Vision Works IP Corp v. Tesla Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vision Works IP Corp. (Washington)
  • Defendant: Tesla, Inc. (Texas)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:25-cv-00999, E.D. Tex., 10/01/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant conducts substantial business in the district, has committed acts of infringement there, and maintains multiple authorized sales locations, including in Plano, Beaumont, and Tyler.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle control systems—specifically its Adaptive Suspension Damping, Autopilot, and Traction and Stability Control features—infringe five patents related to using sensors to detect and respond to vehicle motion.
• Technical Context: The patents relate to the use of accelerometers, gyroscopes, and other sensors to measure a vehicle's motion, such as lateral acceleration (cornering) and proximity to other objects, in order to control performance and safety systems.
• Key Procedural History: The complaint repeatedly alleges that Defendant’s infringement has been willful since "the filing of the original complaint in this matter," suggesting this action follows a prior complaint that placed Defendant on notice of the asserted patents.

Case Timeline

Date	Event
2004-10-05	Earliest Priority Date for all Asserted Patents
2012-01-01	Earliest Accused Product Launch Year Mentioned (Model S)
2012-11-20	U.S. Patent No. 8,315,769 Issues
2014-03-25	U.S. Patent No. 8,682,558 Issues
2017-11-28	U.S. Patent No. 9,830,821 Issues
2019-08-27	U.S. Patent No. 10,391,989 Issues
2019-09-10	U.S. Patent No. 10,410,520 Issues
2025-10-01	Complaint Filing Date

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

U.S. Patent No. 8,315,769 - “Absolute Acceleration Sensor For Use Within Moving Vehicles”

• Issued: November 20, 2012 (’769 Patent)

The Invention Explained

• Problem Addressed: The patent background describes the difficulty conventional accelerometer-based systems have in reliably detecting subtle vehicle deceleration, as they are often unable to distinguish true changes in speed from gravitational forces experienced on hills or banked curves (’769 Patent, col. 2:1-12). This limits their effectiveness as early-warning anti-collision systems (’769 Patent, col. 2:40-44).
• The Patented Solution: The invention proposes using a vehicle's existing vehicle speed sensor (VSS)—which generates a signal correlated to distance traveled—to more directly calculate deceleration ('769 Patent, col. 3:55-63). By monitoring changes in the VSS signal's frequency or pulse width, the system can detect deceleration and modulate vehicle warning lights to provide an earlier collision warning than systems that wait for brake pedal activation (’769 Patent, Abstract; col. 4:1-4).
• Technical Importance: This approach provided a method for creating a more sensitive and reliable early-warning deceleration alert by using existing vehicle hardware, potentially avoiding collisions by giving following drivers additional reaction time (’769 Patent, col. 2:44-52).

Key Claims at a Glance

• The complaint asserts at least independent claim 21 (Compl. ¶24).
• Claim 21 is a method claim with the following essential elements:
  • sensing its lateral acceleration at the vehicle;
  • sending a signal to a plurality of control devices based upon the vehicle's lateral acceleration; and
  • adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle.
• The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 8,682,558 - “Absolute Acceleration Sensor For Use Within Moving Vehicles”

• Issued: March 25, 2014 (’558 Patent)

The Invention Explained

• Problem Addressed: Like its parent patent, the ’558 Patent addresses the challenge of accurately sensing a vehicle's true motion by distinguishing actual acceleration from gravitational effects, a problem that complicates the use of sensors for advanced vehicle control systems (’558 Patent, col. 2:1-12).
• The Patented Solution: The invention describes a system combining an accelerometer and a gyroscope to sense "absolute acceleration" (’558 Patent, Abstract). This sensor data is sent to a vehicle computer unit, which in turn operates vehicle performance systems. The inclusion of a gyroscope allows the system to account for the vehicle's orientation (e.g., pitch and yaw), enabling a more accurate calculation of acceleration independent of the vehicle's incline (’558 Patent, col. 7:1-6). For example, Figure 4 illustrates an accelerometer-gyroscopic sensor (410) providing an "absolute lateral acceleration" signal to a suspension selector (420) that controls individual suspension systems (’558 Patent, Fig. 4).
• Technical Importance: By combining accelerometer and gyroscope data, the technology aimed to provide a more accurate and "absolute" measure of vehicle motion, enabling more precise control of performance systems like adaptive suspension or stability control.

