DCT
2:25-cv-01005
Context Directions LLC v. Gulliver USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Context Directions LLC (Delaware)
- Defendant: Gulliver USA, Inc. (California)
- Plaintiff’s Counsel: Direction IP Law
- Case Identification: 2:25-cv-01005, E.D. Tex., 10/03/2025
- Venue Allegations: Venue is based on Defendant maintaining a place of business in the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that advanced driver-assistance systems in numerous used vehicles sold by Defendant infringe two patents related to hierarchical, energy-efficient methods for sensor-based context detection.
- Technical Context: The technology addresses power consumption in devices with multiple sensors by activating them in a tiered sequence, a significant challenge in battery-powered electronics and complex sensor systems.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2012-02-17 | Priority Date for ’564 and ’791 Patents |
| 2017-10-31 | U.S. Patent No. 9,807,564 Issues |
| 2018-11-27 | U.S. Patent No. 10,142,791 Issues |
| 2025-10-03 | 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. 9807564, issued October 31, 2017.
The Invention Explained
- Problem Addressed: The patent's background describes the problem of high energy consumption in mobile devices that use sensors to determine their context (e.g., being in a moving vehicle). Prior methods that continuously analyzed signals from multiple sensors or used power-intensive sensors like GPS would quickly drain a device's battery (’564 Patent, col. 2:10-21).
- The Patented Solution: The invention proposes a hierarchical method to conserve power. Sensors are organized into groups from lowest-level (less power, less certainty) to highest-level (more power, more certainty). The system first "activates" the lowest-level group. Only if that group returns a positive result for a specific context does the system then activate the next group up in the hierarchy. This avoids needlessly powering higher-energy sensors (’564 Patent, col. 4:5-15). Furthermore, the results from the higher-level, more accurate sensors are used to "adapt the configuration" of the lower-level classifiers, effectively training them to be more accurate over time (’564 Patent, col. 4:15-19; Fig. 2).
- Technical Importance: This tiered activation and adaptation approach provides a framework for context-aware computing that is more energy-efficient than continuous, parallel sensor analysis, which was a critical consideration for battery-powered mobile electronics (’564 Patent, col. 1:41-45).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a device) and 23 (a method).
- Claim 1 (device) requires:
- A mobile device with a plurality of sensors arranged in a hierarchy of sensor groups.
- A plurality of classifiers, each assigned to a sensor group.
- A context detection module configured to:
- Activate a classification by a classifier for a first, lowest-level sensor group.
- Activate a classification by a classifier for a second, higher-level sensor group after a result from the first group.
- Adapt the configuration of the first group's classifier based on the result from 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. 10142791, issued November 27, 2018.
The Invention Explained
- Problem Addressed: The ’791 Patent shares an identical specification with the ’564 Patent and therefore addresses the same problem of excessive power consumption in sensor-based context detection systems (Compl. ¶26; ’791 Patent, col. 2:10-21).
- The Patented Solution: The solution is the same hierarchical sensor activation and classifier adaptation method described in the ’564 Patent, aimed at improving energy efficiency (’791 Patent, col. 4:5-19).
Key Claims at a Glance
- The complaint asserts independent claim 1 (a device).
- Claim 1 (device) requires:
- A mobile device with a plurality of sensors arranged in a hierarchy of sensor groups.
- A plurality of classifiers, each assigned to a sensor group.
- The mobile device being configured to:
- Activate a classification by a classifier for a first, lowest-level sensor group.
- Activate a classification by a classifier for a second, higher-level sensor group after a result from the first group.
- Adapt the configuration of the first group's classifier based on the result from the second group's classifier.
III. The Accused Instrumentality
Product Identification
A wide range of used Nissan, Toyota, and Lexus vehicles from model years 2015 through 2025, referred to as the "Accused Instrumentalities" (Compl. ¶14, ¶27).
Functionality and Market Context
- The complaint alleges that the vehicles' advanced driver-assistance systems (ADAS) and safety features embody the infringing technology (Compl. ¶¶15-17). These features include pre-collision systems, dynamic radar cruise control, lane departure alert with steering assist, and lane tracing assist (Compl. ¶17).
