DCT

6:25-cv-00434

Golden v. Google LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-00434, W.D. Tex., 12/23/2025
  • Venue Allegations: The complaint alleges that Google does business in the state of Texas and within the Western District, but does not specify facts establishing a "regular and established place of business" in the district as required by contemporary venue standards for patent cases.
  • Core Dispute: Plaintiff alleges that Defendant’s Tensor processors (CPUs and TPUs) and Self-Drive Vehicles infringe five patents related to multi-sensor detection, remote monitoring, and vehicle control systems.
  • Technical Context: The technologies at issue relate to central processing units for mobile devices and systems for remotely controlling vehicle functions, which are foundational technologies in the global smartphone and autonomous vehicle industries.
  • Key Procedural History: The complaint references extensive prior litigation between the parties, including cases in the Northern District of California and appeals to the Federal Circuit. These prior cases appear to have established that infringement of some asserted patents requires post-sale "modification" of the accused products by third parties. The complaint also cites a 2015 Inter Partes Review (IPR) proceeding involving a related patent, in which the Patent Trial and Appeal Board (PTAB) construed key claim terms, including "built in, embedded."

Case Timeline

Date Event
2006-04-05 Earliest Priority Date for all Patents-in-Suit
2012-12-18 U.S. Patent No. 8,334,761 Issues
2013-01-01 U.S. Patent No. RE43,891 Issues
2015-10-01 Final Written Decision Issued in IPR2014-00714
2018-12-25 U.S. Patent No. 10,163,287 Issues
2021-04-20 U.S. Patent No. 10,984,619 Issues
2022-10-05 Alleged Service Date in Prior Litigation (Golden v. Google)
2023-05-09 U.S. Patent No. 11,645,898 Issues
2025-06-25 Alleged Federal Circuit Decision in Golden v. Google
2025-12-23 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"

The Invention Explained

  • Problem Addressed: The patent background describes the persistent threat of terrorist activity and the corresponding need for security protocols that can detect chemical, biological, or radiological hazards and control access to assets like shipping containers and vehicles. (’287 Patent, col. 2:1-20).
  • The Patented Solution: The invention proposes a system combining multi-threat detection with a remote disabling lock mechanism. The system is centered on a "detector case" that can house various interchangeable sensors and is capable of transmitting a signal to lock or disable a product upon threat detection, while simultaneously alerting a monitoring station. (’287 Patent, col. 3:59-65). For example, Figure 16 illustrates an embodiment where the detection of an explosive (142) in a vehicle (130) triggers signals to a satellite (136) and a monitoring site (138), which can then transmit a "stall to stop" signal (146) back to disable the vehicle. (’287 Patent, Fig. 16).
  • Technical Importance: The claimed technology integrates remote sensing, wireless communication, and physical asset control to create a proactive, networked security system for assets in transit or storage. (’287 Patent, col. 1:56-62).

Key Claims at a Glance

  • The complaint asserts independent claims 4, 5, and 6 (Compl. ¶25).
  • Independent Claim 4 recites a "communication device" comprising, among other elements:
    • a central processing unit (CPU)
    • a motion sensor, viewing screen, GPS, and internet/Wi-Fi connection
    • a Bluetooth, cellular, or satellite connection
    • a biometric sensor for authentication
    • one or more detectors for chemical, biological, radiological, or explosive agents
    • a near-field communication (NFC) connection
    • a transmitter or transceiver configured to send signals to monitor or control an external door, vehicle, or building
  • Independent Claim 5 recites a similar "monitoring device" that adds a temperature sensor and a sensor for "human detection."
  • Independent Claim 6 recites similar "monitoring equipment" that adds a "light indicator."

U.S. Patent No. 10,984,619 - "Multi Sensor Detection, Stall to Stop, and Lock Disabling System"

The Invention Explained

  • Problem Addressed: As part of the same patent family, the ’619 Patent addresses the same problem of preventing terrorist activity through integrated detection and access control systems. (’619 Patent, col. 2:60-65).
  • The Patented Solution: The invention is claimed as a "communication device" or a "central processing unit" (CPU) capable of processing instructions to perform a wide range of security and control functions. These functions include locking or unlocking the device itself, engaging with a vehicle's systems (e.g., via key-fob or ignition), authenticating users via biometrics, and scanning external sensors. (’619 Patent, col. 15:50-57, col. 17:5-12). Figure 17 shows a cell phone case (150) equipped with sensor units (176) that communicates with a cell phone (152), embodying the concept of an integrated, portable monitoring and control hub. (’619 Patent, Fig. 17).
  • Technical Importance: The patent claims a programmable processing unit that serves as a convergence point for multi-modal sensor data, biometric authentication, and remote telematics, reflecting a shift toward software-defined security and control systems. (’619 Patent, col. 16:21-28).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 11, and dependent claims 2-10 and 12-20 (Compl. ¶13).
  • Independent Claim 1 recites a "communication device" comprising a CPU capable of processing instructions to:
    • lock, unlock, or disable the lock of the communication device
    • activate vehicle functions (start, stall, stop) by engaging with a key-fob or ignition system
    • engage with an unmanned aerial vehicle's operational systems
    • authenticate a user via biometrics
  • Independent Claim 11 recites a "central processing unit (CPU)" itself, capable of processing instructions for a similar set of functions, including biometric authentication, NFC scanning, threat detection, and connecting to the Internet-of-Things (IoT) to control external systems.

