DCT

7:25-cv-00280

Fleet Connect Solutions LLC v. Clarience Tech LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00280, W.D. Tex., 06/20/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains established and regular places of business in the District, including a facility in San Antonio, and has committed acts of infringement from those locations.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management platforms, tracking solutions, and related wireless hardware infringe thirteen patents related to wireless communication, mobile data management, and vehicle tracking technologies.
  • Technical Context: The technologies at issue span fundamental wireless communication techniques, such as channel interference reduction and packet generation, as well as application-level systems for managing and tracking mobile assets and personnel.
  • Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
1999-09-10 Priority Date for U.S. Patent No. 6,647,270
2000-09-18 Priority Date for U.S. Patent Nos. 6,961,586 & 7,593,751
2001-02-21 Priority Date for U.S. Patent No. 6,549,583
2001-08-21 Priority Date for U.S. Patent No. 6,633,616
2001-09-21 Priority Date for U.S. Patent Nos. 7,058,040 & 7,656,845
2002-11-04 Priority Date for U.S. Patent No. 7,206,837
2003-04-15 U.S. Patent No. 6549583 Issued
2003-04-28 Priority Date for U.S. Patent No. 7,260,153
2003-10-06 Priority Date for U.S. Patent No. 7,092,723
2003-10-14 U.S. Patent No. 6633616 Issued
2003-11-11 U.S. Patent No. 6647270 Issued
2004-07-20 Priority Date for U.S. Patent No. 7,742,388
2005-11-01 U.S. Patent No. 6961586 Issued
2006-06-06 U.S. Patent No. 7058040 Issued
2006-08-15 U.S. Patent No. 7092723 Issued
2007-04-17 U.S. Patent No. 7206837 Issued
2007-08-21 U.S. Patent No. 7260153 Issued
2008-06-20 Priority Date for U.S. Patent No. 7,741,968
2009-08-25 Priority Date for U.S. Patent No. 8,494,581
2009-09-29 U.S. Patent No. 7593751 Issued
2010-02-02 U.S. Patent No. 7656845 Issued
2010-06-22 U.S. Patent Nos. 7741968 & 7742388 Issued
2013-07-23 U.S. Patent No. 8494581 Issued
2025-06-20 Complaint Filing Date

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

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

The Invention Explained

  • Problem Addressed: The patent addresses radio frequency interference that occurs when two different wireless communication standards, such as Bluetooth and IEEE 802.11, operate in close proximity within the same unlicensed radio band (e.g., 2.4 GHz) (’040 Patent, col. 1:21-28). This co-location can cause data packet destruction and degraded performance for one or both systems (’040 Patent, col. 1:31-36).
  • The Patented Solution: The invention proposes a method for two different wireless systems sharing a frequency band to coexist by dividing communication into shared time-division multiple access (TDMA) time-slot channels. The method involves allocating a certain number of time slots to the first system (e.g., 802.11) and the remaining slots to the second system (e.g., Bluetooth), and then instructing the transceivers for each system to communicate only during their assigned time slots (’040 Patent, Abstract; col. 2:4-12). This temporal separation is intended to prevent the systems from transmitting simultaneously and causing interference.
  • Technical Importance: This approach provided a method for coordinating otherwise independent wireless protocols to mitigate interference in increasingly crowded unlicensed spectrum, a crucial step for enabling the reliable concurrent use of technologies like Wi-Fi and Bluetooth in a single device or area.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶28).
  • Essential elements of claim 1 include:
    • computing one or more TDMA time-slot channels to be shared between a first and second media that overlap in frequency;
    • allocating one or more time-slot channels to the first medium for data transmission;
    • allocating one or more of the remaining time-slot channels to the second medium for data transmission;
    • dynamically adjusting the number of time-slot channels assigned to one of the media during transmission to remain within limits of a desired level of service.

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

The Invention Explained

  • Problem Addressed: The patent recognizes a demand for higher data rates in wireless LAN environments than what is provided by existing standards like IEEE 802.11a, which operates in the 5 GHz band (’388 Patent, col. 1:62-65). The goal is to increase data rates while maintaining coexistence with legacy devices operating under the existing standard.
  • The Patented Solution: The invention proposes a method to increase the data rate of a communication packet by adding subcarriers to the standard packet structure of a protocol used for a local area network (’388 Patent, Abstract; col. 2:15-20). By populating previously unused frequency bins or narrowing the gap between existing sets of subcarriers, the system can transmit more data within a given time, thereby increasing the overall data rate without fundamentally altering the communication protocol (’388 Patent, col. 5:61–6:24).
  • Technical Importance: This technique represents an approach to evolving wireless standards by extending their capabilities for higher throughput while aiming to preserve backward compatibility with the installed base of legacy devices.

