DCT
2:25-cv-01374
Tolt Tech LLC v. Homebrace Germany GmbH
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Tolt Technologies LLC (Washington)
- Defendant: HomeBrace Germany GMBH (Germany)
- Plaintiff’s Counsel: Lowe Graham Jones PLLC
- Case Identification: 2:25-cv-01374, W.D. Wash., 10/20/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that does not reside in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s MyEcc Prop product, a control system for powered wheelchairs, infringes a patent related to adjusting seating posture using eye gaze input.
- Technical Context: The technology pertains to assistive systems for individuals with severe motor impairments, enabling them to control powered mobility devices like wheelchairs without manual dexterity.
- Key Procedural History: The complaint notes that the asserted patent was exclusively licensed to the Plaintiff, which was formed to bring the inventor's innovations to market. No prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2020-10-07 | ’330 Patent Priority Date |
| 2025-02-18 | ’330 Patent Issue Date |
| 2025-05-01 | Alleged promotion of MyEcc Prop product on LinkedIn (approx.) |
| 2025-06-01 | Alleged promotion of MyEcc Prop product on LinkedIn (approx.) |
| 2025-10-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,226,330 - "Systems, Methods, and Techniques for Eye Gaze Control of Seat and Bed Positioning"
The Invention Explained
- Problem Addressed: Individuals with advanced motor neuron diseases or disabilities such as ALS or muscular dystrophy often cannot use their hands to operate traditional joystick or button-based controls for powered wheelchairs and beds, leaving them reliant on caregivers for positioning adjustments (Compl. ¶9, 12; ’330 Patent, col. 1:35-44).
- The Patented Solution: The invention provides a system that uses an eye gaze camera and a display to present virtual buttons to the user. This allows the user to control actuators that adjust the position of a seat or bed "using only their eye gaze" (’330 Patent, Abstract). The system is described as using a two-step process where a user first selects an "axis of movement" from a first user interface and then adjusts the amount of movement on that axis using a second, distinct user interface (’330 Patent, Fig. 10-12; col. 10:43-col. 11:1).
- Technical Importance: The technology aims to restore independence to users with severe disabilities by providing a more efficient, intuitive, and immediately responsive control mechanism than speech commands or other alternatives (Compl. ¶12; ’330 Patent, col. 2:32-36).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶13).
- Claim 1 is a method claim with the following essential elements:
- Presenting a first user interface for selecting a posture axis via eye gaze, displaying multiple virtual controls for different axes.
- Receiving the selection of an axis by detecting the user's gaze on a corresponding virtual control for a determined time.
- Presenting a second user interface, distinct from the first, for selecting an adjustment amount for the chosen axis.
- Receiving the selection of an adjustment amount by detecting the user's gaze on the second interface for a determined time.
- Forwarding the selected axis and adjustment amount to determine a recommended change and/or overriding values.
- Receiving the recommended change and/or overriding values.
- Determining and modifying the selected axis and adjustment based on the received values.
- Automatically causing actuators to change the user's posture based on the modified selections, responsive "solely to eye gaze input."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The MyEcc Prop product and related accessories (Compl. ¶7, 14).
Functionality and Market Context
- The complaint alleges the MyEcc Prop is a microcontroller-based system that interfaces with a powered wheelchair to allow seat and posture adjustment via actuators (Compl. ¶17, 1[pre]).
- The system is allegedly controlled through eye gaze inputs interpreted by onboard software and is designed to work with existing eye control systems like those from Tobii or ALEA (Compl. ¶17, 1[pre], 1[b]).
- Plaintiff alleges Defendant markets the product in the United States through its website, U.S.-based distribution partners, and international-facing social media such as LinkedIn (Compl. ¶7, 8).
