DCT

1:25-cv-00853

Fleet Connect Solutions LLC v. JJ Keller & Associates Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00853, E.D. Wis., 06/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Wisconsin because Defendant maintains regular and established places of business in the district, including corporate facilities in Neenah, Wisconsin, employs individuals required to reside in the district, and has committed the alleged acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management platforms and telematics devices infringe thirteen U.S. patents related to wireless communications, data packet formation, channel interference reduction, and mobile device management.
  • Technical Context: The technologies at issue concern foundational aspects of wireless communication, including methods for improving data rates, managing interference in crowded radio spectra, and tracking mobile assets, which are central to the telematics and fleet management industries.
  • 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
2000-09-11 U.S. Patent No. 6,647,270 Priority Date
2001-02-21 U.S. Patent No. 6,549,583 Priority Date
2001-08-21 U.S. Patent No. 6,633,616 Priority Date
2001-09-17 U.S. Patent No. 6,961,586 Priority Date
2001-09-21 U.S. Patent No. 7,058,040 Priority Date
2002-11-04 U.S. Patent No. 7,206,837 Priority Date
2003-04-15 U.S. Patent No. 6,549,583 Issued
2003-04-28 U.S. Patent No. 7,260,153 Priority Date
2003-10-06 U.S. Patent No. 7,092,723 Priority Date
2003-10-14 U.S. Patent No. 6,633,616 Issued
2003-11-11 U.S. Patent No. 6,647,270 Issued
2005-07-20 U.S. Patent No. 7,742,388 Priority Date
2005-10-31 U.S. Patent No. 7,593,751 Priority Date
2005-11-01 U.S. Patent No. 6,961,586 Issued
2006-04-11 U.S. Patent No. 7,656,845 Priority Date
2006-06-06 U.S. Patent No. 7,058,040 Issued
2006-08-15 U.S. Patent No. 7,092,723 Issued
2007-04-17 U.S. Patent No. 7,206,837 Issued
2007-08-21 U.S. Patent No. 7,260,153 Issued
2008-06-20 U.S. Patent No. 7,741,968 Priority Date
2009-08-25 U.S. Patent No. 8,494,581 Priority Date
2009-09-29 U.S. Patent No. 7,593,751 Issued
2010-02-02 U.S. Patent No. 7,656,845 Issued
2010-06-22 U.S. Patent No. 7,741,968 Issued
2010-06-22 U.S. Patent No. 7,742,388 Issued
2013-07-23 U.S. Patent No. 8,494,581 Issued
2025-06-13 Complaint Filing Date

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 interference that occurs when multiple wireless communication standards, such as Bluetooth and IEEE 802.11, operate in close proximity within the same unlicensed radio band (e.g., 2.4 GHz) (’040 Patent, col. 1:21-34). This coexistence can lead to signal degradation and require data retransmission, reducing performance ('040 Patent, col. 1:35-40).
  • The Patented Solution: The invention proposes a method to manage data transmission over these overlapping media by treating them as a shared resource. It involves computing time-division multiple access (TDMA) time-slots and allocating them between the different media (e.g., Bluetooth and 802.11) to prevent simultaneous transmission and interference ('040 Patent, Abstract). The system can also dynamically adjust the number of time-slots assigned to each medium to maintain a desired level of service ('040 Patent, col. 2:18-24).
  • Technical Importance: This approach provides a framework for enabling otherwise conflicting wireless protocols to coexist effectively on a single device or in a crowded environment, a critical challenge as more devices began incorporating multiple radio technologies ('040 Patent, col. 1:41-51).

Key Claims at a Glance

  • The complaint asserts one or more claims, including at least independent claim 1 (Compl. ¶¶32-33).
  • Independent Claim 1 requires:
    • A method for data transmission over first and second media that overlap in frequency.
    • Computing one or more TDMA time-slot channels to be shared between the media.
    • Allocating one or more time-slot channels to the first medium.
    • Allocating one or more remaining time-slot channels to the second medium.
    • Dynamically adjusting the number of assigned time-slot channels during transmission to maintain a desired level of service.

