Integral Wireless Tech LLC v. Luminator Technology Group Global LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Integral Wireless Technologies LLC (Texas)
  • Defendant: Luminator Technology Group Global, LLC (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough, PLLC
• Case Identification: 2:25-cv-00798, E.D. Tex., 08/14/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a principal place of business in Plano, Texas, within the district.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle camera systems, recorders, and fleet management products infringe eight patents related to technologies including video processing, wireless communications systems, and network search functionality.
• Technical Context: The asserted technologies span digital video compression (H.265/HEVC), wireless networking (Wi-Fi, Bluetooth), and Multiple Input, Multiple Output (MIMO) antenna systems, which are foundational technologies in modern mobile video and data communication.
• Key Procedural History: The complaint alleges that Defendant maintains a "policy or practice of not reviewing the patents of others," which forms the basis for a pre-suit willful blindness claim, and further alleges actual knowledge of the patents as of the complaint's filing date for ongoing willfulness.

Case Timeline

Date	Event
2003-06-17	’878 Patent Priority Date
2003-08-13	’537 Patent Priority Date
2003-10-08	’031 Patent Priority Date
2003-12-23	’283 Patent Priority Date
2004-07-02	’592 Patent Priority Date
2004-11-24	’408 Patent Priority Date
2006-04-26	’258 Patent Priority Date
2006-06-05	’424 Patent Priority Date
2007-11-06	’283 Patent Issue Date
2007-12-18	’537 Patent Issue Date
2008-07-08	’408 Patent Issue Date
2009-01-27	’878 Patent Issue Date
2009-06-16	’592 Patent Issue Date
2009-09-08	’424 Patent Issue Date
2010-01-26	’031 Patent Issue Date
2010-02-23	’258 Patent Issue Date
2025-08-14	Complaint Filing Date

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

U.S. Patent No. 7,292,283 - Apparatus and Method for Performing Sub-Pixel Vector Estimations Using Quadratic Approximations, issued November 6, 2007

The Invention Explained

• Problem Addressed: The patent describes the problem of "motion judder" that occurs when converting video from one frame rate to another (e.g., 24 frames-per-second film to 60 fields-per-second video) (’283 Patent, col. 1:50-65). Using motion vectors with only whole-pixel accuracy to create interpolated frames results in poor resolution detail, whereas creating full sub-pixel resolution images to find more accurate vectors is computationally expensive and costly (’283 Patent, col. 2:22-34).
• The Patented Solution: The invention proposes a computationally efficient method to refine a motion vector to sub-pixel accuracy. Instead of generating a new high-resolution image, the method takes a few existing correlation values (which measure block matching quality) around an initial best-match vector. It then uses a quadratic equation to mathematically fit a curve to these sample points, with the minimum of that curve identifying a refined, sub-pixel accurate vector position (’283 Patent, Abstract; col. 4:20-38).
• Technical Importance: This approach provided a low-cost computational solution for improving motion estimation accuracy, a critical step for achieving smooth motion in video standards conversion and compression. (’283 Patent, col. 4:46-50).

Key Claims at a Glance

• The complaint asserts independent method claim 1 (Compl. ¶33).
• The essential elements of claim 1 are:
  • defining a minimum vector position value of a converged vector;
  • determining a predetermined number of vector correlation samples around that minimum vector position value to create a coarse correlation surface estimation; and
  • performing a correlation surface fitting on those samples using a quadratic approximation to produce a refined sub-pixel minimum vector position.

U.S. Patent No. 7,310,537 - Communication On Multiple Beams Between Stations, issued December 18, 2007

The Invention Explained

• Problem Addressed: The patent addresses challenges in wireless systems that use multiple fixed transmission beams. Simply selecting a beam based on the highest received power can be inefficient, as neighboring beams may interfere, or signals may arrive via different geometric paths due to reflections, making optimal beam selection difficult (’537 Patent, col. 2:43-56).
• The Patented Solution: The invention embeds unique "beam identity information" into the signals transmitted on each of the multiple beams. This allows a receiving station to identify the specific originating beam for each signal it receives, not just its strength. This enables the receiver to distinguish between geometrically different paths and make a more intelligent selection of which beam or beams to use for communication, then report its selection back to the transmitting station (’537 Patent, Abstract; Fig. 3).
• Technical Importance: The technology allows for more robust beam selection in complex wireless environments, potentially increasing link capacity and reliability without requiring computationally intensive channel analysis by the transmitter (’537 Patent, col. 3:59-65).

