Fleet Connect Solutions LLC v. Rivian Automotive Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fleet Connect Solutions LLC (Texas)
  • Defendant: Rivian Automotive, Inc. (Delaware)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 6:23-cv-00623, W.D. Tex., 08/23/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established and regular place of business within the Western District of Texas, specifically an office in Austin, where it sells, offers for sale, and services its products.
• Core Dispute: Plaintiff alleges that Defendant’s electric vehicles, fleet management platform, and associated cloud and mobile application services infringe ten patents relating to vehicle telematics, maintenance tracking, trip status notification, and various wireless communication technologies.
• Technical Context: The technologies at issue involve vehicle connectivity and wireless communication protocols, which are foundational to modern fleet management, remote diagnostics, and advanced driver-assistance systems (ADAS) in the automotive industry.
• Key Procedural History: The complaint notes that U.S. Patent No. 8,494,581 underwent both Inter Partes Review and Ex Parte Reexamination, resulting in the cancellation of claims 1-20 and 24; the complaint asserts the surviving claim 21. The complaint also alleges Defendant received notice of infringement for U.S. Patent No. 7,450,955 in August 2020 and for several other asserted patents in April 2023, forming a basis for its willfulness allegations.

Case Timeline

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

U.S. Patent No. 7,450,955 - "System And Method For Tracking Vehicle Maintenance Information," issued November 11, 2008

The Invention Explained

• Problem Addressed: The patent describes the need for a system to track vehicle maintenance information and communicate warnings, recognizing that conventional systems were limited. (’955 Patent, col. 1:15-23).
• The Patented Solution: The invention is a method where a system administrator identifies a vehicle via its mobile unit, determines an associated warning (e.g., for maintenance), generates a data packet containing this warning and unique identifiers, and transmits it to the vehicle. (’955 Patent, col. 2:3-13). The system is designed to then receive a confirmation from the mobile unit, ensuring the warning was delivered. (’955 Patent, col. 2:13-15).
• Technical Importance: This technology provided a framework for centralized, remote monitoring and management of vehicle health, a precursor to modern telematics-based fleet management and proactive vehicle service systems.

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶25).
• Claim 1 breaks down into the following essential elements:
  • Identifying by a system administrator a vehicle associated with a vehicle identifier of a receiving mobile unit;
  • Determining a warning associated with the vehicle;
  • Generating baseband message data indicating the warning by constructing at least one data packet from a plurality of data fields, the data fields including a unique identifier of a transmitting mobile unit, and the vehicle identifier of the receiving mobile unit;
  • Upconverting the baseband message data to radio frequency for transmission to the receiving mobile unit;
  • Transmitting the upconverted baseband message data from the transmitting mobile unit to the receiving mobile unit, thereby indicating the warning; and
  • Receiving a confirmation of receipt from the receiving mobile unit including parsing the confirmation of receipt to confirm the warning was received.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,206,837 - "Intelligent trip status notification," issued April 17, 2007

The Invention Explained

• Problem Addressed: The patent addresses the inconvenience and potential danger for a person in transit to manually and repeatedly estimate their time of arrival, especially when needing to consider factors like traffic, weather, and time of day. (’837 Patent, col. 1:44-53).
• The Patented Solution: The invention provides a method for automatically and periodically providing trip status. It involves receiving the location of a mobile device in transit, estimating time-of-arrival bounds using that location and at least one historical travel time statistic, and then sending these bounds to the device. (’837 Patent, Abstract; col. 2:30-41). This allows for dynamic updates based on changing conditions without manual user intervention.
• Technical Importance: This system represents an early approach to predictive, dynamic navigation updates, a core feature of modern GPS navigation and ride-sharing applications that provide users with constantly updated ETAs.

