DCT

2:26-cv-00028

Integral Wireless Tech LLC v. Luminator Technology Group Global LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00028, E.D. Tex., 01/12/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a principal place of business in the district (Plano, Texas) and is registered to do business in Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s passenger information systems, video surveillance products, and telematics devices infringe six patents related to wireless communication protocols, data processing schemes, and user behavior analysis.
  • Technical Context: The patents-in-suit cover a range of technologies fundamental to modern connected devices, including efficient data transmission in MIMO/OFDM systems, rapid data-set analysis, mobile network handovers, and power management for wireless components.
  • Key Procedural History: The complaint does not mention prior litigation or licensing. Public records attached to U.S. Patent No. 7,269,127 indicate that an Inter Partes Review (IPR) proceeding, IPR2014-01185, resulted in the cancellation of claims 1-10 and 17. The complaint asserts claim 20 of this patent, which was not cancelled in the IPR, raising the question of how the patentability arguments from that proceeding may apply to the asserted claim.

Case Timeline

Date Event
2001-10-04 U.S. Patent No. 7269127 Priority Date
2004-12-20 U.S. Patent No. 10,033,716 Priority Date
2005-06-09 U.S. Patent No. 7,953,411 Priority Date
2007-02-21 U.S. Patent No. 7,707,213 Priority Date
2007-03-20 U.S. Patent No. 8,031,654 Priority Date
2007-09-11 U.S. Patent No. 7,269,127 Issued
2010-04-27 U.S. Patent No. 7707213 Issued
2011-05-31 U.S. Patent No. 7953411 Issued
2011-10-04 U.S. Patent No. 8031654 Issued
2013-05-24 U.S. Patent No. 8,812,888 Priority Date
2014-08-19 U.S. Patent No. 8812888 Issued
2018-07-24 U.S. Patent No. 10033716 Issued
2026-01-12 Complaint Filing Date

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

U.S. Patent No. 7,269,127 - *“Preamble Structures for Single-Input, Single-Output (SISO) and Multi-Input, Multi-Output (MIMO) Communication Systems,” issued September 11, 2007*

The Invention Explained

  • Problem Addressed: The patent addresses the inefficiency of prior art preamble structures, such as that in the IEEE 802.11a standard, when applied to more complex MIMO communication systems. These existing structures were described as having considerable redundancy, reducing system throughput, and not being directly applicable to MIMO without significant modification (’127 Patent, col. 3:1-12).
  • The Patented Solution: The invention proposes a more efficient frame structure for wireless transmissions. This structure includes a preamble with at least one 'training symbol' and an 'enhanced training symbol' (’127 Patent, col. 9:55-66). The key innovation lies in the specific length relationships between different parts of the frame: the training block is an integer fraction of the data block length, and the cyclic prefix (a guard interval) is a fraction of the training block length. This specific structure is designed to enable robust time and frequency synchronization and channel estimation with less overhead than prior methods (’127 Patent, col. 4:30-43; FIG. 6).
  • Technical Importance: By creating a shorter, more efficient preamble structure that is still effective for synchronization and channel estimation, the invention purports to increase the overall data throughput of a wireless system by dedicating less time to overhead and more time to transmitting user data (’127 Patent, col. 13:1-6).

Key Claims at a Glance

  • The complaint asserts independent method claim 20 (Compl. ¶34).
  • Claim 20 recites a method of forming a frame structure, comprising the essential steps of:
    • Providing data blocks and training blocks.
    • Combining them in a parallel format and taking an inverse discrete fourier transform (IDFT).
    • Inserting cyclic prefixes to form parallel symbols, then converting to a serial format to form a preamble and a data structure.
    • The data symbols comprise a cyclic prefix of length G and a data block of length N.
    • The preamble includes an enhanced training symbol comprising a cyclic prefix of length G and a training block of length N₁, where N₁ is defined as N/I (I is an integer) and G is defined as N₁/4.

U.S. Patent No. 7,707,213 - *“Hierarchical Update Scheme for Extremum Location,” issued April 27, 2010*

The Invention Explained

  • Problem Addressed: Finding an extremum (i.e., the maximum or minimum value) in a large data set requires searching the entire set. If one or more data values subsequently change, the entire data set must be searched again to find any new extrema, which is computationally expensive and inefficient (’213 Patent, col. 1:6-15).
  • The Patented Solution: The patent describes a method for organizing data into a hierarchical, tree-like structure. The base level of the hierarchy consists of the original data, divided into small partitions. Each successively higher level stores only the extreme values from the partitions in the level directly below it, culminating in a single extremum at the apex (’213 Patent, col. 2:30-44; FIG. 1A). When a data value at the base level is altered, only the single path from that value up to the apex needs to be re-evaluated, rather than the entire data set, dramatically reducing the computational work required to find a new overall extremum (’213 Patent, col. 3:39-5:4).
  • Technical Importance: This hierarchical update scheme allows for near-instantaneous location of a new extremum in very large data sets that are subject to sparse updates, a common scenario in applications like video encoding or system performance monitoring (’213 Patent, col. 1:16-20).