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

The Invention Explained

  • Problem Addressed: The patent identifies a general need for increasing data rates in digital communication systems beyond what standard protocols, such as IEEE 802.11, may support (’388 Patent, col. 1:19-27).
  • The Patented Solution: The invention describes a method for increasing the data rate by generating an "extended packet." The method takes a standard-sized packet, which includes a preamble with first and second training symbols, and increases its size by adding new subcarriers to the second training symbol. This larger, extended packet, carrying more information, is then transmitted from an antenna ('388 Patent, Abstract; col. 2:28-40).
  • Technical Importance: This technique allows for higher data throughput by modifying the structure of a communication packet, potentially enabling backward compatibility with legacy devices that would recognize the standard portion of the packet while allowing newer devices to take advantage of the extended data capacity ('388 Patent, col. 1:28-35).

Key Claims at a Glance

  • The complaint asserts one or more claims, including at least independent claim 1 (Compl. ¶¶43-44).
  • Independent Claim 1 requires:
    • A method comprising: generating a packet with a size corresponding to a protocol, the packet comprising a preamble with a first and a second training symbol.
    • Increasing the packet's size by adding subcarriers to the second training symbol to create an extended packet, where the quantity of subcarriers in the modified second symbol is greater than in the first.
    • Transmitting the extended packet from an antenna.

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

  • Technology Synopsis: This patent, related to the ’040 Patent, describes a method for reducing interference between wireless devices operating on overlapping frequencies. It claims a method where a base station allocates a plurality of data channels between a first and a second medium for transmission and dynamically adjusts the allocation to maintain a desired service level (Compl. ¶63).
  • Asserted Claims: At least claim 1 (Compl. ¶62).
  • Accused Features: The complaint alleges that Defendant’s accused telematics and camera products perform this method of dynamically allocating and adjusting data channels (Compl. ¶63).

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

  • Technology Synopsis: The patent addresses channel evaluation in a multiple-input multiple-output (MIMO) wireless system. The claimed method involves defining a channel matrix metric, obtaining an estimated channel matrix, performing a singular value decomposition (SVD) on that matrix, and calculating a crosstalk measure for data sub-streams (Compl. ¶74).
  • Asserted Claims: At least claim 1 (Compl. ¶73).
  • Accused Features: Defendant’s products are alleged to perform this MIMO channel evaluation method, including the SVD of estimated channel matrices (Compl. ¶¶23, 74).

U.S. Patent No. 6,633,616 - "OFDM Pilot Tone Tracking," issued October 14, 2003

  • Technology Synopsis: This patent describes a method for pilot phase error estimation in an orthogonal frequency division multiplexed (OFDM) receiver. The method involves processing an OFDM preamble waveform with a fast Fourier transform in a path parallel to a step that determines pilot reference points, allowing the phase error estimation to complete before the processing of a subsequent OFDM symbol is finished (Compl. ¶85).
  • Asserted Claims: At least claim 12 (Compl. ¶84).
  • Accused Features: The accused products are alleged to perform error estimation in OFDM receivers and process OFDM symbols in a manner that infringes the patent (Compl. ¶¶23, 85).

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: The patent claims a method for pilot phase error estimation in an OFDM receiver by determining pilot reference points from a preamble and then estimating an aggregate phase error for a subsequent data symbol using complex signal measurements. The estimation step uses a maximum likelihood-based approach (Compl. ¶96).
  • Asserted Claims: At least claim 1 (Compl. ¶95).
  • Accused Features: Defendant’s products are alleged to perform error estimation in OFDM receivers using the claimed method (Compl. ¶¶23, 96).

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

  • Technology Synopsis: The patent relates to estimating arrival times for a mobile device. The claimed method involves receiving a location of a mobile device in transit, estimating time-of-arrival bounds for its destination based on its location and historical travel time statistics, and sending those bounds to the device (Compl. ¶107).
  • Asserted Claims: At least claim 1 (Compl. ¶106).
  • Accused Features: The accused J.J. Keller fleet management, vehicle tracking, and ELD products are alleged to perform this method of estimating and sending time-of-arrival bounds (Compl. ¶¶99, 107).

