DCT

3:25-cv-00497

Fleet Connect Solutions LLC v. Blue Ink Technology Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00497, S.D. W. Va., 08/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the district and has committed the alleged acts of patent infringement from those locations.
  • Core Dispute: Plaintiff alleges that Defendant’s fleet management platform and tracking solutions infringe nine patents related to wireless communication systems, mobile data management, and navigation tracking.
  • Technical Context: The technologies at issue relate to managing wireless signal interference, increasing data packet throughput, and using handheld devices for remote asset management and tracking, which are central to the logistics and fleet management industries.
  • Key Procedural History: The complaint notes that Certificates of Correction were issued for U.S. Patent Nos. 7,656,845 and 6,961,586 after their initial issuance. No other significant procedural events are mentioned.

Case Timeline

Date Event
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
2003-04-28 U.S. Patent No. 7,260,153 Priority Date
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 Issue Date
2006-04-11 U.S. Patent No. 7,656,845 Priority Date
2006-06-06 U.S. Patent No. 7,058,040 Issue Date
2007-04-17 U.S. Patent No. 7,206,837 Issue Date
2007-08-21 U.S. Patent No. 7,260,153 Issue Date
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 Issue Date
2010-02-02 U.S. Patent No. 7,656,845 Issue Date
2010-06-22 U.S. Patent No. 7,742,388 Issue Date
2010-06-22 U.S. Patent No. 7,741,968 Issue Date
2010-11-30 U.S. Patent No. 7,656,845 Certificate of Correction Issued
2013-06-25 U.S. Patent No. 6,961,586 Certificate of Correction Issued
2013-07-23 U.S. Patent No. 8,494,581 Issue Date
2025-08-13 Complaint Filing Date

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

U.S. Patent No. 7,058,040 - Channel Interference Reduction

  • Patent Information: Issued June 6, 2006 (Compl. ¶¶1, 22).

The Invention Explained

  • Problem Addressed: The patent addresses the problem of radio frequency (RF) interference that occurs when multiple wireless communication standards, such as Bluetooth and IEEE 802.11, operate simultaneously in the same unlicensed frequency band (U.S. Patent No. 7,656,845, col. 1:12-32). This co-channel operation can lead to data packet destruction and degraded network performance ('845 Patent, col. 1:33-39).
  • The Patented Solution: The invention proposes a method for managing data transmission across these interfering media by using a time division multiple access (TDMA) scheme. The system computes and allocates distinct time-slots to each communication medium and instructs the respective transceivers to transmit data only within their assigned slots, thereby preventing them from transmitting at the same time and causing interference ('845 Patent, Abstract; col. 3:41-55).
  • Technical Importance: This technology facilitates the coexistence of different wireless protocols in close physical proximity, a critical need as devices increasingly incorporated both short-range (e.g., Bluetooth) and long-range (e.g., Wi-Fi) communication capabilities ('845 Patent, col. 1:25-32).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶28).
  • The complaint does not provide the language of the asserted claims for analysis.

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

  • Patent Information: Issued June 22, 2010 (Compl. ¶¶1, 31).

The Invention Explained

  • Problem Addressed: The patent identifies a need to increase data rates in digital communication systems, such as wireless local area networks (WLANs), beyond what was available under existing standards, while allowing new, higher-rate devices to coexist with legacy devices in the same environment (’388 Patent, col. 2:1-10).
  • The Patented Solution: The invention describes a method and system for increasing the data rate of a packet by adding subcarriers to the standard packet structure of a given protocol. This creates an "extended data signal" capable of carrying more information ('388 Patent, Abstract). The system includes a transmitter that adds the subcarriers and a corresponding receiver with a processor for detecting them, enabling communication at higher data rates ('388 Patent, col. 2:15-28).
  • Technical Importance: This approach provided a method for enhancing bandwidth efficiency in wireless networks, allowing for higher data throughput in increasingly crowded spectrums and enabling service providers to more effectively use their allotted spectrum (’388 Patent, col. 2:6-10).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 (Compl. ¶37).
  • The complaint does not provide the language of the asserted claims for analysis.

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

  • Patent Information: Issued February 2, 2010 (Compl. ¶47).
  • Technology Synopsis: This patent, a continuation of the application that led to the ’040 Patent, is also directed to minimizing RF interference between co-located wireless systems like Bluetooth and IEEE 802.11 ('845 Patent, col. 1:3-7). It discloses a method of allocating distinct time-division multiple access (TDMA) time-slots to each system to prevent simultaneous, interfering transmissions ('845 Patent, Abstract).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶53).
  • Accused Features: The complaint accuses the wireless communication functionalities of the Accused Products, which employ multiple protocols such as Bluetooth and IEEE 802.11 (Compl. ¶17).

