DCT

1:24-cv-00884

Intellectual Ventures II LLC v. Tesla Inc

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Intellectual Ventures II LLC (exclusive licensee)
- Defendant: Tesla, Inc. (Delaware)
- Plaintiff’s Counsel: Cherry Johnson Siegmund James PLLC; Kasowitz Benson Torres LLP
Case Identification: 1:24-cv-00884, W.D. Tex., 06/04/2025
Venue Allegations: Venue is alleged to be proper in the Western District of Texas because Defendant Tesla, Inc. maintains its principal place of business and corporate headquarters in Austin, Texas, and manufactures accused products within the district.
Core Dispute: Plaintiff alleges that Defendant’s automotive vehicles, particularly their connectivity and Autopilot features, infringe eleven patents related to wireless communications, camera systems, image processing, and resource management.
Technical Context: The technologies at issue involve in-vehicle wireless networking (cellular, Wi-Fi), advanced driver-assistance systems (ADAS) using cameras and sensors, and the underlying computer processing architecture.
Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of at least two of the patents-in-suit ('805 and '639 Patents) as of August 7, 2020, and knowledge of the remaining nine patents as of April 11, 2024, via notice letters. These allegations form the basis for the willful infringement claims.

Case Timeline

Date	Event
1991-12-18	Priority Date: U.S. Patent No. 6,894,639
2000-05-25	Priority Date: U.S. Patent No. 7,181,743
2004-06-16	Priority Date: U.S. Patent No. 7,336,805
2004-08-12	Priority Date: U.S. Patent No. 9,706,500
2004-08-12	Priority Date: U.S. Patent No. 10,952,153
2004-08-25	Priority Date: U.S. Patent No. 9,232,158
2005-05-17	Issue Date: U.S. Patent No. 6,894,639
2006-04-28	Priority Date: U.S. Patent No. 7,916,180
2006-05-08	Priority Date: U.S. Patent No. 10,292,138
2006-12-27	Priority Date: U.S. Patent No. 11,664,889
2007-02-20	Issue Date: U.S. Patent No. 7,181,743
2007-09-27	Priority Date: U.S. Patent No. 10,136,416
2008-02-26	Issue Date: U.S. Patent No. 7,336,805
2011-03-29	Issue Date: U.S. Patent No. 7,916,180
2012-01-20	Priority Date: U.S. Patent No. 11,206,670
2016-01-05	Issue Date: U.S. Patent No. 9,232,158
2017-07-11	Issue Date: U.S. Patent No. 9,706,500
2018-11-20	Issue Date: U.S. Patent No. 10,136,416
2019-05-14	Issue Date: U.S. Patent No. 10,292,138
2020-08-07	Alleged Pre-Suit Knowledge of '805 and '639 Patents
2021-03-16	Issue Date: U.S. Patent No. 10,952,153
2021-12-21	Issue Date: U.S. Patent No. 11,206,670
2023-05-30	Issue Date: U.S. Patent No. 11,664,889
2024-04-11	Alleged Pre-Suit Knowledge of Nine Additional Patents
2025-06-04	Amended Complaint Filing Date

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

U.S. Patent No. 7,336,805 - "Docking Assistant"

Issued: February 26, 2008

The Invention Explained

Problem Addressed: The patent describes the difficulty for operators of large vehicles, such as trucks, to maneuver into specific locations like a parking bay or a loading platform without assistance ('805 Patent, col. 1:11-15).
The Patented Solution: The invention proposes a camera-based system that acquires image data from the vehicle's surroundings. This data is processed to detect "potential target objects" by analyzing their geometric form. A "plausibility" check is performed using a matching algorithm, and a trajectory to the most proximate valid destination is calculated to assist the driver ('805 Patent, col. 2:13-52). The system is designed to identify destinations based on shape alone, without requiring special markers or signatures ('805 Patent, col. 2:5-10).
Technical Importance: This technology represents an early approach to machine vision for vehicle guidance, aiming to automate or assist in precise, low-speed maneuvering tasks that are challenging for human drivers.

