DCT

1:25-cv-02182

Perrone Robotics Innovations LLC v. Mazda Motor Of America Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02182, E.D. Va., 11/25/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Virginia because Defendant Mazda conducts substantial business in the district, including operating showrooms and dealerships, deriving sales revenue, and is registered to do business in Virginia.
  • Core Dispute: Plaintiff alleges that Defendant’s i-ACTIVSENSE driver-assistance systems infringe five patents related to a hardware-independent, general-purpose robotics operating system.
  • Technical Context: The technology concerns a modular software architecture for developing and deploying autonomous and robotic functions in vehicles, a commercially significant field in the modern automotive industry.
  • Key Procedural History: The five patents-in-suit belong to a single family originating from a patent application filed in 2006. The complaint alleges that Plaintiff has provided notice of its patents through patent marking on its website. No prior litigation or administrative proceedings involving these patents are mentioned.

Case Timeline

Date Event
2006-02-27 Earliest Patent Priority Date ('233 Patent Application Filing)
2015-11-24 U.S. Patent No. 9,195,233 Issued
2017-12-05 U.S. Patent No. 9,833,901 Issued
c. 2019-11-25 Start of Alleged Infringement Period ("past six years")
2022-04-26 U.S. Patent No. 11,314,251 Issued
2023-10-10 U.S. Patent No. 11,782,442 Issued
2024-12-31 U.S. Patent No. 12,181,877 Issued
2025-11-25 Complaint Filing Date

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

U.S. Patent No. 12,181,877, “General Purpose Robotics Operating System with Unmanned and Autonomous Vehicle Extensions,” Issued Dec. 31, 2024

  • The Invention Explained:
    • Problem Addressed: The patent family addresses the inefficiency and rigidity of prior art robotics development, where specific software had to be created from scratch for each unique hardware configuration of a robot or automated device (Compl. ¶¶ 17, 21). This approach created barriers to scalability, interoperability, and mass production (Compl. ¶¶ 17, 21).
    • The Patented Solution: The invention is a "general purpose robotics operating system" (GPROS) that acts as a standardized, hardware-independent software platform ('251 Patent, col. 1:24-34). It introduces a novel layer of generic software abstractions and dynamic configuration services that decouple application-level logic (e.g., obstacle avoidance) from the underlying physical hardware (e.g., specific sensors or actuators) (Compl. ¶21; '251 Patent, Fig. 1). This architecture allows configurable applications to be developed and deployed across different vehicle models and hardware setups (Compl. ¶22).
    • Technical Importance: This platform-based approach was designed to reduce development time and cost, enabling the rapid and scalable deployment of autonomous features across entire fleets of vehicles, a departure from bespoke, vertically integrated systems (Compl. ¶23).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 (Compl. ¶40).
    • The essential elements of Claim 1 include:
      • A vehicle comprising a steering mechanism, a brake, and a throttle.
      • An operating system with application services to manage an obstacle service, where these services are independent of the underlying hardware platform and configurable for communication and operational tasks.
      • The set of application services is configurable via a configuration service, can be adapted statically and dynamically, and can access configuration data using a generic abstraction.
      • The vehicle includes a graphical user interface.
      • The vehicle is adapted to receive configuration data over a network and is adapted to avoid obstacles.
    • The complaint reserves the right to assert other claims, including dependent claims 2-6, 8, 10, 12, and 14-21 (Compl. ¶39).

U.S. Patent No. 11,782,442, “General Purpose Robotics Operating System with Unmanned and Autonomous Vehicle Extensions,” Issued Oct. 10, 2023

