DCT

3:22-cv-00761

Intellectual Ventures II LLC v. American Honda Finance Corp

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:22-cv-00761, N.D. Tex., 04/04/2022
  • Venue Allegations: Plaintiff alleges venue is proper because Honda maintains numerous regular and established places of business in the Northern District of Texas, including facilities in Irving and Fort Worth, and has committed alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s automotive vehicles and related components, which incorporate infotainment, navigation, and wireless communication systems, infringe eleven U.S. patents.
  • Technical Context: The technologies at issue relate to in-vehicle networking protocols, location-based services, wireless hotspot functionality, and cellular communication standards, which are integral features in the modern connected-vehicle market.
  • Key Procedural History: The complaint alleges that Honda received actual notice of its potential infringement of all asserted patents via a letter dated October 18, 2021, a fact which may be central to Plaintiff’s claims for willful infringement.

Case Timeline

Date Event
1999-05-18 Priority Date: U.S. Patent No. 7,382,771
2000-06-15 Priority Date: U.S. Patent No. 6,832,283
2000-10-06 Priority Date: U.S. Patent No. 7,891,004
2002-03-08 Priority Date: U.S. Patent No. 7,684,318
2004-12-14 Issue Date: U.S. Patent No. 6,832,283
2005-04-29 Priority Date: U.S. Patent No. 8,953,641
2005-08-25 Priority Date: U.S. Patent No. 9,232,158
2006-05-08 Priority Date: U.S. Patent No. 9,681,466
2006-05-08 Priority Date: U.S. Patent No. 10,292,138
2006-12-27 Priority Date: U.S. Patent No. 8,811,356
2008-06-03 Issue Date: U.S. Patent No. 7,382,771
2010-03-23 Issue Date: U.S. Patent No. 7,684,318
2011-02-15 Issue Date: U.S. Patent No. 7,891,004
2012-10-04 Priority Date: U.S. Patent No. 9,602,608
2013-01-10 Priority Date: U.S. Patent No. 9,291,475
2014-08-19 Issue Date: U.S. Patent No. 8,811,356
2015-02-10 Issue Date: U.S. Patent No. 8,953,641
2016-01-05 Issue Date: U.S. Patent No. 9,232,158
2016-03-22 Issue Date: U.S. Patent No. 9,291,475
2017-03-21 Issue Date: U.S. Patent No. 9,602,608
2017-06-13 Issue Date: U.S. Patent No. 9,681,466
2019-05-14 Issue Date: U.S. Patent No. 10,292,138
2021-10-18 Date of Alleged Pre-Suit Notice to Honda
2022-04-04 Complaint Filing Date

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

U.S. Patent No. 6,832,283 - "METHOD FOR ADDRESSING NETWORK COMPONENTS"

The Invention Explained

  • Problem Addressed: The patent describes addressing challenges in complex networks within transport vehicles, particularly when components on an internal data bus also need to communicate with an external network like the Internet (Compl. ¶32; ’283 Patent, col. 2:13-21).
  • The Patented Solution: The invention proposes a dual-addressing method. Within the vehicle's "first network" (e.g., a data bus), components are addressed using "function-specific address components," allowing identical hardware units to be addressed similarly. When a component connects to a "second network" (e.g., the Internet), it is assigned a second, separate address for that communication. This structure is intended to simplify addressing within the vehicle while enabling external connectivity for specific components (’283 Patent, Abstract, col. 2:22-42).
  • Technical Importance: This approach provided a structured method for managing increasingly complex in-vehicle electronic systems and bridging them to external IP-based networks, a foundational concept for modern telematics (Compl. ¶32).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶65).
  • Essential elements of claim 1 include:
    • A method for addressing components of a first network in a data bus system in a transport vehicle.
    • Assigning each component a first address for communication within the network, with these addresses stored in a central register.
    • At least one component communicates with a second network and is assigned a second address by that second network.
    • Addressing within the first network occurs on the basis of "function-specific address components," where identical function blocks are addressed via identical function-specific address components.

