DCT

3:25-cv-00340

WirelessWerx IP LLC v. Mitsubishi Motors North America Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00340, N.D. Tex., 02/11/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains regular and established places of business in the Northern District of Texas, including a specific office in Irving, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicle telematics systems infringe a patent related to methods for controlling movable entities using defined geographical zones.
  • Technical Context: The technology involves using GPS and wireless communication to monitor a vehicle's position relative to a pre-defined geographical area (a "geofence") and automatically trigger pre-configured actions based on events, such as the vehicle entering or leaving that area.
  • Key Procedural History: The complaint notes that Plaintiff and its predecessors-in-interest have entered into settlement licenses with other entities for its patents. It alleges these licenses did not require the licensees to produce a patented article, a point which may be relevant to future disputes over patent marking and the calculation of pre-suit damages.

Case Timeline

Date Event
2004-11-05 U.S. Patent No. 7,323,982 Priority Date
2008-01-29 U.S. Patent No. 7,323,982 Issue Date
2025-02-11 Complaint Filing Date

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

U.S. Patent No. 7,323,982 - "Method and System to Control Movable Entities", issued January 29, 2008

The Invention Explained

  • Problem Addressed: The patent notes that at the time of invention, vehicle tracking systems were often limited to simply relaying GPS information to a control center for display on a map, meaning their full potential for automated control and management had not been realized (’982 Patent, col. 1:47-54).
  • The Patented Solution: The invention describes a system where a "transponder" (a device in a vehicle) is loaded with data defining a geographical zone, such as a "pixilated image" or a series of waypoints (’982 Patent, Abstract). A microprocessor within the transponder is programmed to monitor the vehicle’s status relative to this zone and, upon detecting a specific "event" (e.g., entering or leaving the zone, speeding), automatically executes a "configurable operation" (e.g., sending an alert, locking a door, or turning off the ignition) (’982 Patent, col. 2:1-5). This shifts control logic from a central server to the entity itself, enabling autonomous, real-time actions.
  • Technical Importance: This technology allowed for a shift from passive tracking to active, automated fleet management, enabling functions like increasing fleet efficiency, reducing operating costs, and enhancing vehicle security without constant human oversight (’982 Patent, col. 1:35-46).

Key Claims at a Glance

  • The complaint asserts claims 1-16, with claim 1 identified as exemplary (Compl. ¶16, ¶21).
  • Independent Claim 1 (Method):
    • loading from a computing device to a transponder's memory a plurality of coordinates;
    • programming a microprocessor of the transponder to define a geographical zone by creating an enclosed area on a pixilated image using said plurality of coordinates, wherein said enclosed area is representative of a geographical zone;
    • programming the microprocessor in the transponder to determine the occurrence of an event associated with a status of the entity in relation to the geographical zone; and
    • configuring the microprocessor to execute a configurable operation if the event occurs.
  • The complaint asserts one or more of claims 1-61, suggesting it may seek to assert a broader range of claims, including dependent claims, as the case proceeds (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint does not name specific products, referring generally to "Defendant's Accused Products" and "systems, products, and services in the field of wireless control" (Compl. ¶16, ¶21). Given the Defendant is an automotive manufacturer, these likely refer to vehicle telematics, navigation, and/or remote service platforms.

Functionality and Market Context

The complaint alleges that Defendant "develops, designs, manufactures, distributes, markets, offers to sell and/or sells" products and services that infringe the ’982 Patent (Compl. ¶3). The infringement allegations center on Defendant making, using, selling, and importing these accused systems within the United States (Compl. ¶16). The complaint alleges these products are made available to businesses and individuals throughout the U.S. (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s Accused Products infringe at least claim 1 of the ’982 Patent (Compl. ¶16, ¶21). It states that a claim chart demonstrating this infringement is attached as Exhibit B; however, this exhibit was not included with the filed complaint (Compl. ¶21). The complaint’s narrative theory is that Defendant’s systems and services for wireless control, when made, used, or sold, practice the methods claimed in the ’982 Patent (Compl. ¶16, ¶21). Without the referenced exhibit, the specific mapping of claim elements to accused product features is not detailed in the pleading.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether Defendant's systems, which likely use modern vector map data or simple circular geofences, practice the claimed method of defining a zone by "creating an enclosed area on a pixilated image." The interpretation of this limitation will be critical.
    • Technical Questions: A key evidentiary question will be whether the accused systems perform the claimed "programming" and "configuring" steps within the vehicle's transponder, as required by the claims, or if this logic is primarily executed on a remote server, which could create a mismatch with the claim language.

V. Key Claim Terms for Construction

  • The Term: "a geographical zone by creating an enclosed area on a pixilated image"

    • Context and Importance: This term appears in independent claim 1 and defines the core technical mechanism for establishing the geofence. The case may turn on whether Defendant's method of defining geographical boundaries falls within the scope of this term. Practitioners may focus on this term to determine if the patent is limited to a specific, older method of graphical representation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent repeatedly refers to defining zones more generally through "waypoints" (a coordinate and radius), suggesting that "pixilated image" could be seen as one example of a broader concept of a digitally-defined zone (’982 Patent, Abstract; col. 14:56-65).
      • Evidence for a Narrower Interpretation: The specification provides a detailed description of creating a zone by drawing a square around an area, dividing it into an 80x80 pixel map, and activating pixels to form an outline, which a court could view as the definition of the claimed term (’982 Patent, col. 16:36-40; Fig. 5A).

  • The Term: "configurable operation"

    • Context and Importance: This term defines the action taken by the transponder when an event is detected. The breadth of this term will determine what types of automated vehicle actions can be accused of infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that the system allows "interaction with and control of a wide range of peripheral devices" (’982 Patent, col. 6:30-32). This could support a broad reading covering any software-triggered action.
      • Evidence for a Narrower Interpretation: The patent provides a specific list of exemplary operations, such as "turning on an ignition," "locking a door," and "turning on an alarm" (’982 Patent, col. 2:40-49). A defendant may argue the term should be limited to operations that directly control the physical state of the vehicle, rather than simply generating a data notification.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it alleges Defendant actively encourages and instructs customers on infringing uses through its website and product manuals (Compl. ¶22). For contributory infringement, it alleges the products have no substantial non-infringing use (Compl. ¶23).
  • Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’982 patent from at least the filing date of the complaint (Compl. ¶22-23). The complaint expressly reserves the right to amend the pleading to allege pre-suit knowledge if revealed in discovery (Compl. p. 6, fns. 2-3).

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

  1. Evidentiary Specificity: The complaint is general and does not identify specific accused products or their precise functionalities. A primary threshold question will be whether discovery reveals that Mitsubishi's vehicle telematics systems actually perform the claimed on-board processing, or if the geofencing logic resides primarily on backend servers, potentially taking them outside the scope of the claims.
  2. Claim Construction and Technological Obsolescence: A core legal battle will concern the scope of the term "geographical zone by creating an enclosed area on a pixilated image." The case will likely hinge on whether this claim language can be construed to read on modern mapping and geofencing technologies or if it is inextricably tied to the specific "pixilated image" embodiment detailed in the patent, raising questions about the patent’s applicability to current systems.
  3. Damages and Pre-Suit Conduct: Plaintiff’s proactive discussion of its prior settlement licenses and non-practicing status (Compl. ¶25-26) signals an anticipated dispute over compliance with the patent marking statute. A key question for damages will be whether Plaintiff can establish that it met its obligations under 35 U.S.C. § 287, which is a prerequisite for recovering damages for infringement that occurred before the lawsuit was filed.