Peregrine Data LLC v. SmartDrive Systems Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peregrine Data LLC (NM)
  • Defendant: SmartDrive Systems, Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC; DNL Zito
• Case Identification: 4:25-cv-00516, N.D. Tex., 05/15/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has an established place of business within the Northern District of Texas where it has allegedly committed acts of patent infringement.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle camera systems infringe a patent related to a method for capturing and recording a perimeter view around an automobile for later evidentiary use without distracting the driver.
• Technical Context: The technology at issue involves automotive video recording systems designed to capture evidence of traffic incidents, a field with significant market implications for commercial fleet management, insurance, and law enforcement.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,319,619 - "Stored vision for automobiles", issued November 27, 2012

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of obtaining reliable evidence after a vehicular accident or crime, noting that a driver's primary focus must be on safely operating the vehicle, making it "burdensome, difficult, and even dangerous" for the driver to simultaneously monitor and record external events (U.S. Patent No. 8,319,619, col. 1:18-30). Existing systems are described as insufficient because they may not capture events occurring around the entire vehicle (col. 1:48-51).
• The Patented Solution: The invention proposes a method and system for automatically recording the entire perimeter of a vehicle using multiple cameras (col. 2:19-23). This data is continuously transmitted to a central digital recorder, which is preferably inaccessible to the driver during operation to prevent distraction (col. 2:50-57). The recorded information is intended for offline recovery after the trip is complete, providing "correct and reliable information" for legal proceedings (col. 2:14-18; Fig. 1).
• Technical Importance: The claimed method addresses the persistent challenge of balancing the need for comprehensive evidence collection with the paramount goal of driver safety (col. 2:11-15).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the ’619 Patent, identified as "Exemplary '619 Patent Claims" in an exhibit not attached to the public filing (Compl. ¶11). Independent claims 1 and 2 are available for assertion.
• The essential elements of independent method claim 1 include:
  • placing a plurality of cameras in circumferentially spaced positions around the periphery of the automobile at about the middle of its vertical height
  • activating all cameras to operate continuously throughout an entire trip
  • recording images acquired by each camera in a corresponding separate file
  • using separate node files to provide eight separate files of real-time recorded data
  • using the cameras as a set, with each operating separately and individually
  • locating all apparatus so that it is inaccessible to a driver throughout the entire trip

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products, referring to them generally as "Exemplary Defendant Products" identified in charts incorporated by reference as Exhibit 2 (Compl. ¶11, ¶13).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement but incorporates its substantive theory by reference to claim charts in an exhibit that was not publicly filed (Compl. ¶13, ¶14). A detailed analysis of the infringement allegations is therefore not possible. However, the asserted patent claims suggest that the core of the infringement allegation is that Defendant's products practice a method of continuously recording video from multiple cameras positioned on a vehicle to separate files on a digital medium that is inaccessible to the driver during a trip.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "at about the middle of its vertical height" (Claim 1)

  • Context and Importance: The precise physical location of the cameras is a specific limitation. Its construction will be critical in determining whether accused products with cameras mounted in potentially different locations (e.g., on a windshield or dashboard) meet this element.
  • Intrinsic Evidence for a Broader Interpretation: The specification suggests integrating cameras into "current headlight, brake light, and/or side marker electrical housings," which may not be located at the exact vertical midpoint of the vehicle, potentially supporting a more flexible interpretation of "about the middle" (col. 4:47-49).
  • Intrinsic Evidence for a Narrower Interpretation: The claim language itself provides a specific positional requirement. A defendant may argue that this term should be interpreted according to its plain meaning, referring to the approximate vertical centerline of the main automobile body, distinct from higher (roof) or lower (bumper) positions.

• The Term: "inaccessible to a driver" (Claim 1)

  • Context and Importance: This term is central to the invention's stated purpose of preventing driver distraction. Whether an accused system is "inaccessible" will likely be a key point of dispute.
  • Intrinsic Evidence for a Broader Interpretation: The patent's focus is on preventing the driver from being distracted by the act of recording; parties may argue that "inaccessible" could refer to a system where the recording function cannot be manipulated by the driver, even if other device features are available.
  • Intrinsic Evidence for a Narrower Interpretation: The specification states that the apparatus is "preferably inacessible to the driver while driving the vehicle" and suggests a "battery switch located in a position that is inaccessible to the driver while driving," which could support an argument for physical inaccessibility ('619 Patent, col. 2:56-57; col. 5:53-56).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement; it alleges only "Direct Infringement" (Compl. ¶11).
• Willful Infringement: The complaint does not contain allegations of willful infringement.

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

• A core issue will be one of locational scope: can the claim term "at about the middle of its vertical height" be construed to read on vehicle camera systems that may be mounted at locations such as the windshield, dashboard, or external mirrors, rather than on the side of the vehicle body itself?
• A key evidentiary question will be one of technical implementation: what evidence will be presented to show that the accused systems record data in the specific architecture required by Claim 1, which calls for "eight separate files of real-time recorded data obtained from the respective cameras"?
• The case may also turn on the functional definition of the term "inaccessible to a driver." The court will need to determine whether this requires the physical apparatus to be out of the driver's reach or if it is satisfied by software lockouts or non-interactive recording functions that prevent driver distraction.