Key Claims at a Glance

The complaint asserts infringement of at least exemplary claims of the patent, implying that independent claims are at issue (Compl. ¶55). Independent claim 1 recites:
- A method for assisting guidance of a motor vehicle on the basis of image data,
- comprising acquiring image data from a surrounding field of the motor vehicle,
- extracting positional parameters of at least one potential destination,
- and calculating at least one trajectory describing an optimized travel path to assist subsequent vehicle guidance.
The complaint reserves the right to assert additional claims (Compl. ¶55, ¶62).

U.S. Patent No. 9,706,500 - "Power Control in a Wireless Network"

Issued: July 11, 2017

The Invention Explained

Problem Addressed: The patent addresses the need to manage transmit power in a wireless communication system to balance two competing goals: ensuring a low error rate for a received signal, which requires higher power, and minimizing interference with other signals, which requires lower power ('500 Patent, col. 1:36-52).
The Patented Solution: The invention describes a two-stage power control process with an "outer loop" and an "inner loop." The outer loop adjusts a target signal-to-noise-plus-interference ratio (SNIR Target) based on the observed error rate of the link. The inner loop then tries to force the link to exhibit that SNIR Target by issuing transmit power control (TPC) commands to the mobile device ('500 Patent, col. 2:2-14). This combined approach is intended to compensate for both fast channel fading and changes in interference from other transmitters ('500 Patent, col. 2:32-47).
Technical Importance: This patent details a specific feedback-based method for dynamically managing power in wireless networks, a fundamental challenge in cellular and other radio communication systems.

Key Claims at a Glance

The complaint asserts infringement of at least exemplary claims of the patent (Compl. ¶94). Independent claim 1 recites:
- A network device comprising a transmitter, a receiver, and a processor.
- The processor is configured to select a value of a multi-level transmit power control (TPC) command from a set of values including at least two "up" or "down" values.
- The processor then has the transmitter transmit, on a single physical channel, an allocation of an uplink resource and the multi-level TPC command.
The complaint reserves the right to assert additional claims (Compl. ¶94, ¶101).

Multi-Patent Capsule: U.S. Patent No. 10,292,138

Patent Identification: U.S. Patent No. 10,292,138, "Determining Buffer Occupancy and Selecting Data for Transmission on a Radio Bearer," issued May 14, 2019.
Technology Synopsis: The patent addresses methods for prioritizing data traffic in a wireless system. It describes a user equipment (UE) determining and transmitting buffer occupancy for multiple radio bearers (data channels) and selecting data for transmission based on a received resource allocation, allowing for quality-of-service differentiation ('138 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶107).
Accused Features: The complaint accuses Tesla's automotive vehicles, which provide wireless communication capabilities, of infringement (Compl. ¶107).

Multi-Patent Capsule: U.S. Patent No. 10,952,153

Patent Identification: U.S. Patent No. 10,952,153, "Power Control in a Wireless Network," issued March 16, 2021.
Technology Synopsis: Similar to the '500 Patent, this patent describes a power control method for wireless communications. It details a system combining an open loop scheme (based on path loss) and a closed loop scheme (based on TPC commands) to set the transmit power level of a mobile device ('153 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶120).
Accused Features: The complaint accuses Tesla's automotive vehicles and their wireless communication systems (Compl. ¶120).

Multi-Patent Capsule: U.S. Patent No. 10,136,416

Patent Identification: U.S. Patent No. 10,136,416, "Communicating on a Shared Channel in a Wireless Network," issued November 20, 2018.
Technology Synopsis: The patent describes a method for efficiently managing shared communication channels. User equipment receives broadcast information with bits indicating when a shared channel is active, allowing the device to monitor the channel only during those intervals to determine if information for it is present, thereby saving power ('416 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶133).
Accused Features: The complaint accuses Tesla's automotive vehicles and their wireless communication systems (Compl. ¶133).

