Fleet Connect Solutions LLC v. Grady Rentals LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Fleet Connect Solutions LLC v. Grady Rentals, LLC
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 7:25-cv-00342, W.D. Tex., 08/07/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains regular and established places of business in the district, including facilities in Midland and Gardendale, and has committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management and tracking solutions, provided by Pedigree Technologies, infringe nine patents related to wireless communication systems, mobile data management, and vehicle tracking.
• Technical Context: The technologies at issue involve methods for managing wireless network interference, increasing data packet rates, and using handheld devices for field operations and asset tracking, which are central to the logistics and transportation industries.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history concerning the asserted patents.

Case Timeline

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 describes the problem of radio frequency interference that occurs when multiple wireless communication standards, such as Bluetooth and IEEE 802.11, operate simultaneously in the same unlicensed frequency band (e.g., 2.4 GHz) and in close proximity to one another (US 7,058,040 B2, col. 1:19-27). This interference can cause destruction of data packets and degrade network performance (US 7,058,040 B2, col. 1:30-34).
• The Patented Solution: The invention proposes a method for data transmission over these overlapping media that computes and shares Time Division Multiple Access (TDMA) time-slot channels between them. The method involves allocating specific time-slots to each medium for data transmission and then dynamically adjusting the number of assigned slots based on a "desired level of service" to manage coexistence and avoid collisions (US 7,058,040 B2, Abstract; col. 2:3-22).
• Technical Importance: This approach provided a systematic way for disparate but popular wireless technologies to coexist in increasingly crowded radio spectrum, thereby improving the reliability and performance of both (US 7,058,040 B2, col. 2:60-67).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶28).
• Claim 1 is a method for data transmission over first and second media that overlap in frequency, comprising the steps of:
  • computing one or more time division multiple access (TDMA) time-slot channels to be shared between the first and second media for data transmission;
  • 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; and
  • dynamically adjusting a number of time-slot channels assigned to one of the first and second media during the data transmission to remain within limits of a desired level of service.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,742,388 - "Packet Generation Systems and Methods"

• Issued: June 22, 2010

The Invention Explained

• Problem Addressed: The patent addresses the persistent demand for higher data rates in digital communication networks, particularly in wireless local area networks (WLANs) governed by standards like IEEE 802.11 (US 7,742,388 B2, col. 1:11-14, 63-65).
• The Patented Solution: The invention discloses systems and methods for increasing the data rate of a packet by increasing its standard size. This is achieved by adding subcarriers to the packet, specifically to a training symbol within the packet's preamble, to create an "extended data signal" that carries more information than a standard packet (US 7,742,388 B2, Abstract; col. 2:15-20). The method is described in the context of Orthogonal Frequency-Division Multiplexing (OFDM) systems (US 7,742,388 B2, FIG. 3).
• Technical Importance: This technology offers a method to enhance data throughput beyond existing standards, enabling more efficient use of available bandwidth for service providers and consumers (US 7,742,388 B2, col. 2:5-11).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶38).
• Claim 1 is a method comprising the steps of:
  • generating a packet with a size corresponding to a protocol used for a network transmission, wherein the packet comprises a preamble having a first training symbol and a second training symbol;
  • increasing the size of the packet by adding subcarriers to the second training symbol of the packet to produce an extended packet, wherein a quantity of subcarriers of the second training symbol is greater than a quantity of subcarriers of the first training symbol; and
  • transmitting the extended packet from an antenna.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,656,845 - "Channel Interference Reduction"

• Issued: February 2, 2010
• Technology Synopsis: As a continuation of the ’040 Patent, this patent addresses the same problem of radio frequency interference between co-located wireless systems operating in the same frequency band. The solution is likewise based on allocating and managing TDMA time-slots to enable coexistence (Compl. ¶¶ 50, 53).
• Asserted Claims: At least Claim 1 (Compl. ¶56).
• Accused Features: The complaint accuses products such as Cab-Mate Elite, PM-45, PM-65, and various Pedigree ELD devices (Compl. ¶49).

U.S. Patent No. 7,260,153 - "Multi Input Multi Output Wireless Communication Method and Apparatus Providing Extended Range and Extended Rate Across Imperfectly Estimated Channels"

• Issued: August 21, 2007
• Technology Synopsis: The technology relates to solving the cross-talk interference problem inherent in Multi-Input Multi-Output (MIMO) wireless systems, particularly when the propagation channel characteristics are imperfectly estimated. The patent aims to provide more robust and predictable communication range and data rates in such systems (Compl. ¶63).
• Asserted Claims: At least Claim 1 (Compl. ¶66).
• Accused Features: The complaint accuses various Pedigree ELD devices, dashcams, and telematics & gateway devices (Compl. ¶59).