IV. Analysis of Infringement Allegations
’330 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. presenting a first user interface for selection of a posture axis using eye gaze input, the user interface displaying a plurality of selectable virtual user interface controls... | The system presents a user interface with left and right arrows for selecting a posture axis. The complaint includes a screenshot from the product manual titled "19-02 Seat adjustment" that shows left/right arrows for axis selection (Compl. p. 7). | ¶17, 1[a] | col. 10:43-51 |
| b. receiving, by means of an eye gaze camera and logic configured to detect an occupant's gaze for a determined period of time...a selection of an adjustable axis | The system uses eye tracking cameras (e.g., from Tobii) and is configured to register a selection after a "determined hold focus time." | ¶17, 1[b] | col. 15:26-38 |
| c. presenting a second user interface distinct from the first user interface for selection of an adjustment amount using eye gaze input... | After an axis is selected, the system allegedly presents a second, distinct interface with up and down arrows for selecting the adjustment amount or direction. | ¶17, 1[c] | col. 10:59-col. 11:1 |
| d. receiving, by means of the eye gaze camera and logic configured to detect the occupant's second gaze for a determined period of time...a selection of an adjustment amount | The system allegedly records fixations on the up/down arrows based on a maintained gaze for a "hold duration," confirming selection. | ¶17, 1[d] | col. 4:58-67 |
| e. forwarding the selected adjustable axis and the selected adjustment amount to determine a recommended change and/or overriding values regarding posture of occupant to avoid inadvertent dangers... | The system allegedly forwards selections to motor controllers (e.g., OMNI2) that include software logic to reject unsafe movements, which is alleged to satisfy the "recommended change and/or overriding values" clause. | ¶17, 1[e] | col. 15:56-62 |
| g. determining and modifying the selected adjustable axis and the selected adjustment amount based upon the received recommended change and/or overriding values | The control signal may allegedly be modified based on information from the OMNI2 controller or built-in safety logic before execution. | ¶17, 1[g] | col. 16:1-5 |
| h. responsive solely to eye gaze input...without the occupant typing commands or using oral input, automatically causing actuators to change the modified selected adjustable axis... | The system allegedly causes actuators to move based solely on eye gaze input. The complaint provides a screenshot of a "Seat Adjustment Settings" screen showing programmed settings for seat adjustment steps, which it alleges evidences this functionality (Compl. p. 9). | ¶17, 1[h] | col. 15:39-44 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused product's use of a downstream motor controller's pre-existing safety logic (e.g., the OMNI2 controller) satisfies the claim limitation of "forwarding...to determine a recommended change and/or overriding values." The language suggests an advisory or determinative step, which raises the question of whether a simple safety veto function meets the claim's requirement.
- Technical Questions: The complaint alleges that the accused product presents a "second user interface distinct from the first." The provided visual evidence suggests a single screen where icons (left/right arrows vs. up/down arrows) may become active at different times (Compl. p. 7). A potential dispute is whether this constitutes two "distinct" user interfaces as required by the claim, or a single, context-aware interface.
V. Key Claim Terms for Construction
The Term: "a second user interface distinct from the first user interface"
Context and Importance: The patent's two-step selection process (axis first, then amount) appears to be a core part of the claimed method. The definition of "distinct" will be critical. If construed narrowly to require two separate screens or views, it may present a non-infringement argument for a system that uses a single, dynamically changing screen. If construed broadly to mean functionally distinct states on the same screen, it may support the plaintiff's infringement theory.
- Intrinsic Evidence for a Broader Interpretation: The claim requires two "distinct" interfaces, but does not explicitly require two separate or non-overlapping screens, potentially allowing for a single screen that changes its function.
- Intrinsic Evidence for a Narrower Interpretation: The patent specification describes a flow where a user selects from a first interface (depicted in Fig. 11), which then leads to the presentation of a second interface (depicted in Fig. 12). This sequential presentation of visually different screens (’330 Patent, col. 10:43-col. 11:1) may support an interpretation that "distinct" requires more than just a change in the active icons on a single layout.
The Term: "to determine a recommended change and/or overriding values"
Context and Importance: This term is central to the infringement analysis for element 1[e]. The plaintiff's theory relies on the safety logic of a separate, third-party motor controller to meet this limitation (Compl. ¶17, 1[e]). Practitioners may focus on whether "determine" requires an affirmative calculation or recommendation, or if it can be satisfied by a passive safety check that simply vetoes an unsafe command.
- Intrinsic Evidence for a Broader Interpretation: The patent’s use of "and/or" could suggest that either providing a "recommended change" or simply having "overriding values" is sufficient. The defendant's safety logic provides such overriding values (e.g., a hard stop), which may support this reading.
- Intrinsic Evidence for a Narrower Interpretation: The specification discusses a "posture and pressure advisor logic" that provides recommendations to prevent injury (’330 Patent, col. 4:35-45; col. 5:41-54). This context may suggest that the "determine" step requires a more sophisticated, advisory function than a simple safety override built into a motor controller.
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement but does not plead specific facts to support the knowledge and intent elements required for induced infringement or the specific elements of contributory infringement (Compl. ¶18).
- Willful Infringement: The complaint alleges that Defendant "knew or should have known" its conduct constituted infringement (Compl. ¶15). The basis for this pre-suit knowledge is not specified beyond this general allegation.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and function: Does the claim limitation "to determine a recommended change and/or overriding values" require an active, advisory recommendation as suggested by the patent's "posture advisor" embodiment, or can it be satisfied by the passive safety-veto function of a downstream, third-party motor controller as alleged in the complaint?
- A second key issue will be one of definitional scope: Can the term "distinct," in the context of the first and second user interfaces, be construed to cover different functional states of a single screen layout, or does the patent's description and figures require two sequentially presented, visually separate interfaces? The resolution of this question may hinge on whether the distinction is functional or presentational.