Multi-Patent Capsule: U.S. Patent No. 7,916,180

Patent Identification: U.S. Patent No. 7,916,180, "Simultaneous Multiple Field of View Digital Cameras," issued March 29, 2011.
Technology Synopsis: The patent describes a digital camera system with multiple channels, each having its own optics and sensor array. This allows the system to simultaneously capture images with different fields of view (e.g., one wide-angle, one narrow-angle) and combine the data to provide a high-resolution image ('180 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶146).
Accused Features: The complaint accuses Tesla's automotive vehicles, which are equipped with multiple cameras for their Autopilot system (Compl. ¶146, ¶20).

Multi-Patent Capsule: U.S. Patent No. 9,232,158

Patent Identification: U.S. Patent No. 9,232,158, "Large Dynamic Range Cameras," issued January 5, 2016.
Technology Synopsis: This patent addresses capturing images in scenes with high dynamic range (mixed bright and dark areas). It describes a multi-channel camera where each channel has a different, separately controlled integration time. Data from the channels is combined to generate a single image that captures detail in both bright and dark areas ('158 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶159).
Accused Features: The complaint accuses Tesla's automotive vehicles, presumably targeting the multi-camera Autopilot system's performance in varied lighting conditions (Compl. ¶159, ¶20).

Multi-Patent Capsule: U.S. Patent No. 7,181,743

Patent Identification: U.S. Patent No. 7,181,743, "Resource Allocation Decision Function for Resource Management Architecture and Corresponding Programs Therefor," issued February 20, 2007.
Technology Synopsis: The patent describes a resource manager for a distributed computing environment. It generates signals to start, stop, or move applications across different hosts based on information about application performance and host performance, aiming to optimize resource allocation ('743 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶172).
Accused Features: The complaint accuses Tesla's automotive vehicles, likely targeting the onboard computer systems that manage various software processes for vehicle operation (Compl. ¶172).

Multi-Patent Capsule: U.S. Patent No. 6,894,639

Patent Identification: U.S. Patent No. 6,894,639, "Generalized Hebbian Learning for Principal Component Analysis and Automatic Target Recognition, Systems and Method," issued May 17, 2005.
Technology Synopsis: The patent describes a method for distinguishing targets from background clutter in image data. It uses a neural network-based approach ("Hebbian learning") and principal component analysis to select and extract specific features from data to identify targets ('639 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶184).
Accused Features: The complaint accuses Tesla's automotive vehicles, targeting the Autopilot system's "Tesla Vision" and neural net processing for object recognition (Compl. ¶184, ¶13).

Multi-Patent Capsule: U.S. Patent No. 11,206,670

Patent Identification: U.S. Patent No. 11,206,670, "Communication in a Wireless Network Using Restricted Bandwidths," issued December 21, 2021.
Technology Synopsis: The patent describes a method for a device with limited bandwidth capability to operate on a wider-bandwidth network. The device receives synchronization signals within a first, narrow portion of the cell's bandwidth and then receives information indicating other frequency and time resources for acquiring additional system information, allowing it to function without needing to access the full cell bandwidth ('670 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶68).
Accused Features: The complaint accuses Tesla's automotive vehicles and their wireless communication systems (Compl. ¶68).

Multi-Patent Capsule: U.S. Patent No. 11,664,889

Patent Identification: U.S. Patent No. 11,664,889, "Communications in a Wireless Network," issued May 30, 2023.
Technology Synopsis: The patent describes a method for uplink power control using a feedback channel. A user equipment receives a control message with power control bits in one time slot and then transmits a signal in a subsequent time slot at a power level based on the extracted power control information ('889 Patent, Abstract).
Asserted Claims: Exemplary claims are asserted (Compl. ¶81).
Accused Features: The complaint accuses Tesla's automotive vehicles and their wireless communication systems (Compl. ¶81).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as Tesla's automotive vehicles and their components, including but not limited to those offering "Standard Connectivity," "Premium Connectivity," and "Autopilot" features (Compl. ¶4, ¶19, ¶20).