U.S. Patent No. 7,593,751 - "Conducting Field Operations Using Handheld Data Management Devices," issued September 29, 2009

  • Technology Synopsis: The patent describes a method for managing data on a handheld device for field operations. The claimed method involves providing a device with memory, a microprocessor, a GPS positioning module, a display, a user interface, and a wireless communication module, and enabling a user to access instructions for finding locations and collecting industry-specific data (Compl. ¶118).
  • Asserted Claims: At least claim 6 (Compl. ¶117).
  • Accused Features: The J.J. Keller fleet management, driver apps, and ELD tablet products are alleged to perform this claimed method of managing field operations data (Compl. ¶¶110, 118).

U.S. Patent No. 6,961,586 - "Field Assessments Using Handheld Data Management Devices," issued November 1, 2005

  • Technology Synopsis: This patent, related to the '751 patent, claims a method for conducting a field assessment with a handheld device. The method includes providing a user access to an industry-specific program module for executing assessments such as construction project analysis, HVAC analysis, or remote inventory tracking (Compl. ¶129).
  • Asserted Claims: At least claim 9 (Compl. ¶128).
  • Accused Features: The accused fleet management systems, driver apps, and ELD solutions are alleged to perform the claimed field assessment method (Compl. ¶¶121, 129).

U.S. Patent No. 8,494,581 - "System and Methods for Management of Mobile Field Assets via Wireless and Held Devices," issued July 23, 2013

  • Technology Synopsis: This patent claims a field assessment apparatus comprising means for establishing two-way communication between a server and a remote handheld device, means for accessing a server program, means for managing data, and means for determining the device's geographic location (Compl. ¶¶140-141).
  • Asserted Claims: At least claims 21 and 22 (Compl. ¶139).
  • Accused Features: The accused J.J. Keller fleet management systems, driver apps, and telematics devices are alleged to constitute the claimed apparatus (Compl. ¶¶132, 140-141).

U.S. Patent No. 6,647,270 - "Vehicletalk," issued November 11, 2003

  • Technology Synopsis: The patent claims a system for transmitting data between remote units, where each unit has a unique identifier, memory, a transceiver, a GPS receiver, and a microprocessor. The microprocessor constructs data packets that include sender information (identifier and position) and receiver information (address) (Compl. ¶152).
  • Asserted Claims: At least claim 1 (Compl. ¶151).
  • Accused Features: The accused telematics devices, dash cams, and ELD tablets are alleged to comprise the claimed system (Compl. ¶¶144, 152).

U.S. Patent No. 7,092,723 - "System and Method for Communicating Between Mobile Units," issued August 15, 2006

  • Technology Synopsis: This patent, related to the '270 patent, claims a vehicle configured for voice or data communications. The vehicle comprises a GPS receiver and a remote unit with a memory, transceiver, and microprocessor for constructing and transmitting data packets that include the vehicle's unique identifier and position information (Compl. ¶163).
  • Asserted Claims: At least claim 1 (Compl. ¶162).
  • Accused Features: The accused telematics devices and fleet management systems are alleged to comprise the claimed vehicle communication system (Compl. ¶¶155, 163).

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

  • Technology Synopsis: The patent claims a method of tracking a group of individuals. The method involves receiving current geographic location data for each individual at a portable hand-held device, displaying that data, sending converging instructions to at least one individual, and generating ETAs for the convergence (Compl. ¶174).
  • Asserted Claims: At least claim 4 (Compl. ¶173).
  • Accused Features: The accused fleet management, vehicle tracking, and driver app products are alleged to perform this group tracking method (Compl. ¶¶166, 174).

