Context Directions LLC v. Tyler Motor Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Context Directions LLC (Delaware)
  • Defendant: Tyler Motor Company, Inc. (Delaware)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 2:25-cv-00955, E.D. Tex., 09/16/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a place of business in the district and has allegedly committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s sale of certain vehicles infringes patents related to hierarchically managing sensors on a mobile device to efficiently detect its context, such as being in a moving vehicle.
• Technical Context: The technology relates to power-saving methods for context-aware mobile computing, a significant feature for battery-dependent devices like smartphones, particularly for applications that change behavior based on user activity.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of infringement for both asserted patents on or about October 31, 2023. The complaint also notes that the two patents-in-suit share an identical specification.

Case Timeline

Date	Event
2012-02-17	Earliest Priority Date ('564 & '791 Patents)
2017-10-31	U.S. Patent No. 9,807,564 Issued
2018-11-27	U.S. Patent No. 10,142,791 Issued
2023-10-31	Plaintiff provided written notice of infringement
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" (Issued Oct. 31, 2017)

The Invention Explained

• Problem Addressed: The patent describes a technical challenge where determining a mobile device's context, such as its presence in a moving vehicle, required a trade-off between accuracy and energy consumption (Compl. ¶12). Prior methods that relied on signals from cell phone towers were prone to false positives, while methods using GPS were more accurate but consumed significant battery power, reducing the device's operating time (’791 Patent, col. 2:6-21).
• The Patented Solution: The invention proposes a hierarchical system of sensor groups to conserve energy. A low-power sensor group is used initially to make a preliminary context assessment. Only if this group detects a potential context of interest (e.g., movement) is a higher-power, more accurate sensor group (such as a GPS receiver) activated for confirmation (’791 Patent, col. 4:5-15). This tiered approach aims to provide accurate context awareness without the continuous power drain of high-energy sensors, and further uses results from the higher-level group to adapt and improve the lower-level group's classifier over time (’791 Patent, col. 4:15-19; Fig. 3).
• Technical Importance: This energy-efficient approach addresses the critical constraint of battery life in mobile devices, enabling sophisticated context-aware features to operate without rapidly depleting the device's power (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claim 23 (Compl. ¶14).
• The complaint does not provide the text of these claims or sufficient detail for analysis.

U.S. Patent No. 10,142,791 - "Method and System for Context Awareness of a Mobile Device" (Issued Nov. 27, 2018)

The Invention Explained

• The complaint states that the ’791 Patent shares an identical specification with the ’564 Patent, and therefore addresses the same technical problem with the same proposed solution described above (Compl. ¶21).

Key Claims at a Glance

• The complaint asserts independent claim 1 (’791 Patent, Compl. ¶22).
• The essential elements of independent claim 1 include:
  • A mobile device comprising a plurality of sensors arranged into a hierarchical plurality of sensor groups.
  • A plurality of classifiers, with each classifier assigned to a sensor group to evaluate contexts based on signals from that group's sensors.
  • The mobile device is configured to first activate a classification using a classifier from a "first sensor group" at the "lowest level in the hierarchy."
  • The device is further configured to activate a classification using a classifier from a "second sensor group" after a result from the first group's classification.
  • Finally, the device is configured to "adapt a configuration of the classifier" of the first sensor group based on a result from the second sensor group's classification.

III. The Accused Instrumentality

Product Identification

The complaint identifies numerous vehicles from Hyundai, RAM, and Toyota, with model years ranging from 2017 to 2025, as the "Accused Products" (Compl. ¶14, ¶22).

Functionality and Market Context

The complaint alleges that Defendant infringes by "selling and/or offering for sale" the Accused Products (Compl. ¶14). It does not, however, provide any technical details regarding the specific systems or components within these vehicles that are alleged to practice the patented technology. The infringement theory appears to target an embedded system, such as an infotainment or telematics unit, that performs context detection.

IV. Analysis of Infringement Allegations

'564 Patent Infringement Allegations

The complaint alleges that the Accused Products infringe at least claims 1 and 23 of the ’564 Patent and references claim charts submitted as Exhibits B-D (Compl. ¶14). These exhibits were not publicly filed with the complaint. The pleading itself does not contain a narrative description of how specific features of the Accused Products allegedly meet the limitations of the asserted claims.