Functionality and Market Context

The accused functionality falls into two main categories. The first is Connectivity, which provides data access through various wireless technologies. "Standard Connectivity" offers features over Wi-Fi, including basic maps and music streaming over Bluetooth, while "Premium Connectivity" adds access over cellular networks for features like live traffic visualization and video streaming (Compl. ¶19; Ex. 1, p. 7). The second category is Autopilot, described as an advanced driver assistance system. This system uses multiple external cameras and "powerful vision processing" to perform functions like Traffic-Aware Cruise Control, Autosteer, Auto Lane Change, Autopark, and Smart Summon (Compl. ¶20; Ex. 3, p. 11).
The complaint provides a diagram of a Tesla Model 3 showing the locations of the Autopilot components, which include eight cameras, ultrasonic sensors, and radar that "actively monitor the surrounding roadway" (Compl. Ex. 4, p. 12). The complaint alleges that this hardware, combined with a "powerful onboard computer" and a "deep neural network," processes inputs to enhance driver awareness and safety (Compl. Ex. 6, p. 13).

IV. Analysis of Infringement Allegations

The complaint references external claim chart exhibits that were not provided with the filing (Compl. ¶62, ¶101). The complaint text itself does not contain a narrative infringement theory or map claim elements to accused functionalities. The following analysis is based on the patent claims and the description of the accused instrumentality in the complaint.

U.S. Patent No. 7,336,805 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a method for assisting guidance of a motor vehicle on the basis of image data	Tesla’s Autopilot system, which includes features such as Autopark and Smart Summon that guide the vehicle.	¶20	col. 1:7-10
acquiring image data using an imaging sensor from a surrounding field of the motor vehicle	The Autopilot system uses multiple external cameras to monitor the surrounding roadway.	¶20; Ex. 4, p. 12	col. 2:15-18
extracting from the acquired image data, the positional parameters of at least one potential destination relative to the motor vehicle	The onboard computer processes camera inputs to identify parking spaces or a user's location for Summon, determining their position relative to the vehicle.	¶13; Ex. 6, p. 13	col. 2:18-22
calculating at least one trajectory describing an optimized travel path... to assist a subsequent vehicle guidance	The Autopilot system actively guides the vehicle, such as by navigating into a parking space or to the user's location.	¶11; Ex. 3, p. 11	col. 2:28-32

Identified Points of Contention

Scope Questions: The infringement analysis may focus on whether terms from the 2004-era patent, such as "docking station," can be construed to cover the targets of Tesla's modern Autopilot features, like a perpendicular parking space or a user's location in a parking lot for "Smart Summon." The patent's specification primarily discusses docking trucks at loading platforms ('805 Patent, col. 1:7-10).
Technical Questions: A key question will be whether Tesla's system "extracts positional parameters" based on "geometric objects" in the manner claimed. The complaint alleges Tesla uses a "deep neural network" (Compl. Ex. 6, p. 13), which may operate differently from the specific edge detection, segmentation, and matching algorithm described in the '805 patent's specification ('805 Patent, col. 2:35-52).

U.S. Patent No. 9,706,500 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A network device comprising: a transmitter; a receiver; and a processor	Tesla vehicles contain wireless communication components (e.g., cellular modems) that include transmitters, receivers, and processors.	¶19	col. 4:18-20
the processor is configured to select a value of a multi-level transmit power control (TPC) command from a set of values	The wireless modems in Tesla vehicles perform power control to communicate with cellular networks.	¶19	col. 2:7-14
the processor is configured to have the transmitter transmit, on a single physical channel, an allocation of an uplink resource and the multi-level TPC command	Tesla vehicles transmit data over cellular networks, which involves receiving resource allocations and adhering to power control commands from the network.	¶19	col. 4:48-55

Identified Points of Contention

Technical Questions: The central issue will likely be whether the wireless communication systems in Tesla vehicles, which likely use standard off-the-shelf components, practice the specific method of selecting and transmitting a "multi-level TPC command" on a "single physical channel" along with an "uplink resource allocation" as claimed. The complaint alleges the functionality exists at a high level but provides no details on the specific implementation within the accused products.

