Wyoming Technology Licensing LLC v. General Motors LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wyoming Technology Licensing, LLC (Wyoming)
  • Defendant: General Motors LLC (Delaware)
  • Plaintiff's Counsel: DNL Zito
• Case Identification: 1:26-cv-00810, W.D. Tex., 04/01/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established business presence in the district, specifically identifying GM's "Austin Innovation Center" as a hub for software and digital product development.
• Core Dispute: Plaintiff alleges that Defendant's "Super Cruise" advanced driver-assistance system, and specifically its Automatic Lane Change feature, infringes eight U.S. patents related to automatic vehicle control and signaling systems.
• Technical Context: The technology at issue falls within the domain of Advanced Driver-Assistance Systems (ADAS), which automate certain vehicle functions to improve safety and driver convenience.
• Key Procedural History: The complaint asserts a family of eight patents that share a common specification and claim priority to the same 2004 provisional application. Plaintiff notes that many of the asserted patents expired in January 2025 but asserts that it is entitled to recover damages for past infringement within the statutory six-year limitation period.

Case Timeline

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

U.S. Patent No. 7,482,916 - "Automatic Signaling Systems for Vehicles"

The Invention Explained

• Problem Addressed: The patent's background describes that many drivers fail to use exterior turn signals when making lane changes or turns, which increases the risk of accidents Compl. ¶24 '916 Patent, col. 1:35-41 It further notes that prior art systems based on steering wheel angle could be inaccurate, especially when a vehicle is navigating a curved lane Compl. ¶27 '916 Patent, col. 2:1-32
• The Patented Solution: The invention proposes a system that uses a sensor, such as a camera, to monitor the vehicle's environment and detect its position relative to lane boundaries Compl. ¶27 '916 Patent, abstract A processor analyzes the sensor data to determine if the vehicle is making a lane change maneuver and, if so, automatically activates the appropriate turn signal light Compl. ¶27 '916 Patent, col. 3:5-17 This process is designed to operate independently of the steering wheel's turning angle '916 Patent, col. 2:33-44
• Technical Importance: The described approach sought to improve the reliability of automatic signaling systems by grounding activation decisions in external environmental data (lane markings) rather than solely on internal vehicle state data (steering angle), which could be misleading in certain driving situations Compl. ¶25

Key Claims at a Glance

• The complaint asserts at least independent Claim 33 Compl. ¶65
• Claim 33 of the '916 Patent recites the following essential elements for an automatic signaling system:
  • A processor with an input for receiving information and an output coupled to a vehicle's signaling system.
  • The processor is configured to process the information.
  • The processor is configured to automatically activate the turn signal light based on the processed information "before or when a portion of the vehicle reaches a boundary of a lane in which the vehicle is traveling."

U.S. Patent No. 7,986,223 - "Automatic Signaling System for Vehicles"

The Invention Explained

• Problem Addressed: As a continuation of the application that led to the '916 Patent, the '223 Patent addresses the same problems of driver failure to use turn signals and the unreliability of steering-angle-based automatic systems Compl. ¶10 Compl. ¶24
• The Patented Solution: The '223 Patent discloses the same fundamental solution as the '916 Patent: an automated system that uses a sensor to detect lane boundaries and a processor to activate turn signals based on the vehicle's position relative to those boundaries '223 Patent, col. 3:5-17 '223 Patent, abstract The complaint notes that the patents share a common specification Compl. ¶10
• Technical Importance: The technical contribution is consistent with that of the parent '916 Patent, focusing on improving safety and reliability by using external lane-marking data for turn signal activation Compl. ¶25

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 Compl. ¶79
• Claim 1 of the '223 Patent recites the following essential elements for an automatic signaling system:
  • A sensor configured for sensing at least a portion of a lane.
  • A processor coupled to the sensor.
  • The processor is configured to identify a "lane boundary... able to be crossed over by the vehicle" based on a signal from the sensor.
  • The processor is configured to determine information regarding the position of the lane boundary.
  • The processor is configured to "selectively activate" the appropriate turn signal light based on the determined information.

U.S. Patent No. 8,378,805 - "Automatic Signaling System for Vehicles"

• Technology Synopsis: This patent, from the same family, discloses a system for automatically activating a vehicle's turn signal light based on sensor data indicating the vehicle's position relative to its lane, thereby obviating the need for manual activation by the driver Compl. ¶10 Compl. ¶26
• Asserted Claims: At least Claim 13 Compl. ¶93
• Accused Features: The complaint alleges that GM's Super Cruise system, with its Automatic Lane Change feature, infringes by automatically activating the turn signal during a lane change maneuver Compl. ¶61 Compl. ¶95

U.S. Patent No. 9,248,777 - "Automatic Signaling System for Vehicles"

• Technology Synopsis: This patent discloses an automatic signaling system that includes a user control, allowing a driver to selectively place the system into an active (automatic) state or an inactive (manual) state Compl. ¶10 '777 Patent, claim 1
• Asserted Claims: At least Claim 10 Compl. ¶107
• Accused Features: The complaint alleges that the driver-selectable modes of the Super Cruise system meet the user control limitations of the asserted claims Compl. ¶61 Compl. ¶109