  • The Invention Explained:
    • Problem Addressed: The patent addresses the technical challenge of coordinating the complex, real-time interplay of sensor processing, decision-making, and actuator control across disparate hardware platforms in an autonomous vehicle (Compl. ¶25). Traditional systems solved this with non-portable, hardware-specific implementations (Compl. ¶26).
    • The Patented Solution: The invention claims an autonomous vehicle equipped with a GPROS that uses a set of hardware-independent application services to manage various application threads (synchronous, asynchronous, or real-time) ('442 Patent, cl. 8). This system controls the vehicle’s physical components—steering, brake, and throttle—through corresponding servomechanisms that operate based on a "movement plan" ('442 Patent, cl. 8). This architecture allows the GPROS to orchestrate vehicle actions while remaining decoupled from the specific hardware implementing those actions (Compl. ¶66).
    • Technical Importance: This approach provides a standardized method for controlling vehicle dynamics based on high-level plans, solving the challenge of hardware heterogeneity while maintaining the timing requirements of real-time vehicle control (Compl. ¶26).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 8 (Compl. ¶60).
    • The essential elements of Claim 8 include:
      • An autonomous vehicle with a steering mechanism, brake, and throttle.
      • A GPROS with application services configured to manage synchronous, asynchronous, or real-time application threads, where the services are hardware-independent and configurable.
      • A steering servomechanism to control the steering mechanism based on a movement plan.
      • A brake servomechanism to control the brake based on the movement plan.
      • A throttle servomechanism to control the throttle based on the movement plan.
    • The complaint reserves the right to assert other claims, including dependent claims 1-4, 6, 7, 9, 11, 12, 15, and 17-20 (Compl. ¶59).

Multi-Patent Capsule: U.S. Patent No. 11,314,251

  • Patent Identification: U.S. Patent No. 11,314,251, "General Purpose Robotics Operating System with Unmanned and Autonomous Vehicle Extensions," issued April 26, 2022.
  • Technology Synopsis: This patent claims an autonomous vehicle architecture centered on a GPROS. The GPROS provides a set of configurable, hardware-independent application services that manage application threads and control the vehicle's steering, brake, and throttle servomechanisms based on a movement plan (Compl. ¶79).
  • Asserted Claims: The complaint asserts at least claims 1-8, 11, and 13-19, with claim 2 presented as an exemplary independent claim (Compl. ¶¶ 78-79).
  • Accused Features: The complaint alleges that Mazda's i-ACTIVSENSE system, through features like Lane Keep Assist and Radar Cruise Control, uses a GPROS to control the vehicle's steering, brake, and throttle servomechanisms in a manner that infringes the patent (Compl. ¶¶ 81, 87).

Multi-Patent Capsule: U.S. Patent No. 9,833,901

  • Patent Identification: U.S. Patent No. 9,833,901, "General Purpose Robotics Operating System with Unmanned and Autonomous Vehicle Extensions," issued Dec. 5, 2017.
  • Technology Synopsis: This patent claims a method performed by a GPROS on a computing device. The method involves managing application threads (synchronous, asynchronous, real-time) and managing autonomous vehicle and movement planning services using a set of configurable, hardware-independent application services (Compl. ¶100).
  • Asserted Claims: The complaint asserts at least claims 1-20, with claim 1 presented as an exemplary independent claim (Compl. ¶¶ 99-100).
  • Accused Features: The complaint alleges that Mazda vehicles with i-ACTIVSENSE practice the claimed method by executing a GPROS on their computing devices (e.g., ECUs) to manage ADAS functions like Lane Keep Assist (Compl. ¶¶ 101, 102, 104).

Multi-Patent Capsule: U.S. Patent No. 9,195,233

  • Patent Identification: U.S. Patent No. 9,195,233, "General Purpose Robotics Operating System," issued Nov. 24, 2015.
  • Technology Synopsis: This patent, the earliest in the family, claims a non-transitory medium (e.g., software) encoding a GPROS. The GPROS comprises a set of configurable and hardware-independent application services for robotics and automation, including services for managing peripherals, sensors, actuators, and application threads (Compl. ¶119).
  • Asserted Claims: The complaint asserts at least claims 1-10, 12-16, and 20-24, and 27, with claim 1 presented as an exemplary independent claim (Compl. ¶¶ 118-119).
  • Accused Features: The complaint alleges that the software and firmware within Mazda vehicles that operate the i-ACTIVSENSE system constitute an infringing non-transitory medium encoding the claimed GPROS (Compl. ¶¶ 120-121).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentality is Defendant’s "i-ACTIVSENSE" suite of advanced driver-assistance systems (ADAS) (Compl. ¶31). The complaint alleges that all vehicles sold in the past six years using any version of i-ACTIVSENSE are infringing products (Compl. ¶31, n.4).
  • Functionality and Market Context: The i-ACTIVSENSE suite is promoted as a set of safety and driver-assist features that use cameras, radar, and collision mitigation to increase driver awareness and reduce accidents (Compl. ¶31). Specific accused functionalities include Lane Keep Assist, Mazda Radar Cruise Control, and Smart City Brake Support (Compl. ¶33). The complaint includes a diagram from a Mazda manual showing the Lane-keep Assist System using a camera to detect lane lines and provide steering assistance (Compl. p. 12). It also alleges, on information and belief, that the system is built upon a GPROS based on Arene (a Toyota-developed system) and the AUTOSAR standard (Compl. ¶30).

