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., 12/24/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Tesla conducts substantial business in the district, including operating multiple sales and service locations in cities such as Plano, Flower Mound, Beaumont, and Tyler.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle control systems, specifically Tesla Adaptive Suspension Damping, Autopilot, and Traction and Stability Control, infringe five U.S. patents related to using sensors to detect vehicle acceleration and control vehicle safety systems.
• Technical Context: The patents-in-suit relate to the field of advanced driver-assistance systems (ADAS), which employ sensors to monitor vehicle dynamics in real-time to improve safety, performance, and stability.
• Key Procedural History: The complaint is a First Amended Complaint for Patent Infringement. No prior litigation, licensing history, or post-grant proceedings concerning the asserted patents are mentioned.

Case Timeline

Date	Event
2004-10-05	Earliest Priority Date for all Asserted Patents
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
2025-12-24	Complaint Filed

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

U.S. Patent No. 8,315,769 - *Absolute Acceleration Sensor For Use Within Moving Vehicles* (Issued Nov. 20, 2012)

The Invention Explained

• Problem Addressed: The patent’s background section describes how prior art vehicle safety systems using accelerometers were unreliable. They struggled to distinguish between actual vehicle acceleration/deceleration and the effects of gravity when a vehicle travels on hills or cambered roads, leading to false alerts or missed detections. (Compl. ¶¶ 22-23; ’769 Patent, col. 2:3-17). This limitation reduced their effectiveness as early warning systems for events like potential collisions. (Compl. ¶24; ’769 Patent, col. 2:18-24).
• The Patented Solution: The invention claims to solve this by using an "accelerometer-gyroscope" sensor combination to detect "absolute levels" of acceleration, thereby decoupling the measurements from gravitational forces. (Compl. ¶31; ’769 Patent, col. 1:34-38). By combining accelerometer data with gyroscopic data that measures inclination, the system can more accurately determine a vehicle's true motion and use that information to control vehicle systems, such as by adjusting the suspension while turning. (Compl. ¶37; ’769 Patent, col. 4:11-15).
• Technical Importance: This approach aimed to create more sensitive and accurate vehicle safety systems, such as anti-rollover and collision avoidance technologies, by filtering out the "gravitational acceleration artifacts" that compromised earlier designs. (Compl. ¶25).

Key Claims at a Glance

• The complaint identifies independent claims 1, 9, and 21 as relevant. (Compl. ¶82).
• Claim 1 (Device):
  • An accelerometer-gyroscope for sensing an absolute lateral acceleration;
  • A suspension selector; and
  • A plurality of controllers for individually controlling one or more suspension systems of the vehicle.
• Claim 9 (System):
  • An accelerometer-gyroscope for sensing an absolute lateral acceleration of the vehicle;
  • A suspension selector that receives a signal from the accelerometer-gyroscope;
  • A plurality of controllers that receive a signal from the suspension selector; and
  • One or more suspension systems that are individually activated by the controllers.
• Claim 21 (Method):
  • Sensing a lateral acceleration of the vehicle at the vehicle;
  • Sending a signal to a plurality of control devices based upon the lateral acceleration; and
  • Adjusting a suspension characteristic of the vehicle based upon the lateral acceleration.
• The complaint notes that dependent claims add further specific features and reserves the right to assert them. (Compl. ¶¶ 83-85).

U.S. Patent No. 8,682,558 - *Absolute Acceleration Sensor For Use Within Moving Vehicles* (Issued Mar. 25, 2014)

The Invention Explained

• Problem Addressed: The technology addresses the same core problem as the ’769 Patent: the inability of prior art systems to account for gravity, grades, or camber, which limited the effectiveness of safety systems. (Compl. ¶118). It also addresses the need to monitor and warn about the degradation of vehicle components, such as suspension shock absorbers, that could lead to accidents if left undetected. (Compl. ¶¶ 126-127).
• The Patented Solution: The invention describes a system where an "accelerometer-gyroscope" sends a signal representing "absolute acceleration" to a "vehicle computer unit" (VCU). The VCU processes this signal to operate one or more vehicle performance systems. (Compl. ¶¶ 116-117; ’558 Patent, Abstract). The VCU can also compare the real-time sensor data to "baseline performance data" to identify performance degradation and issue warnings for issues like low tire pressure or worn shock absorbers. (’558 Patent, col. 4:4-14, claims 23-25).
• Technical Importance: The technology provides a framework not only for real-time vehicle control but also for proactive vehicle health monitoring to prevent accidents caused by component failure. (Compl. ¶124).

