DCT

3:26-cv-01586

Privacy4cars Inc v. PII Auto LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:26-cv-01586, N.D. Tex., 05/15/2026
  • Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because Defendant PII Auto, LLC maintains a regular and established physical place of business in Southlake, Texas, where infringing activities are alleged to occur.
  • Core Dispute: Plaintiff alleges that Defendant's mobile application for erasing personal data from vehicles infringes six patents related to systems and methods for identifying and providing vehicle-specific data removal procedures.
  • Technical Context: The technology addresses the challenge of securely erasing personally identifiable information from the fragmented and non-standardized computing systems embedded in modern vehicles, such as infotainment and navigation units.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of several patents-in-suit, based on communications with Defendant's affiliated entities in December 2021 and June 2023, which may form the basis for a willfulness claim.

Case Timeline

Date Event
2018-02-20 Earliest Priority Date for all Patents-in-Suit
2021-10-26 U.S. Patent No. 11,157,648 ('648 Patent) Issues
2021-12-01 Plaintiff allegedly notifies Defendant's affiliates of '648 Patent
2022-02-22 U.S. Patent No. 11,256,827 ('827 Patent) Issues
2022-11-08 U.S. Patent No. 11,494,514 ('514 Patent) Issues
2023-03-16 U.S. Patent No. 11,651,105 ('105 Patent) Issues
2023-06-01 Plaintiff allegedly notifies Defendant's affiliates of '105, '514, and '827 Patents
2023-08-03 Alleged knowledge date for '324 Patent
2024-03-19 U.S. Patent No. 11,934,557 ('557 Patent) Issues
2024-05-21 U.S. Patent No. 11,989,324 ('324 Patent) Issues
2026-01-08 Plaintiff's patents allegedly displayed on its website
2026-02-01 Plaintiff allegedly continued conversations with Defendant's affiliates
2026-05-15 Complaint Filed

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

U.S. Patent No. 11,989,324 - "Data Privacy and Security in Vehicles"

Issued May 21, 2024

The Invention Explained

  • Problem Addressed: Modern vehicles store a vast amount of sensitive, personally identifiable information (e.g., contacts, navigation history, garage door codes) across a wide array of non-standardized electronic modules Compl. ¶20 The patent specifications note that the procedures for erasing this information are inconsistent, difficult to find within lengthy user manuals, and vary significantly by vehicle make, model, year, and trim level, creating a significant data privacy risk Compl. ¶20 '648 Patent, col. 1:21-2:20
  • The Patented Solution: The invention provides a method where a user identifies a target vehicle to a computing device (e.g., a mobile app) Compl. Ex. 7, p. 4 The system uses vehicle parameters to obtain a "privacy information removal file" containing tailored, step-by-step instructions for deleting data from that specific vehicle's systems Compl. Ex. 7, p. 6 The system presents these instructions to the user and incorporates a feedback loop to record the user's experience in a database, allowing the system to be refined over time Compl. Ex. 7, p. 9 Compl. Ex. 7, p. 10
  • Technical Importance: The technology provides a standardized, automated solution to the technical problem of data persistence in a highly fragmented ecosystem of automotive electronics, where no such uniform process previously existed Compl. ¶20 Compl. ¶21

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶31
  • Essential elements of Claim 1 include:
    • A method comprising: obtaining, by a computing device, vehicle information associated with a target vehicle.
    • Determining, by the computing device, a plurality of vehicle parameters associated with the target vehicle.
    • Obtaining, by the computing device, a privacy information removal file comprising data associated with a set of candidate in-vehicle devices based on the vehicle parameters.
    • The data includes an instruction set for removing privacy information from at least one candidate in-vehicle device.
    • Presenting the instruction set, wherein the instruction set is a correct instruction set for instructing removal if the candidate device matches the target device.
    • Obtaining user experience feedback associated with the set of candidate in-vehicle devices.
    • Recording the user experience feedback in a database.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent, but this is standard practice.