U.S. Patent No. 9,602,608 - "SYSTEM AND METHOD FOR NOTIFYING A USER OF PEOPLE, PLACES OR THINGS HAVING ATTRIBUTES MATCHING A USER'S STATED PREFERENCE"

The Invention Explained

  • Problem Addressed: The patent addresses the need to provide mobile users with relevant, localized information that is filtered according to their specific, explicitly stated preferences, rather than presenting a generic set of location-based data (Compl. ¶35).
  • The Patented Solution: The invention is a computer-implemented method that receives a user's preference, the user's mobile device location, and a geographic area limit. It queries a stored database of "objects" (e.g., places, things) that have associated attributes and locations. It identifies a match if an object's attributes satisfy the user's preference and the object is within the specified geographic area. Information about the matching object is then sent to the user (’608 Patent, Abstract; Compl. ¶80).
  • Technical Importance: This technology enables personalized, location-aware recommendations, a core function of modern vehicle navigation and infotainment systems that enhances user experience by filtering points of interest (Compl. ¶35).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶80).
  • Essential elements of claim 1 include:
    • An electronic computer implemented method for matching users with information.
    • Receiving a first user preference, a location of a mobile device, and a geographic area limitation.
    • Storing attributes and locations for a plurality of objects.
    • Determining a matching object based on both its attributes satisfying the preference and its location being within the geographic limitation.
    • Sending information about the matching object to the user.

U.S. Patent No. 7,891,004 - "METHOD FOR VEHICLE INTERNETWORKS"

  • Technology Synopsis: The patent relates to vehicle internetworks that provide for communication among diverse electronic devices within a vehicle and between those devices and external networks. The invention describes a method where a gateway node automatically forms a network by bridging a first vehicle bus (e.g., F-CAN) and a second vehicle bus (e.g., B-CAN) and couples a network element to a remote computer outside the vehicle (Compl. ¶¶38, 95).
  • Asserted Claims: The complaint asserts independent claim 68 (Compl. ¶95).
  • Accused Features: The complaint accuses Honda vehicles equipped with a Mobile Hotspot System and HondaLink®, which allegedly employ a gateway node to bridge multiple in-vehicle networks and a Telematics Control Unit to couple to remote computers (Compl. ¶¶96, 98-102).

U.S. Patent No. 9,291,475 - "DEVICE, SYSTEM AND METHOD FOR CONTROLLING SPEED OF A VEHICLE USING A POSITIONAL INFORMATION DEVICE"

  • Technology Synopsis: The patent describes a device for notifying a recipient of a violation by a driver. The device, located in a vehicle, uses an information module to determine information about the vehicle (e.g., speed and location), a processing module to determine if a violation occurred, and a transmission module to send an indication of the violation to a remote computing system (Compl. ¶¶41, 112).
  • Asserted Claims: The complaint asserts independent claim 15 (Compl. ¶112).
  • Accused Features: The complaint accuses Honda vehicles equipped with HondaLink®, which allegedly collects geolocation and driver behavior information (such as vehicle speed) and can provide alerts (e.g., Geofence Alert, Security Alarm Alert) to a remote system (Compl. ¶¶114-118).

U.S. Patent No. 7,382,771 - "MOBILE WIRELESS HOTSPOT SYSTEM"

  • Technology Synopsis: The patent relates to a stand-alone mobile wireless hotspot system. The system comprises a short-range wireless access point (e.g., Wi-Fi), a long-range wireless Internet access interface (e.g., cellular), and a LAN routing system to manage the data path between them, allowing client devices to access the Internet without needing an external service controller server (Compl. ¶¶44, 127).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶127).
  • Accused Features: The complaint accuses Honda vehicles equipped with "In-Vehicle Wi-Fi" or similar mobile hotspot functionality, which allegedly provides a short-range Wi-Fi access point connected to the Internet via a long-range cellular connection (e.g., AT&T 4G) (Compl. ¶¶126, 129-131).

