Context Directions LLC v. Ewing Buick Plano LP

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Context Directions LLC (Delaware)
  • Defendant: Ewing Buick-Plano, L.P. (Texas)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 2:25-cv-00953, E.D. Tex., 09/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains places of business in the district and has allegedly committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s vehicles, equipped with modern driver-assistance systems, infringe patents related to a method for efficiently detecting the context of a mobile device using a hierarchical system of sensors.
• Technical Context: The technology addresses the need for energy-efficient context awareness in mobile devices, particularly for determining if a device is in a moving vehicle, by using a tiered sensor activation strategy.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement of the patents-in-suit on October 31, 2023, which may form the basis for a claim of willful infringement for any subsequent sales.

Case Timeline

Date	Event
2012-02-17	Earliest Priority Date for ’564 and ’791 Patents
2017-10-31	U.S. Patent No. 9,807,564 Issues
2018-01-01	Approximate launch of earliest accused products (2018 model year vehicles)
2018-11-27	U.S. Patent No. 10,142,791 Issues
2023-10-31	Plaintiff allegedly provides written notice of infringement to Defendant
2025-09-16	Complaint Filed

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

U.S. Patent No. 9,807,564 - "Method for Detecting Context of a Mobile Device and a Mobile Device with a Context Detection Module"

• Patent Identification: U.S. Patent No. 9,807,564, "Method for Detecting Context of a Mobile Device and a Mobile Device with a Context Detection Module," issued October 31, 2017 (’564 Patent).

The Invention Explained

• Problem Addressed: The patent describes a technical challenge with mobile devices: determining the device's "context" (e.g., whether it is in a moving vehicle) without being excessively slow, inaccurate, or power-intensive (’564 Patent, col. 1:58-2:21). Prior methods using cell tower signals were imprecise, while methods using GPS consumed significant battery power, reducing the device's operating time (Compl. ¶12).
• The Patented Solution: The invention proposes a hierarchical system of sensor groups to conserve energy. A lower-level, low-power group of sensors is activated first. If its classification result suggests a specific context (e.g., movement), a higher-level group of more power-intensive but more accurate sensors is then activated to confirm the context (’564 Patent, Abstract). The system is also adaptive, using the results from the higher-level group's classification to update or "adapt the configuration" of the lower-level group's classifier, improving future accuracy (’564 Patent, col. 13:3-10).
• Technical Importance: This tiered, adaptive approach allows a mobile device to achieve accurate and timely context awareness while minimizing energy consumption, which is a critical consideration for battery-powered electronics (Compl. ¶11, ¶13).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 23 (Compl. ¶14). Claim 1 is representative:
• Claim 1 Elements:
  • A mobile device comprising a plurality of sensors arranged into a hierarchy of sensor groups, and a plurality of classifiers each assigned to a sensor group.
  • A context detection module configured to:
    • "activate a classification" by a classifier assigned to a "first sensor group" at a lowest level in the hierarchy;
    • "activate a classification" by a classifier assigned to a "second sensor group" after a result of the classification by the first group's classifier; and
    • "adapt a configuration" of the classifier assigned to the first sensor group based on a result of the classification by the second group's classifier.

U.S. Patent No. 10,142,791 - "Method and System for Context Awareness of a Mobile Device"

• Patent Identification: U.S. Patent No. 10,142,791, "Method and System for Context Awareness of a Mobile Device," issued November 27, 2018 (’791 Patent).

The Invention Explained

• Problem Addressed: The complaint states that the ’791 Patent shares an identical specification with the ’564 Patent (Compl. ¶26). Therefore, it addresses the same technical problem of energy-efficient context detection in mobile devices.
• The Patented Solution: The patented solution is materially the same as that described for the ’564 Patent, involving a hierarchical and adaptive system of sensor groups and classifiers (’791 Patent, Abstract).
• Technical Importance: As with the ’564 Patent, the technical importance lies in enabling accurate context awareness without unduly draining the battery of a mobile device (Compl. ¶¶11-13, 26).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶27).
• Claim 1 Elements:
  • A mobile device comprising a plurality of sensors arranged into a hierarchy of sensor groups, and a plurality of classifiers each assigned to a sensor group.
  • Wherein the mobile device is configured to:
    • "activate a classification" by a classifier assigned to a "first sensor group" at a lowest level in the hierarchy;
    • "activate a classification" by a classifier assigned to a "second sensor group" after a result of the classification by the first group's classifier; and
    • "adapt a configuration" of the classifier assigned to the first sensor group based on a result of the classification by the second group's classifier.

III. The Accused Instrumentality

Product Identification

Various Audi, Toyota, and Lexus vehicles from model years 2018 through 2024 (Compl. ¶14, ¶27).

