Driving Innovation LLC v. Toyota Motor North America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Driving Innovation LLC (Delaware)
  • Defendant: Toyota Motor North America, Inc. (California)
  • Plaintiff’s Counsel: Brown Rudnick LLP
• Case Identification: 2:25-cv-01084, E.D. Tex., 11/20/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a "regular and established place of business" at its North American headquarters in Plano, Texas, where it employs thousands and conducts business related to the accused products.
• Core Dispute: Plaintiff alleges that Defendant’s in-vehicle navigation, audio-visual, and user profile systems infringe four U.S. patents related to location-based mobile services, user-adaptive systems, in-vehicle audio control, and navigation display methods.
• Technical Context: The technologies at issue concern in-vehicle infotainment (IVI) and navigation systems, which are central to the modern automotive user experience, connectivity, and vehicle personalization.
• Key Procedural History: The complaint notes that Defendant has previously admitted or not contested personal jurisdiction in the Eastern District of Texas in prior litigation, referencing Fundamental Innovation Sys. Int'l LLC v. Toyota Motor Corp.

Case Timeline

Date	Event
2000-08-07	U.S. Patent No. 7,742,610 Priority Date
2000-10-11	U.S. Patent No. 7,003,288 Priority Date
2001-05-21	U.S. Patent No. 7,454,545 Priority Date
2006-02-21	U.S. Patent No. 7,003,288 Issued
2007-03-23	U.S. Patent No. 8,467,962 Priority Date
2008-11-18	U.S. Patent No. 7,454,545 Issued
2010-06-22	U.S. Patent No. 7,742,610 Issued
2013-06-18	U.S. Patent No. 8,467,962 Issued
2025-11-20	First Amended Complaint Filed

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

U.S. Patent No. 7,003,288 - “Mobile Communication Terminal”

Issued February 21, 2006

The Invention Explained

• Problem Addressed: The patent’s background section describes the limitations of prior art location-based services, which required time-consuming manual retrieval of information, could not provide dynamically updated content (e.g., daily gas prices), or wasted communication resources by continuously transmitting the user's location to a central server (’288 Patent, col. 2:7-67).
• The Patented Solution: The invention discloses a system where a mobile terminal receives an "information source and distribution condition list" from a central server. This list associates information sources (e.g., websites) with specific geographic conditions (e.g., a distribution radius around a coordinate). The mobile terminal then locally and automatically verifies its own position and movement against these pre-downloaded conditions. Only when a condition is met does the terminal access the corresponding information source to retrieve and present the relevant content, thereby minimizing network traffic. (’288 Patent, Abstract; col. 3:13-42).
• Technical Importance: This method was designed to enable the efficient and automatic delivery of dynamic, location-relevant information to mobile devices by shifting the verification logic from a central server to the terminal itself, conserving bandwidth in an era of more limited mobile data capabilities (’288 Patent, col. 2:56-67).

Key Claims at a Glance

• The complaint alleges infringement of an exemplary claim of the ’288 Patent in its Exhibit E, but does not identify the specific independent claim(s) asserted in the body of the complaint (Compl. ¶31). Assuming Claim 1 is asserted as representative, its essential elements include:
  • A communicating unit for communicating with an information source.
  • A processing unit for verifying the terminal's behavior (including location) against conditions in a received "information source and distribution condition list."
  • The processing unit accesses the verified information source.
  • A presenting unit presents the information received from the source.
• The complaint reserves the right to provide greater detail and scope in future filings (Compl. ¶31).

U.S. Patent No. 7,454,545 - “Individual-adaptive system and information distribution device based on a cellular telephone”

Issued November 18, 2008

The Invention Explained

• Problem Addressed: The patent addresses the inconvenience users face with shared devices, such as in-vehicle navigation systems, where settings (e.g., map colors, startup screens) changed by one user require subsequent users to manually restore their own preferences (’545 Patent, col. 1:39-49).
• The Patented Solution: The invention proposes an "individual-adaptive system" that automatically personalizes a device's settings. An "individual identification section" within the device (e.g., a car navigation system) receives a unique identifier from a user's portable item, such as a cellular phone. The system then uses this identifier to retrieve a corresponding user profile and automatically apply the stored settings, such as a preferred startup screen or map color palette. (’545 Patent, Abstract; col. 2:9-20).
• Technical Importance: The technology aimed to automate the personalization of shared in-vehicle systems by linking device settings to a portable, personal identifier that a user would typically carry, enhancing convenience and creating a seamless user experience (’545 Patent, col. 2:49-54).

Key Claims at a Glance

• The complaint alleges infringement of an exemplary claim of the ’545 Patent in its Exhibit F, without specifying the independent claim(s) asserted in the complaint body (Compl. ¶35). Assuming Claim 1 is asserted as representative, its essential elements include:
  • An individual identification section connectable to a cellular telephone for inputting unique individual identification information from the phone.
  • The individual identification section determines a "setting status" of a device based on the identification information.
  • An operation control section controls the device's setting status based on the determination.
• The complaint reserves the right to provide greater detail and scope in future filings (Compl. ¶35).

