Peregrine Data LLC v. Verizon Communications Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (New Mexico)
  • Defendant: Verizon Communications Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01013, E.D. Tex., 10/07/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that unspecified products from Defendant infringe a patent related to vehicle-mounted, multi-camera systems for continuously recording a vehicle's perimeter for evidentiary purposes.
• Technical Context: The technology addresses systems, often known as dashcams or surround-view monitors, that capture and store video from multiple viewpoints around a vehicle to create a record of driving events like accidents or other incidents.
• Key Procedural History: The asserted patent claims priority to an application filed in 2004, reflecting an earlier generation of this technology. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2004-04-15	’619 Patent Priority Date
2010-03-12	’619 Patent Application Filing Date
2012-11-27	’619 Patent Issue Date
2025-10-07	Complaint Filing Date

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

U.S. Patent No. 8,319,619 - Stored vision for automobiles

• Patent Identification: U.S. Patent No. 8,319,619, "Stored vision for automobiles," issued November 27, 2012. (Compl. ¶9).

The Invention Explained

• Problem Addressed: The patent's background describes the difficulty in obtaining reliable, objective evidence following vehicle accidents, crimes, or other road incidents, noting the scarcity of credible witnesses and the danger posed by drivers attempting to manually record events while operating a vehicle (’619 Patent, col. 1:18-35). A stated priority is allowing the driver to focus on "DRIVING THE VEHICLE CORRECTLY AND SAFELY" without distraction (’619 Patent, col. 1:30-31).
• The Patented Solution: The invention proposes a system of multiple cameras positioned around the vehicle's perimeter to provide a 360-degree view (’619 Patent, col. 3:41-43). These cameras continuously capture and transmit image data to a central digital recorder, which stores the footage from each camera on separate tracks or in separate files for later, off-line retrieval and analysis (’619 Patent, Abstract; col. 2:38-44). The system is designed to be automatic and inaccessible to the driver while driving, thereby preventing distraction (’619 Patent, col. 2:54-57).
• Technical Importance: The described method aims to create a comprehensive and tamper-evident record of events surrounding a vehicle, intended to improve the efficiency and accuracy of legal and insurance investigations following an incident (’619 Patent, col. 1:12-14).

Key Claims at a Glance

The complaint does not specify which claims are asserted, referring only to "exemplary method claims" identified in an unattached exhibit (Compl. ¶11, ¶13). The patent contains two independent method claims, Claim 1 and Claim 2.

• Independent Claim 1:

  • Placing a plurality of cameras in circumferentially spaced positions around a vehicle's periphery with fields of view directed outwardly.
  • Activating all cameras to operate continuously throughout an entire trip.
  • Recording images from each camera into a corresponding separate file.
  • Using separate files and "separate node files" to provide eight separate files of real-time recorded data.
  • Using the cameras as a "set, not a combination," with each operating separately.
  • Locating the apparatus so it is "inaccessible to a driver throughout the entire trip."

• Independent Claim 2:

  • Positioning a plurality of cameras in a circumferentially spaced relationship around the vehicle's periphery.
  • Selecting a digital recording medium with separate tracks and positioning it in a secure location.
  • Continuously energizing the cameras and recording medium throughout a trip to acquire and convert images into electrical information on the separate tracks.
  • Using the cameras as a "set, not a combination," with each camera's data recorded and recovered from a separate track.
  • Arranging the apparatus to be "inaccessible to the driver... while the driver is driving."
  • Retrieving the recorded electrical information after the trip to reconstitute image sequences.

The complaint makes no explicit reservation of rights to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products or services by name. It refers to "Exemplary Defendant Products" that are purportedly detailed in "charts incorporated into this Count" (Compl. ¶11), which are cited as "Exhibit 2" (Compl. ¶13), but this exhibit was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '619 Patent" and "satisfy all elements of the Exemplary '619 Patent Claims" (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that "Exhibit 2 includes charts comparing the Exemplary '619 Patent Claims to the Exemplary Defendant Products" (Compl. ¶13), but this exhibit is not publicly available. In lieu of a claim chart summary, the narrative infringement theory is that the unspecified "Exemplary Defendant Products" practice the claimed technology and therefore satisfy all elements of the asserted claims (Compl. ¶13). The complaint does not provide any specific facts detailing how any accused product meets any specific claim limitation.

