DCT

7:25-cv-00408

Fleet Connect Solutions LLC v. Portable Multimedia Ltd T A Nextbase

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00408, W.D. Tex., 09/04/2025
  • Venue Allegations: Plaintiff alleges that venue is proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district, pursuant to the alien-venue rule.
  • Core Dispute: Plaintiff alleges that Defendant’s dashcams and associated software applications infringe three patents related to vehicle-based communication, emergency alerting, and trip status notification systems.
  • Technical Context: The technology at issue falls within the domain of automotive telematics, which involves integrating telecommunications and informatics for use in vehicles to provide location-based safety, navigation, and information services.
  • Key Procedural History: The complaint notes that this action was previously consolidated into a case in the Eastern District of Texas, [Fleet Connect Solutions LLC](https://ai-lab.exparte.com/party/fleet-connect-solutions-llc) v. Alan Ritchey Inc, et al., and was subsequently deconsolidated, suggesting Plaintiff is engaged in a broader campaign to enforce this patent portfolio.

Case Timeline

Date Event
1999-09-10 ’926 and ’291 Patents Priority Date
2002-11-04 ’837 Patent Priority Date
2003-11-10 ’926 Patent Application Filed
2006-10-17 ’926 Patent Issued
2007-04-17 ’837 Patent Issued
2009-08-24 ’291 Patent Application Filed
2010-06-29 ’291 Patent Issued
2025-09-04 Complaint Filed

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

U.S. Patent No. 7,123,926 - "System and Method for Providing Information to Users Based on the User's Location," Issued October 17, 2006 (’926 Patent)

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the limitations of conventional vehicle communication systems like cellular phones and CB radios, noting difficulties in discovering and privately communicating with nearby vehicles, and highlights the need for improved control and warning systems to reduce automobile accidents (’926 Patent, col. 1:21-51).
  • The Patented Solution: The invention describes a mobile communication unit installed in a vehicle, equipped with a GPS receiver and an RF transceiver (’926 Patent, col. 1:55-61). This unit can determine its own location and status (e.g., speed, direction) and transmit this information in structured communication packets to other vehicles or fixed base stations, enabling location-based advisory and safety communications (’926 Patent, Abstract; col. 2:4-11).
  • Technical Importance: The patent describes a foundational architecture for vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2I) communication, a key concept in the development of modern intelligent transportation and driver-assistance systems.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶31).
  • Claim 1 requires a method comprising the following essential elements:
    • determining a geographic location of the mobile unit;
    • determining an identity of the vehicle based on a unique identification stored in the mobile unit;
    • determining a priority level associated with the emergency situation;
    • assembling a header of a communication, the header including the geographic location, vehicle identity, and priority level, and being capable of being processed by a second mobile unit to alert a remote user;
    • transmitting the communication to the second mobile unit.

U.S. Patent No. 7,206,837 - "Intelligent Trip Status Notification," Issued April 17, 2007 (’837 Patent)

The Invention Explained

  • Problem Addressed: The patent describes the process of manually estimating a trip's time-of-arrival as "an inconvenient and cumbersome task" that requires considering numerous variables and can be dangerous if performed while driving (’837 Patent, col. 1:31-48).
  • The Patented Solution: The invention is a method to automatically and periodically provide trip status updates to a user in transit (’837 Patent, col. 2:60-65). It estimates time-of-arrival metrics by using not only real-time data like current location, but also "calendrical time (i.e., the time and date)" and "historical travel time data" to generate more accurate and context-aware predictions (’837 Patent, col. 2:4-8; Abstract).
  • Technical Importance: This approach of leveraging historical and time-sensitive data automates and enhances the accuracy of travel time estimation, a core function of modern digital mapping and navigation services.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶43).
  • Claim 1 requires a method comprising the following essential elements:
    • receiving a location of a mobile communications device that is in transit to a destination;
    • estimating the time-of-arrival bounds for the device at the destination for a confidence interval based on: (a) the location, and (b) at least one historical travel time statistic;
    • sending the time-of-arrival bounds to the mobile communications device.

Multi-Patent Capsule: U.S. Patent No. 7,747,291 - "Wireless Communication Method," Issued June 29, 2010 (’291 Patent)

  • Technology Synopsis: The ’291 Patent discloses methods for a vehicle's communication system to interact with a user's separate mobile unit (e.g., a smartphone). The vehicle establishes and authorizes a short-range link to the mobile unit, then uses it as a gateway to a wider wireless communication system to send or receive information, such as a traffic update requested via a voice command from the vehicle operator (’291 Patent, Abstract; Fig. 9).
  • Asserted Claims: The complaint asserts independent claim 9 (Compl. ¶55).
  • Accused Features: The complaint alleges that the combination of Nextbase Dashcams, the MyNextbase Connect app, and Nextbase Voice Control infringes by using a connected mobile phone to communicate with a wireless system for services like weather or traffic updates (Compl. ¶¶48, 56).

