Fleet Connect Solutions LLC v. Xirgo Tech LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Fleet Connect Solutions LLC (Texas)
  • Defendant: Xirgo Technologies, LLC (Delaware); Xirgo Holdings, Inc. (Indiana)
  • Plaintiff’s Counsel: Kaleo Legal; Rozier Hardt McDonough PLLC
• Case Identification: 1:25-cv-01941, E.D. Va., 11/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants maintain a regular and established place of business in the district, specifically an office located in Reston, Virginia.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management and telematics products infringe seven patents related to wireless communication protocols, channel interference management, and network-based vehicle tracking and messaging.
• Technical Context: The technology at issue falls within the domain of vehicle telematics and Internet of Things (IoT) devices, a market focused on connecting vehicles to networks for monitoring, control, and data analysis.
• 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

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 (RF) interference that occurs when different wireless communication standards, such as Bluetooth and IEEE 802.11 (Wi-Fi), operate in close proximity within the same unlicensed frequency band (e.g., 2.4 GHz) ('040 Patent, col. 1:20-24).
• The Patented Solution: The invention proposes a method to manage this interference by using a Time Division Multiple Access (TDMA) framework. It involves computing and allocating distinct time-slot channels to each wireless medium (e.g., Bluetooth, Wi-Fi) and instructing the respective transceivers to communicate only within their assigned time slots, thereby avoiding simultaneous transmissions ('040 Patent, Abstract; col. 3:34-53; Fig. 1A).
• Technical Importance: This approach provides a mechanism for enabling the coexistence of multiple, otherwise conflicting, wireless technologies in increasingly crowded radio spectrum ('040 Patent, col. 1:20-24).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶33).
• Claim 1 is a method for data transmission over first and second media that overlap in frequency, comprising the elements of:
  • computing one or more time division multiple access (TDMA) time-slot channels to be shared;
  • allocating one or more time-slot channels to the first medium;
  • allocating one or more of the remaining time-slot channels to the second medium; and
  • dynamically adjusting a number of time-slot channels assigned to one of the media during transmission to remain within limits of a desired level of service.
• The complaint does not explicitly reserve the right to assert dependent claims for the ’040 patent.

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

The Invention Explained

• Problem Addressed: The patent confronts the issue of "cross-talk interference" in Multiple-Input Multiple-Output (MIMO) wireless systems, which arises when the communication channel is imperfectly estimated. This imperfect knowledge prevents the ideal separation of parallel data sub-streams, degrading performance ('153 Patent, col. 2:3-11, col. 4:7-13).
• The Patented Solution: The invention describes a method for evaluating and mitigating this interference. It involves performing a Singular Value Decomposition (SVD) on an estimated channel matrix to obtain its singular values. Based on these values and defined "Channel Matrix Metrics," the system can evaluate the level of cross-talk and apply "Pre-Equalizer" and "Post-Equalizer" operators to transform the channel matrix into one with more favorable transmission properties ('153 Patent, Abstract; col. 4:32-54).
• Technical Importance: The technology aims to make MIMO communication more robust and predictable in real-world conditions where perfect channel information is unavailable, thereby helping to achieve the theoretical gains in data rate and range offered by MIMO architectures ('153 Patent, col. 4:32-39).

Key Claims at a Glance

• The complaint asserts independent claim 28 (Compl. ¶43).
• Claim 28 is a transmission apparatus for evaluating a MIMO channel, comprising:
  • an SVD performer configured for performing an SVD of an estimated channel matrix to obtain estimated channel singular values; and
  • a measure calculator associated with the SVD performer, configured for calculating a respective crosstalk measure for each sub-stream from the estimated channel singular values and a channel matrix metric.
• The complaint does not explicitly reserve the right to assert dependent claims for the ’153 patent.

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

• Technology Synopsis: Belonging to the same family as the ’040 Patent, this patent also addresses channel interference. It claims an apparatus with means for allocating data channels to be shared between a first and second medium, and for dynamically adjusting the number of channels assigned to each medium during transmission to maintain a desired level of service (Compl. ¶48, ¶54).
• Asserted Claims: Independent claim 18 is asserted (Compl. ¶53).
• Accused Features: The complaint alleges that Defendant’s products include apparatuses with a "means for allocating" and a "means for dynamically adjusting" data channels between different communication media (Compl. ¶54).

