Autonomous IP LLC v. Tesla Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Autonomous IP, LLC (Texas)
  • Defendant: Tesla, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:24-cv-00025, W.D. Tex., 01/24/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and conducts substantial business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s Autopilot system infringes a patent related to methods for an autonomous vehicle to detect and maneuver to avoid obstructing an emergency vehicle.
• Technical Context: The technology concerns advanced driver-assistance systems (ADAS) and autonomous vehicle control systems designed to improve road safety by reacting to the presence of first responders.
• Key Procedural History: The complaint states that the Plaintiff is a non-practicing entity. No other significant procedural events, such as prior litigation or administrative proceedings involving the patent-in-suit, are mentioned in the complaint.

Case Timeline

Date	Event
2017-02-11	’818 Patent Priority Date
2018-11-13	’818 Patent Issue Date
2024-01-24	Complaint Filing Date

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

U.S. Patent No. 10,127,818 - Systems And Methods For Detecting And Avoiding An Emergency Vehicle In The Proximity Of A Substantially Autonomous Vehicle

The Invention Explained

• Problem Addressed: The patent addresses the need for substantially autonomous vehicles to perceive their surroundings and respond appropriately to ensure they do not obstruct the path of an emergency vehicle ('818 Patent, col. 3:8-13).
• The Patented Solution: The invention describes a system and method where a substantially autonomous vehicle detects an emergency vehicle, determines that it may be an obstruction, and then executes a maneuver to a different position to clear a path ('818 Patent, Abstract; col. 2:15-24). This process can be initiated by analyzing "captured empirical data" from the environment (e.g., sensor data) or by receiving an "electromagnetic signal" containing information about the emergency vehicle ('818 Patent, col. 2:5-24, col. 2:25-44).
• Technical Importance: The technology aims to improve the safe and efficient integration of autonomous vehicles into traffic environments that include unpredictable events like the approach of emergency vehicles ('818 Patent, col. 3:8-13).

Key Claims at a Glance

• The complaint asserts claims 1-3, with Claim 1 being the sole independent claim asserted (Compl. ¶9).
• Independent Claim 1 requires a system with a processor and memory to perform a multi-step method, including:
  • Processing a "first pre-determined location" for navigation retrieved from a "first electromagnetic signal" corresponding to an input on a "first mobile communications device."
  • Navigating towards that location.
  • Processing an "interruption signal" from a "second electromagnetic signal."
  • Processing a "second pre-determined location" and then a "third pre-determined location."
  • Identifying an "emission that corresponds to an emergency vehicle from an aspect of a captured empirical data."
  • Maneuvering the autonomous vehicle to avoid obstruction, where the maneuver occurs when the vehicle is "greater than 20.2 to 22.5 meters from the third pre-determined location" and is performed at a speed "between 0.0001 km/h and 130 km/h."
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is identified as "Tesla Autopilot and related systems" (Compl. ¶¶9-10).

Functionality and Market Context

• The complaint alleges that Tesla Autopilot is a system that infringes the ’818 patent by identifying emergency vehicles and maneuvering the vehicle to a position where it is not obstructing the emergency vehicle (Compl. ¶8). The complaint does not provide specific technical details on how the Autopilot system achieves this functionality or any specific allegations regarding its market position beyond its general sale by the Defendant (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint references a "preliminary exemplary table attached as Exhibit B" to support its infringement allegations (Compl. ¶10). This exhibit was not filed with the complaint and is not available for analysis. In lieu of a claim chart, the complaint’s narrative theory is that Tesla Autopilot performs the patented method of identifying an emergency vehicle based on an "emission received or captured from the external environment" and causing the vehicle to maneuver to a non-obstructing position (Compl. ¶8).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: The complaint's infringement theory relies on the accused system detecting an "emission" ('818 Patent, col. 36:46-48). A central question will be whether the data processed by Tesla's Autopilot sensors (e.g., light data for cameras, radio waves for radar) falls within the patent's definition of "emission," which the specification defines broadly ('818 Patent, col. 31:16-41).
  • Technical Questions: Claim 1 recites a highly specific sequence of operations involving receiving multiple "pre-determined locations" from distinct "electromagnetic signals" originating from "mobile communications devices" ('818 Patent, col. 35:51-36:45). A key technical question is whether the complaint provides any factual basis to suggest that Tesla's Autopilot operates via this specific communication-based protocol, as opposed to a self-contained, sensor-based reaction system. Further, the claim includes precise numerical limitations, such as maneuvering when "greater than 20.2 to 22.5 meters" from a location ('818 Patent, col. 36:54-56). The plaintiff will face the evidentiary challenge of proving that the accused system meets these exact quantitative constraints.