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶42).
• Claim 1 breaks down into the following essential elements:
  • Receiving a location of a mobile communications device that is in transit to a destination;
  • Estimating the time-of-arrival bounds for said mobile communications device at said destination for a confidence interval based on said location and at least one historical travel time statistic; and
  • Sending the time-of-arrival bounds to said mobile communications device.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 6,549,583 - "Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN," issued April 15, 2003

• Technology Synopsis: This patent addresses the problem of phase noise in Orthogonal Frequency Division Multiplexing (OFDM) wireless receivers, which can degrade communication range and throughput. (Compl. ¶¶55-56; ’583 Patent, col. 1:8-34). The solution involves a method of estimating the aggregate phase error of an OFDM data symbol by determining reference points from pilots in a preamble waveform and then using a maximum likelihood-based estimation on subsequent data symbols. (Compl. ¶60; ’583 Patent, Abstract).
• Asserted Claims: At least Claim 1. (Compl. ¶60).
• Accused Features: The complaint alleges that the Accused Products' implementation of the IEEE 802.11ac and LTE protocols for wireless communication infringes this patent. (Compl. ¶61).

U.S. Patent No. 6,633,616 - "OFDM Pilot Tone Tracking for Wireless LAN," issued October 14, 2003

• Technology Synopsis: This patent, related to the '583 patent, also concerns pilot phase error estimation in OFDM receivers to compensate for performance issues. (Compl. ¶¶66-67; ’616 Patent, col. 2:5-13). The claimed solution involves determining pilot reference points from a preamble and processing the preamble with a fast Fourier transform (FFT) in a parallel path, then determining a phase error estimate for a subsequent symbol before that subsequent symbol's FFT processing is complete. (Compl. ¶70; ’616 Patent, Abstract).
• Asserted Claims: At least Claim 12. (Compl. ¶70).
• Accused Features: The complaint accuses the IEEE 802.11ac and LTE protocol implementations in Defendant's products of infringing this patent. (Compl. ¶71).

U.S. Patent No. 7,058,040 - "Channel Interference Reduction," issued June 6, 2006

• Technology Synopsis: The patent addresses methods for data transmission over first and second media that overlap in frequency, a common issue for coexisting wireless technologies like Wi-Fi and Bluetooth. (Compl. ¶¶75-76; ’040 Patent, col. 1:7-12). The invention describes a method of using Time Division Multiple Access (TDMA) to compute and allocate shared time-slot channels between the two media and dynamically adjusting the allocation to maintain a desired level of service. (Compl. ¶80; ’040 Patent, Abstract).
• Asserted Claims: At least Claim 1. (Compl. ¶80).
• Accused Features: The infringement allegations target the Accused Products' use of LTE, 802.11b, and Bluetooth protocols, which allegedly involve transmission over media that overlap in frequency. (Compl. ¶81).

U.S. Patent No. 8,494,581 - "System and methods for management of mobile field assets via wireless handheld devices," issued July 23, 2013

• Technology Synopsis: This patent describes a system for conducting remote field assessments using a handheld device. (Compl. ¶¶92-93; ’581 Patent, Abstract). The method involves the handheld device accessing a remote assessment program, collecting field data, determining its own geographical location, and communicating both the field data and the location back to a remote computing device. (Compl. ¶97; ’581 Patent, col. 14:7-22).
• Asserted Claims: At least Claim 21. (Compl. ¶97).
• Accused Features: The complaint makes a general allegation that the Accused Products are used to perform the claimed method. (Compl. ¶97).

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range and Extended Rate Across Imperfectly Estimated Channels," issued August 21, 2007

• Technology Synopsis: The patent relates to evaluating channel performance in a Multiple-Input Multiple-Output (MIMO) wireless system. (Compl. ¶¶102-103; ’153 Patent, col. 2:5-12). The claimed method involves defining and estimating a channel matrix metric, performing a singular value decomposition (SVD) on that estimate to get singular values, and then using both the metric and the singular values to calculate a crosstalk measure for the data sub-streams. (Compl. ¶107; ’153 Patent, Abstract).
• Asserted Claims: At least Claim 1. (Compl. ¶107).
• Accused Features: The accused functionality is the implementation of MIMO systems within the LTE and 802.11n communication protocols used by the Accused Products. (Compl. ¶108).

