DCT

1:25-cv-00867

Autel Intelligent Technology Corp Ltd v. Shenzhen Foxwell Technology Co Ltd

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00867, D. Del., 03/05/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Foxwell Technology Inc. is a Delaware corporation that resides in the district, and Defendant Shenzhen Foxwell Technology Co., Ltd is not a U.S. resident but has engaged in infringing activity in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s NT 604 Elite automotive diagnostic device infringes a patent related to the system architecture for communication between a diagnostic tool and a vehicle's onboard computer network.
  • Technical Context: The technology concerns handheld automotive diagnostic tools that connect to a vehicle's On-Board Diagnostics (OBD-II) port to read data from various Electronic Control Units (ECUs) for troubleshooting and analysis.
  • Key Procedural History: The operative pleading is the Plaintiffs' First Amended Complaint; no other significant procedural events such as prior litigation or post-grant proceedings are mentioned in the complaint.

Case Timeline

Date Event
2018-01-08 U.S. Patent No. 11,845,451 Priority Date
2023-12-19 U.S. Patent No. 11,845,451 Issues
2026-03-05 Complaint Filing Date

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

U.S. Patent No. 11,845,451 - "Automobile Diagnostic Method, Apparatus, Device and System, and Diagnostic Connection Device"

  • Patent Identification: U.S. Patent No. 11,845,451 (“the ’451 Patent”), "Automobile Diagnostic Method, Apparatus, Device and System, and Diagnostic Connection Device," issued December 19, 2023. (Compl. ¶25)

The Invention Explained

  • Problem Addressed: The patent’s background describes a problem in prior art automotive diagnostic systems where the separate hardware interface connecting the main tool to the vehicle—the Vehicle Connection Interface (“VCI”)—was required to perform computationally intensive data "protocol conversion" (Compl. ¶¶29-30). This approach required the VCI to have significant processing and memory resources, increasing its hardware cost and complexity, and potentially creating communication inefficiencies (Compl. ¶¶30-31; ’451 Patent, col. 1:35-44).
  • The Patented Solution: The invention relocates the resource-intensive protocol conversion tasks from the VCI to the main automobile diagnostic device, which typically has more powerful processors and greater memory (Compl. ¶34; ’451 Patent, abstract). This allows the VCI to function as a simpler, less expensive component that primarily relays data, while the main diagnostic tool handles the complex task of translating data between the vehicle’s communication protocols and the format used by the tool (Compl. ¶¶35-36; ’451 Patent, col. 6:1-9).
  • Technical Importance: This architectural shift aimed to reduce the hardware requirements, production cost, and performance demands on the VCI, while leveraging the superior computational power of the main diagnostic device to manage communications more efficiently (Compl. ¶52).

Key Claims at a Glance

The complaint asserts direct infringement of independent claims 11 and 12, and indirect infringement of independent claims 1 and 5 (Compl. ¶¶56-57).

  • Independent Claim 11 (An automobile diagnostic device):

    • A display screen
    • A first communication unit configured to send and receive data
    • At least one processor
    • A memory storing an instruction that, when executed, causes the processor to:
      • read a user operation on an interface
      • convert the operation into a diagnostic instruction
      • convert the diagnostic instruction into standard transmission data
      • synchronously send the standard transmission data

  • Independent Claim 12 (A diagnostic connection device):

    • A second communication unit configured to send and receive data
    • At least one communication controller connected to the communication unit and configured to control a bus
    • At least one bus connected to the controller
    • A diagnostic interface connected to the bus to connect to an automobile network
    • The controller comprises a processor and memory with an instruction that, when executed, causes the processor to:
      • synchronously receive standard transmission data from the diagnostic device
      • send that data to the automobile network
      • receive standard transmission data from the automobile network
      • synchronously send that data to the diagnostic device

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is the Foxwell NT 604 Elite automotive diagnostic tool (Compl. ¶2).

