DCT

2:26-cv-06694

Honeywell Aerospace US LLC v. Rivian Automotive LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-06694, D. Ariz., 09/18/2026
  • Venue Allegations: Venue is alleged to be proper in the District of Arizona because Defendants maintain regular and established places of business in the District, including showrooms and service centers, and have committed acts of infringement there. Plaintiff is also headquartered in the District, and some of the inventors named on the patents-in-suit are located in Arizona.
  • Core Dispute: Plaintiff alleges that Defendant’s electric vehicles and their advanced driver-assistance systems infringe seven patents related to vehicle fault detection, navigation, data display, and software license management.
  • Technical Context: The lawsuit concerns technologies central to the field of Advanced Driver-Assistance Systems (ADAS), a key area of competition and innovation in the modern automotive market, particularly for electric and autonomous-capable vehicles.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement, including for the ’264 and ’062 patents, via a letter with detailed claim charts on April 20, 2023. A follow-up letter was allegedly sent on September 25, 2025. This history is cited to support claims of willful infringement. The complaint also proactively asserts that the patented inventions are improvements to vehicle functionality and are not directed to abstract ideas, anticipating potential patent eligibility challenges under 35 U.S.C. § 101.

Case Timeline

Date Event
2002-03-14 ’264 Patent Priority Date
2005-06-29 ’062 Patent Priority Date
2006-08-08 ’264 Patent Issue Date
2006-09-05 ’352 Patent Priority Date
2007-10-23 ’062 Patent Issue Date
2008-10-30 ’334 Patent Priority Date
2009-06-08 ’816 Patent Priority Date
2010-11-23 ’352 Patent Issue Date
2012-11-20 ’816 Patent Issue Date
2013-01-29 ’334 Patent Issue Date
2013-08-08 ’567 Patent Priority Date
2016-05-31 ’567 Patent Issue Date
2016-11-07 ’856 Patent Priority Date
2018-11-20 ’856 Patent Issue Date
2022-01-01 Estimated launch of Rivian Gen 1 vehicles (Model Year 2022)
2023-04-20 Plaintiff sends written notice of infringement to Defendant
2025-01-01 Estimated launch of Rivian Gen 2 vehicles (Model Year 2025)
2025-09-25 Plaintiff sends follow-up letter to Defendant
2025-12-01 Rivian releases "Universal Hands Free" feature via over-the-air update
2026-09-18 Complaint Filing Date

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

U.S. Patent No. 7,088,264 - "Flight Safety System Monitoring Combinations of State Values"

  • Patent Identification: U.S. Patent No. 7,088,264 (“the ’264 Patent”), titled “Flight Safety System Monitoring Combinations of State Values,” issued August 8, 2006 Compl. ¶14

The Invention Explained

  • Problem Addressed: Conventional vehicle fault-detection systems evaluated sensor data one variable at a time, using simple threshold checks. Such systems were unable to identify complex faults that were only revealed by a particular combination of readings across multiple sensors or commands, where no single reading was individually anomalous Compl. ¶18 ’264 Patent, col. 4:3-19
  • The Patented Solution: The invention proposes a method and system that monitors combinations of vehicle state values—which can include both sensor readings and computer commands—and compares these combinations against a pre-identified database of known unsafe or undesirable combinations ’264 Patent, col. 3:10-4:26 Compl. ¶19 By analyzing the relationships between multiple variables simultaneously, the system can identify hazardous conditions that single-variable checks would miss.
  • Technical Importance: This approach represented a shift from simple, single-variable diagnostics to a more sophisticated, multi-variable, combinatorial analysis for vehicle safety systems Compl. ¶23

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a method) and 24 (a computer-readable medium) Compl. ¶16
  • The essential elements of independent claim 1 include:
    • monitoring values of states of the vehicle;
    • comparing combinations of such values of states to known unsafe combinations; and
    • identifying combinations of values of states of the vehicle that correspond to the unsafe combinations ’264 Patent, claim 1
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’264 Patent, but it does reserve the right for other patents.