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification"

• Issued: April 17, 2007
• Technology Synopsis: The patent describes methods for providing trip status information, such as estimated time-of-arrival, to a user in transit. The estimates are based on a variety of data inputs, including calendrical time, historical statistics, current weather and traffic, and forecasts (Compl. ¶73).
• Asserted Claims: At least Claim 1 (Compl. ¶76).
• Accused Features: The complaint accuses Pedigree fleet management software (e.g., Oneview platform), gateway & telematics devices, driver mobile apps, ELD tablets, and dashcams (Compl. ¶69).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices"

• Issued: September 29, 2009
• Technology Synopsis: This patent, a continuation of the ’586 patent, describes systems and methods for using handheld devices to execute field operations. The invention aims to improve the function of communication systems for personnel using such devices in the field (Compl. ¶83).
• Asserted Claims: At least Claim 1 (Compl. ¶86).
• Accused Features: The complaint accuses the Pedigree fleet management software suite, driver mobile apps, ELD tablets, and telematics & gateway devices (Compl. ¶79).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices"

• Issued: November 1, 2005
• Technology Synopsis: The patent discloses systems for conducting field assessments using handheld devices that provide portable access to industry-specific programs and data. It enables two-way communication between field devices and remote computers to facilitate real-time access to information and assistance (Compl. ¶93; '586 Patent, Abstract).
• Asserted Claims: At least Claim 9 (Compl. ¶96).
• Accused Features: The complaint accuses the Pedigree fleet management software, driver mobile apps, ELD tablets, and telematics devices (Compl. ¶89).

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

• Issued: July 23, 2013
• Technology Synopsis: As part of the same family as the '586 and '751 patents, this patent relates to methods and systems for collecting and communicating field data based on geographical location. It aims to improve upon existing methods of managing mobile assets (Compl. ¶103).
• Asserted Claims: At least Claims 21 and 22 (Compl. ¶106).
• Accused Features: The complaint accuses the full range of Pedigree fleet management software, driver apps, ELD tablets, and telematics devices (Compl. ¶99).

U.S. Patent No. 7,741,968 - "System and Method for Navigation Tracking of Individuals in a Group"

• Issued: June 22, 2010
• Technology Synopsis: The patent describes a system for permissive navigational tracking where a sending party can selectively transmit its navigation data to a receiving party. The claimed invention is directed at improving systems for such selective tracking over time (Compl. ¶113).
• Asserted Claims: At least Claim 4 (Compl. ¶116).
• Accused Features: The complaint accuses Pedigree fleet management software, ELD tablets, driver mobile apps, telematics devices, asset trackers, and dashcams (Compl. ¶109).

III. The Accused Instrumentality

Product Identification

• The accused products are the "fleet management platform and tracking solutions provided by Pedigree Technologies, LLC" (Compl. ¶15). This includes a range of hardware and software products, identified as: Cab-Mate Elite, Pedigree ELD, ELD tablets, Pedigree dashcams, Pedigree telematics & gateway devices, Pedigree Fleet Management software (including the Oneview platform and mobile apps), Pedigree driver mobile apps, and Pedigree Asset Trackers (collectively, the "Accused Products") (Compl. ¶15).

Functionality and Market Context

• The complaint alleges that the Accused Products perform wireless communications using various protocols, including Bluetooth, IEEE 802.11 (e.g., 802.11b and 802.11n), and LTE (Compl. ¶16). Their alleged technical functions include generating and transmitting packets for wireless communications, communicating data using multiple wireless transceivers and protocols, encoding data, and performing error estimation in Orthogonal Frequency Division Multiplexed (OFDM) receivers (Compl. ¶¶ 17, 18). These products are positioned in the market for fleet management and logistics, providing tracking and data solutions for commercial vehicles and assets (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint references but does not attach claim-chart exhibits (Exhibits A-I) detailing its infringement theories (Compl. ¶¶ 28, 38, 56, 66, 76, 86, 96, 106, 116). The narrative infringement theories for the lead patents are summarized below.

No probative visual evidence provided in complaint.

’040 Patent Infringement Allegations (Narrative Summary)

• The complaint alleges that the Accused Products infringe the ’040 patent by performing wireless communications using multiple protocols, such as Bluetooth and IEEE 802.11, which operate in overlapping frequency bands (Compl. ¶16). The infringement theory suggests that to manage coexistence and avoid interference between these protocols, the Accused Products implement a method of allocating and dynamically adjusting time-slots for transmission, thereby practicing the method of claim 1 (Compl. ¶17, 28).

’388 Patent Infringement Allegations (Narrative Summary)

• The complaint alleges that the Accused Products utilize OFDM-based protocols like 802.11n to generate and transmit data packets (Compl. ¶¶ 16, 18). The infringement theory appears to be that in implementing these communication standards, particularly for higher data rates, the Accused Products generate packets with an increased number of subcarriers relative to a baseline or earlier standard. This act of generating a packet with more subcarriers in its training symbols is alleged to practice the method claimed in the ’388 patent (Compl. ¶¶ 17, 18, 38).