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

  • Patent Information: Issued August 21, 2007 (Compl. ¶56).
  • Technology Synopsis: This patent addresses the problem of cross-talk interference in Multiple-Input Multiple-Output (MIMO) wireless systems that arises from imperfectly estimated communication channels ('153 Patent, Abstract). The disclosed method aims to solve this interference problem to provide more robust and predictable extended range and data rates in such systems ('153 Patent, Abstract).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶62).
  • Accused Features: The complaint targets the wireless communication methods of the Accused Products, alleging they perform functions associated with MIMO systems, such as singular value decomposition of channel matrices (Compl. ¶19).

U.S. Patent No. 7,206,837 - Intelligent Trip Status Notification

  • Patent Information: Issued April 17, 2007 (Compl. ¶65).
  • Technology Synopsis: The patent describes methods for providing periodic trip status information, such as estimated time-of-arrival, to a user in transit ('837 Patent, Abstract). The system generates these estimates based on a variety of data inputs, including the user's location, calendrical time, historical travel statistics, and current or forecasted weather and traffic conditions ('837 Patent, Abstract).
  • Asserted Claims: At least claim 1 is asserted (Compl. ¶71).
  • Accused Features: The complaint accuses Defendant’s fleet management and tracking solutions, which provide status and location information for vehicles (Compl. ¶16).

U.S. Patent No. 7,593,751 - Conducting Field Operations Using Handheld Data Management Devices

  • Patent Information: Issued September 29, 2009 (Compl. ¶74).
  • Technology Synopsis: The patent relates to systems and methods for using handheld devices to execute field operations ('751 Patent, Abstract). The invention provides a user with a portable device that contains industry-specific programs and data, which guide the user through field operations and allow for communication with remote resources for assistance and data analysis ('751 Patent, Abstract).
  • Asserted Claims: At least claim 6 is asserted (Compl. ¶80).
  • Accused Features: The complaint targets the Blue Ink Tech app and fleet management software, which provide data management and operational functionalities to users in the field (Compl. ¶16).

U.S. Patent No. 6,961,586 - Field Assessments Using Handheld Data Management Devices

  • Patent Information: Issued November 1, 2005 (Compl. ¶83).
  • Technology Synopsis: This patent describes systems for conducting field assessments using handheld devices that provide portable access to industry-specific programs ('586 Patent, Abstract). The technology enables wireless data synchronization between the handheld device and remote servers or workstations for data delivery and analysis ('586 Patent, Abstract).
  • Asserted Claims: At least claim 9 is asserted (Compl. ¶89).
  • Accused Features: The complaint accuses the Blue Ink Tech app and fleet management software platform (Compl. ¶16).

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

  • Patent Information: Issued July 23, 2013 (Compl. ¶92).
  • Technology Synopsis: The patent discloses systems for managing mobile field assets, including personnel and inventory, through wireless handheld devices ('581 Patent, Abstract). The technology supports functions such as dispatch, data synchronization, and logistics by enabling bidirectional data delivery between field devices and enterprise-based servers ('581 Patent, Abstract).
  • Asserted Claims: At least claims 21 and 22 are asserted (Compl. ¶98).
  • Accused Features: The complaint accuses Defendant’s fleet management platform and tracking solutions (Compl. ¶16).

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

  • Patent Information: Issued June 22, 2010 (Compl. ¶101).
  • Technology Synopsis: The patent discloses a system for sharing and tracking navigation information among a group of individuals ('968 Patent, Abstract). A master portable device is grouped with other portable devices and is configured to maintain and display the geographic positions of all devices within the group, facilitating coordinated movement or tracking ('968 Patent, col. 1:44-51).
  • Asserted Claims: At least claim 4 is asserted (Compl. ¶107).
  • Accused Features: The complaint accuses the fleet management and tracking solutions, which inherently involve tracking the location of multiple assets within a group (a fleet) (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

The accused products include the BIT dashcam, BIT ELD adapters, Air Scale, the Blue Ink Tech app, and the Blue Ink - Fleet Management software/application/website (collectively, "Accused Products") (Compl. ¶16).

Functionality and Market Context

The Accused Products constitute a fleet management and vehicle tracking platform (Compl. ¶16). The complaint alleges that these products perform wireless communications using a variety of standard protocols, including Bluetooth, IEEE 802.11, and LTE (Compl. ¶17). Their technical functionality is alleged to include generating and transmitting data packets across multiple wireless transceivers and performing signal processing methods associated with OFDM and MIMO communications (Compl. ¶¶18-19). The products are advertised and offered for sale through Defendant's website (Compl. ¶15). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits for each asserted patent but does not include them with the filing. Therefore, a tabular analysis is not possible. The narrative infringement theories for the lead patents are summarized below.

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

The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’040 patent (Compl. ¶28). The infringement theory is based on the products' use of multiple wireless protocols that operate in overlapping frequency bands, such as Bluetooth and IEEE 802.11 (Compl. ¶17). The complaint asserts that the products embody inventive components that "improve upon the function and operation of preexisting methods of transmitting data over media having overlapping frequencies" (Compl. ¶25), which aligns with the technical problem addressed by the patent. Specific details mapping claim elements to the Accused Products are said to be in Exhibit A, which was not provided (Compl. ¶28).

