DCT
3:25-cv-01362
Ad Innovations LLC v. Mercedes Benz USA LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AD Innovations, LLC (Wyoming)
- Defendant: Mercedes-Benz USA, LLC (Delaware)
- Plaintiff’s Counsel: DNL Zito
- Case Identification: 3:25-cv-01362, N.D. Tex., 09/29/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the Northern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s S-Class and EQS vehicles, equipped with the MBUX multimedia and Drive Pilot systems, infringe a patent related to selectively switching between in-vehicle entertainment audio and critical external sounds.
- Technical Context: The technology addresses the safety risk of drivers in modern, sound-insulated vehicles being unable to hear external sounds such as emergency vehicle sirens.
- Key Procedural History: The complaint is an Amended Complaint for Patent Infringement. No other significant procedural events, such as prior litigation or administrative patent challenges, are mentioned in the filing.
Case Timeline
| Date | Event |
|---|---|
| 2004-10-18 | ’341 Patent Priority Date |
| 2013-11-26 | ’341 Patent Issue Date |
| 2021-12-22 | Date of press release regarding Defendant’s deployment of Cerence Emergency Vehicle Detection technology |
| 2025-09-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,594,341 - "System and Method for Selectively Switching Between a Plurality of Audio Channels"
- Patent Identification: U.S. Patent No. 8,594,341, "System and Method for Selectively Switching Between a Plurality of Audio Channels," issued November 26, 2013 (’341 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section describes that while digital noise reduction and improved sound isolation in vehicles and headphones enhance the user's listening experience, they create a safety problem by preventing the user from hearing critical external sounds, such as the horn of another car or the siren of an emergency vehicle, which may be required by law. (’341 Patent, col. 1:26-50).
- The Patented Solution: The invention is a system that allows a user to listen to a primary audio source (e.g., music) without distraction, while it simultaneously monitors the external acoustic environment. (’341 Patent, col. 4:20-27). The system stores a library of predetermined sound patterns (e.g., a siren) and, upon detecting a match with an external sound, automatically interrupts the primary audio and plays the external sound for the user. (’341 Patent, Abstract; col. 4:55-63).
- Technical Importance: This approach automates a critical safety function, allowing for an immersive audio experience without compromising the driver's awareness of high-priority external acoustic events. (Compl. ¶34).
Key Claims at a Glance
- The complaint asserts independent apparatus Claim 1, independent system Claim 15, and independent method Claim 40 (Compl. ¶64).
- Independent Claim 1, an apparatus claim, includes the following essential elements:
- A vehicular audio device
- A first audio input connection for receiving audio content
- A second audio input connection for receiving an acoustic signal from outside the vehicle
- A memory device for prestoring a plurality of predetermined digital sound patterns
- A controller for receiving both audio streams, determining if the external acoustic signal matches a prestored pattern, and selectively outputting either the audio content (if no match) or the external acoustic signal (if there is a match)
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Mercedes-Benz S-Class and EQS sedans equipped with the MBUX multimedia system, the Drive Pilot automated driving system, and integrated Cerence Emergency Vehicle Detection (EVD) technology (Compl. ¶¶66, 72, 78).
Functionality and Market Context
- The complaint alleges the MBUX system functions as a vehicular audio device, providing entertainment audio from sources like a user's smartphone via Bluetooth (Compl. ¶67). The system allegedly uses the vehicle's microphones to capture external sounds, which are processed by the integrated Cerence EVD software (Compl. ¶68). The Cerence EVD system is alleged to recognize over 1,500 different siren patterns prestored in memory (Compl. ¶69).
- When a siren is detected, the system allegedly overrides the ongoing audio playback (e.g., music) to provide visual and audio alerts to the driver, notifying them of the approaching emergency vehicle (Compl. ¶71). A screenshot from a promotional video shows the vehicle's digital dashboard displaying an alert that "the DRIVE PILOT can detect emergency vehicles approaching from behind" (Compl. p. 29). Another promotional image for the Cerence EVD technology notes that it "Works Also While Music Is Playing," illustrating the simultaneous monitoring and playback functions (Compl. p. 31).
