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 in Reston, Virginia.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle telematics and fleet management products infringe seven patents related to wireless networking, including technologies for channel interference reduction, MIMO communications, packet generation, and vehicle data broadcasting.
• Technical Context: The patents address various aspects of wireless communication, particularly in environments with multiple interfering standards or complex signal paths, as well as system-level methods for managing vehicle fleets.
• Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date	Event
1999-09-10	Priority Date for ’189 & ’715 Patents
2001-09-21	Priority Date for ’040, ’845 & ’053 Patents
2002-09-09	Priority Date for ’153 Patent
2004-07-20	Priority Date for ’388 Patent
2006-06-06	’040 Patent Issued
2007-08-21	’153 Patent Issued
2009-05-19	’189 Patent Issued
2009-10-06	’715 Patent Issued
2010-02-02	’845 Patent Issued
2010-06-22	’388 Patent Issued
2011-08-23	’053 Patent Issued
2025-11-03	Complaint Filed

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 (RF) interference that occurs when multiple wireless standards, such as Bluetooth and IEEE 802.11, operate simultaneously in the same unlicensed frequency band (e.g., 2.4 GHz) (’040 Patent, col. 1:20-34). This "commonality poses a strong potential for radio frequency interference," which can disrupt communications and degrade performance (’040 Patent, col. 1:27-29).
• The Patented Solution: The invention proposes a method to manage this interference by using a time-sharing technique. It involves computing Time Division Multiple Access (TDMA) time-slots to be shared between the two communication media, allocating a certain number of slots to the first medium, allocating the remaining slots to the second, and instructing the respective transceivers to communicate only within their assigned time-slots (’040 Patent, Abstract; col. 3:36-54). The system can also dynamically change the number of slots allocated to each medium during a transmission to maintain a "desired level of service" (’040 Patent, col. 4:1-4).
• Technical Importance: This approach allows for the coexistence of different, potentially interfering, wireless technologies in a shared, crowded spectrum, thereby improving the reliability and performance of both systems (’040 Patent, col. 1:5-6, col. 2:60-64).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶33).
• The essential elements of claim 1 include:
  • A method for data transmission over first and second media that overlap in frequency.
  • Computing one or more time division multiple access (TDMA) time-slot channels to be shared between the media.
  • 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.
  • Dynamically adjusting a number of time-slot channels assigned to one of the media during the data transmission to remain within limits of a desired level of service.

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 addresses a key challenge in Multiple-Input Multiple-Output (MIMO) wireless systems, where multiple antennas are used to increase data rates. The performance of such systems relies on accurate information about the communication channel, but in practice, the channel is "imperfectly estimated" (’153 Patent, col. 2:10-12). This imperfection leads to "cross-talk noise" between the parallel data sub-streams, which degrades signal quality and limits the achievable data rate (’153 Patent, col. 4:5-13).
• The Patented Solution: The invention provides a method and apparatus for evaluating the channel to account for these imperfections. The solution involves performing a mathematical operation known as Singular Value Decomposition (SVD) on the estimated channel matrix to obtain "estimated channel singular values." A "measure calculator" then uses these singular values, along with a "channel matrix metric," to calculate a "respective crosstalk measure for each of said sub-streams" (’153 Patent, Abstract; claim 28). This evaluation allows the system to better understand and potentially compensate for the cross-talk interference.
• Technical Importance: The invention offers a technique to achieve more "robust and predictable" communication performance in practical MIMO systems, helping to realize the theoretical benefits of extended range and higher data rates even with real-world channel estimation errors (’153 Patent, col. 4:31-37).

Key Claims at a Glance

• The complaint asserts independent claim 28 (Compl. ¶43).
• The essential elements of claim 28 include:
  • A transmission apparatus for evaluating a channel of a MIMO wireless communication system.
  • An SVD performer configured to perform an SVD of an estimated channel matrix to obtain estimated channel singular values.
  • A measure calculator configured for calculating a respective crosstalk measure for each sub-stream from the estimated channel singular values and a channel matrix metric.

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

• Patent Identification: U.S. Patent No. 7,656,845, "Channel Interference Reduction," issued February 2, 2010 (Compl. ¶48).
• Technology Synopsis: Related to the ’040 Patent, this patent describes an apparatus for reducing interference between two communication media that overlap in frequency. The solution involves allocating data channels between the two media and dynamically adjusting the allocation to maintain a desired level of service (Compl. ¶54; ’845 Patent, col. 10:18-51).
• Asserted Claims: Independent claim 18 (Compl. ¶53).
• Accused Features: The accused products are alleged to infringe by including a means for allocating data channels between first and second media and a means for dynamically adjusting the number of channels assigned during data transmission (Compl. ¶54).