Key Claims at a Glance

• The complaint asserts independent apparatus claim 26 (Compl. ¶60).
• The essential elements of claim 26 are:
  • an antenna unit configured to receive signals from another station on multiple beams;
  • a controller that identifies the beams based on "beam identity information" associated with the received signals; and
  • wherein a set of "geometrically distinguished" beams is selected for communication based on the information from the identified beams.

U.S. Patent No. 7,483,878 - Generation and Presentation of Search Results Using Addressing Information, issued January 27, 2009

• Technology Synopsis: This patent describes a method for providing search results to a user based on their network browsing activity. The system receives addressing information (e.g., a URL) identifying a user's location on a network, processes that information to generate a keyword, performs a search on that keyword, and presents the results to the user (Compl. ¶67, 71; ’878 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶70).
• Accused Features: The complaint alleges that Defendant's websites, such as "ltgglobal.my.site.com/help/s/", perform the claimed method when a user navigates to the site (Compl. ¶71).

U.S. Patent No. 7,548,592 - Multiple Input, Multiple Output Communications Systems, issued June 16, 2009

• Technology Synopsis: This patent relates to optimizing transmitter and receiver weights in a Multiple-Input, Multiple-Output (MIMO) wireless system. The invention describes a signal transmitter with components configured to weight and combine input signals before transmission via multiple antennas, using specific mathematical relationships (e.g., involving a lower triangular matrix) to define the transmitter and receiver weighting coefficients (Compl. ¶94, 98; ’592 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶97).
• Accused Features: The complaint accuses Defendant’s 802.11n/ac/ax Wi-Fi compatible devices of infringing by providing a MIMO signal transmitter that meets the claim limitations (Compl. ¶98).

U.S. Patent No. 7,586,424 - Data Coding Using An Exponent and A Residual, issued September 8, 2009

• Technology Synopsis: This patent describes a method for efficiently coding data, such as for audio or video compression. The method involves coding a data symbol using an exponent value and a residual value. The exponent is coded using a variable-length code (like Huffman or Golomb coding) based on its frequency of occurrence, while the residual is coded using a fixed-length binary code (Compl. ¶120, 124; ’424 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶123).
• Accused Features: The complaint accuses Defendant’s H.265/HEVC compatible devices of performing this coding method (Compl. ¶124).

U.S. Patent No. 7,668,258 - Systems and Methods for Transmitter Diversity Expansion, issued February 23, 2010

• Technology Synopsis: This patent addresses transmitter diversity expansion, a technique for applying a set of K data streams to a larger number of N antennas to improve wireless transmission. The invention describes a system with a signal processor that generates a second set of data streams by combining a first set via matrix multiplication with a unitary matrix, with the combined streams then transmitted over a plurality of antennas (Compl. ¶146, 150; ’258 Patent, Abstract).
• Asserted Claims: At least claim 7 (Compl. ¶149).
• Accused Features: The complaint accuses Defendant’s 802.11n/ac/ax Wi-Fi compatible devices of infringing (Compl. ¶150).

U.S. Patent No. 7,398,408 - Systems and Methods for Waking Up Wireless LAN Devices, issued July 8, 2008

• Technology Synopsis: The patent describes a method for waking a computing device from a low-power or sleep state over a wireless network. A signal containing a specific "wake-up data sequence" is broadcast; a device in reduced power mode scans for this sequence and, upon detecting a match, restores itself to full power (Compl. ¶173, 177; ’408 Patent, Abstract).
• Asserted Claims: At least claim 1 (Compl. ¶176).
• Accused Features: The complaint accuses Defendant’s Bluetooth v4.2 (BR/EDR) compatible devices of performing this wake-up method (Compl. ¶177).

