DCT

4:25-cv-00328

Nortrup v. Toyota Motor Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00328, E.D. Tex., 03/31/2025
  • Venue Allegations: Venue is alleged to be proper for Toyota Motor Corporation as a foreign entity subject to personal jurisdiction in the district. For the U.S.-based Toyota entities, venue is alleged based on their residence and regular and established places of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicles equipped with Apple CarPlay and Android Auto infringe patents related to systems that use a cell phone's processing and data capabilities to provide real-time navigation and traffic information on an in-vehicle display.
  • Technical Context: The technology addresses integrating a driver's personal, data-connected smartphone with a vehicle's built-in infotainment screen to create a hybrid navigation system.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement for U.S. Patent No. 11,307,048 on April 19, 2022, and for U.S. Patent No. 11,874,131 on March 8, 2024, which forms the basis for the willfulness allegations.

Case Timeline

Date Event
2004-02-05 Earliest Priority Date for Asserted Patents
2014-01-01 Apple CarPlay and Android Auto announced (approx. date per complaint)
2019-01-01 Toyota begins including Apple CarPlay in select vehicles (approx. date per complaint)
2020-01-01 Toyota begins including Android Auto in select vehicles (approx. date per complaint)
2022-04-19 U.S. Patent No. 11,307,048 Issues
2022-04-19 Plaintiff provides notice of infringement of the ’048 Patent to Toyota
2024-01-16 U.S. Patent No. 11,874,131 Issues
2024-03-08 Plaintiff provides notice of infringement of the ’131 Patent to Toyota
2025-03-31 Complaint Filed

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

U.S. Patent No. 11,307,048 - Method and System for Providing Travel Time Information

  • Issued: April 19, 2022

The Invention Explained

  • Problem Addressed: Prior to the invention, vehicle navigation systems presented a trade-off. Built-in systems offered a superior, integrated user interface but were expensive, difficult to upgrade, and generated unreliable traffic data due to their limited user base (Compl. ¶¶6-7). Conversely, cell phone-based navigation offered more robust, crowd-sourced traffic data and was easily upgradable, but suffered from a poor user interface (e.g., small screens) and could not reliably distinguish between vehicle and pedestrian location data (Compl. ¶¶8-9).
  • The Patented Solution: The invention proposes a hybrid system that combines the advantages of both approaches (Compl. ¶10). The system uses a driver's cell phone (a "mobile communication facility") to handle core navigation functions like determining location and receiving traffic data, and then transmits this information for presentation on the vehicle's superior built-in display (a "route information facility user interface") ('048 Patent, col. 2:15-39). This architecture allows the vehicle to provide an advanced, upgradable navigation experience without requiring expensive, dedicated hardware, while improving the safety and usability of the cell phone's navigation apps (Compl. ¶11).
  • Technical Importance: This approach created a framework for leveraging the rapid innovation cycle of mobile devices to enhance the functionality of longer-lifecycle automotive hardware (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('048 Patent, col. 51:14-52:2; Compl. ¶35).
  • The essential elements of Claim 1 include:
    • An in-vehicle computer system.
    • An in-vehicle data receiver (part of a vehicle) configured to receive a roadway map and a route from a first cell phone.
    • An in-vehicle computer display configured to display the roadway map and route.
    • The system relies on an estimated roadway traffic condition that is based on location data from a "plurality of other cell phones" determined to be moving vehicles.
  • The complaint reserves the right to assert additional claims (Compl. ¶34).

U.S. Patent No. 11,874,131 - Method and System for Providing Travel Time Information

  • Issued: January 16, 2024

The Invention Explained

  • Problem Addressed: The '131 Patent, part of the same family as the '048 Patent, addresses the same technical problem of bridging the gap between built-in and cell phone-based vehicle navigation systems (Compl. ¶¶6-9).
  • The Patented Solution: The solution is also a hybrid architecture but is claimed with a more specific data flow. The invention describes an in-vehicle computer that communicates with a cell phone, causing the cell phone to transmit its location and a destination to a remote "networked computer facility" ('131 Patent, claim 1, col. 51:24-34). This networked facility, in turn, sends map data (including a route and traffic conditions derived from other cell phones) back to the cell phone, which then transmits that map data to the in-vehicle computer for display ('131 Patent, claim 1, col. 51:35-47).
  • Technical Importance: This patent claims a specific client-server architecture within the broader hybrid navigation concept, detailing the interaction between the vehicle, the phone, and a remote data provider (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1 ('131 Patent, col. 51:15-51:47; Compl. ¶47).
  • The essential elements of Claim 1 include:
    • An in-vehicle computer system with a display and a computer configured to receive a destination command.
    • The computer communicates with a separate cell phone to cause the cell phone to transmit its location and the destination to a networked computer facility.
    • This action causes the cell phone to receive map data (with a route and traffic conditions based on other cell phones) from the networked facility.
    • The computer then causes the map data to be transmitted from the cell phone to the computer for display.
  • The complaint reserves the right to assert additional claims (Compl. ¶46).

III. The Accused Instrumentality

Product Identification

Toyota and Lexus vehicles that are equipped with Apple CarPlay and/or Android Auto systems ("Accused Vehicles") (Compl. ¶16). The complaint lists dozens of specific models, including the 4Runner, Camry, Corolla, Highlander, RAV4, Tacoma, and various Lexus ES, IS, and RX models (Compl. ¶16).

