DCT

6:25-cv-00434

Golden v. Google LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
    • Plaintiff: Larry Golden (South Carolina), Pro Se
    • Defendant: Google LLC (Delaware)
    • Plaintiff’s Counsel: Pro Se
  • Case Identification: 6:25-cv-00434, W.D. Tex., 09/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Google LLC conducts business in the state and judicial district.
  • Core Dispute: Plaintiff alleges that Google’s Tensor processors jointly infringe patents on multi-sensor monitoring systems when modified by third parties, and that Google’s self-driving vehicles directly infringe related patents on vehicle control systems.
  • Technical Context: The patents-in-suit relate to integrated sensor and control systems designed to detect chemical, biological, or radiological threats and remotely disable associated products or vehicles for security and anti-terrorism purposes.
  • Key Procedural History: The complaint references extensive prior litigation involving the same patent family, including cases against Google and Samsung. Decisions in those cases appear to have found no direct infringement by Google's smartphones as sold, leading Plaintiff to now assert a theory of joint infringement, where infringement is completed by the actions of third parties. The complaint also references a 2015 Inter Partes Review (IPR) proceeding that resulted in constructions for key claim terms.

Case Timeline

Date Event
2006-04-05 Earliest Patent Priority Date ('287, '619, '898, '761, '891 Patents)
2012-12-18 '761 Patent Issue Date
2013-01-01 '891 Patent Issue Date
2015-10-01 Final Written Decision in IPR2014-00714
2018-12-25 '287 Patent Issue Date
2021-04-20 '619 Patent Issue Date
2022-10-05 Alleged Date of Knowledge for Willfulness (Service in NDC Case No. 22-5246)
2023-05-09 '898 Patent Issue Date
2025-09-18 Complaint Filing Date

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

U.S. Patent No. 10,163,287 - "Multi sensor detection, stall to stop and lock disabling system," issued December 25, 2018

The Invention Explained

  • Problem Addressed: The patent’s background section describes the "continuous, daily, worldwide threat" of terrorist activity and the need for security systems that can detect chemical, biological, and radiological hazards and control access to vulnerable assets like shipping containers and vehicles (’287 Patent, col. 2:1-21).
  • The Patented Solution: The invention is a multi-sensor detection and disabling system. It uses a detector case that holds interchangeable sensors to sample for various threats (’287 Patent, col. 4:16-24). Upon detecting a threat, the system can transmit a signal to a disabling mechanism to lock the product, preventing unauthorized access and further contamination. The system can also be interconnected with surveillance towers or satellites to monitor assets remotely and, in the case of vehicles, activate a "stall-to-stop process" (’287 Patent, col. 4:25-49).
  • Technical Importance: The invention describes an integrated approach to security, combining remote sensing, communication, and physical control (locking/disabling) to provide a proactive defense against terrorist threats to goods in transit and vehicles.

Key Claims at a Glance

  • The complaint asserts independent claims 4, 5, and 6 (Compl. ¶24).
  • Independent Claim 4 recites a "communication device" comprising elements including:
    • a central processing unit (CPU)
    • sensors (motion, biometric) and detectors (chemical, biological, radiological, explosive)
    • communication connections (GPS, Wi-Fi, cellular, Bluetooth, NFC)
    • a locking mechanism to engage or disable the device
    • a transmitter or transceiver configured to send signals to monitor and control doors, vehicles, or buildings
  • Independent Claim 5 recites a "monitoring device" with similar elements to claim 4, additionally including a temperature sensor and a sensor for human detection (’287 Patent, col. 18:22-26).
  • Independent Claim 6 recites "monitoring equipment" with similar elements, including a light indicator (’287 Patent, col. 19:8-10).

U.S. Patent No. 10,984,619 - "Multi sensor detection, stall to stop, and lock disabling system," issued April 20, 2021

The Invention Explained

  • Problem Addressed: The patent addresses the same anti-terrorism and security problems described in the ’287 Patent, which is part of the same patent family (’619 Patent, col. 2:50-62).
  • The Patented Solution: The solution is substantively the same as that described in the ’287 Patent: an integrated system of sensors, communication links, and disabling locks for securing products and vehicles (’619 Patent, col. 3:24-4:49). A key distinction in this patent is that its claims are directed not only to a device but also to a "central processing unit" capable of performing the claimed functions.
  • Technical Importance: This patent extends the claimed subject matter from a complete system to the core processing component capable of executing the security and control functions.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 11, as well as various dependent claims (Compl. ¶26).
  • Independent Claim 1 recites a "communication device" (e.g., PC, smartphone, laptop) comprising a CPU capable of processing specific instructions, including:
    • instructions to lock, unlock, or disable the device
    • instructions to activate a lock by engaging a vehicle with a key-fob
    • instructions to activate a stall/stop means by engaging a vehicle's ignition system
  • Independent Claim 11 recites a "central processing unit (CPU)" itself, which is capable of executing the series of processing instructions outlined in Claim 1 (’619 Patent, col. 17:4-44).