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶37).
  • Essential elements of claim 1 include:
    • generating a packet with a size corresponding to a protocol for a network transmission, the packet comprising a preamble with a first and a second training symbol;
    • increasing the size of the packet by adding subcarriers to the second training symbol to produce an extended packet, where the quantity of subcarriers in the second training symbol is greater than in the first;
    • transmitting the extended packet from an antenna.

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

  • Technology Synopsis: This patent is related to the ’040 Patent and addresses the problem of radio frequency interference between co-located wireless systems like Bluetooth and IEEE 802.11 operating in the same frequency band (’845 Patent, col. 1:16-28). The proposed solution is a method of coordinating the systems by allocating distinct TDMA time slots to each, thereby preventing simultaneous transmission and interference (’845 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶53).
  • Accused Features: The complaint accuses Defendant’s fleet management and wireless communication products, which perform wireless communications pursuant to various protocols, of infringement (Compl. ¶16-19, ¶53).

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus…" (issued Aug. 21, 2007)

  • Technology Synopsis: This patent addresses the problem of cross-talk interference in Multi-Input Multi-Output (MIMO) wireless systems where the propagation channel characteristics are imperfectly estimated (’153 Patent, Abstract). The invention proposes methods and apparatus to solve this interference problem, aiming to achieve more robust and predictable extended range and data rates in such MIMO systems (’153 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶62).
  • Accused Features: The complaint alleges infringement by Defendant’s products that perform wireless communications, including those that perform singular value decomposition of estimated channel matrices (Compl. ¶16-19, ¶62).

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

  • Technology Synopsis: The patent addresses phase noise introduced by radio components in an Orthogonal Frequency Division Multiplexed (OFDM) receiver, which can degrade performance, especially under poor signal-to-noise conditions (’616 Patent, Abstract). The solution involves a pilot phase tracking loop that determines a phase error estimate from received OFDM symbols, which is then used to adjust the phase of subsequent symbols to reduce the impact of phase noise (’616 Patent, Abstract).
  • Asserted Claims: At least claim 12 (Compl. ¶71).
  • Accused Features: The complaint alleges infringement by Defendant’s products that perform wireless communications, including those using OFDM and processing OFDM symbols (Compl. ¶16-19, ¶71).

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

  • Technology Synopsis: This patent is related to the ’616 patent and focuses on reducing phase noise requirements in the radio portion of an OFDM receiver (’583 Patent, col. 1:11-15). It discloses a method of pilot phase error estimation that uses a maximum likelihood-based approach, using complex signal measurements from a plurality of pilot tones to estimate an aggregate phase error, thereby improving signal tracking under poor SNR conditions (’583 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶80).
  • Accused Features: The complaint alleges infringement by Defendant’s products that perform wireless communications, including performing error estimation in OFDM receivers (Compl. ¶16-19, ¶80).

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification" (issued Apr. 17, 2007)

  • Technology Synopsis: This patent describes a method for providing periodic trip status information to a user in transit to a destination. The system estimates time-of-arrival metrics based on data including the user's location, calendrical time, historical travel data, weather, and traffic, and provides alerts based on these estimates (’837 Patent, Abstract).
  • Asserted Claims: At least independent claim 1 (Compl. ¶89).
  • Accused Features: Infringement is alleged against Defendant's fleet management and tracking solutions, which include functionalities such as AVL/GPS Fleet Tracking and Safety Dashboard & Reporting (Compl. ¶16, ¶89).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices" (issued Sep. 29, 2009)

  • Technology Synopsis: This patent discloses systems for conducting field operations, such as assessments or inspections, using handheld data management devices (’751 Patent, Abstract). The methods involve using wireless capabilities in the handheld devices to provide access to industry-specific programs and to synchronize data with remote servers or workstations (’751 Patent, Abstract).
  • Asserted Claims: At least claim 6 (Compl. ¶98).
  • Accused Features: The complaint accuses Defendant’s systems for managing mobile field assets, including handheld devices and associated software, of infringement (Compl. ¶16, ¶98).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices" (issued Nov. 1, 2005)

  • Technology Synopsis: This patent, related to the ’751 patent, describes systems and methods for conducting field assessments using handheld devices that provide portable access to industry-specific programs (’586 Patent, Abstract). It enables data synchronization and delivery via wireless capabilities, facilitating real-time access to remote programs and information relevant to the field assessment (’586 Patent, Abstract).
  • Asserted Claims: At least claim 9 (Compl. ¶107).
  • Accused Features: Infringement is alleged against Defendant's systems for managing mobile assets via wireless and handheld devices (Compl. ¶16, ¶107).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices" (issued Jul. 23, 2013)

  • Technology Synopsis: This patent describes systems for managing mobile assets in the field, supporting functions like dispatch, data synchronization, and logistics through communication between enterprise servers and handheld devices (’581 Patent, Abstract). Bi-directional data delivery over wireless networks facilitates real-time access to remote programs and information for personnel in the field (’581 Patent, Abstract).
  • Asserted Claims: At least claims 21 and 22 (Compl. ¶116).
  • Accused Features: The complaint accuses Defendant’s fleet management systems, which include software for mobile assets and handheld devices, of infringement (Compl. ¶16, ¶116).