III. The Accused Instrumentality

Product Identification

The accused products include the "J.J. Keller" fleet management platform and tracking solutions. Specific instrumentalities named are the J. J. Keller Telematics Device, Road Cam, Road & Driver Cam (DASH CAM PRO220), Encompass Fleet Management System, FleetMentor Service, Encompass Vehicle Tracking, driver apps (such as Encompass eDVIR App, ELD App), ELD Tablets, and various other telematics and tracking devices (Compl. ¶20).

Functionality and Market Context

The complaint alleges that the accused products perform wireless communications using various protocols, including Bluetooth, IEEE 802.11, and LTE (Compl. ¶21). Their alleged technical functions include generating and transmitting data packets, communicating via multiple wireless transceivers, performing singular value decomposition of channel matrices, computing time slot channels, and performing error estimation in OFDM receivers (Compl. ¶¶22-23). The complaint identifies these products as part of a "fleet management platform and tracking solutions" portfolio (Compl. ¶20).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

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

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method for data transmission over first and second media that overlap in frequency, The Accused Products perform wireless communications and methods pursuant to various protocols and implementations including Bluetooth, IEEE 802.11, and LTE, which can operate in overlapping frequency bands (e.g., 2.4 GHz) (Compl. ¶¶21, 34). ¶¶21, 34 col. 2:4-6
comprising: computing one or more time division multiple access (TDMA) time-slot channels to be shared between the first and second media... The Accused Products allegedly perform a method that includes computing one or more TDMA time-slot channels to be shared between the first and second media for data transmission (Compl. ¶34). ¶34 col. 2:7-10
allocating one or more time-slot channels to the first medium for data transmission; The Accused Products allegedly allocate one or more of the computed time-slot channels to a first medium for data transmission (Compl. ¶34). ¶34 col. 2:11-12
allocating one or more of the remaining time-slot channels to the second medium for data transmission; The Accused Products allegedly allocate one or more of the remaining time-slot channels to a second medium for data transmission (Compl. ¶34). ¶34 col. 2:13-15
and dynamically adjusting a number of time-slot channels assigned to one of the first and second media during the data transmission... The Accused Products allegedly perform dynamic adjustment of the number of time-slot channels assigned to one of the media during data transmission to remain within limits of a desired level of service (Compl. ¶34). ¶34 col. 2:18-24

U.S. Patent No. 7,742,388 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a method comprising: generating a packet with a size corresponding to a protocol used for a network transmission, wherein the packet comprises a preamble having a first... and a second training symbol; The Accused Products allegedly generate packets for network transmissions, where the packet comprises a preamble with a first and second training symbol (Compl. ¶45). ¶45 col. 4:18-23
increasing the size of the packet by adding subcarriers to the second training symbol... to produce an extended packet, wherein a quantity of subcarriers... is greater than a quantity of subcarriers of the first training symbol; The Accused Products allegedly increase the packet size by adding subcarriers to the second training symbol to create an extended packet, with the quantity of subcarriers in the second symbol being greater than in the first (Compl. ¶45). ¶45 col. 4:24-30
and transmitting the extended packet from an antenna. The Accused Products allegedly transmit the resulting extended packet from an antenna (Compl. ¶45). ¶45 col. 4:31-32

Identified Points of Contention

  • Technical Mapping Questions: The complaint asserts infringement of numerous fundamental wireless communication patents but provides only conclusory allegations that paraphrase the claim language, citing to non-included exhibits (Compl. ¶¶33, 44, et seq.). A primary point of contention will be whether Plaintiff can produce evidence showing that the accused products, which operate on standardized protocols (e.g., 802.11, LTE), actually perform the specific, and in some cases non-standard, steps recited in the claims. For example, for the ’040 Patent, a question is what evidence shows the products "compute" and "allocate" TDMA time slots between two "media," as opposed to using standard channel access methods like Carrier-Sense Multiple Access (CSMA). For the ’388 Patent, a question is what evidence demonstrates that the accused products generate non-standard "extended packets" by "adding subcarriers" to a training symbol.
  • Claim Scope Questions: The infringement analysis may turn on the scope of key terms. For the ’040 Patent, a question is whether the term "media" can be construed to cover two different protocols (e.g., Bluetooth and Wi-Fi) operating on a single device, and whether standard protocol operations meet the definition of "computing... time-slot channels." For the ’388 Patent, a question is whether the term "increasing the size of the packet by adding subcarriers" can be construed to cover standard high-throughput modes in protocols like 802.11n, or if it is limited to the specific packet modification method described in the patent's specification.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a deep analysis of claim construction issues, as it relies on conclusory allegations and references to unavailable exhibits. However, based on the claim language, certain terms may be central to the dispute.