U.S. Patent No. 11,645,898 ('898 Patent) - "Multi sensor detection, stall to stop, and lock disabling system," issued May 9, 2023

Technology Synopsis

Belonging to the same family, this patent describes a system for detecting threats (e.g., chemical, biological, radiological) and remotely disabling or locking an associated product or vehicle to prevent unauthorized access or use (’898 Patent, Abstract). The system integrates sensors, communication capabilities, and a lock-disabling mechanism.

Asserted Claims

Independent claim 1 (Compl. ¶¶ 28, 49).

Accused Features

The complaint alleges joint infringement by Google's Tensor Processing Units (TPUs) when modified by third parties (Compl. ¶30). It separately alleges direct infringement by Google's Self-Drive Vehicles (Compl. ¶51).

U.S. Patent No. 8,334,761 ('761 Patent) - "Multi sensor detection, stall to stop and lock disabling system," issued December 18, 2012

Technology Synopsis

An earlier patent in the same family, the ’761 Patent covers a multi-sensor system for detecting threats and disabling products or vehicles. It describes features such as remote monitoring via satellite, activating a vehicle's stall-to-stop system, and using detector cases with interchangeable sensors (’761 Patent, Abstract).

Asserted Claims

Independent claim 1 (Compl. ¶35).

Accused Features

The complaint alleges direct infringement by Google's Self-Drive Vehicles that incorporate Advanced Driver Assistance Systems (ADAS) (Compl. ¶37).

U.S. Patent No. RE43,891 ('891 Patent) - "Multi sensor detection, stall to stop and lock disabling system," issued January 1, 2013

Technology Synopsis

This reissue patent is also part of the same family and describes the integrated multi-sensor detection and lock-disabling system. The invention is framed as a security system to counter terrorist threats by monitoring assets like shipping containers and controlling access through remote locking and disabling capabilities (’891 Patent, Abstract).

Asserted Claims

Independent claims 11 and 44 (Compl. ¶42).

Accused Features

The complaint alleges direct infringement by Google's Self-Drive Vehicles that incorporate ADAS (Compl. ¶44).

III. The Accused Instrumentality

Product Identification

The complaint identifies two main categories of accused instrumentalities: (1) Google’s Tensor Central Processing Units (CPUs) and Tensor Processing Units (TPUs), specifically the Tensor Series G1-G5 and various TPUs; and (2) Google’s Self-Drive Vehicles and their associated Advanced Driver Assistance Systems (ADAS) (Compl. ¶2, ¶30, ¶37).

Functionality and Market Context

  • Processors (CPUs/TPUs): The complaint alleges that Google's Tensor CPUs are the "brains" of Google's mobile devices, responsible for executing instructions and managing tasks (Compl. ¶10). The complaint includes a diagram of the "Google Tensor" processor architecture, identifying its CPU, GPU, TPU (Tensor Processing Unit for machine learning), and other components (Compl. p. 10). The infringement theory against these processors is one of joint infringement, contingent upon "modification" by third parties, such as by installing software or connecting external sensors (Compl. ¶2, ¶9). The complaint provides an image from the National Institutes of Health showing an NFC-enabled smartphone communicating with an NFC tag to detect hazardous material as one example of such modification (Compl. p. 6, Fig. 1).
  • Self-Driving Vehicles (ADAS): The complaint describes Google's Self-Drive Vehicles (developed by its subsidiary Waymo) as autonomous vehicles that use technologies like adaptive cruise control, lane departure warnings, collision avoidance, and satellite navigation (Compl. ¶21, ¶23). These vehicles employ a suite of sensors (LIDAR, RADAR, cameras) and software modules for perception, localization, and planning to enable self-driving capabilities (Compl. ¶21). The complaint alleges these vehicles and their ADAS functionalities directly infringe the patents-in-suit (Compl. ¶37).

IV. Analysis of Infringement Allegations

The complaint does not contain or attach claim charts. The infringement theory is presented in narrative form.

’287 Patent Infringement Allegations Summary

The complaint advances a theory of "joint infringement" for the ’287 Patent against Google’s Tensor CPUs (Compl. ¶24). The central allegation is that Google’s processors, as sold, do not meet all limitations of the asserted claims but are "modified" post-sale by third-party actors to become infringing (Compl. ¶2). These modifications allegedly include installing software (such as the ATAK application), connecting external NFC tags, or adding other sensors (Compl. p. 6, ¶9). Plaintiff alleges Google is liable for this infringement because it "directs or controls" these third-party actions by controlling the Android operating system and the timing of its source code releases, thereby establishing the "manner or timing" of the third parties' performance under the Akamai legal standard (Compl. ¶4, ¶12).