U.S. Patent No. 7,742,610 - “Automobile Audiovisual System”

Issued June 22, 2010

• Technology Synopsis: This patent addresses the difficulty a driver faces when trying to communicate with rear-seat passengers who are wearing headphones and listening to audio (’610 Patent, col. 2:25-30). The patented solution is an automobile audiovisual system wherein an operating means, accessible to the driver, generates a control signal that temporarily attenuates or replaces the audio signal being sent to the rear-seat headphones, thereby facilitating communication without requiring passengers to remove their headphones (’610 Patent, Abstract).
• Asserted Claims: The complaint refers to an exemplary claim chart in Exhibit G but does not specify the claims asserted (Compl. ¶39).
• Accused Features: The allegations appear directed at the "Toyota/Lexus Rear-Seat Entertainment System" (Compl. ¶25).

U.S. Patent No. 8,467,962 - “Navigation System and Lane Information Display Method”

Issued June 18, 2013

• Technology Synopsis: This patent addresses potentially confusing lane guidance displays in navigation systems, particularly at complex highway interchanges where on-screen arrows may not intuitively match the driver's perception of the road geometry (’962 Patent, col. 2:1-9). The invention is a method that determines the direction for lane guidance arrows by using road attributes (e.g., "highway," "ramp") in addition to physical geometry, with the goal of creating a lane guide map that "meets users' feeling" (’962 Patent, Abstract).
• Asserted Claims: The complaint refers to an exemplary claim chart in Exhibit H but does not specify the claims asserted (Compl. ¶43).
• Accused Features: The allegations target various Toyota navigation platforms, including "Dynamic Navigation," "Toyota Integrated Navigation System," and "Toyota Entune Dynamic Navigation" systems (Compl. ¶25).

III. The Accused Instrumentality

Product Identification

The accused products include, without limitation: "TMNA's navigation computers and associated software and hardware modules, User Profile System, onboard Audio-Visual System, and 'Entune Navigation System'" (Compl. ¶24). The complaint further identifies "all series of Dynamic Navigation, Toyota Integrated Navigation System, Toyota/Lexus User Profile System, Toyota/Lexus Rear-Seat Entertainment System, and Toyota Entune Dynamic Navigation platforms" (Compl. ¶25).

Functionality and Market Context

The complaint describes the accused instrumentalities as systems that "combine car navigation with advanced features, audio visual control components, and interaction with a user's mobile device" (Compl. ¶24). Based on the product categories named, the accused functionalities include providing route guidance and lane information (Navigation Systems), managing in-vehicle media for front and rear passengers (Audio-Visual and Rear-Seat Entertainment Systems), and storing and applying personalized vehicle settings (User Profile System). The complaint does not provide specific details on the market positioning of these systems beyond their inclusion in vehicles from Toyota-managed brands (Compl. ¶1).

IV. Analysis of Infringement Allegations

The complaint alleges that representative claim charts for each of the Patents-in-Suit are attached as Exhibits E-H (Compl. ¶23). However, because these exhibits were not provided with the complaint, the specific narrative infringement theories for each patent cannot be summarized.

The complaint does not provide sufficient detail for analysis of infringement allegations.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

’288 Patent

• The Term: "information source and distribution condition list"
• Context and Importance: This term defines the core data structure that enables the invention's efficiency. The infringement analysis for the ’288 patent may hinge on whether the architecture of Toyota's location-based services can be characterized as using such a "list" that is transmitted to the terminal for local processing.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the list as data that "associates a location on the network of an information source... with distribution conditions" (’288 Patent, col. 3:24-29). Practitioners may argue this language is broad enough to cover various data formats that link content to geographic triggers.
  • Evidence for a Narrower Interpretation: Figures 5 and 6 depict specific, table-like data structures with fields for "distribution radius" and "bearing angle." This could support an argument that the term is limited to a pre-compiled, structured file downloaded for verification on the terminal, as distinct from a system based on real-time server queries.

’545 Patent

• The Term: "determining setting status of a device"
• Context and Importance: This term describes the action the system takes after identifying the user. The dispute may focus on what level of system modification is required to meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract states the system "determines a setting status of a device in accordance with the input individual identification information." This could be argued to cover any automatic system change, however minor, that is linked to the user's ID.
  • Evidence for a Narrower Interpretation: The background section explicitly discusses changing a "startup screen" or "map color" to meet a "user's preference" (’545 Patent, col. 1:26-35). This context may support a narrower construction requiring a substantive change to the device's operational or aesthetic configuration, rather than merely displaying identifying information like a user's name.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induced infringement by its customers through its development, manufacturing, and sale of the Accused Products in the United States (Compl. ¶26).
• Willful Infringement: The complaint alleges that Defendant has knowingly infringed since at least the date of the original complaint for the ’288, ’545, and ’610 patents, and since the date of the First Amended Complaint for the ’962 patent, forming the basis for a willfulness claim (Compl. ¶¶26-27).

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

The resolution of this case may turn on several key technical and legal questions for the court to decide:

• A core issue will be one of architectural interpretation: Does the method by which Toyota's modern, cloud-connected infotainment systems deliver location-based content align with the specific architecture of the ’288 patent, which describes a terminal locally processing a pre-defined "distribution condition list"?
• Another central question will be one of functional scope: For the ’545 patent, does the act of a vehicle system recognizing a connected smartphone and displaying associated data (e.g., a user's name) constitute "determining [the] setting status of a device" as envisioned by the patent, or is a more comprehensive personalization of the vehicle's core functions required to infringe?
• A primary evidentiary question, arising from the complaint's reliance on un-provided exhibits, will be whether Plaintiff’s forthcoming infringement contentions can present sufficient technical evidence to map the specific, and likely complex, software operations of the various accused Toyota systems to the discrete elements of the asserted patent claims.