U.S. Patent No. 9,232,158 - "LARGE DYNAMIC RANGE CAMERAS"

  • Technology Synopsis: The patent describes a camera system for expanding dynamic exposure range. The system comprises a plurality of channels, each with a sensor, and a processing component that determines an integration time for each channel and combines the data from the channels to provide an image (Compl. ¶¶47, 140).
  • Asserted Claims: The complaint asserts independent claim 9 (Compl. ¶140).
  • Accused Features: The complaint accuses Acura models equipped with a "Surround-View" camera system, which allegedly uses four exterior cameras (sensors) to display a 360° view, with hardware and software (a processing component) that combines the images to create a composite view (Compl. ¶¶139, 143-144).

U.S. Patent No. 9,681,466 - "SCHEDULING TRANSMISSIONS ON CHANNELS IN A WIRELESS NETWORK"

  • Technology Synopsis: The patent relates to a user equipment (UE) in a wireless network that receives allocation messages and parameters from a network device. A processor allocates resources for data transmission based on these parameters, prioritizing channels with certain parameter values over others (Compl. ¶¶50, 153).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶153).
  • Accused Features: The complaint accuses Honda vehicles using a 4G LTE modem (e.g., Qualcomm Snapdragon) to support Mobile Hotspot and HondaLink® services, alleging these systems operate as a UE compliant with 3GPP standards for resource allocation (Compl. ¶¶152, 155-159).

U.S. Patent No. 10,292,138 - "DETERMINING BUFFER OCCUPANCY AND SELECTING DATA FOR TRANSMISSION ON A RADIO BEARER"

  • Technology Synopsis: The patent describes a user equipment (UE) that determines buffer occupancies for its radio bearers, transmits a message with this information to a network, receives a single allocation of uplink resources, and selects data for transmission in a two-iteration process based on received parameters and buffered data (Compl. ¶¶53, 169).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶169).
  • Accused Features: The complaint accuses Honda vehicles with Mobile Hotspot/HondaLink® systems using a 4G LTE modem, which allegedly acts as a UE under 3GPP standards to manage buffer status and data selection for transmission (Compl. ¶¶168, 171-178).

U.S. Patent No. 7,684,318 - "SHARED-COMMUNICATIONS CHANNEL UTILIZATION FOR APPLICATIONS HAVING DIFFERENT CLASS OF SERVICE REQUIREMENTS"

  • Technology Synopsis: The patent relates to managing a shared communications channel by queuing data frames and setting a "transmit opportunity" length based on the queue's priority. This allows different applications (e.g., latency-tolerant vs. latency-intolerant) to share the channel intelligently (Compl. ¶¶56, 188).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶188).
  • Accused Features: The complaint accuses Honda vehicles with in-vehicle Wi-Fi that utilizes the IEEE 802.11 standard, which allegedly supports Quality of Service (QoS) via the Enhanced Distributed Channel Access (EDCA) mechanism for prioritizing traffic in different queues (Compl. ¶¶187, 190-192).

U.S. Patent No. 8,953,641 - "METHODS AND APPARATUS FOR MULTI-CARRIER COMMUNICATIONS WITH VARIABLE CHANNEL BANDWIDTH"

  • Technology Synopsis: The patent describes a mobile station in an OFDMA system. It receives broadcast information in a first, narrow band and uses that information to determine a second, wider band for data communication. This allows for efficient network access across variable channel bandwidths (Compl. ¶¶59, 204).
  • Asserted Claims: The complaint asserts independent claim 11 (Compl. ¶204).
  • Accused Features: The complaint accuses Honda vehicles with 4G LTE modems (e.g., Qualcomm Snapdragon) for Mobile Hotspot/HondaLink®, alleging these systems operate as mobile stations under 3GPP standards by receiving broadcast information on a physical broadcast channel (a "first band") to access the wider data channel (Compl. ¶¶203, 205-209).