U.S. Patent No. 7,286,062 - "Perspective View Conformal Traffic Targets Display"

  • Patent Identification: U.S. Patent No. 7,286,062 (“the ’062 Patent”), titled “Perspective View Conformal Traffic Targets Display,” issued October 23, 2007 Compl. ¶27

The Invention Explained

  • Problem Addressed: Prior art systems that displayed traffic targets in a 3D graphical view either rendered all icons at a uniform size (encoding no range information) or scaled them as an unbounded function of range. Unbounded scaling caused distant targets to become invisibly small and near targets to become excessively large, cluttering the display ’062 Patent, col. 2:57-3:53 Compl. ¶30
  • The Patented Solution: The invention addresses this by rendering traffic icons with a size that varies continuously with the target’s distance, but is bounded by a defined maximum and minimum size ’062 Patent, claim 1 This ensures that near targets do not become overly large and far targets do not become too small to see, while still encoding range information in the icon's size Compl. ¶31 The patent also notes this "layered conformal view" reduces processor load compared to unbounded scaling ’062 Patent, col. 3:49-53
  • Technical Importance: The invention provided a method to improve the clarity and cognitive efficiency of 3D traffic displays, resolving the trade-off between encoding range information and maintaining display readability Compl. ¶32

Key Claims at a Glance

  • The complaint asserts independent claim 1 (a display system) Compl. ¶29
  • The essential elements of independent claim 1 include:
    • a display screen, one or more sensors for traffic data, and one or more processors;
    • the display screen displaying traffic targets as icons in a 3-dimensional graphical representation of real space;
    • the display size of the icons is selected from a finite set of sizes corresponding to a finite set of distance ranges;
    • the set of sizes comprises continuous size variations corresponding to distances within one range; and
    • the size variations are bounded by a maximum and a minimum icon size ’062 Patent, claim 1
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’062 Patent.

U.S. Patent No. 7,840,352 - "Method and System for Autonomous Vehicle Navigation"

  • Patent Identification: U.S. Patent No. 7,840,352, "Method and System for Autonomous Vehicle Navigation," issued November 23, 2010 Compl. ¶39
  • Technology Synopsis: The patent addresses the limitations of individual navigation systems (GPS, inertial, image) by proposing a "deep integration" of raw measurements from all three sensor types. This joint processing is designed to produce a single, more reliable position estimate, in contrast to prior methods that would merge independently calculated (and potentially erroneous) estimates from each sensor type Compl. ¶¶42-43
  • Asserted Claims: Independent claims 1, 13, and 20 Compl. ¶41
  • Accused Features: The complaint alleges infringement by Rivian's Gen 1 and Gen 2 vehicles operating Driver+, Autonomy Platform, and Autonomy+ features, which are alleged to use GPS, inertial, and image sensors for navigation Compl. ¶112 Compl. ¶149

U.S. Patent No. 8,314,816 - "System and Method for Displaying Information on a Display Element"

  • Patent Identification: U.S. Patent No. 8,314,816, "System and Method for Displaying Information on a Display Element," issued November 20, 2012 Compl. ¶50
  • Technology Synopsis: The patent addresses challenges in sensor-fusion displays under low-visibility conditions. It describes a method where, upon detecting low visibility, the system stops relying on real-time image data and instead generates a "predicted image" by combining previously buffered (stored) image data with newly acquired, more reliable range data (e.g., from radar) Compl. ¶¶54-55
  • Asserted Claims: Independent claims 1 and 14 Compl. ¶52
  • Accused Features: The complaint alleges infringement by Rivian's vehicles and their driver-assistance platforms, which use a combination of cameras and radars to generate display information Compl. ¶105 Compl. ¶161

U.S. Patent No. 8,364,334 - "System and Method for Navigating an Autonomous Vehicle Using Laser Detection and Ranging"

  • Patent Identification: U.S. Patent No. 8,364,334, "System and Method for Navigating an Autonomous Vehicle Using Laser Detection and Ranging," issued January 29, 2013 Compl. ¶62
  • Technology Synopsis: This patent addresses autonomous navigation using laser scanning (LIDAR). It describes a specific architecture with three independent processing modules (ground plane-based, range-based, intensity-based) that each classify the same scan data. A fourth "classification fusion module" then combines the outputs of the three modules to generate a more reliable final classification of the vehicle's surroundings (e.g., road, curbs, obstacles) Compl. ¶¶65-67
  • Asserted Claims: Independent claims 1 and 13 Compl. ¶64
  • Accused Features: The complaint targets Rivian's vehicles and their driver-assistance platforms, which utilize sensors like cameras and radar for navigation and object detection Compl. ¶105 Compl. ¶173

U.S. Patent No. 9,355,567 - "System and Method for Highlighting an Area Encompassing an Aircraft That Is Free of Hazards"

