DCT

2:25-cv-00798

Integral Wireless Tech LLC v. Luminator Technology Group Global LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00798, E.D. Tex., 12/17/2025
  • 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, and has committed acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile surveillance and fleet management products, which incorporate various video processing and wireless communication technologies, infringe eight patents related to video processing, multi-antenna wireless communications, data coding, context-aware search, and power management.
  • Technical Context: The asserted patents cover a range of technologies integral to modern digital video and wireless communication systems, addressing issues of efficiency, performance, and interoperability.
  • Key Procedural History: This First Amended Complaint asserts infringement of eight U.S. patents. The infringement allegations and technical explanations within the complaint rely heavily on a concurrently filed declaration from an expert, Dr. Steven H. Goldberg. No prior litigation or post-grant validity challenges are mentioned.

Case Timeline

Date Event
2003-03-05 ’031 Patent Priority Date
2003-03-25 ’878 Patent Priority Date
2003-08-13 ’537 Patent Priority Date
2003-12-23 ’283 Patent Priority Date
2004-07-02 ’592 Patent Priority Date
2004-11-24 ’408 Patent Priority Date
2005-04-26 ’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
2025-12-17 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 addresses visual artifacts, such as "motion judder," that arise when converting video from one frame rate to another (e.g., 24 frames-per-second film to 60 fields-per-second television) (’283 Patent, col. 1:63-67). Conventional methods to create smoother, interpolated frames either lacked precision by operating only on whole pixels or were computationally expensive because they required generating and searching full high-resolution, sub-pixel images (’283 Patent, col. 2:23-33).
  • The Patented Solution: The invention provides a computationally efficient method for estimating motion between frames with sub-pixel accuracy. Instead of creating a full sub-pixel image, the method starts with a less-precise, integer-pixel "converged vector." It then takes a small number of correlation samples around that point to get a coarse estimate of the error surface and applies a "quadratic approximation" (a mathematical curve-fitting technique) to calculate a refined, sub-pixel vector position (’283 Patent, Abstract; col. 2:40-54). A flowchart in the complaint illustrates this process of defining a position, sampling, and performing a surface fit to generate a refined vector (Compl. ¶42; ’283 Patent, FIG. 3).
  • Technical Importance: This technique offered a low-cost, hardware-efficient method to improve the visual quality of frame-rate-converted video by refining motion vectors without the high processing and memory costs of prior art sub-pixel estimation methods (Compl. ¶¶ 47, 49).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a method) and 6 (an apparatus) (Compl. ¶¶ 50, 62).
  • Independent Claim 1 includes the essential elements of:
    • defining a minimum vector position value of a converged vector;
    • determining a predetermined number of vector correlation samples around that value to provide 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.
  • Independent Claim 6 recites a computation device configured to perform the same three essential steps as method claim 1.
  • The complaint explicitly reserves the right to assert dependent claims (Compl. ¶50).

U.S. Patent No. 7,310,537 - "Communication On Multiple Beams Between Stations"

  • Issued: December 18, 2007

The Invention Explained

  • Problem Addressed: In early multi-antenna wireless systems (e.g., MIMO), selecting the best transmission beams based solely on received signal power was unreliable (’537 Patent, col. 2:43-49). Because signals on adjacent beams could overlap or arrive from different physical paths (e.g., direct vs. reflected), a receiver could not distinguish whether a strong signal represented a single clean path or interference from multiple paths, leading to poor beam selection and degraded performance (’537 Patent, col. 2:53-3:5). The complaint includes a figure illustrating how signals from a base station can propagate on overlapping portions of adjacent beams (Compl. ¶96; ’537 Patent, FIG. 5).
  • The Patented Solution: The invention proposes embedding unique "beam identity information" into the signals transmitted on each of the multiple beams (’537 Patent, col. 3:15-18). This allows the receiving station to identify the specific beams from which signals are arriving, rather than just measuring aggregate signal strength. With this knowledge, the receiver can select a set of "geometrically distinguished" beams for communication, ensuring the chosen paths are physically distinct and avoiding interference from adjacent or overlapping beams (’537 Patent, col. 4:2-4).
  • Technical Importance: This approach provided a more robust method for beam selection in multi-beam systems by enabling the system to distinguish between different physical propagation paths, thereby reducing interference and improving capacity without relying on complex channel matrix calculations common in other MIMO approaches (Compl. ¶99).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a method) and 26 (a station) (Compl. ¶¶ 124, 151).
  • Independent Claim 1 includes the essential elements of:
    • including beam identity information into signals transmitted on multiple beams by a first station;
    • receiving the signals at a second station;
    • identifying the beams based on said identity information; and
    • selecting a set of beams that are geometrically distinguished from each other.
  • Independent Claim 26 recites a station comprising:
    • an antenna unit configured to receive signals on multiple beams; and
    • a controller for identifying beams based on associated beam identity information;
    • wherein a set of geometrically distinguished beams is selected for transmission based on the identified beams.
  • The complaint references the right to assert dependent claims (Compl. ¶124).

