist the user in collecting industry-specific data." This raises a question of claim scope regarding what constitutes "industry-specific data" and a factual question of whether the allegedly generic fleet management tools of the Accused Products provide the claimed level of specialized instruction.

V. Key Claim Terms for Construction

’837 Patent - Claim 1

• The Term: "historical travel time statistic"
• Context and Importance: This term is central to the method of estimation. Its construction will determine whether the claim requires a pre-compiled database of past travel times (e.g., average speed on a highway segment on Mondays at 8 AM) or if it can be read more broadly to include aggregated real-time data that becomes "historical" once processed. Practitioners may focus on this term because modern systems rely heavily on live traffic data, which may or may not meet a narrower definition of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "statistic" is general and not explicitly defined, which may support an argument for a broader meaning that includes any processed data from past travel, however recent.
  • Evidence for a Narrower Interpretation: The specification describes a "traditional relational database with tables of historical travel time 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. 3:24-42), which may support a narrower construction limited to data from such pre-compiled, categorized databases.

’751 Patent - Claim 6

• The Term: "industry-specific data"
• Context and Importance: The infringement analysis for Claim 6 may depend on whether the data collected by users of the Accused Products is considered "industry-specific." If the term is construed narrowly, a general-purpose fleet management tool may not infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a wide range of examples, including "construction industry," "legal investigations," "HVAC system analysis," and "remote inventory tracking," suggesting the term is intended to be adaptable to any particular industry a user is in (’586 Patent, Claim 1, which is in the same family).
  • Evidence for a Narrower Interpretation: Dependent claim 3 of the ’751 patent recites instructions for a "construction industry project," which a defendant might argue suggests the independent claim should be interpreted in the context of similarly distinct, pre-defined industries rather than covering generic data entry that happens to be used by someone in an industry.

VI. Other Allegations

Indirect Infringement

For the ’968 Patent, the complaint alleges induced infringement, stating that Defendants provide instructions, advertising, and technical support that guide customers to use the Accused Products in an infringing manner (Compl. ¶148-149). The complaint also alleges contributory infringement, asserting that the Accused Products have special features designed for infringement that are not staple articles of commerce (Compl. ¶150).

Willful Infringement

The complaint alleges willful infringement of the ’968 Patent, based on alleged post-suit knowledge from the date of notification of the lawsuit (Compl. ¶147). It further alleges pre-suit knowledge through willful blindness, claiming Defendants have a policy of not reviewing the patents of others (Compl. ¶151). The prayer for relief requests a willfulness finding for the ’968 patent and a "’388 patent," the latter of which appears to be a typographical error as no such patent is asserted in the suit (Compl. ¶156.c).

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

1. A primary issue will be one of temporal scope and technological evolution: can claims from patents with priority dates from 2000-2005, which describe technology in the context of PDA-like handheld devices and early client-server architecture, be construed to cover modern, cloud-based, software-as-a-service (SaaS) fleet management platforms running on smartphones and web browsers?

2. A key technical question will be one of functional specificity: does the accused platform's general-purpose ETA calculation, likely based on real-time data, perform the specific function of estimating "time-of-arrival bounds for a confidence interval" using a "historical travel time statistic" as required by the ’837 patent, or is there a fundamental mismatch in technical operation?

3. A central dispute for the Mobile Field Asset Management patents (’751, ’586, ’581) will likely be one of definitional breadth: can the term "industry-specific data," rooted in patent descriptions of tailored field assessment templates, be read to cover the more generalized data collection capabilities of a modern fleet management system?