III. The Accused Instrumentality

  • Product Identification: The "Accused Products" are identified as a suite of Nextbase hardware and software, including Nextbase Dashcams (models 622GW, 322GW, 522GW, and 422GW), the MyNextbase Connect app, the Nextbase Emergency SOS system, and Nextbase Voice Control (Compl. ¶19).
  • Functionality and Market Context: The complaint describes the Accused Products as a "fleet management platform and tracking solutions" ecosystem (Compl. ¶19). The system's alleged functionality involves the dashcam communicating wirelessly (e.g., via Bluetooth or IEEE 802.11) with a user's smartphone running the MyNextbase Connect app (Compl. ¶¶19, 21). A key feature highlighted is the "Emergency SOS system," which can automatically detect a crash and transmit the vehicle's location to emergency services (Compl. ¶¶19, 32). The "Voice Control" feature is also identified as part of the accused system (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint references claim-chart Exhibits A, B, and C, but these documents were not attached to the publicly filed complaint. The infringement theories are summarized below based on the narrative allegations.

  • ’926 Patent Infringement Allegations
    The complaint alleges that the Accused Products, specifically through the Emergency SOS feature, infringe claim 1 by performing a method of alerting a remote user to an emergency (Compl. ¶32). The narrative theory suggests that upon detecting a crash, the system determines the dashcam's geographic location via GPS, determines a vehicle identity and a priority level (the emergency), assembles this information into a communication, and transmits it to a "second mobile unit," implied to be an emergency services dispatcher (Compl. ¶32).

  • ’837 Patent Infringement Allegations
    The complaint alleges that the Accused Products infringe claim 1 by performing a method of providing trip status notifications (Compl. ¶44). The theory asserts that the products receive a device's location while in transit, estimate "time-of-arrival bounds" based on that location and "at least one historical travel time statistic," and then send these bounds to the device (Compl. ¶44). The complaint does not specify which feature of the Accused Products performs this function or provide facts supporting the use of historical statistics.

  • Identified Points of Contention:

    • Scope Questions: The infringement theory for the ’926 Patent raises the question of whether an emergency services dispatch center qualifies as a "second mobile unit" under the patent's claims. The defense may argue this term should be construed to mean another vehicle-based unit, consistent with the patent's focus on vehicle-to-vehicle communications.
    • Technical Questions: A central question for the ’837 Patent is whether the Accused Products in fact use "historical travel time statistic[s]" to estimate arrival times, as required by the claim. The complaint's allegation on this point is conclusory and lacks specific factual support, suggesting a potential dispute over the actual technical operation of the accused feature.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "second mobile unit" (from ’926 Patent, claim 1)

  • Context and Importance: The viability of the infringement allegation against the Emergency SOS feature depends on this term's scope. If construed narrowly to mean only another vehicle, the allegation that the system alerts a stationary emergency dispatcher may fail. Practitioners may focus on this term because it appears to be a crucial point of mismatch between the patent's context and the accused functionality.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification states that "remote units 16 may be fixed or mobile," which could be argued to encompass a fixed emergency dispatch location (’926 Patent, col. 2:62-63).
    • Evidence for a Narrower Interpretation: The patent's summary and background repeatedly frame the invention in the context of communication "among vehicles," "with neighboring vehicles," and improving "vehicle to vehicle communication," which may support a narrower construction limited to other vehicles or mobile entities (’926 Patent, col. 1:24, 55-56).

  • The Term: "historical travel time statistic" (from ’837 Patent, claim 1)

  • Context and Importance: This term is the technical core of claim 1. Infringement requires proof that the accused system uses this type of data. The defense will likely contend that any ETA calculation it performs relies on non-infringing methods, such as real-time speed and distance alone.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification gives examples of statistics such as "expected trip time and standard deviation," suggesting the term is not limited to one specific type of data (’837 Patent, col. 3:37-39). This could allow for a range of stored data, such as average speed for a road segment, to meet the limitation.
    • Evidence for a Narrower Interpretation: The patent highlights the novelty of using "calendrical time" (e.g., rush hour, holiday) to inform estimates, suggesting the claimed "statistic" is not a simple, static value but one that is contextually dependent on the time and date (’837 Patent, col. 2:5-8, col. 3:31-36).

VI. Other Allegations

  • Indirect Infringement: The complaint makes a general allegation of inducement of third parties but does not plead specific facts, such as quoting user manuals or advertisements, that would show Defendant actively encouraged infringing use of the Accused Products (Compl. ¶16).
  • Willful Infringement: The complaint does not contain a specific claim for willful infringement or allege that Defendant had pre-suit knowledge of the Asserted Patents. The prayer for relief requests a finding of an "exceptional case" for the purpose of recovering attorneys' fees under 35 U.S.C. § 285 (Compl. ¶60.d).

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

  • A core issue will be one of definitional scope: can the term "second mobile unit," which appears in the context of vehicle-to-vehicle communication in the ’926 Patent, be construed broadly enough to read on a stationary emergency services dispatch center as alleged in the complaint?
  • A key evidentiary question will be one of technical proof: does the plaintiff possess evidence demonstrating that the accused Nextbase products actually use "historical travel time statistics" to calculate arrival times as required by the ’837 Patent, or do the products use a different, non-infringing methodology?
  • The case will also present a question of system infringement: for the ’291 Patent, can the plaintiff establish that the defendant is liable for infringing a system claim where critical components and actions involve a user's third-party smartphone and their interaction with the MyNextbase Connect app?