Key Claims at a Glance

• The complaint asserts at least independent claim 21 (Compl. ¶44).
• Claim 21 is a method claim with the following essential elements:
  • an accelerometer-gyroscope for sensing an absolute acceleration of the vehicle;
  • a vehicle computer unit that receives a signal from the accelerometer-gyroscope based upon the absolute acceleration; and
  • the vehicle computer unit operating one or more vehicle performance systems based upon the absolute acceleration.
• The complaint does not explicitly reserve the right to assert other claims.

U.S. Patent No. 9,830,821 - “Absolute Acceleration Sensor For Use Within Moving Vehicles”

• Issued: November 28, 2017 (’821 Patent)
• Accused Features: Tesla Autopilot (Compl. ¶63).

The Invention Explained

The complaint alleges this patent covers inventive components that improve vehicle safety by providing a system for communicating information about a vehicle's speed and its distance to a nearby object (Compl. ¶62). The asserted claim involves calculating a distance, recording an event if the vehicle enters a "safe-zone threshold," and increasing that threshold as the vehicle's speed increases (Compl. ¶64).

Key Claims at a Glance

• Asserted Claims: At least Claim 12 (Compl. ¶64).

U.S. Patent No. 10,391,989 - “Absolute Acceleration Sensor For Use Within Moving Vehicles”

• Issued: August 27, 2019 (’989 Patent)
• Accused Features: Tesla Traction and Stability Control (Compl. ¶83).

The Invention Explained

The patent abstract describes a customizable communication system for a vehicle comprising sensors and control devices (’989 Patent, Abstract). The complaint alleges the invention includes components for detecting lateral acceleration and generating responses to maintain stability, such as reducing vehicle speed if acceleration exceeds a threshold (Compl. ¶82, ¶84). This functionality is characteristic of modern traction and stability control systems.

Key Claims at a Glance

• Asserted Claims: At least Claim 9 (Compl. ¶84).

U.S. Patent No. 10,410,520 - “Absolute Acceleration Sensor For Use Within Moving Vehicles”

• Issued: September 10, 2019 (’520 Patent)
• Accused Features: Tesla Autopilot (Compl. ¶103).

The Invention Explained

The complaint alleges this patent covers components that improve vehicle safety by communicating information about a vehicle's speed and distance to a nearby object (Compl. ¶102). The asserted claim recites a method for determining a safe distance from an object by determining speed, calculating distance, and assessing safety based on a constant value defined according to speed and distance (Compl. ¶104).

Key Claims at a Glance

• Asserted Claims: At least Claim 12 (Compl. ¶104).

III. The Accused Instrumentality

Product Identification

The complaint identifies three accused instrumentalities: Tesla Adaptive Suspension Damping, Tesla Autopilot, and Tesla Traction and Stability Control, which are incorporated into certain Tesla vehicles (Compl. ¶15).

Functionality and Market Context

• Tesla Adaptive Suspension Damping: This system is alleged to control vehicle performance by sensing lateral acceleration and adjusting suspension characteristics accordingly (Compl. ¶24).
• Tesla Autopilot: This system is alleged to be a driver-assistance feature that, among other things, calculates the distance between the vehicle and an object and manages a "safe-zone threshold" that changes with vehicle speed (Compl. ¶64, ¶104).
• Tesla Traction and Stability Control: This system is alleged to monitor the vehicle by detecting lateral acceleration and reducing vehicle speed if that acceleration exceeds a threshold value (Compl. ¶84).
• The complaint alleges that the provision and sale of these features are a "source of revenue and a business focus" for Tesla (Compl. ¶30, ¶50, ¶70, ¶90, ¶110).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, "Evidence of Use" exhibits for each patent (Compl. p. 28). The analysis below is based on the narrative infringement theories presented for the lead patents.

The complaint does not provide sufficient detail for analysis of a claim chart summary. The narrative theory is summarized below.