Functionality and Market Context

  • The complaint describes the NT 604 Elite as a handheld device used by technicians to diagnose vehicle issues (Compl. ¶18). It connects to a vehicle's standard OBD-II port to communicate with the vehicle’s internal computer network (Compl. ¶¶20-21). The complaint alleges the accused product consists of a main diagnostic tool (the "Device") and a Vehicle Communication Interface ("VCI") module that connects the main tool to the vehicle (Compl. p. 12). A teardown image in the complaint purports to show the internal circuit boards of the VCI module and the main diagnostic module (Compl. p. 18, fig. 32). The device allows users to select diagnostic functions via buttons, and it then reads and displays data from the vehicle, such as diagnostic trouble codes and live data streams (Compl. p. 14).
  • The complaint positions the Defendants as "direct competitors" of the Plaintiff and alleges the NT 604 Elite "copies and implements the patented technologies" (Compl. ¶2).

IV. Analysis of Infringement Allegations

’451 Patent Infringement Allegations (Claim 11)

Claim Element (from Independent Claim 11) Alleged Infringing Functionality Complaint Citation Patent Citation
An automobile diagnostic device, comprising The Foxwell NT604 Elite Automotive Diagnostic Tool is identified as the accused automobile diagnostic device. ¶50 col. 5:10-12
a display screen The device includes an LCD Display to show menus and test results. ¶53 col. 5:13
a first communication unit configured to send and receive data The device establishes bi-directional communication with the vehicle to send requests and receive data. p. 23 col. 5:14-15
at least one processor The complaint alleges the device must necessarily include a processor to perform its functions and provides a teardown image identifying a "Processor" on the circuit board. ¶56; ¶58 col. 5:16
a memory communicatively connected to the at least one processor... The device includes memory, which is alleged to be necessarily communicatively coupled to the processor. ¶59; ¶60 col. 5:17-18
the memory stores an instruction that... causes the at least one processor to read an operation performed by a user on an interface The device has physical buttons for user input, and the memory is alleged to store instructions to process these inputs. A diagram from the user manual shows the device's input buttons (Compl. p. 24, fig. 64). ¶61; ¶62 col. 17:7-9
and converting the operation into a corresponding diagnostic instruction The device allegedly converts a user's button press into a specific diagnostic request, such as a request for powertrain diagnostic data. ¶67 col. 17:10-12
convert the diagnostic instruction into standard transmission data corresponding to the diagnostic instruction The diagnostic instruction is necessarily converted into a standard data format for transmission over the automobile network. p. 25 col. 17:13-15
and synchronously send the standard transmission data... The complaint alleges the device uses a CAN bus, which operates synchronously, to transmit the data. ¶76 col. 17:16-18

’451 Patent Infringement Allegations (Claim 12)

Claim Element (from Independent Claim 12) Alleged Infringing Functionality Complaint Citation Patent Citation
A diagnostic connection device, comprising The Foxwell NT604 includes a Vehicle Communication Interface (“VCI”) Module, which is identified as the accused diagnostic connection device. p. 26 col. 5:24-25
a second communication unit configured to send and receive data The VCI module allegedly contains communication interface chips, including a "controller," that form a communication unit. ¶80 col. 5:26-27
at least one communication controller connected to the second communication unit... A teardown image provided in the complaint identifies a "VCI controller/processor" on the VCI module's circuit board (Compl. p. 28, fig. 81). ¶81 col. 5:28-31
the at least one bus connected to the communication controller... The complaint alleges the device and VCI communicate over a vehicle's electronic network, which leverages a CAN bus. ¶83 col. 5:32-34
a diagnostic interface connected to the at least one bus and configured to connect to an automobile network The device is alleged to connect to the vehicle's network to detect the communication protocol automatically. ¶87 col. 5:35-37
the memory stores an instruction that... causes the at least one processor to... synchronously receive... send... receive... and synchronously send The complaint provides screenshots of communication logs alleged to show the VCI module receiving a command from the main device, sending it to the network, receiving a reply, and sending the reply back to the main device in a synchronous cycle (Compl. p. 29, figs. 84-86). ¶98 col. 5:38-52