Multi-Patent Capsules

  • U.S. Patent No. 11,645,898

    • Patent Identification: U.S. Patent No. 11,645,898, "Multi Sensor Detection, Stall to Stop, and Lock Disabling System," issued May 9, 2023.
    • Technology Synopsis: This patent describes a pre-programmed system to stall, stop, or slow a vehicle. A central processing unit is configured to execute these actions based on remotely received signals or automatically in response to detected vehicle conditions such as unintended acceleration, lane departure, or the presence of a hazard. (’898 Patent, col. 15:60-67).
    • Asserted Claims: Independent claim 1 (Compl. ¶¶ 23, 49).
    • Accused Features: The complaint accuses Google's Tensor Processing Units (TPUs) under a joint infringement theory and Google's Self-Drive Vehicles under a direct infringement theory (Compl. ¶¶ 30, 51).

  • U.S. Patent No. 8,334,761

    • Patent Identification: U.S. Patent No. 8,334,761, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued December 18, 2012.
    • Technology Synopsis: An earlier patent in the family, this invention describes a system for remotely controlling a vehicle's "stall-to-stop means" or "slowdown means." The system comprises a vehicle adapted to receive a signal from a remote location, which then controls components such as the brake, ignition, or fuel system to halt the vehicle. (’761 Patent, col. 15:4-10).
    • Asserted Claims: Independent claim 1 (Compl. ¶35).
    • Accused Features: The complaint alleges that Google's Self-Drive Vehicles, which incorporate Advanced Driver Assistance Systems (ADAS), directly infringe the patent (Compl. ¶37).

  • U.S. Patent No. RE43,891

    • Patent Identification: U.S. Patent No. RE43,891, "Multi Sensor Detection, Stall to Stop and Lock Disabling System," issued January 1, 2013.
    • Technology Synopsis: This reissue patent describes a system where a distress signal sent from a communication device (e.g., cell phone) via a network to a monitoring site can trigger commands to be sent back to a vehicle to activate a stall-to-stop system. (’891 Patent, col. 14:1-17).
    • Asserted Claims: Independent claims 11 and 44 (Compl. ¶42).
    • Accused Features: The complaint alleges that Google's Self-Drive Vehicles incorporating ADAS directly infringe the patent (Compl. ¶44).

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused instrumentalities:

  1. Processors: Google's Tensor Central Processing Units (CPU) Series G1-G5 and Tensor Processing Units (TPU) Series TPUv1 through Edge TPU (Compl. ¶¶ 8, 30).
  2. Vehicles: Google's Self-Drive Vehicles, operated by its subsidiary Waymo LLC, which incorporate Google's Advanced Driver Assistance Systems (ADAS) (Compl. ¶37).

Functionality and Market Context

  • Processors: The complaint characterizes Google's Tensor CPUs as the "brains" of Google's mobile devices, responsible for executing instructions and managing tasks (Compl. p. 11-12). The complaint provides a diagram of the "Google Tensor" chip, illustrating the integration of the CPU, GPU, and TPU, among other components (Compl. p. 11). These processors are positioned as essential hardware within the broader Android ecosystem, which the complaint notes has over three billion active users worldwide (Compl. pp. 19-20). The infringement theory for the processors is based on joint infringement, requiring "modification" by third parties (Compl. ¶25).
  • Vehicles: The complaint describes Google's Self-Drive Vehicles (Waymo) as autonomous vehicles that utilize ADAS technologies for functions such as adaptive cruise control, collision avoidance, and lane departure warnings (Compl. p. 22). The infringement theory for the vehicles is based on direct infringement, alleging that these ADAS features incorporate the patented "stall, stop, or vehicle slow-down system" (Compl. ¶37).

IV. Analysis of Infringement Allegations

The complaint references Exhibits A and B, which are described as element-by-element claim charts, but these exhibits were not included with the provided filing (Compl. ¶1). In the absence of claim charts, the infringement theory must be summarized from the narrative allegations in the complaint.

  • '287 and '619 Patents (Processor Infringement): The complaint advances a theory of "joint infringement" for the asserted claims of the ’287 and ’619 patents against Google's Tensor CPUs and TPUs (Compl. ¶¶ 25, 13). The central allegation is that the Google processors, as sold, do not meet all limitations of the asserted apparatus claims but must be "modified" by third parties (e.g., app developers, end users) to become infringing (Compl. ¶25). Plaintiff alleges Google is liable for this third-party activity because it "directs or controls" their performance by providing the Android Open-Source Operating System and controlling the "manner or timing" of its source code releases (Compl. ¶¶ 5, 13). The complaint also posits alternative joint infringement theories, including the formation of a "joint enterprise" with the U.S. Government related to Google's public sector contracts (Compl. ¶¶ 4, 15).