U.S. Patent No. 7,483,878 - "Generation and Presentation of Search Results Using Addressing Information"

  • Issued: January 27, 2009
  • Technology Synopsis: The patent describes a method to provide more relevant search results by monitoring a user's web browsing. The system receives "addressing information" (e.g., a URL) identifying a user's location on a network, processes that information to automatically generate a keyword, performs a search on that keyword, and presents the results to the user, for example in a pop-under window (Compl. ¶¶ 161-163). A screenshot in the complaint depicts search results for "minivan" displayed in a pop-under window, triggered by the user visiting a car-related website (Compl. ¶177; ’878 Patent, FIG. 4).
  • Asserted Claims: Independent claims 1 (method) and 9 (computer-readable storage medium) are asserted (Compl. ¶179).
  • Accused Features: The complaint accuses Defendant's website, alleging it performs a method of providing search results based on receiving addressing information (Compl. ¶203).

U.S. Patent No. 7,548,592 - "Multiple Input, Multiple Output Communications Systems"

  • Issued: June 16, 2009
  • Technology Synopsis: The patent addresses signal distortion, interference, and unequal signal-to-noise ratios in MIMO wireless systems (Compl. ¶¶ 235-236). It discloses systems and methods for optimizing transmitter and receiver "weights" (signal processing coefficients) by employing specific, structured matrix decomposition techniques. The claims define a mathematical relationship between transmitter weights (V), a channel matrix (decomposed into L and Q), and receiver weights (V⁻¹L⁻¹) to create independent, balanced communication channels (Compl. ¶¶ 238, 275).
  • Asserted Claims: Independent claims 1 (transmitter), 9 (system), and 16 (method) are asserted (Compl. ¶274).
  • Accused Features: The complaint accuses Defendant's 802.11n/ac/ax Wi-Fi compatible devices (Compl. ¶304).

U.S. Patent No. 7,586,424 - "Data Coding Using An Exponent and A Residual"

  • Issued: September 8, 2009
  • Technology Synopsis: The invention aims to improve data compression efficiency. It describes a method of coding a data symbol by representing it with an "exponent value" and a "residual value." The innovation lies in coding the exponent value with a variable-length code (e.g., Huffman coding) based on its frequency of occurrence, while coding the residual value with a fixed-length binary code. This "Hybrid Golomb Coder" is alleged to be more efficient than conventional methods in many scenarios (Compl. ¶¶ 334-335, 341-342).
  • Asserted Claims: Independent claims 1, 14, 28, 29, and 30-33 are asserted (Compl. ¶¶ 344-345).
  • Accused Features: The complaint accuses Defendant's H.265/HEVC compatible devices (Compl. ¶361).

U.S. Patent No. 7,668,258 - "Systems and Methods for Transmitter Diversity Expansion"

  • Issued: February 23, 2010
  • Technology Synopsis: The patent discloses a method for expanding a set of K data streams for transmission over a larger set of N antennas (where N>K) to improve diversity and reliability. The technique uses unitary matrix combinations and cyclic shifts to transform the original K streams into N-K additional streams for the extra antennas. This method is designed to be "transparent," meaning the receiver does not require special knowledge or decoding circuitry to benefit from the expanded diversity (Compl. ¶¶ 388-389).
  • Asserted Claims: Independent claims 1 (method), 7 (system), and 13 (computer-readable medium) are asserted (Compl. ¶414).
  • Accused Features: The complaint accuses Defendant's 802.11n/ac/ax Wi-Fi compatible devices (Compl. ¶432).