Functionality and Market Context

The complaint alleges that the vehicles function as "mobile devices" equipped with a "plurality of sensors," including cameras, radar, steering sensors, braking sensors, and speed sensors (Compl. ¶15). These sensors are part of advanced driver-assistance systems that provide features such as pre-collision warning, dynamic radar cruise control, and lane tracing assist (Compl. ¶17). The complaint alleges these features rely on detecting the vehicle's context—specifically, its own motion and its position relative to surrounding objects—to function (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that were not provided with the filed document; therefore, the infringement allegations are summarized below in prose based on the complaint's narrative. (Compl. ¶14, ¶27). No probative visual evidence provided in complaint.

’564 Patent & ’791 Patent Infringement Allegations

The complaint presents a unified infringement theory for both patents. It alleges that the accused vehicles meet the "mobile device" limitation and that their various sensors (camera, radar, etc.) meet the "plurality of sensors" limitation (Compl. ¶15). The core of the allegation is that these sensors are arranged and activated in a hierarchical manner that reads on the claims.

Specifically, the complaint alleges that a "first sensor group" ("Group 1"), comprising the steering, braking, and speed sensors, is activated first to perform a classification that determines the vehicle is in a "moving state" (Compl. ¶16-18). Following this initial classification, a "second sensor group" ("Group 2"), comprising the camera and radar, is allegedly activated to monitor the vehicle's surroundings (Compl. ¶18). This sequence is alleged to meet the two "activate a classification" steps of the claims.

Finally, the complaint alleges that information from the second group's classification (e.g., the distance to a forward vehicle detected by radar) is used to modify the operation of the first group (e.g., by adjusting speed or applying brakes). This feedback mechanism is alleged to meet the "adapt a configuration of the classifier" limitation (Compl. ¶19).

Identified Points of Contention

• Scope Questions: The infringement theory raises the question of whether a passenger vehicle can be considered a "mobile device" within the meaning of the patents. The specifications of both patents primarily describe handheld, battery-powered consumer electronics, which may create a significant dispute over claim scope.
• Technical Questions: The complaint's theory that the vehicle's real-time safety control loop constitutes "adapting a configuration of the classifier" will likely be a point of dispute. The analysis may turn on whether this operational feedback is technically equivalent to the patent's description of modifying a classifier's underlying logical patterns.
• Factual Questions: The complaint’s assertion of a specific two-step activation hierarchy (motion sensors first, then external-facing sensors) is a factual claim about the operation of the accused vehicles that may be subject to technical challenge.

V. Key Claim Terms for Construction

The Term: "mobile device"

• Context and Importance: This term's construction is foundational to the entire case. If a vehicle is determined not to be a "mobile device" as contemplated by the patents, the infringement claims may fail.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "mobile device" is broad and not explicitly limited in the claim language itself.
  • Evidence for a Narrower Interpretation: The specification repeatedly provides a list of exemplary devices: "mobile phones, laptops, PDAs, tablets, watches, music players, satellite navigation devices, cameras" (’791 Patent, col. 1:30-34). The background section focuses on problems unique to such devices, like limited battery capacity, which may suggest the invention was intended for this specific technological context (’791 Patent, col. 2:17-21).

The Term: "adapt a configuration of the classifier"

• Context and Importance: This term is critical for determining whether the accused vehicles perform the final, adaptive step of the claimed method. Practitioners may focus on whether the accused real-time control adjustments rise to the level of adapting a "configuration."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "adapt a configuration" is not narrowly defined, and language in the complaint suggests that modifying "software variables" in response to new sensor data could be argued to fall under this term (Compl. ¶19).
  • Evidence for a Narrower Interpretation: The patent specification describes a specific embodiment of adaptation where "features vectors" are added to or removed from a "set of positive patterns" and a "set of negative patterns" (’791 Patent, Fig. 5; col. 13:3-10). This language may support a narrower construction requiring a change to the classifier's stored reference data, rather than just a transient change in its output.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement by stating that Defendant "induces others to perform a method" by providing the accused vehicles with their driver-assistance features and, implicitly, instructing users on their operation (Compl. ¶15).

Willful Infringement

The willfulness allegation is based on alleged pre-suit knowledge. The complaint asserts that Plaintiff provided written notice of infringement to Defendant on October 31, 2023, and that Defendant’s continued sale of the accused products thereafter was willful (Compl. ¶20, ¶28).

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

• A core issue will be one of definitional scope: can the term "mobile device," which is described in the patent specifications in the context of handheld, battery-powered consumer electronics, be construed to cover a modern passenger vehicle?
• A key technical question will be one of functional equivalence: does the real-time feedback loop in the accused vehicles' safety systems perform the specific function of "adapting a configuration of the classifier" as claimed, or is there a fundamental mismatch between this operational control and the patent's teaching of modifying a classifier's underlying data patterns?
• An evidentiary question will center on the factual operation of the accused systems: do they in fact employ the specific hierarchical sensor activation sequence alleged in the complaint, or do they operate in a different manner that does not map onto the claim limitations?