U.S. Patent No. 11,651,105 - "Data Privacy and Security in Vehicles"

Issued May 16, 2023

The Invention Explained

  • Problem Addressed: As with the '324 Patent, the technology addresses the difficulty and risk associated with erasing personal data from disparate, non-standardized in-vehicle computing systems Compl. ¶20 '648 Patent, col. 1:21-2:20
  • The Patented Solution: The invention is a method for providing vehicle-specific data deletion instructions. A user's computing device obtains information about a target vehicle, which is used to determine vehicle parameters and then obtain a "privacy information removal file" Compl. Ex. 8, p. 7 This file contains instructions for a set of "candidate in-vehicle devices" related to the target vehicle, which are then presented to the user Compl. Ex. 8, p. 9 The system also obtains and records user feedback to a database to improve the system's accuracy Compl. Ex. 8, p. 10 Compl. Ex. 8, p. 11
  • Technical Importance: This technology offers a centralized, dynamic method to overcome the technical fragmentation of in-vehicle data storage, providing a reliable process for data deletion where one did not previously exist Compl. ¶21

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶42
  • Essential elements of Claim 1 include:
    • A method comprising: obtaining, by a user computing device, vehicle information associated with a target vehicle.
    • Determining, by the user computing device, vehicle parameters associated with the target vehicle.
    • Obtaining, by the user computing device, a privacy information removal file with data for a set of candidate in-vehicle devices related to the target vehicle.
    • The data comprises an instruction set for removing privacy information from at least one candidate in-vehicle device.
    • Presenting the instruction set to the user.
    • Obtaining user experience feedback associated with the set of candidate in-vehicle devices.
    • Recording the user experience feedback in a database.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,494,514 - "Data Privacy and Security in Vehicles"

  • Patent Identification: U.S. Patent No. 11494514, "Data Privacy and Security in Vehicles", Issued November 8, 2022 Compl. ¶12
  • Technology Synopsis: The patent describes a method for providing vehicle-specific data deletion instructions. The method involves a user computing device obtaining a Vehicle Identification Number (VIN) for a target vehicle, using it to determine vehicle parameters, obtaining a "privacy information removal file" with tailored instructions, presenting the instructions, and obtaining user feedback Compl. Ex. 9
  • Asserted Claims: At least Claim 1 is asserted Compl. ¶53
  • Accused Features: The PII Auto App is accused of implementing this method by allowing users to input a VIN, receiving tailored data deletion instructions, and providing feedback Compl. ¶54 Compl. Ex. 9

U.S. Patent No. 11,256,827 - "Data Privacy and Security in Vehicles"

  • Patent Identification: U.S. Patent No. 11256827, "Data Privacy and Security in Vehicles", Issued February 22, 2022 Compl. ¶13
  • Technology Synopsis: The patent describes a method where a computing device receives vehicle information, determines parameters, creates a "privacy information removal file" with instructions for candidate devices, and transmits that file to a user's computing device. The method also includes receiving and recording user experience feedback Compl. Ex. 10
  • Asserted Claims: At least Claim 8 is asserted Compl. ¶64
  • Accused Features: The PII Auto App, in conjunction with its backend systems, is accused of receiving vehicle data from a user's device, creating and transmitting a file with instructions, and processing user feedback Compl. ¶65 Compl. Ex. 10

U.S. Patent No. 11,934,557 - "Data Privacy and Security in Vehicles"

  • Patent Identification: U.S. Patent No. 11934557, "Data Privacy and Security in Vehicles", Issued March 19, 2024 Compl. ¶14
  • Technology Synopsis: The patent describes a method executed on a user's computing device. The method involves obtaining an input associated with a target vehicle, using that input to determine vehicle parameters, obtaining a "privacy information removal file" with an instruction set, presenting the instructions, and obtaining a confirmation of the action Compl. Ex. 11
  • Asserted Claims: At least Claim 1 is asserted Compl. ¶75
  • Accused Features: The PII Auto App is accused of performing these steps on the user's device, including obtaining vehicle data, presenting instructions for tasks like "factory reset," and obtaining confirmation that the task is complete Compl. ¶76 Compl. Ex. 11

U.S. Patent No. 11,157,648 - "Data Privacy and Security in Vehicles"

  • Patent Identification: U.S. Patent No. 11157648, "Data Privacy and Security in Vehicles", Issued October 26, 2021 Compl. ¶15
  • Technology Synopsis: The patent describes a vehicle data privacy system with a server communicatively coupled to a user's computing device. The server is configured to receive vehicle information, determine parameters, create and transmit a "privacy information removal file" containing instruction sets for candidate devices, and record user feedback Compl. Ex. 12 '648 Patent, abstract
  • Asserted Claims: At least Claim 1 is asserted Compl. ¶86
  • Accused Features: The PII Auto App and its associated backend server are accused of forming the claimed system, where the app communicates with the server to receive instructions and transmit user feedback Compl. ¶87 Compl. Ex. 12

