DCT

1:25-cv-02463

Fleet Connect Solutions LLC v. Xirgo Holdings Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02463, E.D. Va., 12/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Virginia because Defendants maintain a regular and established place of business in Reston, Virginia, and have committed acts of patent infringement in the district from that location.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management platforms, telematics devices, and related software solutions infringe seven U.S. patents related to mobile asset management, dynamic routing, status notification, and wireless communication technology.
  • Technical Context: The technology at issue falls within the fleet telematics and logistics management sector, a field critical for vehicle tracking, route optimization, operational efficiency, and regulatory compliance in the commercial transportation industry.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
2000-09-18 Priority Date for ’044, ’565, and ’949 Patents
2001-02-21 Priority Date for ’583 Patent
2002-01-10 Priority Date for ’223 Patent
2002-11-04 Priority Date for ’837 Patent
2003-04-15 ’583 Patent Issued
2005-09-06 ’223 Patent Issued
2007-04-17 ’837 Patent Issued
2008-06-20 Priority Date for ’968 Patent
2010-06-22 ’968 Patent Issued
2016-03-29 ’044 Patent Issued
2017-08-29 ’565 Patent Issued
2020-06-02 ’949 Patent Issued
2025-12-24 Complaint Filed

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

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

The Invention Explained

  • Problem Addressed: The patent describes a lack of systems that allow a user with a mobile device to permissively and selectively communicate their geographic location to another selected device for tracking purposes, and for the receiving device to provide return navigational assistance (U.S. Patent No. 7,741,968, col. 1:36-43).
  • The Patented Solution: The invention proposes a system of grouped mobile devices, comprising a "master" device and one or more "target" devices. The master device establishes a communication link, receives location updates from the target devices, and displays their positions. The system also enables the master device to calculate and send "convergence navigational instructions" back to the target devices to guide them toward a location, such as the master device's own position (U.S. Patent No. 7,741,968, Abstract; col. 2:1-4). This creates a two-way, coordinated tracking and guidance environment for a group of users (U.S. Patent No. 7,741,968, FIG. 5).
  • Technical Importance: The technology conceptualized a user-controlled, ad-hoc group coordination system for mobile devices, moving beyond the paradigm of centralized, one-way corporate asset tracking.

Key Claims at a Glance

The complaint asserts infringement of at least claim 4, which depends on independent claim 1 (Compl. ¶32). The essential elements of independent claim 1, a method, are:

  • Creating a select group of target portable devices in association with a master portable device;
  • Establishing at the master device the current geographical positions of the target devices;
  • Displaying on the master device the geographical positions of the target devices;
  • Sending "convergence navigational instructions" from the master device to at least one target device to facilitate convergence between the devices; and
  • Generating ETAs for that convergence.

U.S. Patent No. 6,941,223 - "Method and System for Dynamic Destination Routing," issued September 6, 2005

The Invention Explained

  • Problem Addressed: The patent notes that while navigation systems could compute routes considering traffic, they lacked a method for continuously performing a "self-diagnosis" to determine if the recommended route remains optimal in light of actual driving progress and new information, potentially reducing driver acceptance and trust (U.S. Patent No. 6,941,223, col. 1:15-34).
  • The Patented Solution: The invention is a dynamic routing system that, after determining an initial optimal route, continuously checks whether that recommendation remains valid. It does this by comparing the "real travel parameters" of the vehicle (e.g., actual time elapsed, distance traveled) with the "travel parameters associated with the determined optimal route." If a deviation is detected, or if new external information is received, the system triggers a new optimal route computation for the remainder of the trip (U.S. Patent No. 6,941,223, Abstract; col. 2:60-65). The system also emphasizes providing explanatory information to the driver to clarify its recommendations (U.S. Patent No. 6,941,223, col. 2:35-39).
  • Technical Importance: The patented method describes a more intelligent routing system that validates its own output against real-world conditions, aiming for greater reliability than systems that only react to external traffic alerts.

Key Claims at a Glance

The complaint asserts infringement of at least claim 19, an independent method claim (Compl. ¶41). The essential elements of claim 19 are:

  • Determining an optimal route based on static information;
  • Receiving additional information;
  • Determining if the optimal route remains optimal based on a "comparison of real travel parameters of the vehicle with travel parameters associated with the optimal route"; and
  • Determining a new optimal route using the additional information if the original route is no longer optimal, where travel parameters include travel time or traveled distance.

