DCT

1:26-cv-01036

Peregrine Data LLC v. Detroit Diesel Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-01036, D. Del., 08/13/2026
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation with an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant infringes a patent related to vehicle-mounted camera systems that record the surrounding environment for evidentiary purposes.
  • Technical Context: The technology concerns automotive "black box" video recorders, using multiple cameras to create a 360-degree evidentiary record of events like accidents or crimes.
  • Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit the patent's enforceable term to that of an earlier-expiring, related patent.

Case Timeline

Date Event
2004-04-15 Priority Date for '619 Patent
2010-03-12 Application Date for '619 Patent
2012-11-27 Issue Date for '619 Patent
2026-08-13 Complaint Filing Date

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

U.S. Patent No. 8,319,619 - "Stored vision for automobiles"

  • Patent Identification: U.S. Patent No. 8,319,619, "Stored vision for automobiles," issued November 27, 2012 Compl. ¶9

The Invention Explained

  • Problem Addressed: The patent addresses the lack of reliable evidence following traffic incidents and the danger posed by drivers being distracted while trying to manually record events. '619 Patent, col. 1:21-30 The background notes that eyewitness testimony can be unreliable and that conventional legal processes are often "notoriously expensive and inefficient" due to a "scarcity of reliable evidence." '619 Patent, col. 1:65-68
  • The Patented Solution: The invention is a system that uses multiple cameras mounted on a vehicle's perimeter to continuously and automatically record the surrounding environment. '619 Patent, abstract The system is designed to operate without driver interaction, capturing data that can be retrieved "after the vehicle is stopped" to provide "reliable evidence for use in legal proceedings." '619 Patent, col. 2:17-20 The data from the cameras is sent to a central controller for recording on storage media. '619 Patent, Fig. 4
  • Technical Importance: The described solution aims to create a comprehensive and objective evidentiary record of events around a vehicle, without compromising the driver's primary task of operating the vehicle safely. '619 Patent, col. 2:13-17

Key Claims at a Glance

  • The complaint asserts "one or more claims" of the '619 Patent, including exemplary method claims identified in an exhibit not attached to the pleading Compl. ¶11 Independent claim 1 is a representative method claim.
  • The essential elements of independent claim 1 include:
    • placing a plurality of cameras in circumferentially spaced positions around the vehicle's periphery "at about the middle of its vertical height" and fixedly securing them with fields of view directed outwardly;
    • activating all cameras to operate continuously throughout an entire trip;
    • recording images acquired by "each camera in a corresponding separate file";
    • using "separate node files to provide eight separate files of real-time recorded data";
    • using the cameras as a set where each operates "separately and individually"; and
    • locating all apparatus so that it is "inaccessible to a driver throughout the entire trip." '619 Patent, col. 6:50-col. 8:5

III. The Accused Instrumentality

Product Identification

  • The complaint does not specifically name any accused products in its text. It refers to "Exemplary Defendant Products" that are identified in charts within "Exhibit 2," which was not provided with the pleading Compl. ¶11 Compl. ¶13

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '619 Patent." Compl. ¶13

IV. Analysis of Infringement Allegations

The complaint provides a conclusory allegation of direct infringement, stating that the accused products "satisfy all elements of the Exemplary '619 Patent Claims" as set forth in claim charts in an unprovided "Exhibit 2" Compl. ¶13 The pleading itself contains no specific factual allegations mapping product features to claim limitations. Therefore, a claim chart summary cannot be constructed.

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the language of claim 1 of the '619 Patent and the general nature of the dispute, several questions may become central to the infringement analysis:
    • Scope Questions: The case may turn on the scope of relative or functional terms. For example, what is the proper construction of placing cameras "at about the middle of its vertical height" '619 Patent, col. 6:53-54, and does the accused product placement meet this limitation? Further, what constitutes apparatus that is "inaccessible to a driver" '619 Patent, col. 8:3-4, and does this require physical obstruction or merely a lack of a user interface?
    • Technical Questions: A key technical question may be whether the accused products' data storage architecture satisfies the claim requirement of recording images from "each camera in a corresponding separate file" and using "eight separate files of real-time recorded data." ('619 Patent, col. 6:61-65). The court may need to determine if a modern, multiplexed data stream is equivalent to the "separate file" structure described in the patent.

V. Key Claim Terms for Construction

  • The Term: "at about the middle of its vertical height" '619 Patent, col. 6:53-54

    • Context and Importance: This term defines the required vertical placement of the cameras on the vehicle. Its construction will be critical for determining infringement, as modern vehicle camera systems are often integrated into locations like grilles, mirrors, or rooflines, which may or may not fall within the "middle" of the vehicle's height.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Practitioners may argue that the term "about" suggests a degree of flexibility. The specification's suggestion of integrating lenses into "current headlight, brake light, and/or side marker electrical housings" could support a broader vertical zone beyond a strict geometric midline. '619 Patent, col. 4:47-50
      • Evidence for a Narrower Interpretation: A defendant might argue that the term, even with "about," implies a position generally centered vertically on the vehicle body, excluding high (roof) or low (bumper/grille) placements. The patent does not appear to provide an explicit definition that would limit the term to a specific range.

  • The Term: "inaccessible to a driver" '619 Patent, col. 8:3-4

    • Context and Importance: This limitation requires that the system's apparatus cannot be accessed by the driver during operation. Practitioners may focus on this term because its definition-whether it means physically unreachable or simply lacking a user interface-will determine whether many modern systems with dashboard-integrated controls fall within the claim's scope. The patent's stated goal is to avoid driver distraction. '619 Patent, col. 2:15-17
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: An argument for a broader interpretation (e.g., functionally inaccessible via a user interface) could be supported by the patent's focus on preventing driver distraction, suggesting the key is preventing interaction, not physical reach.
      • Evidence for a Narrower Interpretation: The specification states it is "preferably inacessible to the driver while driving the vehicle." '619 Patent, col. 2:55-57 The use of the word "inaccessible" in the claim itself, without qualification, may support an argument for physical inaccessibility, meaning the driver cannot touch or manipulate the components.

VI. Other Allegations

  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or a request for enhanced damages under 35 U.S.C. § 284. It does, however, request that the case be "declared exceptional" for the purpose of awarding attorneys' fees under 35 U.S.C. § 285 Compl., Prayer ¶E.i. The complaint offers no factual basis to support this allegation of an exceptional case.

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

  1. Pleading Sufficiency: A threshold issue may be whether the complaint, which contains no factual allegations of infringement and relies entirely on incorporation of an unprovided exhibit, meets the plausibility pleading standards required by federal court procedure.
  2. Claim Construction: The dispute will likely hinge on the construction of key claim limitations. A central question for the court will be one of definitional scope: can terms like "at about the middle of its vertical height" and "inaccessible to a driver" be interpreted to cover the design and placement of cameras and controls in modern automotive systems?
  3. Technical Equivalence: A core evidentiary question will be one of functional equivalence: does the accused products' data management system, which may use modern multiplexed streaming, create the "separate file" for each camera as specifically required by claim 1, or is there a fundamental mismatch in the technology's architecture and operation?
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