U.S. Patent No. 8,811,356 - "COMMUNICATIONS IN A WIRELESS NETWORK"

  • Technology Synopsis: The patent describes a user equipment (UE) with a processor configured to receive resource allocation information for an uplink physical control channel. The UE sends data on a separate physical uplink shared channel in assigned intervals and, in other intervals, sends a signal on the control channel based on the received allocation information (Compl. ¶¶62, 225).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶225).
  • Accused Features: The complaint accuses Honda vehicles with 4G LTE modems supporting Mobile Hotspot/HondaLink®, alleging these systems operate as UEs compliant with 3GPP standards that distinguish between the physical uplink control channel (PUCCH) and physical uplink shared channel (PUSCH) for sending control signals and data, respectively (Compl. ¶¶224, 227-231).

III. The Accused Instrumentality

Product Identification

  • The complaint names numerous Honda and Acura vehicles equipped with specific electronic systems as the accused instrumentalities. For the ’283 Patent, the accused products are the Honda Odyssey, Passport, and Pilot (Compl. ¶64). For the ’608 Patent, the accused products include a wider range of Honda and Acura models equipped with the Honda Navigation System, such as the Pilot, Odyssey, Accord, and CR-V (Compl. ¶79).

Functionality and Market Context

  • The relevant functionality for the ’283 Patent allegations is the in-vehicle infotainment system, which allegedly uses the MOST (Media Oriented Systems Transport) network as an internal data bus ("first network") and communicates with external cellular networks ("second network") (Compl. ¶¶66-67, 70). A system diagram in the complaint shows various components like the tuner unit, telematics control unit, and infotainment control unit connected via a MOST bus. This diagram illustrates the alleged "first network" of components (Compl. p. 26). The functionality for the ’608 Patent is the Honda Satellite-Linked Navigation System, which allows users to search for points of interest by category (a "preference") within a defined geographic area and displays matching results (Compl. ¶¶81, 83, 85). Screenshots from Honda's informational materials depict the user interface for selecting categories like "Barbecue" and viewing a list of nearby restaurants that match the query (Compl. p. 32).

IV. Analysis of Infringement Allegations

U.S. Patent No. 6,832,283 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
Method for addressing components of a first network in a data bus system in a transport vehicle... The accused automobiles allegedly use MOST networks, which are data bus systems in a transport vehicle. ¶67 col. 1:12-14
...in which each component is assigned a first address for mutual communication within the network and the first addresses are stored in a central register... The MOST network allegedly assigns addresses to components, and a "NetworkMaster" generates a "Central Registry" to store these addresses. ¶¶68-69 col. 1:15-18
...wherein at least one particular component of the first network communicates with a second network, said one component, when dialling [sic] into the second network, is assigned a second address by the second network... The Infotainment System, HondaLink, or Telematics Control Unit allegedly communicates with external cellular networks and is assigned a second address by that network. ¶¶70-71 col. 2:24-28
...and wherein, within the first network, addressing takes place on the basis of function-specific address components, identical function blocks of the components being addressed via identical function-specific address components. The complaint alleges that addressing in the MOST network takes place on the basis of function-specific address components. ¶68 col. 2:32-37
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the addressing scheme of the industry-standard MOST protocol, as implemented by Honda, meets the specific limitation of "addressing... on the basis of function-specific address components" as defined and required by the patent. The interpretation of "dialling into" a network may also be disputed in the context of a modern "always-on" cellular data connection.
    • Technical Questions: The complaint alleges the existence of a "central register" by citing the MOST specification's description of a "Central Registry" generated by a "NetworkMaster" (Compl. ¶69). A technical question for the court will be whether the functionality of this MOST registry is equivalent to the "central register" where "first addresses are stored" as claimed.