IV. Analysis of Infringement Allegations
'341 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an apparatus for selectively switching between audio channels, the apparatus comprising: a vehicular audio device | The Mercedes-Benz S-Class and EQS vehicles are equipped with the MBUX multimedia system, which functions as the vehicular audio device. A screenshot shows the MBUX central display screen (Compl. p. 27). | ¶66 | col. 8:20-22 |
| a first audio input connection located inside the vehicle for receiving audio content | The MBUX system enables users to connect mobile devices via Bluetooth to listen to media such as music. | ¶67 | col. 8:23-25 |
| a second audio input connection for receiving an acoustic signal associated with sound external to the vehicle | The MBUX system integrates Cerence EVD, which utilizes the vehicle's microphones to detect sirens from emergency vehicles external to the vehicle. | ¶68 | col. 8:26-29 |
| a memory device for prestoring a plurality of predetermined digital sound patterns, each of the plurality...corresponding to a preselected external audio sound | The Cerence EVD feature allegedly recognizes over 1,500 different sirens from police cars, fire trucks, and ambulances, which are prestored as digital sound patterns in the system's memory. | ¶69 | col. 8:30-35 |
| a controller for receiving the audio content...and the acoustic signal...for determining whether the acoustic signal matches at least one of the plurality of predetermined digital sound patterns | The MBUX system includes a processing unit that acts as a controller, simultaneously receiving music via Bluetooth and microphone inputs, and determining if a detected siren matches one of the 1,500 prestored patterns. | ¶70 | col. 8:36-42 |
| if the acoustic signal...matches...the controller sends the acoustic signal to an output connection...if the acoustic signal does not match...the controller outputs the audio content | Upon detecting a siren, the MBUX system overrides the music and plays audio alerts through the vehicle's speakers. If no siren is detected, the system continues playing music. | ¶71 | col. 8:42-53 |
Identified Points of Contention:
- Scope Questions: A central question may be whether the term "controller," which the patent describes in the context of specific hardware like a "microprocessor" and switching mechanisms like a "relay, transistor, etc." (’341 Patent, col. 4:46-50), can be construed to read on the integrated software (Cerence EVD) and processing unit of the MBUX system as alleged.
- Technical Questions: The complaint alleges the Cerence EVD system employs "acoustic echo cancellation to isolate the siren's sound from background noise, thereby generating a processed signal" (Compl. ¶68). A question for the court may be whether this "processed signal" is the same as the "acoustic signal" required by the claim, or if the extensive processing creates a fundamentally different type of signal not contemplated by the patent.
V. Key Claim Terms for Construction
- The Term: "controller"
- Context and Importance: The "controller" is the core of the claimed invention, as it performs the critical steps of receiving two separate audio streams, determining if a match exists with stored patterns, and switching the output accordingly. The viability of the infringement case may depend on whether the accused MBUX processing unit, which executes these functions largely in software, falls within the patent's definition of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the controller as a "microprocessor" which receives the acoustic signal and determines whether it should interrupt the audio content, a relatively general description. (’341 Patent, col. 4:35-39).
- Evidence for a Narrower Interpretation: The specification also describes the controller in conjunction with specific hardware, stating it controls a "switching mechanism 128, e.g., a relay, transistor, etc." (’341 Patent, col. 4:46-48). Further, an alternative embodiment describes using a dedicated "digital signal processor (DSP) 240" for the pattern matching function to increase speed, suggesting a hardware-focused implementation. (’341 Patent, col. 5:46-54).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the accused vehicles with the MBUX and Cerence EVD systems and encourages customers to use the infringing functionality (Compl. ¶¶84-85). This encouragement is allegedly accomplished through marketing materials and vehicle operation.
- Willful Infringement: The complaint does not contain a separate count for willful infringement. However, it alleges that Defendant has had knowledge of the ’341 Patent and the alleged infringement "at least as of the filing of this lawsuit and service of the Complaint" and continued its allegedly infringing conduct, which could form the basis for a claim of post-suit willfulness (Compl. ¶95).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "controller," described in the patent with references to specific hardware components like relays and dedicated DSPs, be construed to cover the integrated MBUX processing unit that allegedly performs the claimed functions primarily through software (Cerence EVD)?
- A key evidentiary question will be one of technical mapping: does the accused system's method of generating a "processed signal" after "acoustic echo cancellation" meet the claim requirement of receiving and determining a match for an "acoustic signal associated with sound external to the vehicle," or does this processing create a technical distinction that places it outside the claim's scope?