U.S. Patent No. 7,398,408 - "Systems and Methods for Waking Up Wireless LAN Devices"

  • Issued: July 8, 2008
  • Technology Synopsis: This patent addresses the challenge of waking a wireless device from a low-power or sleep state when its physical location on a network is unknown, a problem not solved by prior wired "Wake-on-LAN" technology (Compl. ¶463). The solution involves the device's wireless card entering a special monitoring state where it periodically scans wireless channels for a broadcasted "wake-up data sequence" containing its unique hardware address, allowing it to power back on when that sequence is detected (Compl. ¶466).
  • Asserted Claims: Independent claims 1 (method), 7 (system), and 13 (method) are asserted (Compl. ¶488).
  • Accused Features: The complaint accuses Defendant's Bluetooth v4.2 (BR/EDR) compatible devices (Compl. ¶510).

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

  • Issued: January 26, 2010
  • Technology Synopsis: The invention provides a method to prevent interference between two different wireless protocols (e.g., Wi-Fi and Bluetooth) operating on the same shared channel within a single device (Compl. ¶534). The first protocol's transceiver (e.g., Wi-Fi) uses its network timing information, such as from beacon frames, to determine when a "transmit opportunity" will exist on the channel. It then sends a notification to the second protocol's transceiver (e.g., Bluetooth), granting it permission to use the shared channel during that time (Compl. ¶¶ 541, 544).
  • Asserted Claims: Independent claims 1 (method), 15 (apparatus), and 20 (apparatus) are asserted (Compl. ¶554).
  • Accused Features: The complaint accuses Defendant's IEEE 802.11 Wi-Fi and Bluetooth compatible devices (Compl. ¶575).

III. The Accused Instrumentality

Product Identification

  • The complaint names a range of products, primarily under the "RoadRunner" brand, including the RoadRunner™ Pro, RoadRunner™ 4K Recorder, and various interior and exterior cameras (Compl. ¶23). It also identifies the Luminator Inform™ Fleet Management Kit. More broadly, the allegations are directed at Defendant's devices that are compatible with specific technology standards, including H.265/HEVC, 802.11n/ac/ax Wi-Fi, and Bluetooth v4.2 BR/EDR (Compl. ¶23).

Functionality and Market Context

  • The accused products appear to constitute a vehicle-based video surveillance and fleet management system (Compl. ¶23). The system's functionality includes video capture, recording, and processing (implicating H.265/HEVC standards), as well as wireless data transmission (implicating Wi-Fi and Bluetooth standards for communication) (Compl. ¶¶ 63, 304, 361, 432, 510). The complaint alleges Defendant provides user guides and instruction manuals detailing how to use these products (Compl. ¶24).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The narrative infringement theories are summarized below.

  • U.S. Patent No. 7,292,283 Infringement Allegations

    • The complaint alleges that Defendant's H.265/HEVC compatible devices directly infringe at least claim 1 of the ’283 Patent (Compl. ¶¶ 62-63). The theory of infringement mirrors the language of claim 1, alleging that in performing frame conversion, the accused devices: (1) define a minimum vector position of a converged vector; (2) determine vector correlation samples to create a coarse estimation; and (3) perform a correlation surface fitting using a quadratic approximation to find a refined sub-pixel position (Compl. ¶63).

  • Identified Points of Contention:

    • Evidentiary Question: The central dispute may focus on whether the algorithms specified by the H.265/HEVC standard, as implemented in Defendant's products, actually perform the specific three-step process of quadratic surface fitting required by claim 1. The complaint's allegation is conclusory and does not specify which part of the standard or product operation corresponds to each claimed step.
    • Technical Question: A question may arise as to whether the motion vector refinement techniques used in modern video codecs like HEVC are technically equivalent to the specific "quadratic approximation" method disclosed in the patent, or if they rely on different mathematical approaches.

  • U.S. Patent No. 7,310,537 Infringement Allegations

    • The complaint alleges that products such as the Road Runner™ Pro directly infringe at least claim 26 of the ’537 Patent (Compl. ¶¶ 150-151). The infringement theory tracks the language of claim 26, alleging the accused products are a "station" that includes: (1) an antenna unit configured to receive signals on multiple beams; and (2) a controller that identifies beams using "beam identity information" to select a set of "geometrically distinguished" beams for transmission (Compl. ¶151).