V. Key Claim Terms for Construction

For the '805 Patent:

The Term: "destination" (as in "potential destination")
Context and Importance: The construction of this term is critical to the scope of the patent. A broad definition could cover any location a vehicle might be guided to, such as a parking spot, whereas a narrow definition might limit it to the commercial "docking stations" discussed as the primary embodiment in the patent. Practitioners may focus on this term because its scope could determine whether the patent reads on consumer-level features like Autopark.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "destination" without explicit limitation to a commercial context ('805 Patent, col. 7:60). The summary of the invention also refers generally to guiding a vehicle to a "specific location, for example in a parking bay or at a loading platform," suggesting these are examples, not limitations ('805 Patent, col. 1:11-15).
- Evidence for a Narrower Interpretation: The patent title is "Docking Assistant," and the detailed description repeatedly uses the example of a truck approaching a docking station or loading ramp ('805 Patent, Abstract; col. 3:45-48). This context may support an interpretation limiting "destination" to such commercial or industrial environments.

For the '500 Patent:

The Term: "multi-level transmit power control (TPC) command"
Context and Importance: This term defines the specific type of signal claimed. The dispute will likely center on whether the power control signals used in Tesla's standard cellular systems meet the definition of "multi-level" as intended by the patent, which requires "at least two values up or at least two values down" ('500 Patent, Claim 1). The technical details of how power is controlled in the accused systems will be determinative.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of evidence for a broader interpretation.
- Evidence for a Narrower Interpretation: The claim language itself provides a specific definition: "a set of values that includes at least two values up or at least two values down" ('500 Patent, col. 14:15-17). This explicit quantitative requirement may provide a basis for a narrow construction, potentially excluding binary (single-step up/down) TPC systems.

VI. Other Allegations

Indirect Infringement: For each asserted patent, the complaint alleges induced infringement, stating that Defendant encourages and instructs consumers and partners to use the accused products in an infringing manner through advertising, promotion, and user manuals (Compl. ¶58, ¶71). Contributory infringement is alleged on the basis that Defendant provides software and technologies that are especially made or adapted for infringement and have no substantial non-infringing uses (Compl. ¶60, ¶73).
Willful Infringement: The complaint alleges willful infringement for all eleven patents. It claims Defendant had actual knowledge of the '805 and '639 patents no later than August 7, 2020, and of the other nine patents no later than April 11, 2024, from pre-suit notice letters (Compl. ¶57, ¶70, ¶83, ¶96, ¶109, ¶122, ¶135, ¶148, ¶161, ¶174, ¶186).

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

A core issue will be one of definitional scope and technological evolution: can claim terms from patents filed between 1991 and 2012, written in the context of technologies like commercial truck docking and 3G/4G cellular systems, be construed to cover modern, complex systems like Tesla's AI-driven "Smart Summon" and current 5G-capable vehicle connectivity? This will turn on the construction of terms such as "docking station" ('805 Patent) and the specific architectures of patented camera and wireless systems.
A key evidentiary question will be one of technical implementation: the complaint alleges infringement based on the high-level functionality of Tesla's vehicles (e.g., they use cameras, they use cellular) but provides no specific evidence that the underlying systems operate according to the particular methods claimed in the patents (e.g., the specific two-loop power control of the '500 Patent or the feature extraction method of the '639 Patent). The case will likely depend on whether discovery uncovers a direct technical correspondence between the accused systems and the patent claims or reveals a fundamental mismatch in operation.