Orbcomm Inc. v. CalAmp Corp.

Orbcomm Inc. v. CalAmp Corp., No. 3:16CV208-HEH, 2016 WL 3965205, at *1 (E.D. Va. July 22, 2016)

Patent(s):    

  • 6,292,724 | Entitled “Method of and System and Apparatus for Remotely Monitoring the Location, Status, Utilization and Condition of Widely Geographically Dispersed Fleets of Vehicular Construction Equipment and the like and Providing and Displaying Such Information”
  • 6,611,686 | Entitled “Tracking Control and Logistics System and Method”
  • 6,651,001 | Entitled “Method of and System and Apparatus for Integrating Maintenance Vehicle and Service Personnel Tracking Information with the Remote Monitoring of the Location, Status, Utilization and Condition of Widely Geographically Dispersed Fleets of Vehicular Construction Equipment and the Like to be Maintained, and Providing and Displaying Together both Construction and Maintenance Vehicle Information”
  • 6,735,150 | Entitled “Method of and Apparatus for Distinguishing Engine Idling and Working Hours”
  • 8,855,626 | Entitled “Wireless Control for Creation of, and Command Response to, Standard Freight Shipment Messages”

Disposition:               

Motion to Dismiss on the grounds of invalidity dismissed.

Abstract Idea:

Undetermined

Something More:

Undetermined (Based on the limited universe of information, the patents appeared to the court to contain an innovative concept)

Technology:              

The ‘724 Patent: The '724 patent teaches a method for monitoring the location and status of fleets of vehicular construction equipment. It envisions the transmission of information concerning the location, utilization, status, and condition of vehicular equipment through a transponder-satellite communications link system to a ground station via the Internet to an information-processing center.

The ‘001 Patent: The '001 patent pertains to the tracking of geographically dispersed fleets of construction vehicles and equipment using satellite positioning, wireless data communication, and Internet facilities. This patent provides a method of integrating the simultaneous displaying of satellite position-derived location information of the maintenance vehicles servicing said equipment at the respective equipment sites through real-time tracking using said resources and processing.

The ‘686 Patent: The '686 patent claims a system for remotely tracking and monitoring certain types of vehicles and remotely activating certain accessories, such as doors, alarms, and ignitions.

The ‘626 Patent: The ‘626 patent claims a method of translating messages enabling two different kinds of machines to communicate with each other and provides for sending command messages to change the condition of a freight asset based on specialized technological aspects of a freight information system.  These conditions include: temperature, location, speed, direction of movement, vibration, load, humidity, ambient gas, illumination, radiation, and time of arrival or departure. 

The ‘150 Patent: The '150 patent depicts a “method of and apparatus for differentiating and indicating engine idling periods with little fuel consumption, and periods of engine working under load and substantially consuming fuel, ... through monitoring the frequencies of the engine alternator corresponding to the engine speed over time ....”

Summary:                 

As a preliminary matter, the court did not definitively find the patents patentable. Rather, the court explained that it had not had “the benefit of any form of expert testimony amplifying the language and claims of the patents-in-suit enabling the court to determine more definitively whether the patents-at-issue are truly a technological improvement over prior art.” The court held that based on the limited record, it could not determine that the patents-at-issue were patent in-eligible.  

The ‘724 Patent: The court explained that the '724 patent taught an innovative construct—involving satellite communication receivers and GPS receivers—beyond a simple generic computer.

The ‘001 Patent: The court did not reveal its reasoning, but stated that “based upon the descriptive information provided in the complaint, augmented by the patent, it would appear that the system described in the '001 patent meets the criteria of Section 101 at this stage and is facially patentable.”

The ‘686 Patent: The apparatus claims of the '686 patent are tied to a particular machine, specifically non-generic wireless communication units. These units are described as containing a global position sensor and “a selectable port wiring interface.” The Court explained that these special features were sufficient at this stage to defeat a claim of invalidity

The ‘626 Patent: The court held that based on the specialized monitoring features described in Claim 4 of the '626 patent, coupled with the format translation, the complaint “appea[ed] to describe” an innovative technological advancement.

The ‘150 Patent: The court refused to dismiss the ‘150 patent as patent-ineligible, because the innovative technology “allegedly” improved the measurement of fuel consumption. Traditional systems measure engine run time based upon fuel consumption. The '150 patent monitors the frequencies of the engine alternator corresponding to the engine's speed.