• Identified Points of Contention: Based on the patent’s claims and the general nature of the technology, several points of contention may arise during litigation.
  • Scope Questions: A central dispute may concern the meaning of "operate continuously throughout an entire trip" (Claim 1). This raises the question of whether the claim reads on modern systems that may enter a standby mode or use buffered recording that only permanently saves data upon sensing an event (e.g., via an accelerometer), a feature the patent appears to distinguish itself from (’619 Patent, col. 2:26-29).
  • Technical Questions: A key technical question will be whether the accused products record data in "a corresponding separate file" for each camera (Claim 1) or on "separate recording tracks" (Claim 2). The complaint provides no information on the data architecture of the accused products, leaving open the question of whether modern systems that may multiplex video streams into a single container file meet this limitation. Another question is what factual basis exists for the allegation that the accused apparatus is "inaccessible to the driver" while driving, as required by both independent claims.

V. Key Claim Terms for Construction

• The Term: "inaccessible to the driver... while driving the automobile" (Claim 1(f); Claim 2(g)).

• Context and Importance: This term is critical as it relates directly to the patent's stated objective of preventing driver distraction. Its construction will determine whether the claims cover systems with integrated displays or controls that are merely disabled or show non-interactive information while the vehicle is in motion, versus systems that are physically out of the driver's reach.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that "inaccessible" means functionally inaccessible for the purpose of manual recording or operation, and that a system with an automatically disabled user interface meets this limitation even if physically present on the dashboard.
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes preventing any distraction, stating it is preferred to locate the apparatus "in such a way that it cannot distract the driver" (’619 Patent, col. 2:55-56) and is "preferably inacessible to the driver while driving" (’619 Patent, col. 5:53-56). This language may support a construction requiring physical separation or the complete absence of any driver-facing interface for the recording system.

• The Term: "operate continuously throughout an entire trip" (Claim 1(b)).

• Context and Importance: This limitation distinguishes the invention from event-triggered recorders. The definition of "continuously" will be pivotal in determining whether systems that employ loop recording with event-based data preservation infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: An argument could be made that a system that is always powered on and actively monitoring/buffering video is "operating continuously," even if it only permanently writes to storage upon a trigger.
  • Evidence for a Narrower Interpretation: The specification states the method will "capture an entire collision, road rage incident, or fender bender" and that data is transmitted on a "continuous and concurrent basis" to the recording medium (’619 Patent, col. 2:7-9; col. 2:38-41). This supports a reading that requires uninterrupted data recording for the duration of a trip, not merely continuous system operation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges only "Direct Infringement" in its single count for infringement and does not plead the required elements for induced or contributory infringement (Compl. ¶11).
• Willful Infringement: The complaint does not use the term "willful" or allege that Defendant had any pre-suit knowledge of the ’619 Patent. The prayer for relief requests that the case be declared "exceptional" for the purpose of attorney's fees under 35 U.S.C. § 285 but does not explicitly request enhanced damages for willful infringement under § 284 (Compl. p. 4).

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

• Evidentiary Sufficiency: The complaint is devoid of factual allegations connecting any specific accused product to the patent's claims. A primary question is whether the plaintiff can substantiate its conclusory infringement allegations with specific evidence mapping product features to the detailed method steps required by the claims, particularly those concerning data architecture and continuous operation.
• Definitional Scope: A core legal issue will be the construction of "inaccessible to the driver." The case may turn on whether this term can be interpreted to cover modern, highly integrated automotive infotainment systems that may perform background recording but are physically present and interactive for other functions, or if it is limited to physically separate, non-interactive "black box" style recorders as contemplated by the patent.
• Technological Mismatch: The patent, with a 2004 priority date, describes a specific data-handling architecture ("separate file" per camera, "separate tracks"). A key technical question will be one of equivalence: does the data management and storage protocol of a modern, sophisticated vehicle system—which may use a single, multiplexed data stream—perform the same function in substantially the same way to achieve the same result as the claimed method, or is there a fundamental difference in technical operation?