U.S. Patent No. 7,653,031 - Advance Notification of Transmit Opportunities On A Shared-Communications Channel, issued January 26, 2010

• Technology Synopsis: The patent discloses a technique to enable co-existence of different wireless protocols (e.g., IEEE 802.11 Wi-Fi and Bluetooth) on a shared channel. An 802.11 transceiver determines a future "transmit opportunity" based on its protocol's beacon interval and notifies the Bluetooth transceiver, allowing the second protocol to use the shared channel without interference (Compl. ¶199, 203; ’031 Patent, Abstract).
• Asserted Claims: At least claim 15 (Compl. ¶202).
• Accused Features: The complaint accuses Defendant’s devices that are compatible with both IEEE 802.11 Wi-Fi and Bluetooth of infringing (Compl. ¶203).

III. The Accused Instrumentality

Product Identification

The accused products include a range of vehicle-focused electronics, such as the RoadRunner™ Pro and 4K Recorders, various interior and exterior cameras, monitors, the Luminator Inform™ Fleet Management Kit, and Defendant's commercial websites (Compl. ¶23).

Functionality and Market Context

The complaint categorizes the accused products by the industry standards they allegedly implement: H.265/HEVC for video compression, 802.11n/ac/ax for Wi-Fi communication, and Bluetooth v4.2 for short-range wireless communication (Compl. ¶23). These products are marketed for use in vehicles for purposes of surveillance, recording, and fleet management (Compl. ¶23). The complaint alleges Defendant sells, imports, and distributes these products throughout the United States (Compl. ¶25).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’283 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
defining a minimum vector position value of a converged vector	The accused H.265/HEVC devices allegedly perform a method that defines a minimum vector position value of a converged vector during frame conversion.	¶34	col. 4:23-24
determining a predetermined number of vector correlation samples around the minimum vector position value, the predetermined number of vector correlation samples providing a coarse correlation surface estimation of the minimum vector position value	The accused devices allegedly determine a set number of vector correlation samples around the minimum vector position value to create a coarse surface estimation.	¶34	col. 4:25-30
and performing a correlation surface fitting of the predetermined number of vector correlation samples using a quadratic approximation of the coarse correlation surface estimation of the minimum value, the correlation surface fitting resulting in a refined sub-pixel minimum vector position.	The accused devices allegedly perform a correlation surface fitting on these samples using a quadratic approximation to generate a refined sub-pixel vector position.	¶34	col. 4:30-38

Identified Points of Contention (’283 Patent)

• Technical Question: The central dispute may concern whether the motion estimation algorithms used in the H.265/HEVC standard, as implemented in Defendant's products, actually perform a "quadratic approximation." The complaint's allegation is conclusory, and discovery will be needed to determine if the specific interpolation methods used (e.g., DCT-based interpolation filters common in HEVC) meet this claim limitation.
• Scope Question: The meaning of "converged vector" may be a point of construction. The parties may dispute the degree of convergence required before the claimed steps of sampling and fitting are performed.

’537 Patent Infringement Allegations

Claim Element (from Independent Claim 26)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
antenna unit configured to receive signals transmitted from another station on multiple beams	The accused Road Runner™ Pro is alleged to be a station with an antenna unit capable of receiving signals on multiple beams from another station.	¶61	col. 4:45-47
and a controller for identifying beams based on beam identity information associated with signals received from the other station	The accused product is alleged to have a controller that identifies beams using "beam identity information" contained in the received signals.	¶61	col. 4:41-44
wherein a set of beams that are geometrically distinguished from each other is selected for transmission of signals between a first station and a second station based on information of the identified beams.	The accused product allegedly selects a set of "geometrically distinguished" beams for communication based on the identified beam information.	¶61	col. 4:42-45

Identified Points of Contention (’537 Patent)

• Technical Question: A key factual question is what information the accused products' wireless systems actually use for beam selection. The dispute may focus on whether they use standard protocol data (e.g., signal strength, channel quality indicators) or if they transmit and process specific information intended to identify the geometric origin of a transmission beam, as the patent requires.
• Scope Question: The definition of "beam identity information" will be critical. The court will need to determine if this term requires information explicitly encoding a beam's geometric properties, or if it could be construed more broadly to cover other identifiers transmitted within a beamforming protocol.