U.S. Patent No. 7,656,845 - "Channel Interference Reduction," issued February 2, 2010

• Technology Synopsis: This patent, related to the '040 patent, describes a system for managing communication over first and second media. (Compl. ¶¶119-120; ’845 Patent, col. 2:4-10). The system comprises a processor and two transceivers, where at least one transceiver is configured to retry transmission at a lower rate if not acknowledged, and an allocation unit dynamically allocates data channels between the media based on a desired service level. (Compl. ¶124; ’845 Patent, Abstract).
• Asserted Claims: At least Claim 12. (Compl. ¶124).
• Accused Features: The complaint alleges infringement based on the Accused Products' use of LTE, 802.11b, and Bluetooth for coexistent wireless communications. (Compl. ¶¶125, 37).

U.S. Patent No. 7,742,388 - "Packet Generation Systems and Methods," issued June 22, 2010

• Technology Synopsis: The patent addresses generating packets for network transmission. (Compl. ¶¶136-137; ’388 Patent, col. 1:12-16). The method involves generating a packet with a preamble containing a first and second training symbol, and then increasing the packet's size by adding subcarriers to the second training symbol, making its quantity of subcarriers greater than the first. (Compl. ¶141; ’388 Patent, Abstract).
• Asserted Claims: At least Claim 1. (Compl. ¶141).
• Accused Features: The accused functionality relates to packet and frame structures used in the 802.11n and LTE wireless communication standards implemented by Defendant's products. (Compl. ¶142).

U.S. Patent No. 8,005,053 - "Channel Interference Reduction," issued August 23, 2011

• Technology Synopsis: The patent describes a method for managing data from multiple wireless protocols on a single device. (Compl. ¶¶153-154; ’053 Patent, col. 2:1-12). The claimed method is performed by a communication device with multiple transceivers, each for a different protocol. The device selects one protocol, encodes data from an unselected protocol into the format of the selected protocol, and transmits the encoded data using the transceiver for the selected protocol. (Compl. ¶158; ’053 Patent, Abstract).
• Asserted Claims: At least Claim 10. (Compl. ¶158).
• Accused Features: The complaint alleges infringement by the Accused Products' systems for in-device coexistence of Wi-Fi, LTE, and/or Bluetooth communications. (Compl. ¶159).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are Defendant’s R1T, R1S, RCV, and EDV electric vehicles, along with the associated software and service platforms: Rivian FleetOS, the Rivian Vehicle Care System, Driver+, Rivian Cloud, and Rivian's mobile applications (collectively, the "Accused Products"). (Compl. ¶13).

Functionality and Market Context

• The Accused Products form an integrated ecosystem for vehicle operation and management. The Rivian FleetOS platform is described as a tool for managing vehicle fleets, offering insights into vehicle health, performance, charging, and utilization. (Compl. p. 3). The complaint includes a screenshot of the FleetOS Service Overview dashboard, which displays maintenance-related information such as "Service Expenses" and "Warranty Compliance." (Compl. p. 8).
• The Rivian mobile application provides remote vehicle status monitoring and control, including features to check vehicle range and plan trips. (Compl. p. 4). A screenshot from the Apple App Store shows a user interface for planning "electric adventures," which relates to trip status functionality. (Compl. p. 4).
• The vehicles themselves are equipped with hardware to perform wireless communications using various protocols, including, but not limited to, Bluetooth, IEEE 802.11 (including 802.11ac and 802.11n), and LTE. (Compl. ¶¶14-15). The complaint provides a table detailing the "Integrated Module Info" for the vehicles, listing specific modules for WLAN, Cellular, and GPS/GNSS capabilities. (Compl. p. 18).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,450,955 Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether Rivian's automated, cloud-based diagnostic platform functions as a "system administrator" within the meaning of the patent. The defense may argue that the claimed "system administrator" implies a level of human-directed action not present in the accused automated system.
• Technical Questions: The analysis may focus on what constitutes "receiving a confirmation of receipt." The question will be whether the general data exchange between the vehicle and Rivian's servers, which confirms connectivity and data sync, meets the specific requirement of confirming that the particular "warning was received" as claimed.

