Adedamola Ojo v. American Honda Finance Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Adedamola Ojo, a.k.a., John Ojo (California)
  • Defendant: American Honda Finance Corporation (California)
  • Plaintiff's Counsel: Trojan Law Offices, P.C.
• Case Identification: 2:26-cv-02592, C.D. Cal., 03/11/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because the defendant corporation maintains its headquarters, conducts business, and has committed the alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant's internal debt collection system infringes a patent related to methods for determining the optimal time to contact delinquent customers using an automatic dialer.
• Technical Context: The technology at issue falls within the field of call center intelligence, specifically using historical data analysis to improve the efficiency and success rates of automated outbound debt collection campaigns.
• Key Procedural History: The complaint presents an unusual fact pattern, alleging that the plaintiff, currently an Assistant Collections Manager at the defendant company, conceived of the patented technology, proposed it to management, and helped implement the accused system at the company. Plaintiff also alleges pre-issuance notice of the patent application, forming the basis for claims of provisional rights and willful infringement.

Case Timeline

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

U.S. Patent No. 12,477,066 - Best Time to Call in Automatic Dialing Operations

Issued November 18, 2025

The Invention Explained

• Problem Addressed: The patent's background describes a significant inefficiency in conventional automated call centers used for debt collection, where high "wrong party contact rates" result in a "huge waste of agent's time and resources" because the systems lack the ability to determine when a customer is most likely to be available ʼ066 Patent, col. 1:26-34
• The Patented Solution: The invention is a method that analyzes historical call data to identify the specific time windows during the day when a "right party contact" (RPC) is most likely ʼ066 Patent, abstract The system determines a "best time to call" (BTTC) for each delinquent account and uses this information to schedule calls with an automatic dialer, ensuring calls are placed only during these optimal windows ʼ066 Patent, col. 2:50-60 The method also involves segmenting accounts into behavioral categories to further refine collection strategy ʼ066 Patent, col. 2:63-col. 3:10
• Technical Importance: This data-driven approach sought to improve the operational efficiency of call centers by systematically increasing the probability of reaching the intended person, thereby reducing wasted calls and optimizing agent time ʼ066 Patent, col. 1:9-11

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 Compl. ¶18 Compl. ¶20
• The essential elements of independent Claim 1 include:
  • Providing a computerized service control point (SCP) executing software.
  • Dividing a day into specific time windows.
  • Analyzing historical call data to determine the right party contact (RPC) percentage for each time window.
  • Determining a specific time window with the highest RPC as a best time to call (BTTC) for each account.
  • Utilizing the BTTC to prepare a call list for an automatic dialer so accounts are only dialed during their BTTC window.
  • Executing the automatic dialer with the call list.
  • Segmenting delinquent accounts according to the behavior of persons associated with the accounts (e.g., No History, BTTC, No BTTC).
  • Routing answered calls to agents for interaction.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is an internal debt collection call system used by Defendant American Honda Finance Corporation (AHFC), referred to as the "improved BTTC system" Compl. ¶14 The complaint references an internal AHFC document, "RSS 49718_v9c_May 21, 2025," as describing the infringing method Compl. ¶19 Compl. ¶20

Functionality and Market Context

• The complaint alleges the system was implemented to improve the efficiency of AHFC's collections on delinquent accounts Compl. ¶9
• Its functionality is described as determining the best time to call a customer through statistical analysis of robocalls, narrowing the time window for placing such calls, and assigning successful calls to live agents Compl. ¶9
• The plaintiff alleges he proposed and helped implement the system at AHFC to bring the company's collection practices into compliance with anticipated regulations from the Consumer Financial Protection Bureau Compl. ¶14 Plaintiff further alleges the system has resulted in a reduction of over $50 million in annual net credit losses for AHFC Compl. ¶10

IV. Analysis of Infringement Allegations

The complaint references a sealed claim chart (Exhibit 3) that was not publicly available for this analysis Compl. ¶20 The narrative allegations state that AHFC's internal system "has all of the elements of Claim 1" Compl. ¶18

'066 Patent Infringement Allegations

No probative visual evidence provided in complaint.

Identified Points of Contention

• Architectural Questions: A potential point of contention may be whether AHFC's system, presumably a modern software-based call center, incorporates a component that meets the technical definition of a "computerized service control point (SCP)," a specific term of art in telecommunications, as required by the claim.
• Functional Questions: The infringement analysis may turn on whether the defendant's system performs the specific multi-category "segmenting" of accounts based on behavior (e.g., "No History," "BTTC," "No BTTC") as detailed in the patent specification and recited in the claim, or if it merely categorizes customers in a more general way.
• Equitable Questions: The plaintiff's alleged role as a current employee who helped implement the accused system raises the possibility of equitable defenses, such as an implied license or estoppel, which may become central to the dispute.

V. Key Claim Terms for Construction

"service control point (SCP)"

• Context and Importance: This term appears in the preamble of Claim 1 and describes a core architectural component. Practitioners may focus on this term because its construction could determine whether the claim reads on modern, software-defined call center architectures or is limited to older systems using specific telecommunications hardware.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly define the term, which may support an argument that it should be given its plain and ordinary meaning, potentially encompassing any centralized server that provides intelligent call routing.
  • Evidence for a Narrower Interpretation: The specification explicitly shows "SCP" as a distinct element (128) in the system architecture diagram ʼ066 Patent, Fig. 1 and describes its interaction with a network switch (102) ʼ066 Patent, col. 2:58-60 This could support a narrower construction limited to such a component.

"segmenting delinquent accounts according to behavior"

• Context and Importance: This is a key data processing step in Claim 1. The dispute will likely center on what specific actions and categorizations satisfy this limitation. Infringement will depend on whether AHFC's system performs the type of segmentation described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is somewhat general, which could support a construction that covers any method of categorizing customers based on their response patterns.
  • Evidence for a Narrower Interpretation: The claim itself provides examples of the required segments, including "No History (NH) accounts," accounts for which a "BTTC has been determined," and a third segment "designated NB for No BTTC" ʼ066 Patent, col. 11:27-39 The specification provides detailed definitions for these segments, which may support a narrower construction requiring this specific three-part categorization ʼ066 Patent, col. 8:45-col. 9:40

VI. Other Allegations

Indirect Infringement

The complaint does not contain specific allegations of indirect infringement (inducement or contributory infringement). The focus is on direct infringement by AHFC through its use of the accused system Compl. ¶18

Willful Infringement

Willfulness is alleged based on pre-suit knowledge Compl. ¶26 The complaint alleges that AHFC was "placed on notice" of the infringement but failed to respond meaningfully Compl. ¶10 It further alleges that AHFC had possession of the published patent claims by "late 2024" and was formally provided the publication number in January 2025, nearly a year before the patent issued Compl. ¶23 Compl. ¶24 Continued use of the technology after this alleged notice is the stated basis for willfulness Compl. ¶26

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

• A central issue will be the legal and equitable implications of the plaintiff's alleged role as a current employee who personally conceived, proposed, and implemented the accused system for the defendant. This raises threshold questions of inventorship, ownership, and the potential existence of an implied license or "shop right" that could impact the entire case.
• A key technical question will be one of definitional scope: does the defendant's modern call center software architecture include a component that meets the specific definition of a "service control point (SCP)" as described in the patent, or is there a fundamental mismatch in the claimed system architecture?
• An evidentiary question will be one of functional proof: can the plaintiff demonstrate that the accused system performs the specific, multi-category "segmenting" of accounts required by Claim 1, or does the system's method of categorizing customers differ in a technically significant way from that claimed in the patent?