V. Key Claim Terms for Construction

For the ’283 Patent

• The Term: "quadratic approximation"
• Context and Importance: This term defines the core mathematical step of the invention. The infringement analysis will turn on whether the accused devices' method for refining motion vectors meets this specific technical requirement, as opposed to other known interpolation techniques. Practitioners may focus on this term because video compression standards like H.265/HEVC often use standardized interpolation filters that may or may not be properly characterized as a "quadratic approximation."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the concept generally as estimating a curve through three pixel points, stating, "The curve between the three points P1, P2 and P3 is estimated by the quadratic equation F(x)" (’283 Patent, col. 3:35-37).
  • Evidence for a Narrower Interpretation: The detailed description provides a specific mathematical sequence, including Equations [1] through [8], to implement the approximation, which could be argued to limit the scope of the term to that specific implementation or its equivalents (’283 Patent, col. 3:41-col. 4:19).

For the ’537 Patent

• The Term: "beam identity information"
• Context and Importance: This term is central to distinguishing the invention from conventional beam selection methods. Infringement depends on whether the accused Wi-Fi and Bluetooth products transmit and use information that specifically identifies the transmission beam itself, rather than just identifying the transmitting device or signal quality.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent suggests the information could be part of standard transmissions, stating it "may be included in pilot signals sent via the beams" (’537 Patent, col. 4:52-54).
  • Evidence for a Narrower Interpretation: The purpose of the information is explicitly tied to geometry: to allow a receiver to select a set of "geometrically distinguished" beams (’537 Patent, cl. 26). The specification clarifies that this allows distinguishing between "geometrically distinct radio propagation path[s]" (’537 Patent, col. 5:30-33), suggesting the information must convey more than a generic device ID.

VI. Other Allegations

• Indirect Infringement: For each asserted patent, the complaint alleges induced infringement. The factual basis is that Defendant provides customers with instruction manuals, user guides, and technical support that allegedly instruct them on how to use the Accused Products in an infringing manner (Compl. ¶24, 38-40, 61, 75-77).
• Willful Infringement: The willfulness allegations for each patent are based on two theories: (1) pre-suit willful blindness, stemming from an alleged "policy or practice of not reviewing the patents of others," and (2) post-suit willfulness based on actual knowledge of the patents acquired upon service of the complaint (Compl. ¶35-36, 72-73).

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

• A central evidentiary issue will be one of technical specificity: the complaint accuses products implementing broad industry standards (H.265, 802.11, Bluetooth) of infringing patents with specific method steps. The case may turn on whether discovery reveals that the particular algorithms within Defendant's products practice the claimed nuances—such as using a "quadratic approximation" for video processing or embedding specific "beam identity information" for wireless routing—or if the allegations rest on a higher-level functional overlap that does not map to the claim language.
• A key legal issue will be one of definitional scope: the dispute will likely involve construing claim terms that are technologically specific. For example, can "beam identity information," which the patent ties to distinguishing geometric signal paths, be interpreted to cover standard identifiers in a modern Wi-Fi protocol? Similarly, does the "wake-up data sequence" of the ’408 patent read on the methods used in the Bluetooth standard?
• A critical question for damages will be the Defendant's state of mind: the complaint repeatedly alleges a "policy of not reviewing the patents of others" to support willful blindness. The viability of this claim, and the potential for enhanced damages, will depend on Plaintiff's ability to produce evidence of such a corporate policy, distinguishing it from a mere failure to conduct patent searches.