U.S. Patent No. 9,602,608 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
...receiving a first user preference, a location of a mobile device of the first user, and a geographic area limitation; The Honda Navigation System allegedly receives a user's search for a category (e.g., "Barbecue") as a "preference" and uses the vehicle's location as the geographic area. ¶83 col. 12:28-36
...storing, for a plurality of objects, a set of attributes of each corresponding object, and a location of the corresponding object; The system allegedly stores a database of points of interest ("objects") with associated attributes (e.g., restaurant type) and locations. ¶84 col. 12:37-43
...determining an object... that matches the first user based on at least: (a) the set of attributes for the object satisfies the first user preference, and (b) the distance between the received location... and the object is within the geographic area limitation; The system allegedly determines matches by filtering the database based on the selected category and proximity to the vehicle's location. ¶85 col. 12:44-55
...sending to the first user... information about the matching object; The system allegedly displays a list of matching places, such as restaurants, to the user. ¶86 col. 12:56-59
  • Identified Points of Contention:
    • Scope Questions: A primary point of contention may be the construction of "user preference." The complaint equates a one-time search query (e.g., for a restaurant category) with a "preference." Defendant may argue that the claim requires a more persistent, stored preference, rather than a transient search term.
    • Technical Questions: What evidence does the complaint provide that the accused system determines a match based on both attributes and distance simultaneously as required by the claim's "based on at least" language, versus performing a sequential filtering process? The complaint's screenshots show a search being initiated "near Signal Hill, CA" and then showing results, which may support the allegation (Compl. p. 32).

V. Key Claim Terms for Construction

  • The Term: "function-specific address components" (’283 Patent, cl. 1)

  • Context and Importance: This term is central to the novelty of the claimed addressing method. The infringement analysis for the ’283 Patent will depend on whether the addressing used in Honda's implementation of the MOST protocol is based on components' functions in the manner claimed, rather than merely their physical or logical position on the network.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language itself is broad, referring to addressing that "takes place on the basis of" these components without specifying the exact mechanism. The patent summary states this approach is advantageous because a component can be addressed via its "main function block" (’283 Patent, col. 2:36-39).
    • Evidence for a Narrower Interpretation: The claim requires that "identical function blocks" are addressed via "identical function-specific address components." This may suggest a specific one-to-one mapping rule that must be present in the accused system, potentially narrowing the term's scope to exclude systems that use other identifiers (like instance IDs) to differentiate identical blocks.

  • The Term: "receiving a first user preference" (’608 Patent, cl. 1)

  • Context and Importance: The infringement case for the ’608 Patent hinges on whether a user's act of selecting a search category (e.g., "Restaurants") in a navigation system constitutes "receiving a first user preference." Practitioners may focus on this term because if it is construed to require a persistent, stored setting (like in a user profile), a one-time search query may not infringe.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent title refers to a "User's Stated Preference," which could support Plaintiff's view that any preference explicitly stated by the user, including a search query, falls within the claim scope. The patent abstract describes matching content "with the expressed preferences of mobile users" (’608 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The complaint's summary of the patent mentions matching profiles of media content with "explicit preferences" and "expressed preferences" (Compl. ¶35). This language, particularly the reference to "profiles," may suggest that the "preference" is part of a stored user profile rather than a single, transient query.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Honda induces infringement by providing customers with vehicles containing the accused systems and instructing them on how to use the infringing features (Compl. ¶¶75, 90). For contributory infringement, the complaint alleges Honda knowingly sells products that are especially adapted for use in an infringing manner and are not staple articles of commerce (Compl. ¶¶76, 91).
  • Willful Infringement: The complaint alleges willful infringement based on Honda's alleged actual knowledge of each patent-in-suit since "not later than receipt of a letter dated October 18, 2021" (Compl. ¶¶74, 89). The continuation of allegedly infringing activity after this date is asserted as the basis for willfulness.

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

  • A core issue will be one of technical implementation: for the numerous patents related to industry standards (e.g., MOST for the '283 Patent; 802.11 for the ’318 Patent; 3GPP/LTE for the ’466, ’138, ’641, and ’356 Patents), does Honda's specific implementation of those standards practice the particular methods claimed by the patents-in-suit, or are there material operational differences?
  • A key question of definitional scope will arise for the '608 Patent: can a user's transient search query in a navigation system be construed as the "first user preference" required by the claim, or does the claim's context require a more persistent, stored preference within a user profile?
  • A central evidentiary question for willfulness will be the effect of the October 18, 2021 notice letters. The case may turn on what actions, if any, Honda took to investigate the infringement allegations post-notice and whether its continued conduct can be characterized as objectively reckless.