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 7,206,837, "Intelligent Trip Status Notification," issued April 17, 2007.

  • Technology Synopsis: The patent describes a method for providing periodic trip status updates to a user in transit. The system estimates time-of-arrival metrics by processing a variety of data inputs, including the device's current location, calendrical time (time and date), historical travel statistics, and current/forecasted weather and traffic conditions (’837 Patent, Abstract).

  • Asserted Claims: At least independent claim 1 (Compl. ¶50).

  • Accused Features: The complaint accuses Xirgo's overall transportation solution and fleet management platform (Compl. ¶22).

  • Patent Identification: U.S. Patent No. 9,299,044, "System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices," issued March 29, 2016.

  • Technology Synopsis: The patent discloses a system for managing mobile workers. A central server provides a handheld device with a "template" listing tasks for a work shift. The worker reports progress via synchronization with the server, which then updates the template with unfinished or new tasks for a subsequent worker or shift, facilitating multi-shift project coordination (’044 Patent, Abstract; col. 11:4-21).

  • Asserted Claims: At least independent claim 1 (Compl. ¶59).

  • Accused Features: The complaint accuses Xirgo's overall transportation solution and fleet management platform (Compl. ¶22).

  • Patent Identification: U.S. Patent No. 9,747,565, "System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices," issued August 29, 2017.

  • Technology Synopsis: Belonging to the same family as the ’044 Patent, this invention also relates to a system where a server and a mobile device synchronize task "templates" to manage and coordinate the activities of field personnel across different work shifts (’565 Patent, Abstract).

  • Asserted Claims: At least independent claim 1 (Compl. ¶68).

  • Accused Features: The complaint accuses Xirgo's overall transportation solution and fleet management platform (Compl. ¶22).

  • Patent Identification: U.S. Patent No. 10,671,949, "System And Methods For Management Of Mobile Field Assets Via Wireless Handheld Devices," issued June 2, 2020.

  • Technology Synopsis: Also a member of the same patent family as the ’044 and ’565 Patents, this invention covers methods for managing mobile assets by synchronizing task lists or "templates" between a central server and wireless handheld devices to coordinate work, particularly across multiple shifts (’949 Patent, Abstract).

  • Asserted Claims: At least independent claim 1 (Compl. ¶77).

  • Accused Features: The complaint accuses Xirgo's overall transportation solution and fleet management platform (Compl. ¶22).

  • Patent Identification: U.S. Patent No. 6,549,583, "Optimum Phase Error Metric for OFDM Pilot Tone Tracking in Wireless LAN," issued April 15, 2003.

  • Technology Synopsis: This patent addresses a technical problem in wireless signal processing. It describes a method to improve signal tracking in an Orthogonal Frequency-Division Multiplexing (OFDM) receiver—a technology used in Wi-Fi and 4G/LTE—by estimating and correcting for "phase error" using multiple pilot tones in the signal. This enhances communication reliability, especially in low signal-to-noise environments (’583 Patent, Abstract).

  • Asserted Claims: At least independent claim 1 (Compl. ¶86).

  • Accused Features: The complaint targets Xirgo products that communicate using 4G/LTE protocols (Compl. ¶22(b)).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are collectively identified as "Xirgo's transportation solution," which includes a "fleet management platform and tracking solutions" (Compl. ¶22). This encompasses a range of hardware and software products, including in-cab tablets, Electronic Logging Devices (ELDs), various models of Xirgo Telematics Devices and Asset Tracking Devices, and software such as the Xirgo Fleet Management application and the Xirgo Driver app (Compl. ¶22(a)-(c)).

Functionality and Market Context

The accused products provide a suite of functionalities for commercial vehicle and asset management, including tracking, routing, monitoring, messaging, and regulatory compliance (Compl. ¶22(b)). The devices are alleged to use GNSS/GPS for location services and 4G/LTE for communication (Compl. ¶22(b)). The complaint also notes that these products are marketed to commercial motor vehicle operators, some of whom are required to use such systems under federal regulations (Compl. ¶22(a)). The complaint includes a screenshot from Defendant's website showing its U.S. office locations, including one in Reston, Virginia, from which it allegedly conducts business related to the accused products (Compl. ¶16, p. 4, Figure 1).