Key Claims at a Glance

  • The complaint asserts independent method claim 16 (Compl. ¶45).
  • Claim 16 recites a method for generating data, comprising the essential steps of:
    • Partitioning, by a computing device, a base level data set into one or more partitions in memory.
    • Generating, by the computing device, a coarse representation of extrema of each partition by finding and storing the extrema.
    • Updating, by the computing device, the coarse representation if one or more data values are altered.
    • The updating step comprises finding and storing new extrema from the partition(s) that include the altered data values.

U.S. Patent No. 7,953,411 - *“Virtual Soft Hand Over in OFDM and OFDMA Wireless Communication Network,” issued May 31, 2011*

  • Technology Synopsis: The patent describes a "virtual soft handover" (VSHO) mechanism for mobile devices in wireless networks. The technique aims to improve handover quality with reduced complexity by allowing a mobile station to transmit and receive data from only one base station at a time while simultaneously monitoring signals from other nearby base stations in an "active set," enabling a fast switch to a better station without the high overhead of traditional soft handovers (Compl. ¶70).
  • Asserted Claims: At least claim 10 (Compl. ¶73).
  • Accused Features: The complaint alleges that Defendant’s 5G compatible devices, including the Road Runner Pro, infringe the ’411 patent (Compl. ¶66).

U.S. Patent No. 8,031,654 - *“Wireless Communication System, Apparatus for Supporting Data Flow and Methods Therefor,” issued October 4, 2011*

  • Technology Synopsis: The patent addresses inefficiencies in handling acknowledgment (ACK) signals for data transfers using TCP. It proposes a system where the network allocates not only the downlink (DL) resources for sending a data segment to a wireless device, but also pre-allocates sufficient uplink (UL) resources for the device to send back a stand-alone ACK. This allocation is based on a count of data segments transmitted, aiming to reduce the latency associated with the device having to separately request UL resources for the ACK (Compl. ¶¶ 81, 85).
  • Asserted Claims: At least claim 5 (Compl. ¶84).
  • Accused Features: The complaint accuses Defendant’s 5G compatible devices, including the Road Runner Pro, of infringement (Compl. ¶78).

U.S. Patent No. 8,812,888 - *“Systems and Methods for Scanning for A Wake Up Packet Addressed to A Wireless Device,” issued August 19, 2014*

  • Technology Synopsis: The technology relates to a power-saving method for wireless devices. A device in a low-power mode periodically scans wireless channels for a specific "wake-up packet." The key feature is that the scanning is performed only for a predetermined period of time; if the packet is not received within that time, the device ceases scanning to conserve power before potentially resuming later (Compl. ¶¶ 108, 112).
  • Asserted Claims: At least claim 1 (Compl. ¶111).
  • Accused Features: The complaint accuses Defendant’s Bluetooth compatible devices, such as the INFORM Telematics Tablet and Inform Telematics GEOTAB G09, of infringement (Compl. ¶105).

U.S. Patent No. 10,033,716 - *“Method and Device for Publishing Cross-Network User Behavioral Data,” issued July 24, 2018*

  • Technology Synopsis: The patent describes a method for client-side tracking of user web browsing behavior. Software on the user's computer summarizes their interactions across various websites and "publishes" this summarized behavioral data to a local memory structure (e.g., a cookie). A server can then access this data when the user visits an authorized domain to deliver customized messages or advertisements (Compl. ¶¶ 119, 122).
  • Asserted Claims: At least claim 1 (Compl. ¶121).
  • Accused Features: The complaint alleges that Defendant performs a computer-implemented method involving a server and client computer, suggesting infringement by Defendant’s websites and portals (Compl. ¶¶ 23, 122).

III. The Accused Instrumentality

Product Identification

The accused products comprise a wide range of Defendant’s offerings, including but not limited to the RoadRunner series of video recorders and cameras, the Apollo RoadRunner 4K Recorder, the INFORM Telematics Tablet, various on-board and exterior dome cameras, and the Luminator Technology Group websites/portals (Compl. ¶23).

Functionality and Market Context

The complaint categorizes the accused hardware as devices compatible with various communication standards, including H.265/HEVC for video compression, 802.11n/ac/ax Wi-Fi, 5G cellular, and Bluetooth (Compl. ¶23). These products form passenger information and video security systems used in public transit and other fleet vehicles. The complaint alleges these products are distributed and sold throughout the United States via distribution partners, retailers, and direct sales (Compl. ¶25). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exhibits containing evidence of infringement for each patent but does not include those exhibits in the filing. Therefore, the infringement allegations are summarized below based on the narrative descriptions in the complaint.

’127 Patent Infringement Allegations

The complaint alleges that the Accused Products, which are described as being compatible with standards like 802.11 Wi-Fi, perform a method of forming a frame structure for transmission (Compl. ¶¶ 23, 35). The alleged method tracks the elements of claim 20, including forming a preamble with an "enhanced training symbol" and a data structure, where the components of these symbols (cyclic prefix and data/training blocks) adhere to the specific fractional length relationships recited in the claim (G=N₁/4 and N₁=N/I) (Compl. ¶35).