For the ’040 Patent

  • The Term: "computing one or more time division multiple access (TDMA) time-slot channels to be shared"
  • Context and Importance: This term defines the core action of the method claim. The interpretation of "computing" and "shared" will be critical. Defendant may argue its products merely use pre-existing, standardized channel access schemes and do not actively "compute" new TDMA structures to be "shared" between distinct "media" as contemplated by the patent. Practitioners may focus on whether this requires a specific, dynamic calculation process not present in standard protocols.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's discussion of a "system" that performs the allocation might support a broader reading where any logical process that results in time-slicing between two protocols constitutes "computing" ('040 Patent, col. 2:18-24).
    • Evidence for a Narrower Interpretation: The patent's background focuses specifically on the conflict between Bluetooth and 802.11, suggesting the claimed "computing" may be limited to a specific co-existence algorithm for those technologies, rather than a general principle applicable to all wireless communications ('040 Patent, col. 1:21-34).

For the ’388 Patent

  • The Term: "increasing the size of the packet by adding subcarriers to the second training symbol"
  • Context and Importance: This phrase describes the specific structural modification that creates the "extended packet." The dispute will likely center on whether the accused products' packet generation methods meet this structural requirement. Defendant may argue its products use standard high-throughput packet formats (e.g., from 802.11n) which achieve higher data rates through different means, not by "adding subcarriers" to a training symbol.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: General statements in the patent about creating extended packets to increase data rates could be cited to argue for a broader functional interpretation ('388 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific modification to the second long training symbol of an OFDM preamble, which could support a narrower construction limited to that precise technical implementation ('388 Patent, col. 2:28-40; Fig. 7).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for U.S. Patent Nos. 7,742,388 and 7,741,968. Inducement is alleged based on Defendant providing the accused products with the specific intent for customers to use them in an infringing manner, supported by user manuals, advertising, and technical support (Compl. ¶¶47-48, 176-177). Contributory infringement is alleged on the basis that the accused products have "special features" designed for infringement that are not staple articles of commerce and have no substantial non-infringing uses (Compl. ¶¶49, 178).
  • Willful Infringement: The complaint alleges willful infringement of the ’388 and ’968 patents. The allegations are based on knowledge of the patents acquired no later than the date of service of the complaint ("post-suit knowledge") (Compl. ¶¶46, 52, 175, 181). The complaint further alleges that Defendant has a "policy or practice of not reviewing the patents of others," which it characterizes as willful blindness (Compl. ¶¶50, 179).

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

  • A central evidentiary question will be one of technical proof: Given the complaint's reliance on conclusory allegations and unavailable exhibits, can Plaintiff produce sufficient technical evidence to demonstrate that Defendant’s products, which operate on standardized wireless protocols, actually perform the specific, often bespoke, method steps recited in the asserted claims (e.g., "computing" TDMA slots or "adding subcarriers" to a training symbol)?
  • A core legal issue will be one of claim construction and scope: Can the claim terms, which appear to describe particular solutions to specific problems (such as Bluetooth/Wi-Fi coexistence), be construed broadly enough to cover the general operation of modern, standardized telematics devices, or will they be limited to the specific embodiments described in the patents?
  • A key procedural question will be one of adequacy of pleading: The complaint makes sweeping allegations across thirteen patents with minimal specific factual support for how any particular accused product infringes any specific claim. This raises the question of whether the allegations meet the plausibility standard required by Twombly and Iqbal, an issue that may be tested early in the litigation through a motion to dismiss.