DCT

4:23-cv-00750

Stellar LLC v. Motorola Solutions Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:23-cv-00750, E.D. Tex., 08/21/2023
  • Venue Allegations: Venue is alleged to be proper based on Defendants maintaining a regular and established place of business in Allen, Texas, within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s in-car and body-worn video camera systems infringe eight patents related to loop recording, pre-event video capture, and the write-protection of specific recorded segments.
  • Technical Context: The technology concerns mobile video recording for applications like law enforcement, where the ability to continuously record and reliably capture unforeseen events without manual intervention is a critical operational feature.
  • Key Procedural History: The complaint alleges that Defendant Motorola Solutions, Inc. (MSI) had pre-suit knowledge of several of the asserted patents from a business presentation given by Plaintiff on September 27, 2016, and of others from an email exchange on December 4, 2019. These allegations form the basis for claims of willful and induced infringement. The complaint also notes that MSI acquired Defendant Watchguard on July 11, 2019.

Case Timeline

Date Event
2006-08-31 Earliest Priority Date for all Asserted Patents
2009-09-22 U.S. Patent No. 7,593,034 Issues
2012-11-13 U.S. Patent No. 8,310,540 Issues
2014-04-08 U.S. Patent No. 8,692,882 Issues
2015-01-06 U.S. Patent No. 8,928,752 Issues
2016-09-27 Plaintiff allegedly presents technology to Defendant MSI
2016-11-01 U.S. Patent No. 9,485,471 Issues
2018-03-06 U.S. Patent No. 9,912,914 Issues
2019-07-11 Defendant MSI acquires Defendant Watchguard
2019-12-04 Alleged email exchange between Plaintiff's agent and MSI
2019-12-31 U.S. Patent No. 10,523,901 Issues
2021-03-30 U.S. Patent No. 10,965,910 Issues
2023-08-21 Complaint Filed