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

The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’388 patent (Compl. ¶37). The infringement theory rests on the allegation that the products perform methods of "generating packets in a digital communications system" that are inventive over preexisting systems (Compl. ¶34). This connects to the products' alleged functionality of generating and transmitting packets for wireless communications (Compl. ¶18). The complaint states that a detailed explanation of infringement is provided in Exhibit B, which was not included with the filing (Compl. ¶37).

Identified Points of Contention

  • Scope Questions: For the ’040 Patent, a central question may be whether the Accused Products' method for managing coexisting wireless protocols constitutes the specific steps of "computing" and "allocating" time-slots as may be required by the claims, or if the products merely implement standardized, pre-configured coexistence mechanisms.
  • Technical Questions: For the ’388 Patent, a key technical question will be whether the packet generation methods used in the standard protocols implemented by the Accused Products (e.g., IEEE 802.11n, LTE) fall within the scope of the claims. The infringement allegation appears to depend on whether these standard operations can be characterized as "adding subcarriers" to a packet in the specific manner patented.

V. Key Claim Terms for Construction

The complaint does not provide the language of the asserted independent claims, precluding a definitive analysis of key terms. However, based on the patents' technology descriptions, disputes may arise over terms defining the core technical function.

The Term: "computing one or more ... time-slot channels" (concept from ’040 Patent family)

  • Context and Importance: This term appears central to the inventive concept of the ’040 patent. Its construction will be critical in determining whether the patent covers standardized coexistence protocols or is limited to systems that perform a more active, dynamic calculation to create a channel sharing scheme. Practitioners may focus on this term because Defendant may argue its products use standard, off-the-shelf coexistence features rather than performing a separate "computing" step as claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's summary may describe the invention broadly as including "computing one or more time division multiple access (TDMA) time-slot channels," which could potentially encompass any rule-based or algorithmic determination ('845 Patent, col. 2:9-11).
    • Evidence for a Narrower Interpretation: The detailed description and figures may depict a specific process where a device actively determines and then allocates time slots, potentially suggesting that "computing" requires a specific, non-trivial calculation rather than the passive implementation of a pre-set industry standard ('845 Patent, Fig. 1A).

The Term: "adding subcarriers to the packet" (concept from ’388 Patent)

  • Context and Importance: This term defines the core technical mechanism of the ’388 patent for increasing data rates. The infringement dispute will likely focus on whether the packet structures defined by modern standards like 802.11n, used by the Defendant, constitute "adding subcarriers" to a baseline packet in the manner claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes the invention as increasing a packet's standard size "by adding subcarriers to the packet to produce an extended data signal," language which could be argued to read on any protocol that uses more subcarriers than a predecessor standard ('388 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The specification may disclose a specific method where a baseband processor starts with a legacy packet format and inserts additional subcarrier data in a particular way, potentially limiting the claim to specific, non-standard implementations that perform this explicit "adding" step ('388 Patent, Fig. 6; col. 6:15-24).

VI. Other Allegations

Indirect Infringement

For the ’388 and ’968 patents, the complaint alleges both induced and contributory infringement (Compl. ¶¶39, 41, 109, 111). The inducement allegations are based on Defendant allegedly providing instructions, advertising, and technical support that guide users to infringe, with knowledge of the patents dating from receipt of the complaint (Compl. ¶¶38, 40, 108, 110). The contributory infringement allegations assert that the Accused Products contain special features designed for infringement that are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶41, 111).

Willful Infringement

Willfulness is alleged for the ’388 and ’968 patents (Compl. ¶¶44, 114). The allegations are based on post-suit knowledge of the patents and a contention that Defendant was willfully blind to Plaintiff's patent rights due to a "policy or practice of not reviewing the patents of others" (Compl. ¶¶42, 112).

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

  • A primary technical question will be one of operational correspondence: do the Accused Products, which implement standard wireless protocols, actually perform the specific methods of channel management (’040/’845 patents) and packet generation (’388 patent) required by the asserted claims, or is there a fundamental mismatch between the patented solutions and the standardized technologies at issue?
  • A key evidentiary question will be one of feature mapping across a broad portfolio: with nine patents covering distinct technologies from RF signal processing to group navigation and field data management, the case will require Plaintiff to demonstrate how specific, individual features of the accused platform practice the claimed inventions of each asserted patent, raising the question of whether a single product line can infringe such a diverse set of technologies.
  • A central legal issue will be one of claim scope: the case will likely turn on how narrowly the court construes key claim terms. The dispute may focus on whether the claims require specific, novel algorithmic steps not present in the standardized protocols and fleet management functionalities that the Accused Products are alleged to implement.