’619 Patent Infringement Allegations Summary

The joint infringement theory for the ’619 Patent is similar, but with a specific focus on independent claim 11, which is directed to a "central processing unit" itself (’619 Patent, col. 17:4-8). The allegation is that Google makes and sells the CPU, and third parties perform actions (e.g., using software) that cause the CPU to execute the patented series of instructions (Compl. ¶26). This division of actions, Plaintiff alleges, constitutes joint infringement for which Google is liable because it controls the Android ecosystem that enables these actions (Compl. ¶27).

Identified Points of Contention

  • Legal Question (Joint Infringement): A central legal question will be whether Plaintiff’s allegations—that Google controls the Android OS, provides source code, and operates the Google Play store—are sufficient to establish "direction or control" over the actions of end-users who install third-party software or connect peripherals. The analysis may turn on whether Google's conduct "conditions participation in an activity or receipt of a benefit upon performance of a step or steps of a patented method and establishes the manner or timing of that performance" (Compl. ¶4, citing Akamai).
  • Scope Question (Device vs. Component): The infringement analysis may raise the question of whether claims directed to a complete "communication device" or "monitoring equipment" can be read onto a general-purpose CPU component that is later integrated into a larger system by a third party.
  • Technical Question (Modification): The court may need to resolve what constitutes a "modification." The complaint cites prior judicial findings that installing software is a "modification" that creates an infringing product (Compl. ¶16). A key technical question will be whether the alleged modifications actually cause the accused processors to perform the specific functions recited in the claims, such as activating a vehicle's ignition system or a disabling lock.

V. Key Claim Terms for Construction

The Term

"built in, embedded"

Context and Importance

This term appears in a claim construction from a prior IPR proceeding cited in the complaint (Compl. p. 5). Its definition is critical because the joint infringement theory depends on combining Google's products with external components (e.g., "external NFC tags," software like "ATAK application") to meet all claim limitations (Compl. ¶9). Whether these external or non-pre-installed components can be considered "built in, embedded" will be central to the infringement analysis.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The complaint cites a Patent Trial and Appeal Board (PTAB) construction from IPR2014-00714, which defined the term as "something is included within, incorporated into, disposed within, affixed to, connected to, or mounted to another device, such that it is an integral part of the device" (Compl. p. 5). This language, particularly "connected to, or mounted to," may support an interpretation that includes externally attached hardware or even logically connected software.
  • Evidence for a Narrower Interpretation: A defendant may argue that the phrase "such that it is an integral part of the device" limits the scope to components that are physically and permanently integrated at the time of manufacture. Language in the patent describing detector cases mounted "in or upon" monitored products like shipping containers could be used to argue for a physical, rather than purely logical, connection (’287 Patent, Abstract; col. 4:33-35).

VI. Other Allegations

Indirect Infringement

The complaint frames its primary theory against the processors as "joint patent infringement," which is a theory of liability for direct infringement under 35 U.S.C. § 271(a) (Compl. ¶1). The complaint does not explicitly plead separate counts for indirect infringement (inducement or contributory infringement) under 35 U.S.C. § 271(b) or (c).

Willful Infringement

The complaint alleges that Google's infringement has been willful (Compl. ¶40, ¶47, ¶54). The basis for this allegation is purported pre-suit knowledge of the patents, dating at least as early as the service date of October 5, 2022, in a prior litigation, Golden v. Google LLC, NDC Case No. 22-5246 (Compl. ¶39).

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

This case appears to be an attempt to overcome prior pleading deficiencies by reframing the infringement theory around joint liability. The central issues for the court will likely be:

  • A core issue will be one of legal sufficiency: Do the complaint's allegations regarding Google's control over the Android ecosystem plausibly satisfy the high bar for "direction or control" required to hold a defendant liable for the actions of third-party users under the Akamai framework for joint infringement?
  • A second key issue will be one of definitional scope: Can the claims, which originate from a patent family focused on specialized anti-terrorism and vehicle disabling systems, be construed broadly enough to cover general-purpose consumer electronics processors that are combined with third-party applications and peripherals?
  • Finally, a dispositive question may be one of claim construction: How will the court interpret the term "integral part of the device" from the prior PTAB construction of "built in, embedded," and will that interpretation permit post-sale software installations and external hardware attachments to satisfy the claim limitations?