Identified Points of Contention

• Technical Questions: A central question for the '040 patent will be whether the Accused Products' coexistence mechanism for Bluetooth and Wi-Fi actually employs the specific "dynamic adjusting" of TDMA time-slots required by claim 1, or if it uses other well-known mechanisms not covered by the claim. For the '388 patent, a key question is whether the accused 802.11n devices perform the affirmative step of "increasing the size of the packet by adding subcarriers" to a training symbol, or if they simply generate a packet of a predefined, larger format according to the 802.11n standard itself.
• Scope Questions: The infringement analysis for the ’040 patent may turn on how broadly the term "dynamically adjusting" is construed. The analysis for the '388 patent raises the question of whether merely practicing a later-generation standard (like 802.11n) that uses more subcarriers than a predecessor standard (like 802.11a/g) falls within the scope of a method claim for "increasing the size of the packet."

V. Key Claim Terms for Construction

’040 Patent, Claim 1

• The Term: "dynamically adjusting a number of time-slot channels"
• Context and Importance: This term is central to the novelty of the claimed method. The dispute will likely focus on whether the Accused Products perform any active, responsive adjustment of time-slot allocations between different wireless media, or if they use a static or non-TDMA-based coexistence mechanism. Practitioners may focus on this term because proving "dynamic adjustment" requires evidence of a system responding to changing conditions, such as the "desired level of service" mentioned in the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that dynamic adjusting can be done to "remain within limits of said desired level of service" ('040 Patent, col. 2:18-22), which could be interpreted broadly to cover any change in allocation based on network conditions.
  • Evidence for a Narrower Interpretation: The specification also discusses a process involving "deallocation request[s]" ('040 Patent, col. 4:60), which a defendant might argue narrows the term to a specific request-and-release protocol rather than any automated adjustment.

’388 Patent, Claim 1

• The Term: "increasing the size of the packet by adding subcarriers to the second training symbol"
• Context and Importance: This active, step-by-step language is critical. The case may depend on whether the accused devices can be shown to perform an affirmative act of "adding" subcarriers to a baseline packet structure, versus simply generating a packet in a native, larger format defined by a standard. Practitioners may focus on this term to dispute whether practicing a standard that inherently uses more subcarriers constitutes infringement of this specific method.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's summary describes the invention as a method for "increasing data rate of a packet" ('388 Patent, col. 2:15-16), suggesting the overall goal is paramount and could cover any implementation that results in a larger packet.
  • Evidence for a Narrower Interpretation: The detailed description and figures show adding subcarriers into specific "gaps" or onto the edges of an existing legacy waveform ('388 Patent, FIG. 5; col. 6:1-11). This could support a narrower construction limited to modifying a pre-existing packet structure rather than generating a new, larger one from scratch.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced and contributory infringement for the ’388 and ’968 patents. The inducement allegations are based on Defendant providing the Accused Products with instructions, advertising, and technical support that allegedly guide customers to use them in an infringing manner (Compl. ¶¶ 40-41, 118-119). Contributory infringement is alleged on the basis that the Accused Products have "special features" designed for infringement and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶ 42, 120).

Willful Infringement

• Willfulness is alleged for the ’388 and ’968 patents. The allegations are based on knowledge of the patents as of the filing of the complaint (Compl. ¶¶ 39, 117). The complaint further alleges that Defendant has a "policy or practice of not reviewing the patents of others," constituting willful blindness (Compl. ¶¶ 43, 121).

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

• 1. Coexistence Mechanism vs. Claim Scope: A central issue will be one of technical operation: Do the Accused Products' methods for managing coexistence between different wireless protocols (e.g., Bluetooth and Wi-Fi) implement the specific "dynamic adjusting" of TDMA time-slots as claimed by the ’040 patent, or do they employ alternative, unpatented techniques common in the industry?
• 2. Packet Formation vs. Claim Language: A key question of claim interpretation will be whether the accused 802.11n devices perform the affirmative step of "increasing the size of the packet by adding subcarriers" as recited in the ’388 patent, or if they simply generate a packet of a predefined, larger format, raising the question of whether merely practicing a standard constitutes infringement of this method claim.
• 3. System-Level Functionality: For the patents related to field operations and fleet management (e.g., '586, '837, '968), a critical evidentiary question will be one of system integration: Can the plaintiff demonstrate that the accused hardware and software, as used by Defendant's customers, practice every element of the asserted system and method claims, or will the defense argue that the required functionality is fragmented across non-infringing components or depends on user actions not directed by the defendant?