  • Patent Identification: U.S. Patent No. 9,355,567, "System and Method for Highlighting an Area Encompassing an Aircraft That Is Free of Hazards," issued May 31, 2016 Compl. ¶73
  • Technology Synopsis: The patent addresses moving-map displays by introducing a "swath icon" that dynamically depicts the hazard-free zone around a vehicle. The invention specifies that this swath icon contracts based on the proximity of a detected object and that the system recognizes and displays potential collision avoidance maneuvers based on the object, the map, and the vehicle's type Compl. ¶¶78-80
  • Asserted Claims: Independent claim 1 Compl. ¶75
  • Accused Features: The complaint alleges infringement by Rivian's driver-assistance displays, which show the vehicle on a map with surrounding objects and provide features like "Universal Hands Free" driving (Compl. ¶¶108, 110, 185). The "Autonomy+" screenshot shows a graphic of a vehicle with a highlighted path ahead of it Compl. p. 32

U.S. Patent No. 10,133,856 - "Method and System for Managing Software License for Vehicle"

  • Patent Identification: U.S. Patent No. 10,133,856, "Method and System for Managing Software License for Vehicle," issued November 20, 2018 Compl. ¶86
  • Technology Synopsis: The patent addresses a problem with fixed-time software license expirations on vehicles, which could disable a critical function at an inopportune moment. The invention solves this by making the decision to deny access to a software module dependent not just on the expiration time, but also on the vehicle's current "operating state" as determined by a sensor Compl. ¶¶90-91
  • Asserted Claims: Independent claims 1 and 10 Compl. ¶88
  • Accused Features: The complaint alleges infringement by Rivian's vehicles, which utilize features like "Autonomy+" that are available via subscription and delivered through over-the-air software updates Compl. ¶111 Compl. ¶198

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's Rivian R1T, R1S, and R2 electric vehicles, along with their associated driver-assistance systems, identified as "Driver+," the "Rivian Autonomy Platform," and "Autonomy+" Compl. ¶¶98-101 Compl. ¶103 Compl. ¶106

Functionality and Market Context

The accused vehicles are equipped with a suite of hardware for autonomous driving features, including numerous exterior cameras, ultrasonic sensors, and radars that provide 360-degree coverage and long-range perception (Compl. ¶¶104-105; Compl. ¶107). These hardware components support ADAS features such as Highway Assist, Adaptive Cruise Control, Lane Keep Assist, and hands-free driving capabilities Compl. ¶103 Compl. ¶108

The complaint describes two generations of vehicles: Gen 1 (model year 2022-2024) with the "Driver+" feature set, and Gen 2 (model year 2025 onward) with the more advanced "Rivian Autonomy Platform" Compl. ¶102 An "Autonomy+" subscription service offers enhanced capabilities like "Universal Hands Free" driving Compl. ¶108 Functionality is improved and expanded through cloud-enabled, over-the-air software updates Compl. ¶1

A graphic in the complaint provides a "Scan your surroundings" visualization, depicting 360-degree multi-modal perception using 10 high-resolution cameras and multiple radars Compl. p. 30 Another visual from the defendant's website shows the "Autonomy+" feature, which includes "Universal Hands-Free" driving and "Lane Change on Command" Compl. p. 32

IV. Analysis of Infringement Allegations

The complaint references exhibits containing detailed claim charts for the asserted patents Compl. ¶125 Compl. ¶138 Compl. ¶150 Compl. ¶162 Compl. ¶174 Compl. ¶186 Compl. ¶199 As these exhibits were not attached to the publicly filed complaint, a tabular analysis is not possible. The narrative infringement theories are summarized below.

’264 Patent Infringement Allegations

The complaint alleges that Rivian's vehicles, through their driver-assistance platforms, infringe claim 1 of the ’264 Patent Compl. ¶125 The infringement theory is that the vehicles' safety systems (e.g., Forward Collision Warning, Automatic Emergency Braking) use data from various sensors (e.g., cameras, radars, chassis stability sensors) to monitor multiple "values of states" of the vehicle Compl. ¶103 Compl. ¶113 It is alleged that the systems then compare "combinations" of these states against predefined rules or unsafe conditions to "identify" a hazardous situation, thereby practicing the steps of the claimed method Compl. ¶16 Compl. ¶124

’062 Patent Infringement Allegations

The complaint asserts that Rivian's vehicles infringe claim 1 of the ’062 Patent Compl. ¶138 The alleged infringement centers on the driver-assistance display, which provides a 3D graphical representation of the vehicle's surroundings, including other traffic targets (Compl. pp. 30, 32). The complaint's theory appears to be that the icons representing these targets are sized based on their distance from the vehicle using a continuous scaling function that is "bounded by a maximum and a minimum icon size," as required by the claim, to maintain visibility and prevent display clutter Compl. ¶29 Compl. ¶31