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

• Technology Synopsis: This patent relates to the structure of data packets in a digital communication system. The invention involves generating a packet whose preamble contains a first training symbol and a second training symbol, where the second training symbol comprises a greater quantity of modulated subcarriers than the first, a technique that may be used to support different communication modes or backward compatibility in OFDM systems (Compl. ¶58, ¶64).
• Asserted Claims: Independent claim 28 is asserted (Compl. ¶63).
• Accused Features: The complaint accuses Defendant's products of including a PHY unit configured to generate a packet with the claimed two-part training symbol structure in its preamble (Compl. ¶64).

U.S. Patent No. 8,005,053 - "Channel Interference Reduction," issued August 23, 2011

• Technology Synopsis: Also from the "Channel Interference Reduction" family, this patent claims an apparatus for managing communication between different wireless protocols. The apparatus contains two transceivers for two different protocols and a controller configured to select one transceiver to communicate data for both, while encoding the data from the unselected protocol into the format of the selected protocol (Compl. ¶75, ¶81).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶80).
• Accused Features: The complaint alleges Defendant’s products function as an apparatus with two transceivers and a controller that selects one for transmission and encodes data from the unselected protocol for that transmission (Compl. ¶81).

U.S. Patent No. 7,536,189 - "System and Method for Sending Broadcasts in a Social Network," issued May 19, 2009

• Technology Synopsis: This patent describes a system for a system administrator to broadcast advisory communications to remote units, such as vehicles in a fleet. The method includes accessing a website, filtering a plurality of remote units based on an information field, assembling data or voice packets, and forwarding them for transmission (Compl. ¶85, ¶90).
• Asserted Claims: Independent claim 1 is asserted (Compl. ¶89).
• Accused Features: The complaint accuses Defendant's fleet management solutions of performing the claimed method of using a website-based interface to filter and send advisory broadcasts to remote units (Compl. ¶90).

U.S. Patent No. 7,599,715 - "System and Method for Matching Wireless Devices," issued October 6, 2009

• Technology Synopsis: This patent claims a method for tracking vehicle maintenance information. The system receives a signal from a vehicle containing a vehicle identifier and status, stores it, determines associated maintenance information, constructs a communication packet with this information, and forwards it over the Internet (Compl. ¶95, ¶102).
• Asserted Claims: Independent claim 29 is asserted (Compl. ¶101).
• Accused Features: The complaint alleges Defendant's products perform the claimed method of tracking vehicle maintenance by receiving telematics data, parsing it to determine maintenance needs, and communicating that information through a network (Compl. ¶102).

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are "Xirgo's transportation solution," which includes a wide range of fleet management platforms, tracking solutions, and telematics devices identified by specific model numbers (e.g., KP2, XT3100 Series, XG3700), as well as associated software and websites (Compl. ¶22).
• Functionality and Market Context: The complaint alleges these products provide fleet management and tracking solutions, incorporating wireless communication capabilities including, but not limited to, Bluetooth and IEEE 802.11 standards (Compl. ¶22-23). The complaint alleges Defendants market, sell, and distribute these products within the Eastern District of Virginia and throughout the United States, operating from a place of business in Reston, Virginia (Compl. ¶12, ¶16, ¶20). The complaint provides a screenshot from Defendant's website listing a "Virginia Office" in Reston, VA, as part of its allegations regarding Defendant's business presence in the district (Compl. Figure 1, p. 4).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits for each asserted patent (e.g., Exhibits A1, A2 for the ’040 patent) but does not attach them (Compl. ¶33, ¶43, ¶53, ¶63, ¶80, ¶89, ¶101). The analysis below is based on the narrative infringement summaries provided in the body of the complaint.

’040 Patent Infringement Allegations

• Narrative Summary: The complaint alleges that Defendants, through the use of the Accused Products, perform the method of claim 1 for data transmission over first and second media that overlap in frequency. This allegedly includes computing and sharing TDMA time-slot channels, allocating them between the media, and "dynamically adjusting a number of timeslot channels assigned" to maintain a desired level of service (Compl. ¶34).
• Identified Points of Contention:
  • Scope Question: A potential question is whether the Accused Products' use of standardized protocols, which may have their own resource allocation schemes, constitutes the specific method of "computing," "allocating," and "dynamically adjusting" TDMA time-slots as recited in claim 1.
  • Technical Question: What evidence does the complaint provide that the Accused Products perform the specific function of "dynamically adjusting a number of timeslot channels" during transmission to manage a "desired level of service," as required by the final element of claim 1?