U.S. Patent No. 6,647,270 - "Vehicletalk" (issued Nov. 11, 2003)

  • Technology Synopsis: The patent describes a communication system for providing a link among a plurality of mobile units (vehicles) (’270 Patent, Abstract). Each mobile unit is equipped with a transceiver, a GPS receiver, and a microprocessor to allow for communication of information such as position, direction, and speed between vehicles (’270 Patent, col. 1:49-61).
  • Asserted Claims: At least independent claim 1 (Compl. ¶125).
  • Accused Features: The complaint accuses Defendant’s fleet management platforms and tracking solutions, which provide vehicle tracking and communication, of infringement (Compl. ¶16, ¶125).

U.S. Patent No. 7,092,723 - "System and Method for Communicating Between Mobile Units" (issued Aug. 15, 2006)

  • Technology Synopsis: This patent, related to the ’270 patent, details a system and method for communication between mobile units, including the generation of communication packets containing sender, receiver, and administrative information (’723 Patent, Abstract; col. 2:54-57). The system is designed to facilitate communication between vehicles and with roadside networks (’723 Patent, col. 1:19-24).
  • Asserted Claims: At least independent claim 1 (Compl. ¶134).
  • Accused Features: Infringement is alleged against Defendant's fleet management and tracking solutions that enable communication between mobile units (Compl. ¶16, ¶134).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group" (issued June 22, 2010)

  • Technology Synopsis: This patent discloses a system where a "master" portable device can be grouped with other portable devices to maintain and display the geographic positions of all devices in the group (’968 Patent, Abstract). It allows for permissive navigational tracking where a sending party selectively transmits navigation data to a receiving party (’968 Patent, col. 1:19-24).
  • Asserted Claims: At least claim 4 (Compl. ¶143).
  • Accused Features: Defendant's fleet management and tracking solutions, which include features for tracking groups of vehicles or assets, are accused of infringement (Compl. ¶16, ¶143).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies a broad range of products and services, collectively termed the "Accused Products" (Compl. ¶16). These include fleet management and tracking solutions sold under brand names such as “Clarience”, “Road Ready”, and “Fleetilla”; hardware such as the “MobileMule” series of in-vehicle tablets and “Smart Reach” wireless bridges; and software applications including “Safefleet Compass,” “FleetLink,” and various driver apps (Compl. ¶16).
  • Functionality and Market Context: The Accused Products are alleged to constitute fleet management platforms that perform wireless communications using various standard protocols, including Bluetooth, IEEE 802.11, and LTE (Compl. ¶17). Their alleged technical functions include generating and transmitting data packets, communicating data via wireless transceivers, and processing signals using techniques like Orthogonal Frequency Division Multiplexing ("OFDM") (Compl. ¶18, ¶19). These products are marketed for applications such as live GPS tracking, cargo management, temperature monitoring, and video surveillance for commercial and municipal vehicle fleets (Compl. ¶16).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges infringement of each asserted patent and states that the detailed bases for these allegations are provided in Exhibits A through Q (Compl. ¶28, ¶37, ¶53, ¶62, ¶71, ¶80, ¶89, ¶98, ¶107, ¶116, ¶125, ¶134, ¶143). These exhibits were not filed with the complaint and are not available for analysis. The infringement theory must therefore be inferred from general allegations in the body of the complaint.

  • U.S. Patent No. 7,058,040 Infringement Allegations
    The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’040 patent (Compl. ¶28). The general allegations state that the Accused Products perform wireless communications using a plurality of protocols (Compl. ¶17-18). The core of the infringement theory, presumably detailed in the missing Exhibit A, would need to show that the Accused Products, in managing communications between co-located wireless technologies (e.g., on-board Bluetooth sensors and a Wi-Fi or cellular hub), practice the claimed method of computing, allocating, and dynamically adjusting TDMA time slots to mitigate interference.

  • U.S. Patent No. 7,742,388 Infringement Allegations
    The complaint alleges direct infringement of at least claim 1 of the ’388 patent (Compl. ¶37). The general allegations suggest the Accused Products generate and transmit packets for wireless communications (Compl. ¶18). The infringement theory, presumably detailed in the missing Exhibits B-D, would need to establish that the Accused Products generate packets that meet the specific structural requirements of claim 1, namely by adding subcarriers to a second training symbol to create an "extended packet" for increased data rates.