Functionality and Market Context

The accused functionality is the integration of a user's smartphone with the vehicle's infotainment system via Apple CarPlay or Android Auto (Compl. ¶12). This allows navigation applications running on the phone (such as Apple Maps, Google Maps, or Waze) to use the vehicle's built-in screen for display and its controls for user input (Compl. ¶12, ¶40). The complaint alleges these features are extremely popular, citing reports that 98% of new cars in the U.S. have CarPlay installed and that 79% of buyers would only purchase a car that supported it (Compl. ¶13). The complaint includes a depiction of an infotainment system showing the Apple CarPlay interface to illustrate the technology. (Compl. p.5). A similar depiction is provided for the Android Auto interface. (Compl. p.6).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not included in the filed document; therefore, the infringement allegations are summarized below in narrative form.

  • '048 Patent Narrative Summary: The complaint alleges that the Accused Vehicles embody the claimed "in-vehicle computer system." The vehicle's infotainment hardware that communicates with a connected smartphone via USB or Bluetooth is alleged to be the "in-vehicle data receiver." This receiver obtains a "roadway map" and "route" from the user's smartphone (the "first cell phone") when a navigation app is active. The vehicle's dashboard screen serves as the "in-vehicle computer display." The complaint alleges that the traffic data shown on the map is crowd-sourced by the navigation app's provider (e.g., Apple, Google) from a "plurality of other cell phones" in other vehicles, thus meeting the final limitation of claim 1 (Compl. ¶¶10, 35, 40).

  • '131 Patent Narrative Summary: The infringement theory for the '131 Patent follows the more detailed architecture of its claim 1. It is alleged that when a user enters a destination into a navigation app via the vehicle's interface, the vehicle's "computer" receives the command and "causes" the connected cell phone to transmit its location and the destination to a "networked computer facility" (e.g., Apple or Google's servers). This action, in turn, "causes" the phone to receive map data, a route, and crowd-sourced traffic information back from the server. Finally, the phone transmits this map data to the vehicle's computer, which displays it on the screen (Compl. ¶¶10, 47, 52).

  • Identified Points of Contention:

    • Scope Questions: For the '048 Patent, a potential issue is whether a system like CarPlay or Android Auto, often described as a projection system, constitutes an "in-vehicle data receiver" that "receive[s] a roadway map" from a cell phone, or if it merely receives display data.
    • Technical Questions: A central question for the '131 Patent will be one of control and causation. The analysis may focus on whether the vehicle's computer actively "causes" the phone to transmit its location to a server, or if the phone's navigation application performs this step independently, with the vehicle system acting primarily as a peripheral for display and user input.

V. Key Claim Terms for Construction

  • The Term: "in-vehicle data receiver ... configured to receive a roadway map ... and a route from ... a first cell phone" (’048 Patent, Claim 1)

  • Context and Importance: This term's construction is fundamental to the infringement case for the '048 Patent. The dispute may center on whether the hardware and software interface for Apple CarPlay and Android Auto meets this definition. Practitioners may focus on whether "receiving a roadway map" requires receiving the underlying map data itself, or if receiving processed video or display data that depicts a map is sufficient.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes an "in-vehicle communication facility" that includes a "communication facility adapted for data, voice, and or information communication," which could be argued to encompass the complex data streams used by CarPlay/Android Auto ('048 Patent, col. 3:25-29).
    • Evidence for a Narrower Interpretation: The specific examples of interfaces listed, such as "cell phone interface, portable transmission interface, pda interface," could be argued to contemplate a different type of data exchange than the projection-style protocols of the accused systems ('048 Patent, col. 2:31-34).

  • The Term: "said computer being configured to communicate with a cell phone ... to cause said cell phone to transmit a self-determined location" (’131 Patent, Claim 1)

  • Context and Importance: The definition of "cause" is critical to the infringement analysis of the '131 Patent and implicates the issue of divided infringement. The case may turn on whether the vehicle's computer is the actor that initiates the phone's communication with the remote server, or if the phone's app is the true actor.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent does not appear to provide a special definition for "cause." Plaintiff may argue that by providing the user interface that launches and controls the navigation app, the vehicle's computer is the proximate cause of the phone's subsequent actions, satisfying the plain and ordinary meaning of the term.
    • Evidence for a Narrower Interpretation: Defendant may argue that "to cause" requires a specific command from the vehicle's computer to the phone, rather than simply providing a passive interface for an independently operating application. They might point to the architecture of CarPlay/Android Auto to suggest the phone's operating system, not the car's computer, directs the app's core network functions.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges Toyota induces infringement by both its dealerships and its customers (Compl. ¶¶39-40, 51-52). The alleged inducing acts include supplying the Accused Vehicles, providing technical support and marketing services to dealers, and publishing instructional materials, such as YouTube videos, that explicitly instruct customers on how to use the accused Apple CarPlay and Android Auto features with third-party navigation apps (Compl. ¶¶41, 53).
  • Willful Infringement: Willfulness is alleged for both patents based on Toyota's purported continuation of infringing activities after receiving actual notice. The complaint specifies that notice for the '048 Patent was provided on April 19, 2022, and notice for the '131 Patent was provided on March 8, 2024 (Compl. ¶¶36, 43, 48, 55).

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

  • A core issue will be one of technical control and causation: Does Toyota’s in-vehicle computer system actively "cause" a connected cell phone to transmit its location to a server as required by the '131 patent, or does it merely act as a passive display and input interface for a phone application that operates independently? The resolution of this question may also determine the viability of a divided infringement defense.
  • A second key issue will be one of architectural scope: Can the '048 patent's claim of an "in-vehicle data receiver" that "receive[s] a roadway map... from a first cell phone" be construed to cover modern projection systems like CarPlay and Android Auto, or does the claim language and specification imply a fundamentally different data-sharing architecture than the one implemented in the accused systems?
  • A third question will be evidentiary: Assuming the claim scope covers the accused systems, the case will require factual evidence demonstrating that the traffic data displayed in the Accused Vehicles originates from the specific source required by the claims—location data from a "plurality of other cell phones."