WirelessWerx IP LLC v. Tail Light LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WirelessWerx IP LLC (Texas)
  • Defendant: Tail Light, LLC d/b/a Bouncie (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: WirelessWerx IP LLC v. Tail Light, LLC d/b/a Bouncie, 3:25-cv-01026, N.D. Tex., 04/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the Northern District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Bouncie vehicle telematics products and services infringe a patent related to systems and methods for remotely controlling movable entities via transponders and pre-configured geographical zones.
• Technical Context: The technology concerns vehicle telematics, specifically the use of on-board transponders with GPS capabilities to monitor and control a vehicle's status and functions in relation to user-defined geographical boundaries (geofences).
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity. The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other, unnamed entities, but asserts these licenses did not grant rights to produce a patented article and therefore do not trigger patent marking requirements.

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, "Method and System to Control Movable Entities," issued January 29, 2008 (’982 Patent).

The Invention Explained

• Problem Addressed: The patent describes a market where existing GPS vehicle tracking systems were "limited to relaying the GPS information to a control center or a web server and plotting the position of the vehicle on a computer map," suggesting that the full potential of such systems had not been realized (’982 Patent, col. 1:50-54).
• The Patented Solution: The invention proposes a more intelligent system where a transponder attached to a "movable entity" (e.g., a vehicle) is itself programmed to define a geographical zone and autonomously execute a pre-configured operation when a specific event occurs in relation to that zone, such as entering or leaving it (’982 Patent, Abstract). This shifts some decision-making logic from a central server to the remote device, enabling local, pre-programmed responses to location-based events (’982 Patent, col. 2:1-5).
• Technical Importance: This technology allows for more advanced and automated control over remote assets, moving beyond simple location tracking to enable pre-configured, location-aware actions and rules. (’982 Patent, col. 5:25-34).

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-61 (Compl. ¶18). Independent claim 1 is central.
• Independent Claim 1 recites a method with the following essential elements:
  • 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;
  • 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 reserves the right to assert dependent claims (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are identified as "Bouncie’s products," available through its website (Compl. ¶15).

Functionality and Market Context

• The complaint alleges that Defendant "maintains, operates, and administers a system with methods and user interface for controlling an entity having an attached transponder" (Compl. ¶18). A cited help article titled "device-health-and-location" suggests the products involve vehicle tracking and monitoring (Compl. ¶21). The functionality is broadly characterized as a system for controlling a transponder-equipped entity, which Plaintiff alleges infringes the ’982 Patent (Compl. ¶18). The complaint does not provide further technical detail on the operation of the Bouncie system.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not filed with the complaint (Compl. ¶19). The infringement theory is based on general allegations in the body of the complaint. No probative visual evidence provided in complaint.

’982 Patent Infringement Allegations

• Identified Points of Contention:
  • Architectural Questions: A central question is whether the accused Bouncie system performs the key processing steps—defining zones and determining events—on the transponder's microprocessor as required by the claim language. The complaint does not provide evidence to distinguish between on-device processing and an alternative architecture where this logic resides on a remote server that communicates with the transponder.
  • Technical Questions: What evidence does the complaint provide that the accused system defines a geographical zone by "creating an enclosed area on a pixilated image"? The complaint's allegations are high-level and do not describe the specific data structures or methods used by the Bouncie system to represent geofences.

V. Key Claim Terms for Construction

• The Term: "programming a microprocessor of the transponder to define a geographical zone"

  • Context and Importance: The location of the processing logic is central to the claim. Practitioners may focus on this term because its construction will determine whether the claim reads on systems where geofence logic is executed on a back-end server (a common modern architecture) versus systems where this logic must reside and execute locally on the vehicle's hardware.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that "programming" is broad enough to include configuring the transponder to respond to commands from a server that performs the "defining" function, thereby indirectly causing the transponder to operate within a defined zone.
    • Evidence for a Narrower Interpretation: The claim recites programming the microprocessor of the transponder to perform the action of defining the zone. This language, combined with the patent's abstract describing a microprocessor "programmed to determine the occurrence of an event," suggests the defining and determining logic is intended to be executed locally on the device itself (’982 Patent, Abstract).

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

  • Context and Importance: This term appears to require a specific method for representing a geographical zone. Its construction is critical because if interpreted narrowly, it may not cover modern systems that use alternative data representations (e.g., vector-based polygons) for geofences.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "pixilated image" should be understood functionally as any digital grid-based representation of a space, not necessarily a visual graphic file. The specification discusses assigning coordinates to pixels and connecting them with lines, which could be framed as a logical process not tied to a specific image format (’982 Patent, col. 15:20-31).
    • Evidence for a Narrower Interpretation: The claim language is specific. The specification explicitly describes and illustrates the use of a "pixel map," showing an 80x80 grid where pixels are activated to form a boundary shape (’982 Patent, col. 15:53-61; Fig. 5A). This provides strong support for a narrower construction tied to a literal bitmap or pixel-grid data structure.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by providing instructions to customers on how to use the Bouncie system in an infringing manner (Compl. ¶20). It also alleges contributory infringement, asserting that Defendant provides instruction manuals and online help for infringing uses and that the product is not a staple commodity with substantial non-infringing uses (Compl. ¶21).
• Willful Infringement: The complaint alleges knowledge of the ’982 Patent as of the filing date of the lawsuit, establishing a basis for post-suit willfulness (Compl. ¶¶20-21). The prayer for relief also seeks a declaration of willfulness if discovery reveals pre-suit knowledge of the patent (Compl. p. 8, ¶e).

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

• A core issue will be one of architectural alignment: Does the accused Bouncie system perform its geofence definition and event determination logic locally on the transponder's microprocessor, as the claim language appears to require, or is this functionality primarily handled by remote servers? The complaint’s high-level allegations leave this critical factual question open for discovery.
• A key legal battle will be over definitional scope: Can the claim term "creating an enclosed area on a pixilated image," which is described in the patent with specific reference to pixel-grid maps, be construed broadly enough to read on the potentially different data structures used by a modern telematics system to represent geographical boundaries? The resolution of this claim construction issue may be dispositive.