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

• Patent Identification: U.S. Patent No. 7,742,388, "Packet Generation Systems and Methods," issued June 22, 2010 (Compl. ¶58).
• Technology Synopsis: This patent relates to the structure of wireless data packets, specifically the preamble used for training and synchronization. The invention describes a PHY unit that generates a packet where the preamble includes a first training symbol and a second training symbol, with the second symbol comprising a greater quantity of modulated subcarriers than the first (’388 Patent, Abstract; claim 28).
• Asserted Claims: Independent claim 28 (Compl. ¶63).
• Accused Features: The accused products are alleged to include a PHY unit that generates packets with the claimed preamble structure, including first and second training symbols with different numbers of modulated subcarriers (Compl. ¶64).

U.S. Patent No. 8,005,053 - “Channel Interference Reduction”

• Patent Identification: U.S. Patent No. 8,005,053, "Channel Interference Reduction," issued August 23, 2011 (Compl. ¶75).
• Technology Synopsis: This patent describes an apparatus with two transceivers configured for two different wireless protocols. A controller selects one of the transceivers to communicate data for both protocols by encoding the data of the unselected protocol into the data format of the selected protocol (’053 Patent, Abstract; claim 1).
• Asserted Claims: Independent claim 1 (Compl. ¶80).
• Accused Features: The accused products are alleged to infringe by including a first wireless transceiver, a second wireless transceiver for a different protocol, and a controller that selects one transceiver and encodes data from the other protocol for transmission (Compl. ¶81).

U.S. Patent No. 7,536,189 - “System and Method for Sending Broadcasts in a Social Network”

• Patent Identification: U.S. Patent No. 7,536,189, "System and Method for Sending Broadcasts in a Social Network," issued May 19, 2009 (Compl. ¶85).
• Technology Synopsis: This patent describes a method for a system administrator to broadcast an advisory communication to remote units (e.g., vehicles in a fleet). The method involves accessing a website, filtering a plurality of remote units to select recipients, assembling a data or voice packet, and forwarding it through a router for transmission (’189 Patent, Abstract; claim 1).
• Asserted Claims: Independent claim 1 (Compl. ¶89).
• Accused Features: The accused products are alleged to perform the claimed method, allowing an administrator to use a website to filter remote units and broadcast advisory communications to them (Compl. ¶90).

U.S. Patent No. 7,599,715 - “System and Method for Matching Wireless Devices”

• Patent Identification: U.S. Patent No. 7,599,715, "System and Method for Matching Wireless Devices," issued October 6, 2009 (Compl. ¶95).
• Technology Synopsis: This patent details a method for tracking vehicle maintenance information. The system receives a signal from a vehicle containing an identifier and status, stores it, parses the signal to determine maintenance information, constructs a communication packet with this information, and forwards it over the Internet (’715 Patent, Abstract; claim 29).
• Asserted Claims: Independent claim 29 (Compl. ¶101).
• Accused Features: The accused products are alleged to perform this method by receiving signals from vehicles, determining maintenance information, and constructing and transmitting packets with that information over a network (Compl. ¶102).

III. The Accused Instrumentality

• Product Identification: The complaint identifies a broad range of "Xirgo's transportation solution which incorporates fleet management platform and tracking solutions" (Compl. ¶22). This includes dozens of specific hardware devices (e.g., KP2, KP2 AI camera, XT series, XG series, FMS500 series) and associated software systems (e.g., Xirgo Fleet Management Solution, Xirgo Global Logistics software/website) (Compl. ¶22).
• Functionality and Market Context: The accused instrumentalities are telematics devices and platforms used for managing fleets of vehicles (Compl. ¶22). They are alleged to perform wireless communications using various protocols, including Bluetooth and IEEE 802.11 (Compl. ¶23). Functionally, these products are designed to be installed in vehicles to track location, monitor performance, and communicate data back to a central management platform.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint references claim chart exhibits for each asserted patent (Exhibits A-G), but these exhibits were not filed with the complaint (Compl. ¶33, ¶43, ¶53, ¶63, ¶80, ¶89, ¶101). The infringement theories are therefore summarized below based on the narrative allegations in the complaint.

U.S. Patent No. 7,058,040 Infringement Allegations

• Narrative Summary: The complaint alleges that the Accused Products perform the method of claim 1 for data transmission over media that overlap in frequency (Compl. ¶34). The infringement theory is that the products compute and use TDMA time-slots, allocating some to a first medium and the rest to a second, and "dynamically adjusting a number of timeslot channels assigned... during the data transmission to remain within limits of a desired level of service" (Compl. ¶34).
• Identified Points of Contention:
  • Scope Question: A potential point of contention may be whether the channel access methods used by the accused products, which likely comply with modern standards like 802.11, can be characterized as "computing one or more time division multiple access (TDMA) time-slot channels to be shared" as required by the claim.
  • Technical Question: The allegation of "dynamically adjusting" slots "during the data transmission" to maintain a "desired level of service" raises a factual question. The analysis may focus on what evidence demonstrates that the accused products perform this specific type of real-time adjustment for the claimed purpose, as opposed to using other channel management or interference avoidance techniques.

