WirelessWerx IP LLC v. Mercedes Benz USA LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: WirelessWerx IP, LLC (Texas)
  • Defendant: Mercedes-Benz USA, LLC (Georgia)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:25-cv-02823, N.D. Tex., 02/03/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Northern District of Texas, specifically identifying a learning and performance center and a parts distribution center.
• Core Dispute: Plaintiff alleges that Defendant’s "Mercedes me connect" application and associated systems infringe two patents related to the remote control and monitoring of movable entities using geofencing technology.
• Technical Context: The technology concerns systems for tracking and controlling vehicles or other movable assets by defining geographical zones and triggering actions when those zones are entered or exited.
• Key Procedural History: Plaintiff, a non-practicing entity, notes that it and its predecessors have entered into prior settlement licenses with other entities but states that none of these settlements included admissions of infringement or created an obligation to mark products under 35 U.S.C. § 287(a).

Case Timeline

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

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U.S. Patent No. 7,323,982 - “Method and System to Control Movable Entities” (Issued Jan. 29, 2008)

The Invention Explained

• Problem Addressed: The patent describes prior art vehicle tracking systems as being limited to relaying GPS information to a control center and plotting a vehicle's position on a map, lacking more advanced control capabilities ʼ982 Patent, col. 1:47-54
• The Patented Solution: The invention proposes a system where a "transponder" attached to a movable entity is programmed with a "geographical zone." The transponder's onboard microprocessor can then independently determine when an "event" occurs (e.g., entering or leaving the zone) and automatically execute a "configurable operation" (e.g., locking a door, turning off the ignition) in response ʼ982 Patent, abstract ’982 Patent, col. 2:1-8 The geographical zone can be defined by a set of waypoints, each comprising a coordinate and a radius, or by creating an enclosed area on a pixilated image ʼ982 Patent, abstract
• Technical Importance: This technology enabled more sophisticated and autonomous asset management by moving decision-making logic from a central server to the device itself, allowing for real-time, automated actions based on location without constant communication with a control center.

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-61 Compl. ¶18 Independent claims include 1, 20, and 43. Claim 20 is representative of the geofencing method:
  • defining a geographical zone using a plurality of waypoints, wherein each waypoint is defined by a geographical coordinate and a radius originating from the geographical coordinate;
  • loading from a computing device to the transponder's memory a plurality of waypoints;
  • programming a microprocessor in a transponder to determine the occurrence of an event associated with a status of the entity in relation to the geographical zone; and
  • configuring the microprocessor to execute a configurable operation if the event occurs.
• The complaint does not specify which dependent claims may be asserted.

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U.S. Patent No. 8,009,037 - “Method and System to Control Movable Entities” (Issued Aug. 30, 2011)

The Invention Explained

• Problem Addressed: As a divisional of the application leading to the ʼ982 Patent, this patent addresses the same limitations in prior art vehicle tracking systems ʼ037 Patent, col. 1:45-52
• The Patented Solution: The ʼ037 Patent also describes a system for controlling a movable entity using a geofence. However, its independent claims introduce a different operational flow, where the transponder executes an operation "upon receiving a command from a control center" ʼ037 Patent, abstract ’037 Patent, col. 3:25-34 This suggests a system where the control center initiates the action, rather than the transponder acting autonomously upon detecting an event.
• Technical Importance: This patent family covers both device-centric autonomous control and server-centric commanded control, broadening the potential scope of the claimed asset management systems.

Key Claims at a Glance

• The complaint asserts infringement of one or more of claims 1-65 Compl. ¶25 Independent claims include 1, 16, 35, and 49. Claim 16 is representative:
  • defining a geographical zone using a plurality of waypoints...;
  • loading from a computing device to the transponder's memory a plurality of waypoints; and
  • sending a command to the transponder to execute a configurable operation upon receiving a command from a control center, the command being associated with a status of the entity in relation to the geographical zone.
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

• Product Identification: The complaint identifies the "Mercedes me connect app" and related systems and services as the Accused Instrumentalities Compl. ¶15
• Functionality and Market Context: The complaint alleges that Defendant "maintains, operates, and administers a system with methods and user interface for controlling an entity having an attached transponder" Compl. ¶¶18, 25 The complaint provides a URL for the accused app but offers no specific technical details about its architecture, its interaction with the vehicle's onboard systems, or how it implements geofencing functionalities Compl. ¶15 The complaint does not provide sufficient detail for a full analysis of the accused instrumentality's functionality.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's system infringes the patents but refers to preliminary claim charts in Exhibits B and D, which were not filed with the complaint Compl. ¶¶19, 26 The narrative allegations are general and lack specific mappings of product features to claim limitations.

