DCT

2:25-cv-00785

Aprese Systems Texas LLC v. Hyundai Motor Co

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00785, E.D. Tex., 08/12/2025
  • Venue Allegations: Venue is alleged to be proper based on the defendant’s status as a foreign corporation, with personal jurisdiction established through the defendant’s placement of products into the stream of commerce in Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicles equipped with the Android Auto platform infringe a patent related to context-aware methods for delivering and accessing software applications.
  • Technical Context: The technology operates in the domain of application provisioning for computing devices, a field of significant commercial importance for connected vehicles and in-car infotainment systems.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2010-08-04 U.S. Patent No. 11,893,378 Priority Date
2022-12-30 U.S. Patent No. 11,893,378 Application Date
2024-02-06 U.S. Patent No. 11,893,378 Issues
2025-08-12 Complaint Filed

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

U.S. Patent No. 11,893,378 - METHOD, APPARATUS, AND SYSTEMS FOR ENABLING DELIVERY AND ACCESS OF APPLICATIONS AND SERVICES

  • Patent Identification: U.S. Patent No. 11,893,378, "METHOD, APPARATUS, AND SYSTEMS FOR ENABLING DELIVERY AND ACCESS OF APPLICATIONS AND SERVICES," issued February 6, 2024.

The Invention Explained

  • Problem Addressed: The patent's background section describes the process for users to discover and install applications for specific, context-dependent tasks as "tedious and/or impractical" (’378 Patent, col. 2:25-30). It notes that conventional methods, such as searching app stores or scanning barcodes, discourage users from installing applications for short-term or location-specific uses, such as interacting with a media broadcast or accessing services at a particular store (’378 Patent, col. 2:31-55).
  • The Patented Solution: The invention proposes a system that automates application delivery based on the user's or device's "context" (e.g., environment or activity) (’378 Patent, Abstract). The system determines this context, generates a corresponding "contextual tag," and uses the tag to identify and enable access to one or more relevant applications, thereby simplifying the user experience (’378 Patent, col. 3:25-39). The architecture involves distinct entities, including a "consumer device," a "provider device," and a "generator device," which communicate through a defined protocol to manage application access (’378 Patent, FIGS. 1A, 2A, 3A).
  • Technical Importance: The technology aimed to create a more dynamic and seamless ecosystem for application delivery, allowing services and content to be provisioned to users precisely when and where they are relevant, without requiring manual user intervention (’378 Patent, col. 3:9-15).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-7, 9, and 10 (Compl. ¶15).
  • The essential elements of independent claim 1, directed to a "consumer device," include:
    • Determining the presence of a connected ANDROID smartphone that has specific sets of applications installed.
    • Receiving "generator information" from the smartphone, which comprises a "third tag type."
    • Sending "provider information" to the smartphone, which comprises a "fourth tag type."
    • Receiving "first tag related information" from the smartphone, which is enabled by the prior sending of the provider information.
    • Determining a "first tag" based on the first tag related information.
    • Sending the "first tag" to the smartphone, which enables the smartphone to determine, access, and execute a "first application."
    • Enabling a user interface element on the consumer device itself that allows a user to initiate the determination and sending of the first tag.
  • The complaint does not specify which dependent claims it may pursue.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's vehicles that support the Android Auto platform (Compl. ¶15).

Functionality and Market Context

The complaint alleges that these vehicles, in connection with Android Auto, infringe the ’378 patent (Compl. ¶15). The complaint itself does not provide technical details on the operation of the Android Auto system within the accused vehicles. It incorporates by reference a "preliminary claim chart attached hereto as Exhibit A," but this exhibit was not filed with the complaint (Compl. ¶15). Consequently, the complaint lacks a specific description of the accused functionality.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a narrative description of its infringement theory or a claim chart. It states that infringement is "detailed in the preliminary claim chart attached hereto as Exhibit A" (Compl. ¶15). As Exhibit A was not provided, the specific factual basis for the infringement allegation is not available for analysis in the public filing.

Identified Points of Contention

Based on the language of the asserted claim and the identification of the accused product, the infringement analysis raises several key questions.

  • Scope Questions: Claim 1 recites a "consumer device" that is distinct from, but communicates with, an "ANDROID smartphone." A primary question for the court may be whether the vehicle's infotainment head unit constitutes the claimed "consumer device." The defendant may argue that the vehicle and phone form an integrated system that does not map onto the distinct two-part architecture required by the claim.
  • Technical Questions: The asserted claim requires a specific, multi-step communication protocol involving the exchange of "generator information," "provider information," and "tag related information" in a defined sequence. A central technical question will be whether the standard communication that occurs when a smartphone connects to a vehicle via Android Auto performs these specific claimed functions. The complaint provides no facts suggesting that the accused vehicles implement this particular patented protocol.

V. Key Claim Terms for Construction

The Term: "consumer device"

Context and Importance

The definition of this term is critical because the claim requires the "consumer device" to be a distinct entity from the "ANDROID smartphone" while also performing specific functions like enabling a user interface element. The infringement analysis will depend on whether the vehicle's head unit can be properly characterized as this claimed device. Practitioners may focus on this term because the accused product is a vehicle, a more complex system than the examples in the patent.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification uses the term interchangeably with "computing device" and lists examples including mobile phones, tablets, and portable audio/video devices, suggesting the term is not limited to a specific form factor (’378 Patent, col. 3:60-65).
  • Evidence for a Narrower Interpretation: The figures consistently depict the "Consumer Device (CD)" (e.g., 102 in FIG. 1A) as a standalone hardware block separate from any external network or other devices, which could support an interpretation that it is not merely a component of a larger system like a vehicle.

The Term: "generator information"

Context and Importance

This term, along with "provider information" and "tag related information," defines the specific protocol allegedly infringed. Its construction will determine whether the data exchanged in a standard Android Auto connection meets this claim limitation. The dispute will likely center on whether any data sent from the phone to the car at the start of a session qualifies as the claimed "generator information."

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent states that messages can be exchanged in various ways and that the fields shown are illustrative, which might support a broader functional definition of the information exchange (’378 Patent, col. 15:11-14, col. 50:1-14).
  • Evidence for a Narrower Interpretation: The specification provides a detailed definition for "GeneratorInfo" (GI) and its associated data fields in FIG. 17, including "genId", "contact", and "assocType". This detailed structure could support a narrower construction requiring the accused data to have these specific attributes (’378 Patent, FIG. 17; col. 51:60 - col. 52:4).

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain a count for indirect (induced or contributory) infringement.
  • Willful Infringement: The complaint does not allege that the defendant had knowledge of the ’378 patent prior to the lawsuit and does not use the term "willful."

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

  • A threshold procedural question will be one of pleading sufficiency: Does the complaint, by pointing only to a missing exhibit for its technical infringement theory, provide sufficient factual matter to state a claim for patent infringement that is "plausible on its face" under the Twombly/Iqbal standard?
  • A core issue will be one of architectural mapping: Can the patent’s two-component system, comprising a distinct "consumer device" and an "ANDROID smartphone," be mapped onto the integrated functionality of a vehicle head unit operating with a connected smartphone via the Android Auto platform?
  • A key evidentiary question will be one of functional equivalence: Does the data exchanged during a standard Android Auto session perform the specific, multi-step signaling protocol recited in Claim 1, or is there a fundamental mismatch in the technical operation of the communication protocols?