Key Claims at a Glance

• The complaint identifies independent claims 1, 11, and 21 as relevant. (Compl. ¶117).
• Claim 1 (Device):
  • An accelerometer-gyroscope;
  • A vehicle computer unit; and
  • An internal warning system, wherein the accelerometer-gyroscope sends a signal to the VCU, which in turn operates one or more vehicle performance systems.
• Claim 11 (System):
  • An accelerometer-gyroscope for sensing an absolute acceleration;
  • A vehicle computer unit that receives a signal from the sensor based on the absolute acceleration;
  • Wherein the VCU operates one or more vehicle performance systems based upon the absolute acceleration.
• Claim 21 (Method):
  • Sensing an absolute acceleration of the vehicle;
  • Sending a signal to a vehicle computer unit based on the absolute acceleration; and
  • Operating one or more vehicle performance systems based on the absolute acceleration.
• The complaint notes the existence of twenty-two dependent claims adding further limitations. (Compl. ¶117).

U.S. Patent No. 9,830,821 - *Absolute Acceleration Sensor For Use Within Moving Vehicles* (Issued Nov. 28, 2017)

• Patent Identification: U.S. Patent No. 9,830,821, Absolute Acceleration Sensor For Use Within Moving Vehicles, issued November 28, 2017. (Compl. ¶145).
• Technology Synopsis: This patent describes a communication system for improving vehicle safety using a pointable range finder to calculate the distance to an object. The system includes a recorder that records an "operation status" if the vehicle enters a "safe-zone threshold" that is dynamic and increases as the vehicle's speed increases. (Compl. ¶¶ 42, 150).
• Asserted Claims: The complaint identifies independent claims 1, 12, and 19, and specifically alleges infringement of at least Claim 12. (Compl. ¶¶ 151, 162).
• Accused Features: Tesla Autopilot is accused of infringing by providing a method that calculates a distance to an object and records an event if the vehicle enters a safe-zone threshold that is set based upon and increases with vehicle speed. (Compl. ¶162).

U.S. Patent No. 10,391,989 - *Absolute Acceleration Sensor For Use Within Moving Vehicles* (Issued Aug. 27, 2019)

• Patent Identification: U.S. Patent No. 10,391,989, Absolute Acceleration Sensor For Use Within Moving Vehicles, issued August 27, 2019. (Compl. ¶176).
• Technology Synopsis: This patent is directed to an anti-rollover system. An accelerometer detects a vehicle's lateral acceleration, and if it exceeds a threshold, a control device sends a signal to a speed reduction circuit to reduce the vehicle's speed "based on a heading of the vehicle." (Compl. ¶¶ 56, 181). The complaint includes a block diagram from the patent illustrating a system where an accelerometer input leads to a speed reduction output. (Compl. ¶58, Fig. 25).
• Asserted Claims: The complaint identifies independent claims 1, 9, and 20, and specifically alleges infringement of at least Claim 9. (Compl. ¶¶ 182, 190).
• Accused Features: Tesla Traction and Stability Control is accused of infringing by providing a method that detects lateral acceleration and reduces vehicle speed based on the vehicle's heading when a threshold is exceeded. (Compl. ¶190).