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is Defendant's "data privacy protection app," referred to as the PII Auto App Compl. ¶23 Compl. ¶43

Functionality and Market Context

  • The PII Auto App is a mobile application designed to erase Personally Identifiable Information (PII) from modern vehicles Compl. ¶4 Compl. ¶22 According to the complaint, a user identifies a target vehicle to the app, for example by scanning a VIN or searching by year, make, and model Compl. Ex. 11, p. 3 The app then provides step-by-step instructions for erasing data from specific in-vehicle systems such as satellite navigation and Bluetooth Compl. Ex. 11, p. 4 A screenshot in the complaint shows the app's main interface for a 2018 Chevrolet Silverado, listing "FACTORY RESET," "SATELLITE NAVIGATION," and "BLUETOOTH" as data removal tasks Compl. Ex. 11, p. 4 The complaint alleges that Defendant markets the app as "the first and only mobile process designed to help erase Personally Identifiable Information from modern vehicles" Compl. ¶22

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,989,324 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method, comprising: obtaining, by a computing device, vehicle information associated with a target vehicle... The PII Auto App, running on a user's mobile phone (a computing device), obtains vehicle information by, for example, having the user scan a VIN or input the vehicle's make, model, and year. ¶32; Ex. 7, p. 4 '648 Patent, col. 9:8-20
determining, by the computing device, a plurality of vehicle parameters associated with the target vehicle... The app determines parameters such as make, model, year, and specific features like "factory reset," "satellite navigation," and "Bluetooth" based on the initial vehicle information. ¶32; Ex. 7, p. 5 '648 Patent, col. 9:41-47
obtaining, by the computing device, a privacy information removal file comprising data associated with a set of candidate in-vehicle devices... The app obtains a file containing instructions for a set of candidate devices (e.g., satellite navigation, Bluetooth) based on the determined vehicle parameters. ¶32; Ex. 7, p. 6 '648 Patent, col. 10:2-10
presenting, by the computing device, the instruction set... wherein the instruction set is a correct instruction set... if the at least one candidate in-vehicle device matches the target in-vehicle device The app presents a correct instruction set for removing data (e.g., from a garage door opener or Bluetooth) if the candidate device (e.g., the specific infotainment system) matches the target vehicle. ¶32; Ex. 7, p. 8 '648 Patent, col. 10:11-20
obtaining, by the computing device, a user experience feedback associated with the set of candidate in-vehicle devices... After an operation, the app obtains feedback from the user, for example, regarding their experience with removing Bluetooth data. ¶32; Ex. 7, p. 9 '648 Patent, col. 10:21-27
recording, by the computing device, the user experience feedback in a database. The app records the user's feedback in a database, as shown in a "PERSONALLY IDENTIFIABLE INFORMATION REMOVAL REPORT". ¶32; Ex. 7, p. 10 '648 Patent, col. 10:28-31

U.S. Patent No. 11,651,105 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A method, comprising: obtaining, by a user computing device, vehicle information associated with a target vehicle... The PII Auto App, operating on a mobile device, obtains vehicle information such as make, model, year, and VIN from the user. ¶43; Ex. 8, p. 5 '648 Patent, col. 9:8-20
determining, by the user computing device, vehicle parameters associated with the target vehicle... Based on the input vehicle information, the app determines vehicle parameters including features like "factory reset," "satellite navigation," and "Bluetooth." ¶43; Ex. 8, p. 6 '648 Patent, col. 9:41-47
obtaining, by the user computing device, a privacy information removal file comprising data associated with a set of candidate in-vehicle devices... The app obtains a file containing instructions for a set of candidate devices (e.g., navigation, Bluetooth) that are related to the target vehicle. ¶43; Ex. 8, p. 7 '648 Patent, col. 10:2-10
presenting, by the user computing device, the instruction set associated with removing privacy information from the at least one candidate in-vehicle device... The app presents the user with step-by-step instructions for performing data removal from the identified candidate devices, such as a factory reset or clearing a garage door opener. ¶43; Ex. 8, p. 9 '648 Patent, col. 10:11-20
obtaining, by the user computing device, a user experience feedback associated with the set of candidate in-vehicle devices... The app prompts the user to provide feedback on their experience after attempting a data removal process, such as for Bluetooth. ¶43; Ex. 8, p. 10 '648 Patent, col. 10:21-27
recording, by the user computing device, the user experience feedback in a database. A "PERSONALLY IDENTIFIABLE INFORMATION REMOVAL REPORT" allegedly shows that the user experience feedback is recorded in a database. ¶43; Ex. 8, p. 11 '648 Patent, col. 10:28-31