'791 Patent Infringement Allegations

The complaint alleges that the sale of the Accused Products infringes at least claim 1 of the ’791 Patent, referencing claim charts in Exhibits F-H that were not publicly filed (Compl. ¶22, ¶6). Similar to the allegations for the ’564 Patent, the complaint does not provide a narrative infringement theory explaining how the Accused Products meet the claim limitations.

Identified Points of Contention

• Scope Questions: A primary legal question may be whether an integrated vehicle infotainment or telematics system, which is powered by the vehicle's main electrical system, qualifies as a "mobile device" as that term is used in the patent.
• Technical Questions: A central evidentiary question for the court will be whether the systems in the Accused Products actually perform the claimed method. The complaint does not specify what evidence demonstrates that these systems utilize hierarchically-ordered sensor groups and, critically, perform the "adaptation" of a lower-level classifier based on feedback from a higher-level one, as required by the claims.
• No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Analysis is based on independent claim 1 of the ’791 Patent.

The Term: "mobile device"

• Context and Importance: The applicability of the patent to the accused vehicles will depend heavily on the construction of this term. Practitioners may focus on this term because the accused products are vehicles, whereas the patent specification provides examples such as "mobile phones, laptops, PDAs, tablets, watches, music players" (’791 Patent, col. 2:30-33).
• Intrinsic Evidence for a Broader Interpretation: The patent describes the invention's applicability to any device with sensors where context awareness and power consumption are considerations, suggesting the provided list of devices is exemplary rather than exhaustive (’791 Patent, col. 2:30-38).
• Intrinsic Evidence for a Narrower Interpretation: The specification frequently refers to a "battery-powered mobile device" and the problem of limited operating time due to battery capacity, a context that may not apply to a system integrated into a vehicle's electrical system (’791 Patent, col. 2:65-66).

The Term: "adapt a configuration of the classifier"

• Context and Importance: This term appears to require an active "learning" or feedback process, which is a key technical aspect of the claimed invention. The infringement analysis will turn on whether the accused systems perform such adaptation, as opposed to merely using a static, tiered decision tree for sensor activation.
• Intrinsic Evidence for a Broader Interpretation: The patent describes the adaptation mechanism in general terms as a process that "consists of additions, deletions and exchanging patterns in the sets" that the classifier uses for its analysis (’791 Patent, col. 12:60-63).
• Intrinsic Evidence for a Narrower Interpretation: The specification discloses a specific algorithm for this adaptation, involving the management of "a set of positive patterns" and "a set of negative patterns" based on the classification results from higher-level sensor groups (’791 Patent, Fig. 5; col. 13:3-15). A party could argue that the claim term should be construed consistently with this detailed embodiment.

VI. Other Allegations

Indirect Infringement

The complaint makes conclusory allegations of "indirect infringement" but does not plead specific facts to support either induced or contributory infringement, such as knowledge of direct infringement by others or the intent to encourage such acts (Compl. ¶15, ¶23).

Willful Infringement

The complaint alleges willful infringement based on Defendant's alleged continuation of infringing activities after receiving written notice of infringement from Plaintiff on or about October 31, 2023 (Compl. ¶15, ¶23).

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

• A core issue will be one of definitional scope: can the term "mobile device," described in the patent specification with examples of personal, battery-powered electronics, be construed to cover the integrated infotainment and telematics systems within the accused vehicles?
• A key evidentiary question will be one of technical operation: what evidence will Plaintiff be required to produce to demonstrate that the accused systems perform not only a hierarchical activation of sensors but also the specific claim limitation of "adapting" the configuration of a lower-level classifier based on results from a higher-level one?
• A threshold question may be one of liability for sale: the complaint targets a vehicle dealership for infringement by "selling and/or offering for sale" used vehicles. The case may therefore involve an analysis of how the act of selling a product containing an allegedly infringing system satisfies the elements of direct infringement for the asserted system and method claims.