- The complaint frames the entire vehicle as the "mobile device" (Compl. ¶15). It alleges that sensors such as those for steering, braking, and speed form a first sensor group (Group 1), while camera and radar sensors form a second, higher-level group (Group 2) (Compl. ¶16). The alleged infringement occurs when Group 1 sensors are used to control the moving vehicle, and Group 2 sensors are then activated to monitor the surrounding environment and provide feedback that modifies the vehicle's movement (Compl. ¶¶17, 19).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’564 Patent Infringement Allegations (based on Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A mobile device, comprising: a plurality of sensors and a plurality of sensor groups... arranged according to a hierarchy | The accused vehicle is the "mobile device," with sensors like steering, braking, and speed sensors in "Group 1" and camera and radar sensors in "Group 2" (Compl. ¶15, ¶16). | ¶16 | col. 4:8-10 |
| activate a classification by a classifier assigned to a first sensor group... at a lowest level in the hierarchy | The steering, braking, and speed sensors (Group 1) are allegedly activated first to measure and control the vehicle's movement (Compl. ¶17). | ¶17 | col. 14:56-59 |
| activate a classification by a classifier assigned to a second sensor group... after a result of the classification by the classifier assigned to the first sensor group | Once the vehicle is moving (i.e., after Group 1 is active), the camera and radar (Group 2) are activated to monitor surrounding objects (Compl. ¶17). | ¶17 | col. 14:61-64 |
| adapt a configuration of the classifier assigned to the first sensor group based, at least in part, on a result of the classification by the classifier assigned to the second sensor group | Information from the camera and radar (Group 2) "teaches" the steering, speed, and braking sensors (Group 1) to control the vehicle's motion, such as by changing lanes or adjusting speed (Compl. ¶19). | ¶19 | col. 14:65-67 |
- Identified Points of Contention:
- Scope Question: A primary issue may be whether the term "mobile device" can be construed to cover an entire automobile. The patent specification's background and examples focus exclusively on problems of small, battery-powered personal electronics like phones and PDAs, raising the question of whether the invention's scope extends to vehicles with fundamentally different power sources and architectures (’564 Patent, col. 1:30-34).
- Technical Question: The complaint’s infringement theory appears to describe a logical sequence of operations, whereas the patent heavily emphasizes a physical sequence of powering sensors on and off to conserve energy. A potential point of contention is whether the accused systems "activate" sensor groups by changing their power state, as the patent specification suggests is the purpose of the hierarchy, or if all sensors are continuously powered when the vehicle is on, which may not align with the patented method’s energy-saving goal (’564 Patent, col. 4:47-52).
- Technical Question: It is an open question whether the real-time feedback in an ADAS (e.g., radar data causing brakes to be applied) meets the claim limitation of "adapting a configuration of the classifier." The patent describes a machine-learning process where the underlying classification model is updated over time, which may differ from the direct, rule-based control feedback alleged in the complaint (’564 Patent, col. 13:3-12).
V. Key Claim Terms for Construction
The Term: "mobile device"
- Context and Importance: The applicability of the patents to the accused automobiles hinges on the construction of this term. The defendant may argue it is limited to small, portable, battery-powered electronics.
- Intrinsic Evidence for a Broader Interpretation: The term itself is not explicitly limited in the claims, and the specification lists examples "such as mobile phones, laptops, PDAs, tablets, watches, music players," which does not foreclose other possibilities (’564 Patent, col. 1:30-33).
- Intrinsic Evidence for a Narrower Interpretation: The patent’s background section is entirely devoted to the problems of portable devices with small batteries, stating that power consumption can reduce operating time "to such levels that are unacceptable to the user" (’564 Patent, col. 2:13-15). This context may support an interpretation limited to devices where battery conservation is a primary design constraint.
The Term: "activate a classification"
- Context and Importance: This term is central to the infringement analysis, as it distinguishes between a logical process flow and a physical power-state change. The complaint's theory appears to rely on the former.
- Intrinsic Evidence for a Broader Interpretation: The term could be interpreted to mean initiating a data processing step, regardless of the hardware's power state.
- Intrinsic Evidence for a Narrower Interpretation: The specification repeatedly links activation to power management, describing "switching on power supply of the sensors" and changing a sensor's mode "from a more energy efficient to a less energy efficient" one (’564 Patent, col. 4:11-13, 4:47-52). This suggests "activate" requires a change in power consumption.
The Term: "adapt a configuration of the classifier"
- Context and Importance: This term distinguishes between a simple real-time control loop and the adaptive learning process described in the patent. Practitioners may focus on whether the accused ADAS systems "learn" or are merely executing pre-programmed instructions.
- Intrinsic Evidence for a Broader Interpretation: One could argue that any modification to the behavior of the first sensor group based on input from the second group constitutes an "adaptation."
- Intrinsic Evidence for a Narrower Interpretation: The patent details a specific mechanism for adaptation involving updating sets of "positive patterns" and "negative patterns" based on feedback from higher-level classifiers, which mirrors a machine-learning training process (’564 Patent, Fig. 5; col. 13:3-12). This may support a narrower construction requiring a change to the underlying classification algorithm, not just an instantaneous response to new data.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, stating Defendant provides the accused vehicles and advertises their features, thereby encouraging and instructing customers to use them in an infringing manner (Compl. ¶¶15-19, 20).
- Willful Infringement: Willfulness is alleged based on knowledge of the patents obtained "At least as early as the filing of the Complaint" (Compl. ¶20, ¶28). The allegations support a claim for post-suit willful infringement but do not plead facts suggesting pre-suit knowledge.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "mobile device," as defined and used in a patent focused on conserving battery life in portable electronics, be construed to encompass a modern automobile, which operates on a fundamentally different power scale?
- A key evidentiary question will be one of technical operation: do the accused vehicle systems "activate" sensors by cycling their power state to save energy as described in the patent, or does the complaint's allegation of a logical data-processing sequence suffice to meet a claim limitation rooted in power conservation?
- The case may also turn on the distinction between control and learning: does the real-time operational feedback within the accused driver-assistance systems constitute "adapting a configuration of the classifier" in the machine-learning sense taught by the patent, or is there a fundamental mismatch in how the patented invention and the accused systems function?