’769 Patent Infringement Allegations

The complaint alleges that Tesla's Adaptive Suspension Damping system infringes at least Claim 21 of the ’769 Patent (Compl. ¶24). The theory is that the system performs the claimed method by: (1) "sensing its lateral acceleration at the vehicle," (2) "sending a signal to a plurality of control devices based upon the vehicle's lateral acceleration," and (3) "adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle" (Compl. ¶24).

’558 Patent Infringement Allegations

The complaint also targets Tesla's Adaptive Suspension Damping with the ’558 Patent, alleging infringement of at least Claim 21 (Compl. ¶44). The infringement theory is that the system provides the claimed method by including: (1) an "accelerometer-gyroscope for sensing an absolute acceleration of the vehicle," (2) a "vehicle computer unit that receives a signal from the accelerometer-gyroscope," and (3) this computer unit "operates one or more vehicle performance systems based upon the absolute acceleration of the vehicle" (Compl. ¶44).

Identified Points of Contention

• Scope Questions: A central question for the '558 Patent may be whether Tesla's system measures "absolute acceleration" as that term is used in the patent. The patent family distinguishes "absolute acceleration" from measurements that are confounded by gravity (’989 Patent, col. 2:20-34). The case may turn on whether Tesla's sensors and algorithms perform the specific gravity-cancellation function contemplated by the patent.
• Technical Questions: For both patents, a key factual question will concern the specific operation of the accused systems. For the ’769 Patent, this may involve what specific "suspension characteristic" is adjusted and whether it is adjusted "based upon" lateral acceleration in the manner claimed. For the ’558 Patent, it raises the question of what specific hardware constitutes the claimed "accelerometer-gyroscope" and "vehicle computer unit" in Tesla's architecture.

V. Key Claim Terms for Construction

The Term: "absolute acceleration" (’558 Patent, Claim 21)

• Context and Importance: This term appears to be the primary point of novelty asserted by the inventor to overcome the limitations of prior art accelerometers that are sensitive to gravity. Its construction will be critical because if it is construed narrowly to require a specific method of isolating acceleration from gravity, infringement may be more difficult to prove. If construed broadly to cover any system that attempts to compensate for gravity, the patent's validity could be challenged.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves do not specify how absolute acceleration is sensed, only that an "accelerometer-gyroscope" is used for the purpose. This may support an interpretation covering any system that uses this combination of hardware to derive an acceleration value.
  • Evidence for a Narrower Interpretation: The patent specification repeatedly discusses the problem of gravitational artifacts and the need to "precisely account for gravitational forces" (’989 Patent, col. 2:20-21). A defendant may argue that "absolute acceleration" is not merely any acceleration value, but one that has been specifically processed to remove gravitational components, as detailed in the specification.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Tesla induces infringement by instructing customers on how to use the accused features through owner's manuals, brochures, and its website (Compl. ¶26, ¶46, ¶66, ¶86, ¶106). It further alleges contributory infringement on the basis that the accused systems have "special features that are specially designed to be used in an infringing way and that have no substantial uses" other than infringing uses (Compl. ¶29, ¶49, ¶69, ¶89, ¶109).

Willful Infringement

Willfulness is alleged based on knowledge of the patents dating from "the filing of the original complaint in this matter" (Compl. ¶34, ¶54, ¶74, ¶94, ¶114). The complaint also alleges willful blindness, stating on information and belief that Tesla has a "policy or practice of not reviewing the patents of others" (Compl. ¶32, ¶52, ¶72, ¶92, ¶112).

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

This dispute will likely center on two key questions for the court:

1. A core issue will be one of definitional scope: What is the proper construction of the term "absolute acceleration"? Can it be read broadly to cover any modern vehicle system that uses sensor fusion to estimate motion, or is it limited to the specific methods of gravity cancellation described in the patents' specifications?
2. A key evidentiary question will be one of technical implementation: Does the actual software and hardware architecture of Tesla's accused systems—which rely on complex, integrated processing of data from numerous sensors—map onto the discrete components and method steps recited in the patent claims, such as a distinct "accelerometer-gyroscope" sending a signal to a "vehicle computer unit" that performs a specific claimed function?