  • Identified Points of Contention:

    • Scope Questions: A primary point of contention will likely be the scope of "beam identity information" and "geometrically distinguished." The analysis may question whether standard identifiers in 802.11 protocols (e.g., BSSID, channel number) function as "beam identity information" in the manner claimed, and whether the beam selection methods used in the accused products select beams that are "geometrically distinguished" in a physical sense, as opposed to being distinguished merely by frequency, time, or coding.

V. Key Claim Terms for Construction

  • The Term: "converged vector" (’283 Patent, Claim 1)

    • Context and Importance: This term defines the starting point for the claimed refinement method. Its construction is critical because it determines what type of input the accused process must begin with to infringe. Practitioners may focus on whether this term is limited to the output of a specific type of preliminary search (e.g., a block-matching search) or can encompass any initial integer-level motion vector.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent specification does not appear to provide a specific, limiting definition, referring to it as an input from which the inventive process begins, which may support an argument that it covers any initial integer-pixel vector estimate (Compl. ¶39; ’283 Patent, col. 4:23-25).
      • Evidence for a Narrower Interpretation: The complaint's own expert declaration defines it as "the integer-pixel motion vector produced by an initial block-matching correlation search—the point where that search has converged to a minimum correlation value" (Compl. ¶41). This language could be used to argue for a narrower construction tied to a specific, antecedent technical process.

  • The Term: "geometrically distinguished" (’537 Patent, Claim 1)

    • Context and Importance: This term is central to the patent's proposed solution for avoiding interference. The infringement analysis will likely turn on whether the method of beam selection in the accused products results in beams that are "geometrically distinguished." Practitioners may focus on whether this requires distinction based on physical propagation paths and angles or if logical separation (e.g., by frequency or code) is sufficient.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide a precise mathematical definition, which may support a broader, more functional interpretation where any method that successfully avoids interference between beams could be considered to select "distinguished" beams.
      • Evidence for a Narrower Interpretation: The specification repeatedly links the term to physical geometry, describing how signals "travel in geometrically distinguished propagation environments" and how different radio propagation paths "may have different geometries" (Compl. ¶¶ 104, 107; ’537 Patent, col. 5:9-12, 5:47-52). This suggests a narrower meaning rooted in physical separation, such as angle of arrival or the use of distinct reflection paths.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for each asserted patent. Inducement is based on Defendant allegedly providing user guides, instruction manuals, and technical support that instruct customers on how to use the Accused Products in an infringing manner (Compl. ¶¶ 67-69). Contributory infringement is based on allegations that the Accused Products contain special features designed for infringement that are not staple articles of commerce (Compl. ¶¶ 75-76).
  • Willful Infringement: The complaint alleges willful infringement on two grounds: (1) pre-suit willful blindness, based on an alleged "policy or practice of not reviewing the patents of others," and (2) post-suit willfulness, based on actual knowledge of the patents from at least the date of the original complaint (Compl. ¶¶ 64-65).

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

  • A core issue will be one of implementation vs. claim scope: For the patents asserted against standardized technologies (e.g., H.265/HEVC, 802.11, Bluetooth), a central question will be whether the specific algorithms and protocols in those standards, as implemented in Defendant's products, perform the exact sequence of steps or contain the specific components recited in the asserted claims. The case may turn on detailed technical evidence comparing the operation of the accused devices against claim limitations concerning, for example, "quadratic approximation," "unitary matrix" combinations, or "Hybrid Golomb" coding.
  • A key legal question will be one of definitional breadth: For patents involving more conceptual terms, such as the ’537 patent, the case will likely hinge on claim construction. The analysis will raise the question of whether terms like "geometrically distinguished" can be broadly construed to read on modern wireless systems that separate signals using methods (e.g., frequency, coding) that may not have been explicitly contemplated by the patent's focus on physical propagation paths.
  • An evidentiary question will be one of knowledge and intent: Regarding willfulness and indirect infringement, the case may explore what evidence supports Plaintiff's allegation of a corporate "policy or practice of not reviewing the patents of others." The viability of the pre-suit willfulness claim could depend on Plaintiff’s ability to substantiate this allegation of willful blindness.