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement for each of the seven asserted patents but does not provide a narrative infringement theory or claim charts in the body of the complaint itself. For each patent, the complaint makes a conclusory allegation of infringement and states that the details are provided in Exhibits A through G, respectively (Compl. ¶¶ 32, 41, 50, 59, 68, 77, 86). These exhibits were not filed with the complaint. Consequently, the complaint does not provide sufficient detail for a tabular analysis of the infringement allegations.

  • Identified Points of Contention:
    Based on the asserted claims and the general nature of the accused products, several key disputes may arise.
    • For the ’968 Patent: An issue may be whether the architecture of the accused fleet management system maps onto the "master portable device" and "target portable devices" structure required by claim 1. The analysis may question whether a fleet manager's web dashboard or desktop application can be construed as a "master portable device" and whether the system sends "convergence navigational instructions" as claimed.
    • For the ’223 Patent: A central technical question may be whether the accused routing system performs the specific self-diagnostic step of a "comparison of real travel parameters of the vehicle with travel parameters associated with the determined optimal route," as required by claim 19. The dispute could turn on whether the accused system's re-routing is triggered by this specific comparison or by a more generic response to new, external traffic data.

V. Key Claim Terms for Construction

While the complaint does not detail specific infringement theories, the technology and claims suggest certain terms will be central to the dispute.

  • Term from the ’968 Patent: "master portable device" (Claim 1)

    • Context and Importance: The scope of this term may be critical. Infringement could depend on whether a stationary or web-based fleet management console, used by a dispatcher, qualifies as a "portable device." Practitioners may focus on this term because the patent's embodiments appear to depict handheld, person-to-person devices rather than a centralized command center.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "portable," which may leave room for an argument that any device that is not permanently fixed is "portable."
      • Evidence for a Narrower Interpretation: The patent's figures depict handheld cellular-style devices (e.g., ’968 Patent, FIG. 1, FIG. 5). The title, "Navigation Tracking of Individuals in a Group," may also suggest a context of mobile individuals coordinating with each other, rather than a fixed base station tracking a fleet.

  • Term from the ’223 Patent: "comparison of real travel parameters ... with travel parameters associated with the determined optimal route" (Claim 19)

    • Context and Importance: This phrase describes the core "self-diagnosis" feature of the invention. The case may turn on whether the accused system performs this specific comparison as a trigger for re-routing, or if it uses a different logic.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue this language covers any dynamic routing system that implicitly uses a vehicle's real-time progress to determine if a new route is needed.
      • Evidence for a Narrower Interpretation: The specification describes this as an explicit check, stating "a constant comparison is made during the drive of whether the actual driving progress... corresponds to the driving progress computed when determining the optimal route" (’223 Patent, col. 2:1-7). This language suggests a specific, continuous validation process rather than a simple reaction to external events like a new traffic alert.

VI. Other Allegations

The complaint does not contain allegations of indirect infringement or willful infringement.

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

  1. Pleading Sufficiency: A threshold issue will be the complaint's lack of factual allegations supporting infringement. By relying exclusively on unfiled exhibits, the complaint raises the question of whether it provides sufficient factual matter to state a plausible claim for relief under the Twombly/Iqbal pleading standard, which will likely be tested in early motions practice.

  2. Definitional and Temporal Scope: Several of the asserted patents claim priority to the early 2000s and describe technology within the context of that era's PDAs and 2G/3G networks. A core issue will be one of definitional scope: can claim terms rooted in that technological context, such as "master portable device" ('968 Patent) or task-management "templates" on early handhelds ('044 Patent family), be construed to cover modern, cloud-based fleet management platforms operating over 4G/LTE networks?

  3. Evidentiary Mismatch: The asserted portfolio is broad, ranging from fleet management methods to a specific wireless signal processing technique ('583 Patent). A key evidentiary question will be one of functional equivalence: does the accused system, which is alleged to use standard 4G/LTE technology, perform the specific, novel logical steps claimed in the various method patents (e.g., the self-diagnostic comparison of the '223 Patent), or is there a fundamental mismatch in technical operation?