WirelessWerx IP LLC v. Tesla Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WirelessWerx IP, LLC (Texas)
  • Defendant: Tesla, Inc. (Texas)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 7:25-cv-00093, W.D. Tex., 02/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has regular and established places of business in the district, including at 1 Tesla Rd, Austin, TX, and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and systems for controlling movable entities using defined geographical zones.
• Technical Context: The technology relates to geofencing, where a virtual boundary is used to trigger actions in a vehicle or other mobile asset, a key feature in modern fleet management and advanced driver-assistance systems.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses in prior litigations with other entities but alleges that none of those licenses involved producing a patented article, which may be relevant to potential arguments over patent marking and damages limitations.

Case Timeline

Date	Event
2004-11-05	U.S. Patent No. 7,323,982 Priority Date
2008-01-29	U.S. Patent No. 7,323,982 Issued
2025-02-27	Complaint Filed

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

U.S. Patent No. 7,323,982 - "Method and System to Control Movable Entities", issued January 29, 2008

The Invention Explained

• Problem Addressed: The patent observes that while GPS tracking systems were becoming common, their functionality was often limited to simply relaying GPS information to a control center to be plotted on a map, and that their benefits had yet to be maximized (’982 Patent, col. 1:47-54).
• The Patented Solution: The invention describes a system where a transponder on a movable entity (e.g., a vehicle) can be loaded with pre-configured geographical zones ("geofences"). The transponder's microprocessor is programmed to independently determine when an "event" occurs in relation to that zone (e.g., entering or leaving the zone) and then execute a "configurable operation" as a result, such as turning off the ignition or locking a door (’982 Patent, Abstract; col. 2:1-6). This shifts intelligence from a central server to the remote entity, enabling autonomous, location-based control actions.
• Technical Importance: This approach allows for more immediate and sophisticated remote control of assets without requiring constant communication with a central server, enabling automated policy enforcement based on an asset's real-time location.

Key Claims at a Glance

• The complaint asserts claims 1-61, focusing on at least independent claim 1 (Compl. ¶16).
• Independent Claim 1 recites a method with the following essential elements:
  • loading a plurality of coordinates from a computing device to a transponder's memory;
  • programming a microprocessor of the transponder to define a geographical zone by creating an enclosed area on a pixilated image using said coordinates;
  • programming the microprocessor to determine the occurrence of an event associated with the entity's status relative to the geographical zone; and
  • configuring the microprocessor to execute a configurable operation if the event occurs.
• The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶21).

III. The Accused Instrumentality

Product Identification

The complaint broadly identifies "Defendant's Accused Products" without naming specific models or systems (Compl. ¶16). It later refers to them as "systems, products, and services in the field of indoor mapping and control" (Compl. ¶21).

Functionality and Market Context

The complaint does not provide specific details about the technical operation of the accused products. It alleges in general terms that Defendant makes, uses, sells, and imports products and services that practice the claimed methods (Compl. ¶¶7, 16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" which was not provided with the filing; therefore, the infringement theory is summarized below in prose (Compl. ¶21). No probative visual evidence provided in complaint.

The complaint alleges that Defendant directly infringes, literally or under the doctrine of equivalents, at least claim 1 of the ’982 Patent (Compl. ¶16). The narrative theory asserts that Defendant’s products and services, particularly those related to "indoor mapping and control," infringe one or more claims of the patent (’982 Patent, Compl. ¶21). The complaint does not, however, map specific features of any Tesla product or service to the individual limitations of the asserted claims.

• Identified Points of Contention:
  • Evidentiary Questions: A central question will be what evidence Plaintiff can produce to show that any specific Tesla product performs the steps of the asserted claims. The complaint's lack of specificity suggests this will be a primary focus of discovery.
  • Technical Questions: The infringement analysis will likely question whether any accused system defines a geographical zone by "creating an enclosed area on a pixilated image," as explicitly required by claim 1 (’982 Patent, col. 27:36-37). The specific mechanism for defining the zone will be a critical technical point. It also raises the question of what specific "configurable operation" is executed by an accused Tesla product in response to a geofence-related event.

V. Key Claim Terms for Construction

• The Term: "geographical zone by creating an enclosed area on a pixilated image"

  • Context and Importance: This term is the core of the claimed method for defining the geofence. The infringement analysis will depend heavily on whether the accused systems use a method that can be characterized as creating a "pixilated image." Practitioners may focus on this term because its specificity could provide a strong non-infringement argument if Tesla's systems use a different method (e.g., vector-based polygons) for defining virtual boundaries.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue the term should not be read literally as a graphical image file, but rather as any digital representation that maps coordinates to a grid-like data structure to define a boundary, as this is the functional purpose described (’982 Patent, col. 15:19-30).
    • Evidence for a Narrower Interpretation: The specification provides a detailed description of this process, including drawing a "bounding" square, pixilating it, marking pixels as activated, and connecting them to form a "contiguous line of pixels" (’982 Patent, col. 15:22-30, 52-57; Fig. 5A). This detailed disclosure of a specific embodiment may be used to argue for a narrower construction limited to this explicit method.

• The Term: "configurable operation"

  • Context and Importance: This term defines the action taken in response to a geofence event. Its construction will determine whether a simple software notification or alert qualifies, or if a more significant, physical control action is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad. The specification lists a wide array of possible operations, from changing speed to turning on a light indicator, suggesting the term encompasses a wide variety of actions (’982 Patent, col. 2:41-49).
    • Evidence for a Narrower Interpretation: A party could argue the term should be limited to actions that directly control the physical state or function of the vehicle itself (e.g., "turning off the ignition," "locking a door or latch"), as these are the primary examples given to solve the stated problem of enhancing control over a remote asset, distinguishing it from merely providing information to a user (’982 Patent, col. 2:41-45).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by asserting that Defendant encourages and instructs customers on how to use its products and services in an infringing manner through materials like its website and instruction manuals (Compl. ¶¶22-23). It alleges contributory infringement by claiming the accused products are not staple articles of commerce and their only reasonable use is an infringing one (Compl. ¶23).
• Willful Infringement: The complaint alleges knowledge of the ’982 Patent and its underlying technology "from at least the filing date of the lawsuit" (Compl. ¶¶22-23). This allegation supports a claim for post-suit willful infringement but does not plead facts supporting pre-suit knowledge. The Plaintiff explicitly reserves the right to amend if discovery reveals pre-suit knowledge (Compl. p. 6, n. 2).

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

• A central issue will be one of evidence and specificity: Can Plaintiff identify a specific Tesla system and present evidence that it practices every element of an asserted claim, particularly given the generic allegations in the complaint?
• The case will also turn on a question of claim scope: Can the term "geographical zone by creating an enclosed area on a pixilated image", which is taught with significant particularity in the patent, be construed to read on the geofencing technology, if any, used in Tesla's products?
• A third key question will be one of functional operation: Does any accused Tesla feature execute a "configurable operation" in the sense of an active vehicle control function as emphasized in the patent's specification, or do the features provide only alerts and information to the driver, potentially creating a mismatch with the claimed invention?