’982 Patent Infringement Allegations

The complaint does not provide sufficient detail to populate a claim chart. The infringement theory appears to be that the Mercedes me connect system allows users to establish geofences and that the vehicle system (the alleged "transponder") then determines its status relative to that geofence and can trigger certain operations, thereby practicing the patented method Compl. ¶¶17-18

• Identified Points of Contention:
  • Scope Question: A primary question may be whether the vehicle's integrated telematics control unit or the smartphone running the "Mercedes me connect app" qualifies as the claimed "transponder." The patent specification depicts a discrete, attachable hardware unit '982 Patent, Figs. 2, 3A-3C
  • Technical Question: A key factual dispute may concern the system's architecture. Claim 20 requires "programming a microprocessor in a transponder to determine the occurrence of an event." This suggests the geofence logic resides and is executed on the device in the vehicle. The court may need to determine whether the accused system performs this determination on the vehicle itself or on a remote server that communicates with the vehicle, which could present a mismatch with the claim language.

’037 Patent Infringement Allegations

Similar to the ʼ982 patent allegations, the complaint lacks the detail needed to construct a claim chart. The infringement theory for the '037 patent appears to be that the Mercedes me connect system allows a central server to send commands to the vehicle to execute operations based on its location relative to a geofence Compl. ¶25

• Identified Points of Contention:
  • Scope Question: The "transponder" scope question identified for the '982 patent is also central here.
  • Technical Question: The '037 patent's claims require executing an operation "upon receiving a command from a control center." An evidentiary question will be whether the accused system operates via this specific command-and-control sequence, as distinguished from the autonomous, device-side processing suggested by the '982 patent. The complaint does not describe the specific data flow or logic of the accused system.

V. Key Claim Terms for Construction

• The Term: "transponder"

  • Context and Importance: This term is foundational to all asserted claims. The infringement dispute may hinge on whether the accused system—which involves a software application and integrated vehicle electronics—contains a component that meets the definition of a "transponder" as described in the patents. Practitioners may focus on this term because the patents' embodiments depict a distinct hardware box, which may differ from the integrated nature of modern vehicle telematics.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the transponder in functional terms as containing a processor, memory module, communications modem, and GPS receiver, without explicitly limiting it to a standalone form factor ʼ982 Patent, col. 5:45-56 This could support an interpretation covering any device with these capabilities, such as a smartphone or an integrated Telematics Control Unit (TCU).
    • Evidence for a Narrower Interpretation: Figures 2 and 3A-3C explicitly show a separate, attachable hardware unit with specific external ports and indicators (ʼ982 Patent, Figs. 2, 3A-3C). The description notes it can be "mounted, attached, manufactured, or otherwise included upon/in various articles" ʼ037 Patent, col. 5:34-36, which may suggest a discrete component rather than a fully integrated system.

• The Term: "programming a microprocessor in a transponder to determine the occurrence of an event" (in the context of the ʼ982 Patent)

  • Context and Importance: This phrase is central to the autonomous operation claimed in the ʼ982 Patent. Its construction will determine whether the decision-making logic must reside on the end-device (the "transponder") or if server-side processing is permissible.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: "Programming" could be argued to mean simply loading configuration data (like geofence coordinates) onto the device, which the device then uses in communication with a server that makes the ultimate determination.
    • Evidence for a Narrower Interpretation: The claim language recites programming the microprocessor to determine the event, which suggests the determinative logic and calculation must be performed by the microprocessor within the transponder itself, independent of a control center '982 Patent, col. 2:1-4

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for both patents. For inducement, it alleges Defendant instructs customers on how to use the accused services to control their vehicles Compl. ¶¶20, 27 For contributory infringement, it alleges the accused products are not staple articles of commerce and have no substantial non-infringing uses Compl. ¶21 Compl. ¶28
• Willful Infringement: Willfulness allegations are based on Defendant's alleged knowledge of the patents "from at least the filing date of the lawsuit" Compl. ¶¶20, 27 The prayer for relief also seeks a finding of willfulness if discovery reveals pre-suit knowledge of the patents Compl. p. 10, prayer e

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

The resolution of this case may depend on the answers to a few central questions concerning the relationship between the patent disclosures and modern connected-vehicle technology.

• A core issue will be one of definitional scope: can the term "transponder," depicted in the patents as a discrete, attachable hardware unit, be construed to cover a modern vehicle's highly integrated telematics control unit or a user's smartphone running the accused application?
• A second key issue will be one of architectural functionality: does the accused "Mercedes me connect" system perform geofence event determination and trigger subsequent actions autonomously on the in-vehicle device, as required by the claims of the '982 patent, or is this logic primarily executed on remote servers?
• Finally, an evidentiary question will be whether the accused system's operation aligns with the server-initiated "command from a control center" model required by the claims of the '037 patent, potentially creating a conflict between the infringement theories for the two patents-in-suit.