V. Key Claim Terms for Construction

• The Term: "emission"

• Context and Importance: This term is fundamental to the infringement allegation, as the system must "identify an emission that corresponds to an emergency vehicle" ('818 Patent, col. 36:46-47). The breadth of this term's construction will determine what types of sensor data can meet the limitation. Practitioners may focus on this term because its scope could either encompass or exclude the specific sensor modalities used by the accused Autopilot system.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides an explicit and expansive definition, stating "'emissions' may refer to light, thermal radiation, electromagnetic, sound, sonar, radar, infrared, laser, vibration, ultrasound, combinations thereof, and the like" ('818 Patent, col. 31:16-20).
  • Evidence for a Narrower Interpretation: A party might argue that in the context of the overall invention, the term should be limited by the specific examples and embodiments described, potentially distinguishing it from the raw data streams of certain modern ADAS sensors.

• The Term: "process a first pre-determined location ... retrieved at least in part from a first electromagnetic signal, and further wherein the first pre-determined location corresponds to an first input signal registered at a first user-interface of a first mobile communications device"

• Context and Importance: This complex limitation appears to describe the initial step of setting a navigation destination ('818 Patent, col. 35:51-60). Its construction is critical because it may require a specific chain of events involving a mobile device, a user interface, and an electromagnetic signal. The viability of the infringement case could depend on whether this is construed narrowly to require a specific V2X-type communication or broadly to cover any destination entered into a navigation system that uses wireless signals.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that this language should be read functionally to cover the common scenario of a user entering a destination on a smartphone, which is then sent wirelessly to the car's navigation system.
  • Evidence for a Narrower Interpretation: The claim's precise recitation of a "first input signal registered at a first user-interface of a first mobile communications device" that "corresponds" to the location retrieved from a "first electromagnetic signal" may be argued to require a direct, traceable link that is more specific than a general navigation command, potentially limiting the claim to specific communication protocols not used by the accused system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant instructs its customers on how to use the Autopilot systems in a manner that infringes claims 1-3 (Compl. ¶11). Contributory infringement is also alleged (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’818 patent "from at least the date of the filing of the lawsuit" (Compl. ¶¶11-12). Plaintiff reserves the right to amend if discovery reveals evidence of pre-suit knowledge (Compl. p. 4, fns. 1-2).

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

• A central issue will be one of claim construction and scope: can the patent's sequence of receiving "pre-determined locations" from signals tied to "mobile communications devices" be construed to read on the real-world operation of Tesla's Autopilot, which may rely primarily on on-board sensors and more general navigation inputs?
• A key evidentiary question will be one of factual sufficiency: does the accused Autopilot system actually perform the highly specific, multi-step process of Claim 1, including meeting the precise, non-intuitive numerical distance ("20.2 to 22.5 meters") and speed ("0.0001 km/h and 130 km/h") limitations required for the accused maneuver?
• The case may also turn on a technical comparison: does the data processed by Tesla's sensor suite (e.g., cameras, radar) constitute an "emission" and "captured empirical data" as those terms are used and defined within the patent, or is there a fundamental mismatch between the technology described and the technology accused?