IV. Analysis of Infringement Allegations

12,181,877 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A vehicle comprising: a steering mechanism, a brake, and a throttle Mazda vehicles such as the CX-5 are equipped with these components. Lane Keep Assist uses the steering mechanism, and Radar Cruise Control uses the brake and throttle. ¶42 '251 Patent, col. 65:58-60
an operating system comprising a set of application services configured to manage at least one obstacle service of the vehicle... i-ACTIVSENSE is alleged to be an operating system (a GPROS based on Arene/AUTOSAR) with application services like Smart City Brake Support that manages obstacle detection and avoidance. ¶43 '251 Patent, col. 18:28-31
wherein the set of application services is independent of an underlying hardware platform... The i-ACTIVSENSE software platform is alleged to be independent of the underlying hardware and usable across different Mazda models, such as the CX-5. ¶45 '251 Patent, col. 2:50-54
wherein the set of application services: is configurable using a configuration service, is configurable to be adapted both statically and dynamically, and is configurable to access configuration data using a generic abstraction i-ACTIVSENSE allegedly allows ADAS settings to be configured through a generic abstraction. Calibration is alleged to be performed statically (in a controlled environment) and dynamically (while driving). ¶46 '251 Patent, col. 2:25-34
a graphical user interface Mazda vehicles are equipped with a graphical user interface that allows for configuration of ADAS settings. ¶46 '877 Patent, cl. 1
wherein the vehicle is adapted to receive the configuration data over a network... The i-ACTIVSENSE system includes over-the-air software update capabilities. ¶47 '251 Patent, col. 4:45-56
wherein the vehicle is adapted to avoid obstacles. The Smart City Brake Support feature detects obstacles and applies the brakes to avoid them. The complaint provides a diagram illustrating this function. ¶48; p. 12 '251 Patent, col. 18:28-31
  • Identified Points of Contention:
    • Scope Questions: A primary dispute may concern whether the i-ACTIVSENSE system, allegedly built on industry standards like AUTOSAR, meets the specific definition of the claimed "operating system" that is "independent of an underlying hardware platform." The analysis may question whether using a standardized hardware abstraction layer like AUTOSAR is equivalent to the GPROS architecture described in the patent.
    • Technical Questions: The allegation that sensor calibration constitutes being "adapted both statically and dynamically" (Compl. ¶46) raises the question of whether this meets the claim's requirement. A court may need to determine if "dynamic adaptation" requires architectural software changes, as described in the patent's specification, rather than adjustments to operational parameters.

11,782,442 Patent Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
An autonomous vehicle comprising: a vehicle having a steering mechanism, a brake, and a throttle Mazda CX-5 vehicles provide autonomous functions via i-ACTIVSENSE and are equipped with these components. ¶¶62-63 '251 Patent, col. 66:13-15
a general purpose robotics operating system comprising a set of application services configured to manage at least one of synchronous, asynchronous, or real time application threads... i-ACTIVSENSE is alleged to be a GPROS that manages multiple threads to process information from sensors and prioritize data for ADAS applications. ¶¶64-65 '251 Patent, col. 10:49-54
wherein the set of application services is independent of an underlying hardware platform... The i-ACTIVSENSE platform is alleged to be independent of specific hardware and is used across multiple Mazda models. ¶66 '251 Patent, col. 2:50-54
a steering servomechanism configured to control the steering mechanism based on a movement plan i-ACTIVSENSE allegedly uses a steering servomechanism for its Lane Keep Assist feature to keep the vehicle centered in its lane. ¶67 '251 Patent, cl. 2
a brake servomechanism configured to control the brake based on the movement plan; and a throttle servomechanism configured to control the throttle based on the movement plan Mazda's Radar Cruise Control allegedly relies on brake and throttle servomechanisms to adjust vehicle speed based on its operational logic. ¶67 '251 Patent, cl. 2
  • Identified Points of Contention:
    • Scope Questions: The definition of "movement plan" will be a central issue. The analysis will question whether the real-time, reactive logic of features like Lane Keep Assist or Radar Cruise Control constitutes the "movement plan" described in the patent specification, which also discloses more complex route and course planning (e.g., '251 Patent, Figs. 61-62).
    • Technical Questions: The infringement theory depends on mapping specific vehicle components to the claimed "steering servomechanism," "brake servomechanism," and "throttle servomechanism." A dispute could arise over whether the accused vehicle's integrated control system operates with the distinct, delineated components as recited in the claim.