  • Identified Points of Contention:

    • Scope Questions: For the ’040 Patent, a potential issue is whether the Accused Products’ use of standard protocols like Bluetooth and 802.11, which may have their own coexistence mechanisms, meets the specific claim limitations of "computing," "allocating," and "dynamically adjusting" TDMA time slots as claimed. For the ’388 Patent, a question may arise as to whether generating packets compliant with a standard like 802.11n (which offers higher data rates than 802.11a/g) inherently involves "adding subcarriers to the second training symbol" in the manner claimed.
    • Technical Questions: A key evidentiary question for both patents will be how the Accused Products actually function at the physical layer. For the ’040 Patent, what evidence demonstrates that the products actively manage time slots between different media, as opposed to relying on standard, built-in coexistence features? For the ’388 Patent, what evidence shows that the packet generation process involves the specific structural modification of adding subcarriers to a training symbol, as opposed to simply using a different, higher-rate modulation and coding scheme?

V. Key Claim Terms for Construction

  • For the ’040 Patent:

    • The Term: "dynamically adjusting a number of time-slot channels ... to remain within limits of a desired level of service" (Claim 1).
    • Context and Importance: This term is central to the invention's adaptive nature. The scope of infringement may depend on whether this requires an active, real-time assessment and reallocation of time slots based on performance metrics, or if it can be read more broadly to cover pre-set or less frequent adjustments. Practitioners may focus on this term because the functionality of standard wireless protocols might be argued to meet a broad definition, while a narrower definition would require proof of a specific, sophisticated allocation algorithm in the accused products.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not specify the frequency or mechanism of adjustment, which may support an interpretation covering any non-static allocation scheme.
      • Evidence for a Narrower Interpretation: The specification discusses adjusting the allocation in response to a detected failure to meet a "desired level of service" and transmitting a "channel assignment message" with the new configuration, suggesting an active feedback and control loop (’040 Patent, col. 2:20-29).

  • For the ’388 Patent:

    • The Term: "increasing the size of the packet by adding subcarriers to the second training symbol" (Claim 1).
    • Context and Importance: This term defines the specific technical mechanism for increasing the data rate. The infringement analysis will likely turn on whether the accused high-data-rate products achieve their performance by this specific structural modification to a packet's training symbol. A key dispute may be whether creating a packet for a higher-bandwidth standard (e.g., 802.11n) constitutes "adding subcarriers" to a legacy packet structure (e.g., 802.11a).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that the goal is to increase data rate and that this is achieved by adding subcarriers, without strictly limiting the context to modifying a legacy packet versus generating a new, larger native packet (’388 Patent, col. 2:15-20).
      • Evidence for a Narrower Interpretation: Figures 5 and 6 of the patent depict the process as starting with a standard 52-subcarrier waveform and literally "adding" subcarriers to create a 56-subcarrier packet, suggesting a modification process rather than the generation of a different native packet type (’388 Patent, FIG. 5-6).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement for at least the ’388 and ’968 patents. Inducement is alleged based on Defendant’s actions of advising or directing customers to use the Accused Products through instructions, advertising, and technical support (Compl. ¶39-40, ¶145-146). Contributory infringement is alleged on the basis that the Accused Products have "special features that are specially designed to be used in an infringing way and that have no substantial uses other than ones that infringe" (Compl. ¶41, ¶147).
  • Willful Infringement: Willfulness is alleged for at least the ’388 and ’968 patents, based on knowledge of the patents "at least as of the date Defendant was notified of the filing of this action" (Compl. ¶38, ¶144). The complaint further alleges, upon information and belief, that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness (Compl. ¶42, ¶148). The prayer for relief requests a finding of willfulness for the '388 and '968 patents (Compl. ¶153.c).

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

  • A central threshold question will be one of pleading sufficiency: Given that the complaint incorporates by reference seventeen exhibits (A-Q) that allegedly detail the infringement of thirteen patents but does not attach them, a primary issue for the court may be whether the complaint's general, high-level technical allegations are sufficient on their own to state a plausible claim for infringement under prevailing federal pleading standards.
  • A core technical question will be one of standards versus invention: The Accused Products are alleged to operate using established wireless standards (e.g., IEEE 802.11, LTE, Bluetooth). The case will likely turn on whether the Plaintiff can prove that the specific, inventive steps recited in the patent claims are mandated by these standards, or if the Accused Products implement unique, infringing functionalities that go beyond the standard specifications.
  • A key evidentiary question will be one of technical specificity: Without the detailed claim charts, the dispute raises the fundamental question of what specific structures, methods, or algorithms within the vast and diverse array of Accused Products actually practice the patent claims. The case will depend on whether discovery reveals concrete evidence of the claimed "dynamic adjustment" of time-slots, the specific "addition of subcarriers" to training symbols, and the other detailed functionalities required by the thirteen asserted patents.