Identified Points of Contention

  • Scope and Evidentiary Questions: A central issue for several patents will likely be whether the accused systems perform the specific, multi-step or multi-component functions as claimed. For the ’264 Patent, a key question is what evidence shows that Rivian's systems evaluate "combinations" of states against a database of "known unsafe combinations," as opposed to using a different logic. For the ’334 Patent, the analysis will turn on whether Rivian’s system employs the specific three-module classification architecture recited in the claims Compl. ¶¶66-67
  • Technical and Functional Mismatches: The infringement analysis will likely raise technical questions about the operation of the accused systems. For the ’062 Patent, the court may need to determine if Rivian's icon scaling method is in fact "bounded by a maximum and a minimum" as claimed, or if it uses a functionally different approach. For the ’567 Patent, a question will be whether the graphics on Rivian's display constitute a "swath icon" that "contract[s]" in the specific manner required by the claim Compl. ¶79

V. Key Claim Terms for Construction

Term: "combinations of... values of states" (’264 Patent)

Context and Importance: This phrase is the central element of the asserted claims. The scope of what constitutes a "combination" and what qualifies as a "state" will be critical to determining infringement. A broad definition could encompass many modern vehicle safety systems, while a narrow one could limit the patent to its specific disclosed embodiments.

Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint points to specification language describing states as including "both sensed physical conditions and commands pending or being implemented by onboard computers or other devices," which may support a broad reading that includes sensor data and software logic Compl. ¶19
  • Evidence for a Narrower Interpretation: A defendant may argue the term is limited by the patent's examples, which are drawn from an aviation context (e.g., speedbrakes and thrust) ’264 Patent, Fig. 4 The patent's title, "Flight Safety System," could also be used to argue for a narrower, aviation-specific construction, though the specification states it can apply to land-based vehicles ’264 Patent, col. 2:35-37

Term: "bounded by a maximum and a minimum icon size" (’062 Patent)

Context and Importance: This limitation distinguishes the invention from prior art that used unbounded scaling. The interpretation of "bounded" will determine whether any form of size-capping infringes, or if a more specific technical implementation is required. Practitioners may focus on this term because it is the core inventive concept alleged to solve the prior art's display-clutter problem Compl. ¶32

Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify how the bounding must be implemented, which may support an interpretation that covers any system preventing icons from becoming smaller than a minimum or larger than a maximum size.
  • Evidence for a Narrower Interpretation: The specification discusses the invention in the context of a "layered conformal view" that "reduces the load placed on the processor" ’062 Patent, col. 3:49-53 A defendant may argue that "bounded" should be construed to require this specific processor-efficient implementation, not just any method of limiting icon size.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant directs and encourages its customers to use the infringing features through user manuals, marketing materials, and software updates Compl. ¶132 Compl. ¶144 It also pleads contributory infringement, alleging that the infringing aspects of the accused products are especially designed for infringement and have no substantial non-infringing use Compl. ¶133 Compl. ¶145

Willful Infringement

Willfulness is alleged based on Defendant's purported pre-suit knowledge of the patents-in-suit. The complaint cites a detailed notice letter sent on April 20, 2023, which allegedly included claim charts for some of the patents, and a follow-up letter sent on September 25, 2025. The complaint asserts that Defendant never provided a substantive response, allegedly demonstrating a disregard for Plaintiff's patent rights Compl. ¶¶114-122 Compl. ¶135

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

  1. Patent Eligibility: The complaint's repeated and detailed arguments that the inventions are concrete improvements to vehicle computer systems, rather than abstract ideas, suggests Plaintiff anticipates a significant challenge under 35 U.S.C. § 101. A central legal question will be whether the asserted claims, which involve data processing and software-based logic, are directed to patent-eligible subject matter or to abstract ideas implemented on generic computer components.

  2. Claim Construction and Scope: For several patents, the outcome may hinge on claim construction. A core issue for the ’264 patent will be one of definitional scope: can the term "combinations of... states", rooted in aviation examples, be broadly construed to cover the complex rule sets in a modern automotive ADAS? For the ’062 patent, a key question will be the scope of "bounded by a maximum and a minimum icon size," and whether it reads on the specific scaling algorithms used in Rivian's displays.

  3. Evidentiary Proof of Infringement: A key evidentiary question will be one of functional and architectural correspondence: does the complaint, and subsequent discovery, provide sufficient evidence that Rivian’s systems operate in the specific manner claimed? For example, for the ’334 patent, does Rivian’s system use the claimed three-module architecture for classifying sensor data, or does it achieve a similar result through a fundamentally different process? Proving a direct technical mapping between the accused software and the claim limitations will be a primary focus.