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

  • Patent Identification: U.S. Patent No. 7,593,034, “Loop Recording With Book Marking,” issued September 22, 2009.
  • The Invention Explained:
    • Problem Addressed: The patent describes a problem with conventional video recorders having limited memory, which required users to manually stop recording to transfer data, creating an "inconvenience and inflexibility for recording on the go" (’034 Patent, col. 1:40-42; Compl. ¶11, 17). Existing loop recording systems would indiscriminately overwrite older data, risking the loss of important, unforeseen events (Compl. ¶18).
    • The Patented Solution: The invention proposes a system that continuously records video data into a "circular buffer" on a local memory (’034 Patent, col. 2:13-16). Upon receiving a signal, a "protecting facility" designates a segment of that recording for preservation, including data captured before the signal was received (pre-recorded subset) and after (post-recorded subset) (’034 Patent, col. 2:35-45). This "book-marked" segment is indexed as a distinct file and is not overwritten, and a "sending facility" can wirelessly transmit it to a remote memory to free up space without interrupting the ongoing recording process (’034 Patent, Abstract).
    • Technical Importance: This approach enabled continuous surveillance while allowing for the reliable capture and preservation of specific, unanticipated events without halting the recording process (Compl. ¶14, 16).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 and dependent claims 7 and 12 (Compl. ¶26).
    • Independent Claim 1 requires:
      • A surveillance apparatus with a camera, a local memory, and a wireless transmitter.
      • A "recording facility" that continuously records a data stream into a circular buffer in the local memory.
      • A "protecting facility" that responds to a signal by designating a segment of the buffer (including pre- and post-recorded subsets) as write-protected and "indexing the write-protected portion as a second distinct file."
      • A "sending facility" that uses the transmitter to wirelessly send the "second file" to a remote memory.
    • The complaint does not explicitly reserve the right to assert other claims.
  • Patent Identification: U.S. Patent No. 8,310,540, “Loop Recording With Book Marking,” issued November 13, 2012.
  • The Invention Explained:
    • Problem Addressed: The patent addresses the same core problem as the ’034 Patent: the limitations of finite memory in mobile recording devices and the risk of overwriting crucial footage in simple loop-recording systems (’540 Patent, col. 1:13-24; Compl. ¶11).
    • The Patented Solution: The invention describes a method where a recorder uses portions of memory as a loop, which is treated as a "single file" (’540 Patent, cl. 1). Upon a trigger, portions of this loop are protected from being overwritten. A key aspect is "allowing the editing of the imaged data in protected multiple portions... via a recorder control while recording additional segments" (’540 Patent, cl. 1). This allows for active management of saved clips without stopping the continuous recording function.
    • Technical Importance: This method provided a framework for managing saved video events within a continuous loop, enhancing user control and memory efficiency in surveillance applications (Compl. ¶16).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 (Compl. ¶40).
    • Independent Claim 1 requires a method of:
      • Using multiple portions of a memory as a memory loop and treating it as a single file.
      • Protecting portions within that single file from being overwritten.
      • "Allowing the editing of the imaged data" in the protected portions using a recorder control, all "while recording additional segments" into the loop.
    • The complaint does not explicitly reserve the right to assert other claims.
  • Patent Identification: U.S. Patent No. 8,692,882, “Loop Recording With Book Marking,” issued April 8, 2014.
  • Technology Synopsis: This patent, part of the same family, describes a surveillance apparatus with a camera, local memory, and a facility for continuous loop recording. The inventive concept centers on responding to a trigger signal by write-protecting a segment of the recording that includes pre-event data, indexing it as a distinct file, and allowing access to that file, for example, for transmission to a remote memory (’882 Patent, Abstract; Compl. ¶11-12).
  • Asserted Claims: Independent claim 1 and dependent claims 12, 21, and 22 (Compl. ¶54).
  • Accused Features: The complaint accuses WatchGuard In-Car Video Systems of infringing by performing loop recording and triggered, write-protected event capture (Compl. ¶53).
  • Patent Identification: U.S. Patent No. 8,928,752, “Recording Device With Pre-Start Signal Storage Capability,” issued January 6, 2015.
  • Technology Synopsis: This patent discloses a system that utilizes an area of memory as a circular buffer to record a data stream. In response to a start signal, the system protects a "recently used segment" of the buffer, which includes a "pre-signal portion." The system then records a second data stream into the buffer without overwriting the protected segment (’752 Patent, Abstract; Compl. ¶14).
  • Asserted Claims: Independent claim 1 (Compl. ¶68).
  • Accused Features: The complaint accuses WatchGuard In-Car Video Systems of infringing by capturing and storing video from a period prior to a triggering event (Compl. ¶67).
  • Patent Identification: U.S. Patent No. 9,485,471, “Write Protected Recording,” issued November 1, 2016.
  • Technology Synopsis: This patent describes a recording apparatus and method focused on write-protecting segments of a continuous recording in a circular buffer. The system designates a segment for preservation based on a trigger, including pre- and post-trigger data, indexes it as a file, and can transmit it to a remote memory, all while continuing to record (’471 Patent, Abstract; Compl. ¶11-12).
  • Asserted Claims: Independent claim 1 and dependent claims 2 and 3 (Compl. ¶82).
  • Accused Features: The complaint accuses WatchGuard VISTA Body cameras of infringing by using loop recording with triggered, write-protected event capture (Compl. ¶81).
  • Patent Identification: U.S. Patent No. 9,912,914, “Write-Protected Recording,” issued March 6, 2018.
  • Technology Synopsis: This patent, from the same family, details a recording system with a sensor interface, memory, and a protecting facility. The system responds to a trigger by write-protecting a segment of a data stream in a buffer, including a pre-recorded subset, and stores it as a file. The system allows for the transmission of this file to a remote memory (’914 Patent, Abstract; Compl. ¶14).
  • Asserted Claims: Independent claim 1 (Compl. ¶96).
  • Accused Features: The complaint accuses WatchGuard In-Car Video Systems of infringing by capturing pre-event video and protecting it from being overwritten (Compl. ¶95).
  • Patent Identification: U.S. Patent No. 10,523,901, “Wearable Recording System With Memory Designation,” issued December 31, 2019.
  • Technology Synopsis: This patent describes a wearable recording system that uses a circular buffer to continuously record sensor data. In response to a first trigger, it designates a first portion of sensor data for saving, including data captured prior to the trigger. In response to a second trigger, it designates a second portion for saving, while automatically overwriting portions not designated for saving (’901 Patent, Abstract, cl. 1).
  • Asserted Claims: Independent claim 1 (Compl. ¶111).
  • Accused Features: The complaint accuses WatchGuard In-Car Video Systems, including the Vista XLT, of infringing by capturing and saving multiple, distinct events that include pre-trigger video (Compl. ¶109-110).
  • Patent Identification: U.S. Patent No. 10,965,910, “Wearable Recording System With Memory Designation,” issued March 30, 2021.
  • Technology Synopsis: This patent discloses a recording system that continuously records to a memory and, in response to trigger signals, designates portions of the data for write-protection. The protected portions include data captured prior to the trigger. The system is configured to continue recording while the first portion is designated for write-protecting and to overwrite non-protected data (’910 Patent, Abstract, cl. 1).
  • Asserted Claims: Independent claim 1 (Compl. ¶125).
  • Accused Features: The complaint accuses WatchGuard 4RE In-Car Video Systems of infringing by performing continuous loop recording with the ability to save triggered events, including pre-event footage (Compl. ¶124).

III. The Accused Instrumentality

  • Product Identification: The complaint names WatchGuard In-Car Video Systems, specifically citing the WatchGuard 4RE In-Car Video System, and WatchGuard VISTA Body cameras as the Accused Instrumentalities (Compl. ¶25, 81). A footnote extends the allegations to other products, including the Vista, Vista XLT, V700, V300, and VB400 models (Compl. ¶25 n.1).
  • Functionality and Market Context: The Accused Instrumentalities are described as components of Defendant's "public safety device and application ecosystems" (Compl. ¶32). While the complaint does not detail the technical operation of the products, its allegations suggest they are video recording devices used by law enforcement that feature continuous or loop recording. A core accused feature is the ability to capture and save video of an "event," including footage from a period of time immediately preceding a trigger (often called "pre-event recording"), thereby preventing that footage from being overwritten (Compl. ¶13-14).
    No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶26, 40). The narrative allegations suggest the following infringement theories:

For the ’034 Patent, the complaint alleges that the Accused Instrumentalities embody the claimed "surveillance apparatus." The product's camera, memory, and continuous recording function are alleged to meet the "camera," "local memory," and "recording facility" limitations. The function where a user or sensor triggers the saving of an event, including pre-event video, is alleged to constitute the "protecting facility that... index[es] the write-protected portion as a second distinct file." The ability to offload this saved footage is alleged to be the "sending facility" (Compl. ¶25-27).