U.S. Patent No. 7,206,837 Infringement Allegations

Identified Points of Contention

• Scope Questions: The dispute may center on the terms "time-of-arrival bounds" and "confidence interval." The question will be whether a standard Estimated Time of Arrival (ETA) provided by a modern navigation system inherently meets these claim limitations, or if the patent requires a more specific statistical calculation of an explicit upper and lower bound.
• Technical Questions: A key evidentiary question will be what data Rivian's system uses to calculate ETAs. The complaint alleges the use of a "historical travel time statistic," and discovery will likely focus on whether the accused routing and traffic algorithms actually use such historical data in the manner contemplated by the patent.

V. Key Claim Terms for Construction

For U.S. Patent No. 7,450,955:

• The Term: "system administrator"
• Context and Importance: This term is critical because it defines the entity that initiates the claimed method. Its construction will determine whether the claim is limited to a human operator performing the steps or if it can read on a fully automated, server-based system like the accused Rivian Cloud and Vehicle Care platform.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims do not specify that the administrator must be human. The specification discusses the system in functional terms (e.g., "the system administrator may also provide detour instructions"), which could be interpreted to encompass automated logic. (’955 Patent, col. 5:29-30).
  • Evidence for a Narrower Interpretation: The term "administrator" itself may suggest human oversight or action. The patent's context often implies an entity making decisions (e.g., for law enforcement or emergency services), which may support an interpretation requiring human involvement. (’955 Patent, col. 5:6-9).

For U.S. Patent No. 7,206,837:

• The Term: "historical travel time statistic"
• Context and Importance: This term is a cornerstone of the claimed invention, as it is the basis for the ETA estimation. The dispute will turn on whether the traffic and routing data used by Rivian's navigation system qualifies as a "historical travel time statistic" as understood in the patent, or if it is a different form of real-time or predictive data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to limit the "statistic" to a specific format, referring generally to "how long it has normally taken in the past." (’837 Patent, col. 1:21-23). This could be read broadly on any algorithm that incorporates past travel data, even if mixed with real-time inputs.
  • Evidence for a Narrower Interpretation: The patent provides specific examples of what influences historical data, such as "calendrical time (i.e., the time and date)," suggesting a requirement for structured, time-indexed historical data rather than a generic, real-time traffic algorithm. (’837 Patent, col. 2:5-8).

VI. Other Allegations

Indirect Infringement

• For all asserted patents, the complaint alleges induced infringement, stating that Defendant provides the Accused Products with instructions, user manuals, and advertising that direct and encourage end-users to operate them in an infringing manner. (e.g., Compl. ¶¶27, 44). The complaint also pleads contributory infringement, alleging the Accused Products contain special features specifically designed for infringing use which are not staple articles of commerce suitable for substantial non-infringing use. (e.g., Compl. ¶¶28, 45).

Willful Infringement

• The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents prior to the lawsuit. This knowledge is alleged to stem from a notice letter regarding the '955 patent sent in August 2020 and additional notice letters regarding at least seven other asserted patents sent in April 2023. (Compl. ¶¶29, 46). The complaint further alleges that Defendant has a policy of "willfully blind[ing]" itself to the patent rights of others. (Compl. ¶¶30, 47).

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

• A core issue will be one of temporal and technological scope: can the specific, often sequential method steps recited in patents from the early- to mid-2000s be mapped onto the functionality of a modern, highly integrated, cloud-based automotive ecosystem? The case may turn on whether Rivian's automated, multi-faceted platforms perform the same functions in substantially the same way as envisioned by the patents' more discrete, step-by-step processes.
• A second central question will be one of standard-essentiality: for the numerous patents directed at wireless communication protocols, the court will likely need to determine whether compliance with industry standards like IEEE 802.11n/ac and LTE necessarily requires practicing the specific, patented methods for functions such as MIMO channel estimation, OFDM error correction, and multi-protocol coexistence, or if non-infringing alternatives exist within those standards.