WirelessWerx IP LLC v. American Honda Motor Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WirelessWerx IP LLC (Texas)
  • Defendant: American Honda Motor Company, Inc. (Delaware/California)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-00342, 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 within the Northern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s products and services for wireless vehicle control infringe a patent related to monitoring and controlling movable entities using pre-configured geographical zones.
• Technical Context: The technology at issue falls within the domain of vehicle telematics and geofencing, which involves tracking a vehicle's location and triggering actions when it enters or leaves a defined geographic area.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities concerning its patent portfolio, but states that these licenses did not involve admissions of infringement or authorize the production of patented articles. Plaintiff is a non-practicing entity.

Case Timeline

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

U.S. Patent No. 7,323,982 - Method and System to Control Movable Entities

• Patent Identification: U.S. Patent No. 7,323,982, issued on January 29, 2008 (the ’982 Patent).

The Invention Explained

• Problem Addressed: The patent describes a technical landscape where existing vehicle tracking systems were seen as limited, primarily relaying GPS information to a central server for passive monitoring on a map, with their full potential "yet to be maximized" (’982 Patent, col. 1:48-54).
• The Patented Solution: The invention discloses a system where a transponder attached to a movable entity possesses local intelligence. This transponder can be loaded with coordinates that define a "geographical zone" on a "pixilated image" stored in its memory (’982 Patent, Abstract). A microprocessor within the transponder is programmed to determine the occurrence of an event (e.g., entering or leaving the zone) and can execute a "configurable operation" (e.g., locking a door, turning off the ignition) in response, without needing constant direction from a central server (’982 Patent, col. 2:1-4).
• Technical Importance: The described technology represents a shift from purely passive, server-based vehicle tracking to an active, locally intelligent system capable of autonomous, pre-configured actions based on geofencing events (’982 Patent, col. 1:57-col. 2:4).

Key Claims at a Glance

• The complaint asserts claims 1-16, with a focus on independent claim 1 (’982 Patent, col. 27:30-49; Compl. ¶ 16).
• The essential elements of independent claim 1 are:
  • A method to wirelessly control an entity with an attached transponder, comprising:
  • loading a plurality of coordinates from a computing device to the transponder's memory;
  • programming the transponder's microprocessor to define a geographical zone by creating an enclosed area on a pixilated image using those coordinates;
  • programming the microprocessor to determine when an event occurs related to the entity's status within that zone; and
  • configuring the microprocessor to execute a configurable operation if the event occurs.
• The complaint reserves the right to assert additional claims, including dependent claims, and elsewhere references claims 1-61 (Compl. ¶ 21).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, systems, or services by name. It refers generally to "Defendant's Accused Products" (Compl. ¶ 16) and "systems, products, and services in the field of wireless control" (Compl. ¶ 21).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or operation. It makes general allegations that Defendant "develops, designs, manufactures, distributes, markets, offers to sell and/or sells infringing products and services" (Compl. ¶ 3).

IV. Analysis of Infringement Allegations

The complaint states that a claim chart demonstrating infringement of claim 1 is attached as Exhibit B (Compl. ¶ 21). This exhibit was not included with the filed complaint. The complaint body itself does not contain a narrative infringement theory or provide sufficient technical detail to construct a claim chart summarizing the infringement allegations. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether any of Honda's telematics systems, which may use modern vector-based mapping or server-side processing, can be said to practice the claim limitation of "creating an enclosed area on a pixilated image" stored within the transponder itself.
  • Technical Questions: A key evidentiary issue will be whether the complaint can substantiate that the accused products perform the claimed functions locally on the in-vehicle device, as opposed to relying on a remote server. This includes the local "programming" of the microprocessor to define zones and the local execution of "configurable operations" based on events detected by that microprocessor.

V. Key Claim Terms for Construction

The Term: "creating an enclosed area on a pixilated image using said plurality of coordinates"

• Context and Importance: This term appears central to defining the invention's specific technical implementation. Practitioners may focus on this term because its construction will determine whether the claim reads on modern geofencing systems that may use different data structures (e.g., vector graphics) or perform zone calculations on a remote server rather than on a local "pixilated image."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly disclaim other methods, which a party might argue leaves the door open for equivalents. However, the specification consistently refers to this specific method.
  • Evidence for a Narrower Interpretation: The specification provides a detailed description of how this is achieved, including drawing a "bounding" square, pixilating it, and activating pixels that lie on the lines forming the zone boundary (’982 Patent, col. 15:18-43). This detailed description of a specific embodiment could be used to argue the claim is limited to such a raster-based, device-side implementation.

The Term: "configurable operation"

• Context and Importance: The scope of this term will be critical to determining what responsive actions constitute infringement. Practitioners may focus on this term to dispute whether a standard, hard-coded system alert qualifies, or if the term requires the level of user-customization shown in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a long list of potential operations, including "turning on an ignition to the entity, turning off the ignition to the entity, increasing speed of the entity, decreasing speed of the entity," and many others, suggesting a broad scope of possible actions (’982 Patent, col. 2:41-49).
  • Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific "Configuration Utility" with tabs and fields for a user to define how events trigger specific outputs (’982 Patent, Figs. 4A-4G, col. 11:16-col. 12:65). A party could argue the term is limited to operations that are configurable by an end-user in such a manner.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed others (e.g., its customers...)" on how to use its products to infringe (Compl. ¶ 22). Contributory infringement is also alleged, based on the theory that the accused products are not staple articles of commerce and their only reasonable use is an infringing one (Compl. ¶ 23).
• Willful Infringement: The complaint alleges willfulness based on Defendant's knowledge of the ’982 Patent "from at least the filing date of the lawsuit" and reserves the right to amend the complaint if pre-suit knowledge is discovered (Compl. ¶ 22, fn. 2).

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

• A core issue will be one of definitional scope: can the term "creating an enclosed area on a pixilated image," which is described in the patent as a specific device-side, raster-based process, be construed to cover modern telematics systems that may use different technologies like server-side processing or vector-based map data?
• A key evidentiary question will be one of functional operation: given the complaint’s lack of specificity, the plaintiff will face the challenge of demonstrating through discovery that an accused Honda system performs the specific, multi-step method of Claim 1, particularly the requirements for local processing, device-side zone definition, and execution of locally "configurable" operations.