For the ’540 Patent, the complaint alleges the Accused Instrumentalities practice the claimed method. Their operation of continuously recording to a memory buffer is alleged to be the use of a "memory loop." The system's process for saving specific events is alleged to meet the limitation of "protecting" portions from being overwritten. The user's ability to manage these saved events (e.g., view, transfer, or delete) while the device continues to record is alleged to be the claimed step of "allowing the editing of the imaged data... while recording" (Compl. ¶39-41).

  • Identified Points of Contention:
    • Scope Questions: A potential point of contention for the ’034 Patent may be whether the accused products' method of flagging and preserving a video segment within a larger data stream constitutes "indexing the write-protected portion as a second distinct file." The litigation may explore whether this requires the creation of a new file in the file system or if metadata pointers suffice.
    • Technical Questions: For the ’540 Patent, a key question may be the scope of the term "editing." The analysis will likely focus on whether the accused products' functionalities for managing saved clips (e.g., categorizing, transferring, or deleting) meet the claim requirement of "allowing the editing of the imaged data," or if "editing" implies modification of the video content itself.

V. Key Claim Terms for Construction

  • The Term: "indexing the write-protected portion as a second distinct file" (’034 Patent, cl. 1)
  • Context and Importance: This term is central to the data management aspect of the invention. The infringement analysis for the ’034 Patent will depend on whether the software architecture of the accused systems, which preserves triggered video events, performs an operation that can be characterized as creating a "distinct file." Practitioners may focus on this term because a defendant could argue its system merely uses pointers or metadata to define a segment within a single, continuous recording file, rather than creating a structurally separate file.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests flexibility, stating that write-protected portions "are preferably stored as separate files in the memory" and "could be stored in physically dis-contiguous parts of the circular buffer" (’901 Patent, col. 7:61-63). This may support a functional interpretation where any method that logically separates and protects the data segment, regardless of the underlying file structure, meets the limitation.
    • Evidence for a Narrower Interpretation: The use of the specific words "second distinct file" could be argued to require more than just logical separation. A party could contend that this language implies the creation of a new, standalone file with its own entry in the file system, separate from the primary recording stream.
  • The Term: "allowing the editing of the imaged data" (’540 Patent, cl. 1)
  • Context and Importance: The viability of the infringement claim for the ’540 Patent may hinge on the construction of "editing." If construed narrowly to mean altering video content, infringement may be questionable. If construed broadly to include file management, the infringement case may be stronger.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A related patent in the family states that an authenticated user can "control indexing, editing, transmitting, or adjusting content data in memory" (’034 Patent, col. 5:35-37). The grouping of "editing" with other data management functions like "transmitting" may suggest the term was intended to have a broad meaning encompassing file-level operations.
    • Evidence for a Narrower Interpretation: In common parlance, "editing" video typically refers to content modification like trimming, splicing, or adding effects. A defendant may argue that the term should be given this plain and ordinary meaning, and that file management operations like copying or deleting do not constitute "editing the imaged data" itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides support materials, online training resources via a "Learning Experience Portal," and marketing presentations that instruct and encourage customers to use the Accused Instrumentalities in a manner that directly infringes the asserted patents (Compl. ¶29-31, 43-45, 57-59, 71-73, 85-87, 99-101, 114-116, 127-129).
  • Willful Infringement: The complaint alleges willful infringement based on Defendant MSI’s purported pre-suit knowledge of the asserted patents. Knowledge is alleged to stem from a September 2016 business presentation for the ’034, ’540, ’882, and ’752 patents, and a December 2019 email exchange for the ’471, ’914, and ’901 patents (Compl. ¶34, 48, 62, 76, 84, 98, 113). For the latest patents, willfulness is alleged to have begun at least from the filing of the complaint (Compl. ¶90, 104, 119, 132).

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

  • A core issue will be one of technical and definitional mapping: can the specific claim terms used to describe the patented data management methods, such as "indexing... as a second distinct file" and "allowing the editing," be shown to read on the specific software functions and data structures implemented in the Accused Instrumentalities? The outcome may depend heavily on claim construction and evidence revealing the products' underlying operation.
  • A central evidentiary question will concern knowledge and intent: what was the extent of Defendant MSI's knowledge regarding the asserted patents following the alleged 2016 presentation and 2019 communications? The facts surrounding these events will be critical to resolving the claims of induced and willful infringement, which require proof of specific intent and knowledge.