’213 Patent Infringement Allegations

The complaint alleges that the Accused Products perform a method for generating data that mirrors the language of claim 16 (Compl. ¶46). This method involves partitioning a base level data set in memory, generating a "coarse representation of extrema" for each partition, and updating this coarse representation by finding and storing new extrema only from the partitions that contain altered data values (Compl. ¶46). The complaint does not specify what data (e.g., video data, sensor data) is being processed in this hierarchical manner.

Identified Points of Contention

  • Scope Questions: For the ’127 Patent, a central question may be whether the frame structures used in standardized protocols like 802.11n/ac/ax Wi-Fi meet the specific definitions and mathematical relationships of the claimed "enhanced training symbol," particularly the G=N₁/4 requirement. For the ’213 Patent, a question of scope is whether the data processing performed by the accused devices constitutes "generating...a coarse representation of extrema," as that term is understood in the context of the patent.
  • Technical Questions: A key technical question for the ’127 Patent is what evidence demonstrates that the accused products implement the precise preamble structure of claim 20, as opposed to other preamble structures common in the accused standards. For the ’213 Patent, the primary technical question is whether the accused products, when updating data sets, actually employ the claimed hierarchical partitioning and updating method to find new extrema, or if they use an alternative method such as re-sorting a list or re-scanning an entire data set.

V. Key Claim Terms for Construction

For the ’127 Patent

  • The Term: "enhanced training symbol" (from claim 20)
  • Context and Importance: This term defines the core structural element of the preamble. Its construction will be critical because infringement depends on whether the accused devices' preambles contain a symbol with the specific structural properties (a cyclic prefix and a training block with lengths G and N₁, where G=N₁/4) required to be an "enhanced training symbol."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the enhanced training symbol as being located at the beginning of the preamble structure and used for synchronization (’127 Patent, col. 11:3-7), which could support arguing that any symbol serving this function at this location falls within the term's scope.
    • Evidence for a Narrower Interpretation: The patent repeatedly and specifically defines the structure of the symbol with reference to its components and their mathematical relationships (e.g., "G=N₁/4, or 25% of N₁") (’127 Patent, col. 4:48-50). This language may support a narrow construction limited to symbols that strictly adhere to this formula.

For the ’213 Patent

  • The Term: "coarse representation of extrema" (from claim 16)
  • Context and Importance: This term describes the data stored at the higher levels of the claimed hierarchy. The infringement analysis will depend on whether the data structures within the accused products can be characterized as containing such a "coarse representation," as opposed to simply a sorted list or a full copy of the underlying data.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes upper levels as "successively coarser representations of extrema where each successive level... may be formed by finding and storing extrema of a previous level's partitions" (’213 Patent, col. 3:1-4). This language could support an interpretation that any hierarchical structure that abstracts extremum information qualifies.
    • Evidence for a Narrower Interpretation: Figure 1A and its description show a specific pyramidal structure where each level contains only the extrema from the level below (’213 Patent, FIG. 1A; col. 2:55-61). This could support a narrower construction requiring a data structure that explicitly discards all non-extremum data at each hierarchical level.

VI. Other Allegations

Indirect Infringement

For the ’213, ’654, and other patents, the complaint alleges induced infringement, stating that Defendant advises and directs end-users to use the Accused Products in an infringing manner through "distributing instructions," "advertising and promoting the use," and providing "ongoing instructional and technical support" (Compl. ¶¶ 52, 91). Contributory infringement is also alleged, based on the assertion that the Accused Products have special features "specially designed to be used in an infringing way" that are not staple articles of commerce (Compl. ¶¶ 57-58, 96-97).

Willful Infringement

Willfulness is alleged for the ’213 and ’654 patents. The allegations are based on two theories: first, that Defendant was "willfully blind" by maintaining a "policy or practice of not reviewing the patents of others," and second, that Defendant gained actual knowledge of the patents "at least the time of receiving the original complaint in this action" (Compl. ¶¶ 47-48, 86-87).

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

  1. Claim Scope vs. Industry Standards: A recurring issue across multiple asserted patents will be whether the specific, and in some cases novel, methods described in the claims are actually practiced by products that implement standardized technologies (e.g., Wi-Fi, 5G, Bluetooth). The case may turn on whether Plaintiff can prove that compliance with these standards necessarily requires performance of the patented methods, or if the standards allow for non-infringing alternatives.

  2. Evidentiary Proof of Internal Operation: For patents like the ’213 (hierarchical update) and ’654 (TCP ACK allocation), infringement depends on the specific internal software operations of the accused devices. A key evidentiary question will be what proof Plaintiff can obtain and present to demonstrate that the accused systems perform these precise, undisclosed methods, rather than functionally similar but structurally different ones.

  3. Validity in Light of Prosecution History: For the ’127 patent, a core issue will be the validity of the asserted independent claim 20. Given that numerous other claims were cancelled during an Inter Partes Review, the court will likely need to closely examine the distinctions between claim 20 and the cancelled claims in the context of the prior art that was asserted in the IPR proceeding.