U.S. Patent No. 10,410,520 - *Absolute Acceleration Sensor For Use Within Moving Vehicles* (Issued Sep. 10, 2019)

• Patent Identification: U.S. Patent No. 10410520, Absolute Acceleration Sensor For Use Within Moving Vehicles, issued September 10, 2019. (Compl. ¶204).
• Technology Synopsis: This patent describes a system that uses a vehicle speed sensor and a range finder to determine if a vehicle is a safe distance from an object. The "safe distance is determined according to a constant value defined according to the speed of the vehicle and the distance between the vehicle and the object." (Compl. ¶¶ 209, 210). A diagram from the patent shows a range finder and vehicle speed sensor providing input to a control device. (Compl. ¶46, Fig. 14).
• Asserted Claims: The complaint identifies independent claims 1, 12, and 22, and specifically alleges infringement of at least Claim 12. (Compl. ¶¶ 210, 221).
• Accused Features: Tesla Autopilot is accused of infringing by providing a method for determining a safe distance from an object based upon a constant value defined according to the vehicle's speed and distance to the object. (Compl. ¶221).

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 features incorporated into certain Tesla vehicles. (Compl. ¶73).

Functionality and Market Context

The complaint alleges the technical operation of these features maps onto the patent claims.

• Tesla Adaptive Suspension Damping is alleged to control vehicle performance by continuously updating suspension based on sensed lateral acceleration during cornering. (Compl. ¶¶ 96-97).
• Tesla Autopilot is alleged to perform methods for maintaining safe following distances by calculating distance to objects and making decisions based on speed-dependent thresholds. (Compl. ¶¶ 162, 221).
• Tesla Traction and Stability Control is alleged to monitor for unsafe lateral acceleration and reduce vehicle speed based on the vehicle’s heading to prevent instability or rollovers. (Compl. ¶190).
• These features are central to the marketing and function of modern advanced vehicles, positioned as enhancing both safety and performance. The complaint references Tesla's owner's manuals as instructing customers on how to use these features. (Compl. ¶74).

IV. Analysis of Infringement Allegations

’769 Patent Infringement Allegations

The complaint alleges infringement of at least method Claim 21 by Tesla's provision of its Adaptive Suspension Damping system. (Compl. ¶97).

Claim Element (from Independent Claim 21)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of controlling the performance characteristics of a vehicle, comprising: sensing a lateral acceleration of the vehicle at the vehicle;	Defendant's system provides a method for controlling performance characteristics by sensing the vehicle's lateral acceleration.	¶97	col. 4:18-22
sending a signal to a plurality of control devices based upon the lateral acceleration of the vehicle; and	The system sends a signal to control devices based upon the sensed lateral acceleration.	¶97	col. 11:45-52
adjusting a suspension characteristic of the vehicle based upon the lateral acceleration of the vehicle.	The system adjusts a suspension characteristic of the vehicle based on the lateral acceleration signal.	¶97	col. 4:11-15

Identified Points of Contention

• Scope Questions: A central question may be whether the sensor systems in Tesla vehicles perform the function of sensing "absolute lateral acceleration" by decoupling gravitational forces as taught by the patent, or if they use a different technical method to achieve a similar result. The complaint's diagrams show the combination of an accelerometer and a gyroscope to account for inclination. (Compl. ¶35, Figs. 1B and 2C).
• Technical Questions: The infringement analysis may turn on evidence demonstrating that Tesla's system architecture contains a "suspension selector" and a "plurality of controllers" that function in the manner recited in claims 1 and 9, which the complaint also discusses. (Compl. ¶82).

’558 Patent Infringement Allegations

The complaint alleges infringement of at least method Claim 21 by Tesla's provision of its Adaptive Suspension Damping system. (Compl. ¶131).

