L4T Innovations LLC v. Garmin Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: L4T Innovations LLC (Michigan)
  • Defendant: Garmin Ltd. (Switzerland) and Garmin Corporation (Taiwan)
  • Plaintiff’s Counsel: L4T Innovations LLC (in-house)
• Case Identification: 2:26-cv-00091, E.D. Tex., 02/04/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendants are foreign corporations, which may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s Dash Cam products, in conjunction with associated software, infringe a patent related to systems for marking and retrospectively capturing video of notable events.
• Technical Context: The technology addresses the challenge of isolating important moments within long, continuous video recordings, a common issue in applications like action cameras and vehicle dash cams.
• Key Procedural History: The complaint does not mention prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit. The patent-in-suit claims priority from two U.S. provisional applications.

Case Timeline

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

U.S. Patent No. 11,189,321 - “RETROSPECTIVE CAPTURE TRIGGER”

• Patent Identification: U.S. Patent No. 11,189,321 (“the ’321 Patent”), “RETROSPECTIVE CAPTURE TRIGGER,” issued November 30, 2021.

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of locating noteworthy events within large volumes of captured media, such as hours of video from a camera, noting that manually searching through such recordings can be "tedious and time-consuming" (’321 Patent, col. 3:7-10).
• The Patented Solution: The invention is an "event marking device" that marks the real time of a notable event when a user activates a trigger (’321 Patent, abstract). This device contains a real-time clock, a trigger circuit, a microcontroller, and a communication interface (’321 Patent, FIG. 1). When triggered, the device records the precise time and outputs this "trigger event data" to an external device (e.g., a video camera), enabling that external device to flag, save, or "retrospectively capture" the media corresponding to that specific time (’321 Patent, col. 2:1-6; ’321 Patent, col. 4:51-62).
• Technical Importance: This approach decouples the event-marking action from the media-capture device, allowing a user to conveniently flag an important moment using a separate, often more accessible, trigger.

Key Claims at a Glance

• The complaint asserts independent claims 1, 8, and 15, as well as several dependent claims Compl. ¶21
• Independent Method Claim 8:
  • generating real-time clock data with a real-time clock of an event marking device;
  • generating, with a trigger circuit of the event marking device, a trigger signal;
  • identifying, from the real-time clock data with a microcontroller of the event marking device, a real time corresponding to a receipt of the trigger signal;
  • writing, with the microcontroller, trigger signal data to a memory of the event marking device indicating the real time associated with receipt of the trigger signal;
  • outputting, with a communication interface of the event marking device, the trigger event data including the time of generating the trigger signal to an external device;
  • whereby outputting the trigger event data causes the external device to preserve a recording captured at the time of the enablement of the trigger circuit.
• The complaint reserves the right to assert other claims, including dependent claims Compl. ¶21

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as the Garmin Dash Cam 47, 57, 67W, Mini 2, and X310 (the "Garmin Dash Cams") when used with the Garmin Drive App and/or Garmin Vault (the "Garmin Software Products") Compl. ¶16

Functionality and Market Context

• The complaint characterizes the accused instrumentalities as "video event recording and transmission dash cam hardware products and associated software products" Compl. ¶16 The allegations center on the system's ability to record video events and transmit data. The complaint alleges these products are part of Garmin's "outdoor line of products" Compl. ¶7 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of method claim 8 but relies on a separate "Exhibit 2" for detailed evidence, which was not filed with the complaint Compl. ¶22 The following chart is based on the narrative summary of infringement provided in the complaint's body.

’321 Patent Infringement Allegations

Identified Points of Contention:

• Scope Questions: A central question may be whether the accused system architecture meets the claim limitations of a distinct "event marking device" and an "external device." The patent’s specification and figures consistently depict these as two separate hardware components (e.g., a wrist-worn trigger and a head-mounted camera) (’321 Patent, FIG. 5). The complaint’s theory appears to treat the Garmin Dash Cam as the "event marking device" and the associated software on a smartphone or cloud server as the "external device." This raises the question of whether a software application or a remote server can be construed as the claimed "external device."
• Technical Questions: The complaint does not specify what component of the Garmin Dash Cams constitutes the "trigger circuit" or how the "trigger signal" is generated. The patent discloses various triggers, including physical buttons, motion sensors, and microphones (’321 Patent, col. 5:28-6:65). The evidence regarding the specific triggering mechanism in the accused products will be a key factual issue.

V. Key Claim Terms for Construction

The Term: "event marking device"

• Context and Importance: The definition of this term is fundamental to the infringement analysis. The dispute may turn on whether an "event marking device" must be a standalone component primarily for marking events, as depicted in the patent’s embodiments, or if the term can be construed more broadly to cover an integrated device, like a dash cam, that performs both recording and marking functions.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves do not explicitly require physical separability from a recording device. A party could argue that any device performing the claimed functions of generating a trigger signal, processing it with a clock and microcontroller, and outputting data fits the definition.
  • Evidence for a Narrower Interpretation: The patent’s summary and detailed description consistently describe the "event marking device" in relation to an "external device," often a media capture device (’321 Patent, col. 2:5-6; ’321 Patent, FIG. 3). Embodiments show the marking device as physically distinct, such as a device worn on the wrist that communicates wirelessly with a separate head-mounted camera (’321 Patent, FIG. 5).

The Term: "external device"

• Context and Importance: This term's construction is coupled to "event marking device." If the dash cam is the "event marking device," then the identity of the "external device" becomes critical. The Plaintiff's theory appears to require this term to cover software entities like the "Garmin Drive App" or "Garmin Vault" cloud service Compl. ¶16
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that "external" simply means logically or communicatively separate from the core processing of the marking device, which could potentially include a software application on a different processor (e.g., a smartphone).
  • Evidence for a Narrower Interpretation: The patent specification repeatedly refers to the external device as a "media capture device" such as a "video camera" (’321 Patent, col. 9:43-44). The figures depict the external device as a distinct piece of hardware (’321 Patent, FIG. 3, item 350). This may support an argument that "external device" must be a separate hardware component.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants provide instructions that guide end-users to use the products in an infringing manner Compl. ¶23 It also alleges contributory infringement on the basis that the Accused Products have special features designed for infringement with no substantial non-infringing use Compl. ¶24
• Willful Infringement: Willfulness allegations are based on knowledge of the ’321 Patent acquired "at least as of the date when it was notified of the filing of the Original Complaint in this action" Compl. ¶25 This suggests a theory of post-filing willfulness. The complaint further alleges Defendants' actions are "at least objectively reckless" Compl. ¶26

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

• A core issue will be one of system architecture and claim scope: Can the claim terms "event marking device" and "external device," which are described in the patent's embodiments as physically separate hardware units, be construed to read on an integrated system where a dash cam communicates with a software application on a smartphone or a cloud-based service?
• A key evidentiary question will be one of technical implementation: Assuming the complaint's architectural theory is viable, what specific hardware and software components within the Garmin ecosystem perform the claimed method steps, and does their operation align with the functions required by the claims of the ’321 Patent?