’153 Patent Infringement Allegations

• Narrative Summary: The complaint alleges the Accused Products are "transmission apparatuses for evaluating a channel of a MIMO wireless communication system" as recited in claim 28. This allegedly includes an "SVD performer" for obtaining estimated channel singular values and a "measure calculator" for calculating a "crosstalk measure" from those singular values and a "channel matrix metric" (Compl. ¶44).
• Identified Points of Contention:
  • Scope Question: A point of contention may be whether hardware or software components within the Accused Products, which are designed to comply with standards like 802.11n/ac, can be construed as the claimed "SVD performer" and "measure calculator."
  • Technical Question: How does the complaint substantiate the allegation that the Accused Products calculate a "crosstalk measure" using the specific inputs of "estimated channel singular values and a channel matrix metric" as required by claim 28, beyond a conclusory recitation of the claim language?

V. Key Claim Terms for Construction

For the ’040 Patent

• The Term: "dynamically adjusting a number of time-slot channels"
• Context and Importance: This term describes a key functional step in the claimed method. The infringement analysis may hinge on whether the resource management performed by the accused systems meets this definition. Practitioners may focus on this term because it appears to claim a responsive, in-progress modification of channel allocation, which may or may not be present in the accused systems.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language links the adjustment to remaining "within limits of a desired level of service," which could be argued to encompass a wide range of Quality of Service (QoS) management techniques ('040 Patent, col. 9:28-32).
  • Evidence for a Narrower Interpretation: The specification describes a specific implementation of this dynamic adjustment, which includes "detecting the medium that fails to meet said desired level of service" and "transmitting a channel assignment message" with additional time slots ('040 Patent, col. 10:40-46). This could support an argument that the term requires this specific sequence of detection and reassignment.

For the ’153 Patent

• The Term: "crosstalk measure"
• Context and Importance: This term defines the output of the claimed "measure calculator" and is critical for the claimed method of evaluating a MIMO channel. The dispute may turn on whether any metric calculated by the accused devices falls within the patent's definition of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims state that the "predefined functions provides a measure of cross-talk signal to noise ratio (SNR) for said respective sub-stream" ('153 Patent, col. 16:48-51), suggesting the term could cover various calculations that quantify SNR.
  • Evidence for a Narrower Interpretation: The specification introduces specific "Matrix Metrics Si" that are derived from the channel's singular values and relate to the probability of achieving a certain cross-talk SNR ('153 Patent, col. 8:1-12). A party could argue that "crosstalk measure" is limited to these or similar formally defined metrics.

VI. Other Allegations

• Indirect Infringement: For the ’388 patent, the complaint alleges induced infringement based on Defendants allegedly advising, directing, advertising, and distributing instructions that guide users to use the Accused Products in an infringing manner (Compl. ¶65). Contributory infringement is alleged on the basis that the Accused Products have special features that are material to the invention and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶66).
• Willful Infringement: The complaint alleges willful infringement of the ’388 patent. The basis for willfulness includes alleged knowledge of the patent "at least as of the date when they were notified of the filing of this action" (Compl. ¶67). It also alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶68).

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

1. A central issue will be one of functional mapping: do the accused products' standard-compliant wireless communication functions perform the specific, affirmative steps of dynamic time-slot adjustment ('040 patent), protocol data encoding ('053 patent), and packet preamble construction ('388 patent) as recited in the asserted claims, or is there a fundamental mismatch between the patent's specific methods and the operation of a standard-compliant device?
2. An evidentiary question will concern the internal architecture of the accused products: what proof will be offered that the MIMO-capable devices internally implement the specific "SVD performer" and "measure calculator" to determine a "crosstalk measure" as required by the ’153 patent, beyond the mere fact of their compliance with MIMO-based standards?
3. A key question for the software-based claims will be one of method step correlation: does the ordinary use of the accused fleet management and telematics software platforms necessarily cause users to perform the specific, ordered steps of the methods for broadcasting advisory messages ('189 patent) and tracking vehicle maintenance ('715 patent), or can the platforms be used in a non-infringing manner?