  • Identified Points of Contention:

    • Scope Questions (Joint Infringement): The complaint's primary theory for the processor patents hinges on attributing the conduct of third parties to Google. A central legal question will be whether providing an open-source operating system and development tools constitutes "direction or control" sufficient to establish joint infringement under the standard set in Akamai Techs., Inc. v. Limelight Networks, Inc., or if it is merely arms-length cooperation. The complaint itself quotes prior judicial opinions in cases involving the same plaintiff which found that the accused products "do not infringe without modification" (Compl. p. 17).
    • Technical Questions (Vehicle Infringement): For the vehicle-related patents ('761, '891, and parts of '898), the complaint alleges direct infringement by Google's Self-Drive Vehicles (Compl. ¶¶ 37, 44, 51). A key evidentiary question will be whether the ADAS functionalities in Waymo vehicles perform the specific steps of the claimed "stall, stop, or vehicle slow-down system," particularly with respect to activation by a remote command signal as described in the patents. A footnote in the complaint states that "Google's Self-Drive Vehicle can function without the inclusion of Plaintiff's stall, stop, or vehicle slow-down system," which may raise questions regarding the essentiality and operation of the accused features (Compl. p. 24, fn. 1).

V. Key Claim Terms for Construction

  • The Term: "built in, embedded"

    • Context and Importance: This term appears to be central to the dispute, as the complaint's infringement theories rely on combining Google's smartphones with external software (e.g., the ATAK application) or hardware (e.g., NFC tags, external sensors) (Compl. pp. 7-10). The scope of this term will be critical in determining whether a product that requires such post-sale "modification" can be found to infringe the apparatus claims.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint cites a construction from a prior PTAB decision: "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. 6). The language "connected to, or mounted to" may support an interpretation that covers external peripherals or software plug-ins that work with the core device.
      • Evidence for a Narrower Interpretation: The complaint also cites prior court orders finding no infringement "without modification," suggesting those courts adopted a narrower view that the claimed functionality must be present at the time of sale (Compl. p. 17). The phrase "integral part of the device" from the PTAB construction itself could also be argued to support a narrower scope, requiring a more permanent and essential connection than simply installing an app.

  • The Term: "communication device"

    • Context and Importance: Asserted claims of the ’287 and ’619 patents are directed to a "communication device." The infringement allegations target Google's Tensor CPUs, which are components within a larger device (Compl. ¶13, ¶25). The construction of "communication device" will be important for determining whether a processor component can, by itself, satisfy the claim limitation, or whether the entire end-user product (e.g., a smartphone) must be the accused instrumentality.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent specifications disclose that the "communication device" can encompass a wide range of products, including cell phones, laptops, and PDAs, suggesting the term is meant to be capacious (’287 Patent, col. 15:5-10). The complaint alleges the CPU is the "brain" of the device, which may support an argument that it is the core of the claimed "device" (Compl. p. 11).
      • Evidence for a Narrower Interpretation: The asserted claims recite a list of other components (e.g., biometric sensor, motion sensor, GPS) as being part of the "communication device" (’287 Patent, Claim 4). This may support an argument that the term requires a single, integrated apparatus containing all the recited elements, rather than just the processor that enables their function.

VI. Other Allegations

  • Indirect Infringement: The complaint's primary infringement theory against the accused processors is "joint infringement," which is a theory of direct infringement under 35 U.S.C. § 271(a) (Compl. ¶1). However, the factual allegations—that Google "directs or control[s]" the performance of third parties by providing the Android OS and source code—also contain the elements of knowledge and intent required for a claim of induced infringement under § 271(b) (Compl. ¶¶ 5, 13).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge of the patents (Compl. p. 1). The basis for this allegation is Google's alleged knowledge of the patents-in-suit from at least October 5, 2022, the service date in a prior litigation, Golden v. Google LLC, NDC Case No. 22-5246 (Compl. ¶39, ¶46, ¶53). The complaint alleges that Google continued to release new products despite this knowledge (Compl. ¶39).

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

  • A central legal issue will be one of attributed liability: can the act of providing an open-source operating system and hardware platform (the Android ecosystem) satisfy the "direction or control" standard for joint infringement under Akamai, or will the court view the relationship between Google and third-party developers/users as arms-length cooperation that does not give rise to liability for direct infringement?
  • A key issue of claim scope will be whether the court construes the asserted "apparatus" claims as requiring all elements to be present in the accused product at the time of sale, or whether infringement can be based on post-sale "modification" by end-users, which would align with the plaintiff's joint infringement theory but may blur the line between apparatus and method claims.
  • For the vehicle patents, a core evidentiary question will be one of functional operation: does the accused ADAS in Google's Self-Drive Vehicles perform the specific "stall, stop, or vehicle slow-down" functions as recited in the claims, particularly concerning the capability to be activated by a remote command, or is there a fundamental mismatch in the intended and actual operation of the accused systems?