Identified Points of Contention

  • Architectural Questions: The patent's stated improvement is moving protocol conversion off the VCI. The complaint, however, identifies a "processor" and "controller" within the accused VCI (Compl. p. 31, fig. 93). This raises the question of what functions this VCI processor performs. The analysis may focus on whether the accused VCI is merely a simple data relay, as the patent appears to envision for its improved system, or if it performs more complex tasks that might place it outside the scope of the claims or closer to the prior art the patent sought to improve upon.
  • Technical Questions: The complaint's infringement theory relies heavily on communication logs to demonstrate the claimed data transmissions (Compl. p. 15, fig. 15). A key technical question will be whether these logs accurately depict the claimed "synchronous" sending and receiving operations as required by the claims, and whether the operations shown are performed by the components as alleged (i.e., the VCI versus the main diagnostic device).

V. Key Claim Terms for Construction

  • The Term: "synchronously send" / "synchronously receive" (Claims 11, 12)

    • Context and Importance: These terms appear in the asserted independent claims and define the timing and nature of the communication between the diagnostic device, the VCI, and the vehicle network. The complaint supports its infringement allegation by asserting the accused product uses a CAN bus, which is a synchronous protocol (Compl. ¶24; Compl. ¶76). The dispute may center on whether the product's operation meets the specific meaning of "synchronous" as used in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification discloses both a "synchronous sending module" and an "asynchronous sending module" (as well as receiving counterparts) as optional components of the software interface (e.g., ’451 Patent, col. 11:19-27). This express distinction may support an argument that "synchronously" should be given its plain and ordinary technical meaning in contrast to asynchronous methods.
      • Evidence for a Narrower Interpretation: The patent provides detailed descriptions of asynchronous communication involving "callback function[s]" ('451 Patent, FIG. 3; '451 Patent, FIG. 4). A party may argue that "synchronously" should be construed as any communication method that is not the specific, detailed asynchronous method disclosed, potentially limiting its scope to blocking, time-coordinated communications.

  • The Term: "communication controller" (Claim 12)

    • Context and Importance: This term defines the processing component within the accused VCI. The scope of this term is central because the patent's purported innovation is to reduce the VCI's processing load. The complaint identifies a "VCI controller/processor" on the accused VCI's circuit board (Compl. p. 28, fig. 81). Practitioners may focus on this term because its construction could determine whether the accused VCI is the type of simplified device covered by the claims.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself defines the controller as comprising "at least one processor" and a "memory," which is a broad definition for a programmable component (’451 Patent, col. 20:2-10).
      • Evidence for a Narrower Interpretation: The specification repeatedly contrasts the patented invention with prior art where the connection device performs complex "protocol conversion" (’451 Patent, col. 6:1-9). An argument could be made that to be consistent with the invention's purpose, the term "communication controller" must be limited to a component that does not perform the kind of resource-intensive protocol conversion that the invention intentionally moved to the main diagnostic device.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement to infringe claims 1 and 5, asserting that Defendants provide "instructions, marketing materials, and technical support" that encourage end users to operate the NT 604 Elite in an infringing manner (Compl. ¶57).
  • Willful Infringement: The complaint alleges willfulness based on Defendants' alleged pre-suit "actual knowledge" of the ’451 Patent or "willful blindness" to its infringement (Compl. ¶58). This allegation is based on the parties being "sophisticated competitors" and Defendants' alleged knowledge of Plaintiff's patent portfolio prior to or during the launch of the accused product (Compl. ¶58).

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

  • A central issue will be one of system architecture: The patent is predicated on an architectural shift that moves processing-intensive "protocol conversion" from the VCI to the main diagnostic tool. A key question for the court will be whether the accused Foxwell VCI, which the complaint shows contains its own "processor" and "controller," functions as the simplified data conduit envisioned by the patent or if it performs functions that align more closely with the prior art architecture the patent purports to improve upon.
  • A second core issue will be one of evidentiary proof: The infringement case relies on screenshots of communication logs to demonstrate the "synchronous" data transmissions required by the claims. This raises a key evidentiary question: do these logs provide sufficient and unambiguous proof that the accused product performs the specific sequence of receiving and sending steps as claimed, and can Plaintiff establish that the correct components (main device vs. VCI) are performing these steps?
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