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused product's retrieval and display of instructions from a database constitutes "obtaining a privacy information removal file" as recited in the claims. The defense may argue this term implies a discrete, self-contained data object that is created and transmitted, as opposed to simply querying a database for instructional content.
  • Technical Questions: For the '324 patent, a key question will be the interpretation of a "correct instruction set." The claim requires presenting a "correct" set if the candidate device "matches" the target. This raises the evidentiary question of what technical process the accused app uses for this matching and verification, and whether it meets the claim's conditional logic. The complaint's visual evidence shows a confirmation screen after a factory reset is completed, which may be argued to support the "obtaining a confirmation" step in claim 1 of the '557 patent Compl. Ex. 11, p. 9

V. Key Claim Terms for Construction

  • The Term: "privacy information removal file"

  • Context and Importance: This term appears in the independent claims of multiple asserted patents and is central to the infringement theory. Its construction will determine whether the accused process-which the complaint alleges involves retrieving instructions from a server or database-meets the claim limitation. Practitioners may focus on this term because its definition could distinguish between the delivery of a discrete data package versus the dynamic display of information from a remote source.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the system creating and transmitting a "file" that "comprises data associated with a set of candidate in-vehicle devices" (e.g.,'648 Patent, col. 2:48-50). This could be interpreted broadly to cover any collection of data, however formatted or transmitted, that contains the necessary instructions.
    • Evidence for a Narrower Interpretation: The detailed description of creating the file involves discrete steps of querying a database, retrieving instruction sets, sorting them, and adding them to the file (e.g., '648 Patent, col. 17:1-18:2; FIG. 6A-6D). This structured creation process may suggest that a "file" is a specific, organized data object created for a particular query, not just a stream of instructional data.

  • The Term: "candidate in-vehicle devices"

  • Context and Importance: This term defines the universe of data from which the system retrieves instructions. The patents describe a system that can retrieve instructions not only for the exact target vehicle but also for "related" vehicles (e.g., different model years or trims) (e.g.,'648 Patent, col. 3:12-19). The scope of this term is critical because infringement may depend on whether the accused app is shown to consider a set of "candidate" devices or only the single, specific device identified by the user.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims state the set of devices are "related to the target vehicle" '105 Patent, claim 1 This language could support a broad interpretation encompassing any vehicle sharing a make, model, or OEM group.
    • Evidence for a Narrower Interpretation: The specification provides detailed flowcharts for sorting instruction sets from vehicles that are +/- one or two model years, or different models of the same make/year (e.g.,'648 Patent, FIG. 6A-6C). This detailed logic for identifying specific, closely related "candidates" could support a narrower interpretation requiring a more structured relationship than simply being "related."

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is primarily based on allegations that PII Auto's website and marketing materials instruct and encourage its customers (e.g., auto auctions, dealerships) to use the accused app in an infringing manner Compl. ¶35 Compl. ¶36 Contributory infringement is based on the allegation that the accused app is a material part of the invention, not a staple article of commerce, and is especially adapted for infringement Compl. ¶37
  • Willful Infringement: Willfulness is alleged for all asserted patents. The claim is based on alleged pre-suit knowledge of specific patents-in-suit, stemming from communications Plaintiff had with Defendant's "affiliated entities" around December 2021 and June 2023 Compl. ¶25 The complaint also asserts knowledge based on the publication and issuance dates of the patents Compl. ¶39 Compl. ¶50

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

This case appears to center on the specific implementation details of how a mobile application retrieves and presents instructions for erasing vehicle data. The key questions for the court will likely be:

  1. A core issue will be one of definitional scope: can the term "privacy information removal file," which the patents describe as being created and transmitted, be construed to read on the accused product's process of querying a database and displaying instructions to a user?

  2. A second issue will be one of functional correspondence: does the accused app's process for selecting instructions and gathering user ratings perform the specific, multi-step method of identifying, sorting, and presenting information from a set of "candidate in-vehicle devices" and recording "user experience feedback in a database" as required by the claims, or is there a fundamental mismatch in technical operation?

  3. Finally, for specific claims like claim 1 of the '324 patent, a key evidentiary question will be one of conditional logic: what evidence shows that the accused product performs the claimed step of verifying an instruction set is "correct" for a "matching" device before presenting it, as this limitation appears to require a specific verification step not present in other asserted claims?

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