V. Key Claim Terms for Construction

  • The Term: "independent of an underlying hardware platform" (from '877 Patent, cl. 1; '442 Patent, cl. 8)

    • Context and Importance: This term is fundamental to the patents' claimed novelty over prior art systems that were tightly integrated with specific hardware. Its construction will determine whether a system built on industry standards like AUTOSAR, which provides its own hardware abstraction, falls within the scope of the claims.
    • Intrinsic Evidence for a Broader Interpretation: The specification's background section criticizes "monolithic robotics and automation architectures" and highlights the need to bridge the "gap and complexities between robotics and automation application software and hardware" ('251 Patent, col. 2:50-54), which may support a broad reading covering any architecture that is not bespoke to a single hardware configuration.
    • Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific "GPROS" framework with unique components (e.g., '251 Patent, Fig. 1). An argument could be made that "independent" must be understood only in the context of this specific disclosed architecture, not merely as general portability.

  • The Term: "movement plan" (from '877 Patent, cl. 1; '442 Patent, cl. 8)

    • Context and Importance: This term dictates how the claimed servomechanisms are controlled. Whether the operational logic of individual ADAS features like lane-keeping constitutes a "movement plan" will be a key point of contention.
    • Intrinsic Evidence for a Broader Interpretation: The term itself is not explicitly defined, and the claims link it to the control of steering, braking, and throttle. This may support an interpretation that any set of logic dictating these actions, including reactive lane-keeping, is a "movement plan."
    • Intrinsic Evidence for a Narrower Interpretation: The specification provides detailed examples of a "MovementPlanGeneric" that incorporates "maneuvers," which in turn are composed of "maneuver actions" ('251 Patent, Fig. 61). It is also linked to a "RoutePlanner" and "PathPlanner" ('251 Patent, Fig. 62), suggesting a more complex, pre-determined or goal-oriented navigational plan than simple reactive control.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Mazda induces infringement by providing customers and dealers with instructional, marketing, and sales materials that instruct on the use of the infringing i-ACTIVSENSE features and tout their advantages (Compl. ¶¶ 50, 69, 89). The allegations are based on knowledge "at least since being served with this Complaint."
  • Willful Infringement: The complaint does not explicitly use the term "willful infringement." However, the allegations of knowledge post-filing could form the basis for enhanced damages for any continuing infringement. The prayer for relief requests attorneys' fees pursuant to 35 U.S.C. § 285, which is awarded in "exceptional cases," a standard often met by a finding of willfulness (Compl. p. 39).

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

  • A central issue will be one of definitional scope: can the patents' specific "general purpose robotics operating system" architecture, described as being "independent of an underlying hardware platform," be construed to read on a system like i-ACTIVSENSE, which is allegedly based on industry standards such as AUTOSAR that provide their own form of hardware abstraction?
  • A key evidentiary question will be one of functional equivalence: does the operational logic of discrete ADAS features like lane keeping or adaptive cruise control meet the claims' requirements for a "movement plan," or does the patent specification require a more comprehensive, multi-step navigational construct involving routes and waypoints?
  • The dispute may also turn on a technical distinction: does the adaptability of the accused system, such as through sensor calibration and user-preference settings, satisfy the claim requirement of being "adapted both statically and dynamically," or does that term, in the context of the patent, require a more fundamental, on-the-fly reconfiguration of the software architecture itself?