Claim Element (from Independent Claim 21)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method of monitoring and controlling the performance characteristics of a vehicle, comprising: sensing an absolute acceleration of the vehicle at the vehicle;	The accused system includes an accelerometer-gyroscope for sensing an absolute acceleration of the vehicle.	¶131	col. 3:63-67
sending a signal to a vehicle computer unit based upon the absolute acceleration of the vehicle; and	The system's sensor sends a signal based upon the absolute acceleration to a vehicle computer unit.	¶131	col. 4:8-10
operating one or more vehicle performance systems based upon the absolute acceleration of the vehicle.	The vehicle computer unit operates one or more vehicle performance systems based upon the received signal.	¶131	col. 4:10-14

Identified Points of Contention

• Scope Questions: A potential dispute may arise over the definition of "vehicle computer unit." Defendant could argue its distributed processing architecture does not map onto the singular "VCU" structure described in the patent's embodiments. (Compl. ¶40, Fig. 3A, item 340 "Control Device").
• Technical Questions: An evidentiary question may be whether Tesla's system specifically senses "absolute acceleration" (as opposed to another motion parameter) and whether the operation of the performance systems is "based upon" that specific signal as required by the claim.

V. Key Claim Terms for Construction

"accelerometer-gyroscope" (’769 Claim 1; ’558 Claim 1)

• Context and Importance: This term defines the core sensor technology claimed to be inventive. Its construction is critical because the infringement analysis will depend on whether Tesla’s sensor suite constitutes an "accelerometer-gyroscope" as contemplated by the patents. Practitioners may focus on this term to dispute whether a collection of separate sensors working together meets the limitation, or if a single integrated unit is required.
• Evidence for a Broader Interpretation: The specification describes the use of an accelerometer "in conjunction with" a gyroscope, suggesting a functional relationship rather than a mandatory physical integration. (Compl. ¶33; ’769 Patent, col. 4:22-26).
• Evidence for a Narrower Interpretation: The claims use the hyphenated term "accelerometer-gyroscope," and the patents’ block diagrams label a single box as the "Accelerometer-Gyroscopic Sensor," which may suggest a single, combined component. (Compl. ¶40, Fig. 3A, item 310; ’769 Patent, col. 11:37-38).

"absolute lateral acceleration" (’769 Claim 1)

• Context and Importance: This term is central to the patents' asserted novelty over prior art that was allegedly confounded by gravitational forces. The definition of "absolute" will be a key battleground in determining both infringement and validity.
• Evidence for a Broader Interpretation: The specification defines the invention in terms of a general goal: "detecting absolute levels of longitudinal, lateral and vertical acceleration" to solve the problem of gravitational artifacts, suggesting any measurement that achieves this goal could be considered "absolute." (’769 Patent, col. 1:34-38).
• Evidence for a Narrower Interpretation: The detailed description explains specific sensor orientations and combinations (e.g., a gyroscope mounted parallel to the pitch-yaw plane to sense lateral inclination) to achieve the measurement, which could be used to argue for a narrower construction tied to these specific embodiments. (Compl. ¶36; ’769 Patent, col. 5:27-35).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all five patents. The inducement allegations are based on claims that Tesla instructs customers on how to use the accused features through its website, owner's manuals, and other promotional materials. (Compl. ¶¶ 100-101, 134-135, 165-166, 193-194, 224-225).
• Willful Infringement: Willfulness is alleged for all five patents. The allegations are primarily based on Defendant's alleged continued infringement after being made aware of the patents through the filing of the original complaint. The complaint also alleges a "policy or practice of not reviewing the patents of others" as evidence of willful blindness. (Compl. ¶¶ 105-107, 139-141, 170-172, 198-200, 229-231).

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

• A core issue will be one of definitional scope: can terms like "accelerometer-gyroscope" and "absolute... acceleration," which are central to the patents' claims of novelty, be construed to read on the specific sensor hardware, software, and data processing methods used in Tesla's vehicle control systems?
• A key evidentiary question will be one of technical mapping: does the operational logic of Tesla's Autopilot, Adaptive Suspension, and Traction Control systems perform the specific steps recited in the asserted method claims? For example, does Autopilot's following-distance logic implement a "safe-zone threshold" that "increases as the speed of the vehicle increases" in the manner claimed by the ’821 patent?
• A third question may concern architectural equivalence: do the patents’ descriptions of discrete components like a "vehicle computer unit" or "suspension selector" correspond to the potentially more integrated and distributed computing architecture within Tesla’s vehicles, or is there a fundamental mismatch that places the accused systems outside the scope of the claims?