U.S. Patent No. 7,260,153 Infringement Allegations

• Narrative Summary: The complaint alleges that the Accused Products are "transmission apparatuses for evaluating a channel of a MIMO wireless communication system" as recited in claim 28 (Compl. ¶44). The theory is that the products contain an "SVD performer" that performs a singular value decomposition of an estimated channel matrix and a "measure calculator" that calculates a "crosstalk measure" for each data sub-stream from the resulting singular values (Compl. ¶44).
• Identified Points of Contention:
  • Scope Question: The analysis may question whether the hardware or software architecture of the accused devices contains discrete, identifiable components that function as an "SVD performer" and a "measure calculator," or if these functions are integrated into a larger signal processing unit in a way that does not map directly onto the claim's structure.
  • Technical Question: A key factual dispute may be whether the algorithms used in the accused products to manage MIMO communications actually calculate a "crosstalk measure" based on "estimated channel singular values," or if they employ alternative, non-infringing methods for channel estimation and interference mitigation.

V. Key Claim Terms for Construction

Term from ’040 Patent: "dynamically adjusting... during the data transmission"

• Context and Importance: This term is central to the method of claim 1. The infringement analysis will depend heavily on whether the accused products' channel management occurs "during" an active transmission, as the claim requires, versus between transmissions or at initialization. Practitioners may focus on this term because modern wireless devices employ many forms of adaptation, and the case may turn on whether the specific type used by Xirgo meets this temporal and functional requirement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states that the system can "dynamically adjust a number of time slots assigned to the media during the transmission to remain within limits of said desired level of service" (’040 Patent, col. 2:18-22), which could be read to cover any on-the-fly adjustment made to preserve quality.
  • Evidence for a Narrower Interpretation: The detailed description outlines a specific multi-step process for this adjustment, which includes "detecting the medium that fails to meet said desired level of service" and "transmitting an additional channel assignment message" (’040 Patent, col. 2:23-28). A party could argue the term should be construed as being limited to this more specific, disclosed sequence of operations.

Term from ’153 Patent: "crosstalk measure"

• Context and Importance: The calculation of this "measure" is the core function of the claimed "measure calculator." Whether the accused devices infringe claim 28 will likely depend on what technical meaning is given to this term. Practitioners may focus on this term because if it is construed narrowly to a specific formula, non-infringement may be easier to establish, whereas a broad definition could cover a wide range of interference metrics.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification does not appear to provide an explicit definitional formula for "crosstalk measure," instead describing it functionally as something calculated from singular values and a channel matrix metric (’153 Patent, claim 28). This may support an argument for its plain and ordinary meaning to one skilled in the art, which could be any quantitative assessment of crosstalk.
  • Evidence for a Narrower Interpretation: The background section discusses how "cross-talk SNR depends on... certain relationships between the singular values of H" (’153 Patent, col. 4:8-11). A party might argue that "crosstalk measure" is not just any metric but must be one derived from the specific matrix perturbation theory and singular value relationships that the patent's background identifies as the basis for the problem the invention purports to solve.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for the ’388 patent (Compl. ¶65-66). Inducement is alleged based on Defendants "advising or directing customers," "advertising and promoting," and "distributing instructions that guide users to use the Accused Products in an infringing manner" with knowledge of the patent (Compl. ¶65). Contributory infringement is alleged on the basis that the Accused Products have "special features that are specially designed to be used in an infringing way" and are not "staple articles of commerce suitable for substantial non-infringing use" (Compl. ¶66).
• Willful Infringement: Willfulness is alleged for the ’388 patent (Compl. ¶70). The complaint bases this on knowledge acquired at least from the filing of the lawsuit (post-suit knowledge) (Compl. ¶67). It further alleges pre-suit willful blindness, claiming Defendants "have a policy or practice of not reviewing the patents of others" and that their actions were "at least objectively reckless" (Compl. ¶68-69).

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

• A central issue will be one of functional mapping: whether the specific channel management and protocol-handling techniques used in Xirgo's modern telematics devices perform the particular methods of time-slot allocation, dynamic adjustment, and protocol encoding as claimed in patents from the early-to-mid 2000s ('040, '845, '053 Patents).
• A key technical question will be one of algorithmic correspondence: whether the signal processing algorithms within the accused products' wireless chipsets—particularly for MIMO channel evaluation and packet formation—map onto the specific claimed steps involving SVD, "crosstalk measures," and preamble training symbols ('153, '388 Patents).
• A third core question will be one of system-level equivalence: whether the architecture and operation of the accused fleet management platform, which facilitates communication between vehicles and a central administrator, practice the specific methods for broadcasting advisories and tracking maintenance information as recited step-by-step in the claims ('189, '715 Patents).