CDN Innovations LLC v. Toyota Motor Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CDN Innovations, LLC (Georgia)
  • Defendant: Toyota Motor Corporation (Japan); Toyota Motor North America, Inc. (California/Texas); Toyota Motor Sales, U.S.A., Inc. (California/Texas)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:26-cv-00097, E.D. Tex., 02/05/2026
• Venue Allegations: Plaintiff alleges venue is proper for Toyota Motor Corporation as a foreign corporation, and for its U.S. subsidiaries because they allegedly commit acts of infringement and have a regular and established place of business in the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendants' in-vehicle systems for recognizing spoken commands infringe a patent related to a method for recognizing spoken identifiers that have predefined grammatical structures.
• Technical Context: The technology at issue involves structured voice recognition, where phrases are constructed from predefined word sets arranged in a specific grammatical order to improve recognition accuracy and user memorability.
• Key Procedural History: The complaint states that Plaintiff's agent contacted Toyota in April 2025 regarding its patent portfolio and later provided a claim chart for the patent-in-suit, but the parties were unable to resolve the dispute before the lawsuit was filed.

Case Timeline

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

U.S. Patent No. 6,865,532 - "Method for recognizing spoken identifiers having predefined grammars"

• Patent Identification: U.S. Patent No. 6,865,532, issued March 8, 2005 (the "'532 Patent").

The Invention Explained

• Problem Addressed: The patent describes a problem with contemporary voice-operated devices, noting the difficulty in correctly recognizing long sequences of numbers, such as telephone or account numbers, via speech '532 Patent, col. 1:45-51 This difficulty made hands-free operation of devices like cellular phones distracting and error-prone '532 Patent, col. 1:35-39
• The Patented Solution: The invention proposes a method to create more memorable and machine-recognizable spoken identifiers '532 Patent, col. 2:45-56 Instead of a string of numbers, an identifier is formed from a phrase with a series of "word slots" arranged in a "predetermined grammatical structure" (e.g., number-adjective-noun-verb-preposition-proper noun) '532 Patent, col. 5:1-13 Each slot is filled by selecting a word from a limited, unique set of words (e.g., the "adjective" slot might contain "yellow," "green," "white") '532 Patent, col. 5:1-13 Table B Concatenating the selected words creates a unique phrase, such as "four green dogs flew through Boston," which is easier for a person to remember and a speech recognizer to parse correctly than a long numeric string '532 Patent, col. 5:35-42
• Technical Importance: This structured-phrase approach was designed to improve the reliability of voice command systems at a time when speech recognition technology was less advanced and more susceptible to errors, particularly in noisy environments.

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claim 7 '532 Patent, col. 6:21-42 Compl. ¶20
• Independent Claim 1:
  • defining a phrase having a plurality of word slots, the plurality of word slots arranged in the phrase in a predetermined order and according to a predetermined grammatical structure of a target language;
  • associating a set of unique words with each word slot, the words in each set selected from the target language according to the grammatical structure;
  • generating a plurality of unique identifiers by selecting one word from each set for each word slot for each identifier such that a concatenating of the selected words in the predetermined order form the unique identifier.

III. The Accused Instrumentality

Product Identification

The complaint does not identify specific accused products by name. It broadly accuses "Defendants' systems and processes for selecting and recognizing spoken identifiers incorporated in Defendants' vehicles" Compl. ¶20

Functionality and Market Context

The complaint alleges infringement in connection with voice command functionalities within Toyota vehicles but does not describe the specific features, user interface, or underlying technology of these systems Compl. ¶20 The complaint does not provide sufficient detail for analysis of the accused functionality.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in Exhibit B to detail its infringement allegations; however, this exhibit was not provided Compl. ¶20 The complaint's narrative allegations state that Defendants' in-vehicle systems for recognizing spoken identifiers practice the claimed methods Compl. ¶20 No specific examples of infringing commands or system operations are provided in the body of the complaint.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The core dispute may center on whether the "predetermined grammatical structure" and "word slots" required by Claim 1 can be read to cover modern natural language voice command systems. A question for the court will be whether a system that allows users to speak commands in varied phrasing (e.g., "Call John Doe," "Dial John Doe," "Phone John Doe") meets the claim limitation of a "predetermined order" and fixed grammatical structure.
• Technical Questions: A factual question will be whether Defendants' systems perform the claimed step of "generating a plurality of unique identifiers by selecting one word from each set for each word slot." The complaint does not provide evidence showing that the accused systems construct identifiers from discrete, pre-defined word sets associated with grammatical slots, as opposed to using general speech-to-text and natural language processing to interpret user commands.

V. Key Claim Terms for Construction

• The Term: "predetermined grammatical structure"

  • Context and Importance: This term is central to the claimed invention, defining the rigid, slot-based framework for creating identifiers. The outcome of the case may depend on whether this term is construed narrowly, to cover only specific syntactic patterns like the one disclosed, or broadly enough to encompass the more flexible command patterns recognized by modern voice-control systems.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not limit the "grammatical structure" to a specific sequence, which could support an argument that any defined command syntax qualifies (e.g., Verb-Noun).
    • Evidence for a Narrower Interpretation: The specification provides a single, specific example of the structure: "number:adjective:noun:verb:preposition:proper-noun" '532 Patent, col. 5:1-2 A defendant may argue that this detailed embodiment limits the claim scope to similarly complex, multi-part grammatical patterns.

• The Term: "generating a plurality of unique identifiers"

  • Context and Importance: This term is critical to understanding what action constitutes infringement. Practitioners may focus on whether this step requires the system to pre-populate a list or database of valid identifiers, or if it is satisfied at the moment the system successfully recognizes a spoken command from a universe of possible valid commands.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: One might argue that a system capable of recognizing any valid combination of words from the predefined sets is inherently "generating" the identifier upon receipt and successful parsing of the spoken phrase.
    • Evidence for a Narrower Interpretation: The abstract describes the method as "generat[ing identifiers] by selecting one word from each set for each slot," which suggests a more affirmative act of creation, potentially before recognition occurs, rather than the act of recognition itself '532 Patent, abstract

VI. Other Allegations

• Indirect Infringement: The complaint includes allegations framed to address potential divided infringement, stating that to the extent a third party (e.g., an end-user) performs a claim step, Defendants "conditioned the third party's use of the functionality... on the performance of that step" and "controlled the manner and/or timing of the accused functionality" Compl. ¶21
• Willful Infringement: The complaint does not explicitly plead willful infringement. However, it establishes a basis for pre-suit knowledge by alleging that Plaintiff's agent contacted Toyota on April 1, 2025, and subsequently provided a claim chart detailing the alleged infringement, prior to filing the lawsuit Compl. ¶¶11-12

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

The resolution of this dispute will likely depend on the court’s determination of two key issues:

• A core issue will be one of definitional scope: Can the patent's claim terms, such as "predetermined grammatical structure" and "word slots," which describe a rigid, grammar-based system for creating identifiers, be construed to read on the functionality of modern, flexible, natural-language-based automotive voice command systems?
• A key evidentiary question will be one of technical implementation: Assuming a favorable claim construction, what evidence can Plaintiff provide to demonstrate that Toyota's accused systems actually perform the specific steps recited in the claims—particularly the step of "generating" identifiers by selecting words from predefined sets associated with grammatical slots?