U.S. Patent No. 9,505,343 - "Automatic Control Systems for Vehicles"

• Technology Synopsis: This patent claims a control system for a vehicle that includes a lever (such as a turn signal lever) that is operable to turn the automatic control system from an "off state" to an "on state" '343 Patent, claim 1
• Asserted Claims: At least Claim 1 Compl. ¶122
• Accused Features: The infringement allegation centers on the user-interface for activating the Super Cruise system, which allegedly corresponds to the claimed lever for enabling the automatic functionality Compl. ¶61 Compl. ¶124

U.S. Patent No. 10,046,696 - "Automatic Control Systems for Vehicles"

• Technology Synopsis: This patent claims an apparatus with a processor that performs a "statistical analysis" using sensor data to determine a control parameter and which has "machine learning capability" '696 Patent, claim 1
• Asserted Claims: At least Claim 1 Compl. ¶136
• Accused Features: The complaint accuses the Super Cruise system of infringing by using complex data analysis and adaptive features that allegedly meet the "statistical analysis" and "machine learning" claim limitations Compl. ¶61 Compl. ¶138

U.S. Patent No. 10,293,743 - "Automatic Control Systems for Vehicles"

• Technology Synopsis: This patent claims an apparatus that uses a "laser device" to acquire data, which a processing unit then uses to determine a control signal for a component of the car, such as a turn signal '743 Patent, abstract '743 Patent, claim 10
• Asserted Claims: At least Claim 10 Compl. ¶150
• Accused Features: The infringement allegation focuses on the Super Cruise system's use of "LiDAR map data" to perform lane changes, which Plaintiff alleges meets the "laser device" limitation Compl. ¶61 Compl. ¶152

U.S. Patent No. 10,569,700 - "Automatic Control Systems for Vehicles"

• Technology Synopsis: This patent claims a system wherein a processing unit detects an "automatic activation" of a turn signal and is also configured to generate a control signal to "automatically turn off" the turn signal light, for example after a lane change is complete '700 Patent, claim 1
• Asserted Claims: At least Claim 12 Compl. ¶164
• Accused Features: The complaint alleges the Super Cruise system infringes by not only automatically activating the turn signal for a lane change but also automatically deactivating it upon completion of the maneuver Compl. ¶61 Compl. ¶166

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are "Super Cruise" branded advanced hands-free driver assistance systems included in various General Motors vehicle models Compl. ¶61 The complaint specifically identifies the "Automatic Lane Change" feature of this system Compl. ¶61

Functionality and Market Context

• The complaint describes Super Cruise as a system that, when activated, "allows the vehicle to autonomously perform safe lane changes along with a turn signal activation and controlled steering maneuvers" Compl. ¶61 The system allegedly evaluates multiple parameters, including "road curvature obtained from LiDAR map data, lane geometry detected using cameras, vehicle trajectory determined from current speed, vehicle load, prevailing weather conditions, and the behavior of surrounding vehicles" Compl. p. 15, ll. 22-25 Compl. p. 16, ll. 1-2 The complaint provides an extensive list of accused vehicle models, including those from the Buick, Cadillac, Chevrolet, and GMC brands Compl. ¶61 The complaint provides a screenshot describing GM's Austin Innovation Center as a hub for software and digital product development, data analysis, and research Compl. ¶7, Fig. 1

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart exhibits for each asserted patent (e.g., Compl. ¶67; Compl. ¶81), but these exhibits were not provided for this analysis. Therefore, a claim chart summary cannot be constructed. The infringement theory is summarized below based on the narrative allegations in the complaint.

The core of the infringement allegation is that GM's Super Cruise system with Automatic Lane Change practices the technology claimed in the Asserted Patents Compl. ¶67 The system is alleged to use sensors (such as cameras) and other data sources (such as LiDAR map data) to understand the vehicle's position relative to lane boundaries Compl. p. 15, ll. 22-25 Compl. p. 16, l. 1 When an automatic lane change is performed, the system's processor allegedly automatically activates the vehicle's turn signal Compl. ¶61 This functionality is alleged to satisfy the elements of claims such as Claim 33 of the '916 Patent and Claim 1 of the '223 Patent, which recite a system that automatically activates a turn signal based on the vehicle's position relative to a lane boundary Compl. ¶67 Compl. ¶81

• Identified Points of Contention:
  • Scope Questions: The infringement analysis may raise the question of whether the claims, which describe systems for automatic turn signal activation, are properly construed to cover modern, integrated ADAS platforms like Super Cruise. For example, for the '743 Patent, a question for the court will be whether the use of "LiDAR map data" Compl. ¶61 by a processor meets the claim requirement of an "apparatus for use with a car" that comprises a "laser device."
  • Technical Questions: A key factual question will be the precise operational logic and timing of the accused feature. For Claim 33 of the '916 Patent, which requires activation "before or when a portion of the vehicle reaches a boundary of a lane," evidence regarding the exact moment the Super Cruise system initiates the turn signal relative to the physical lane markings will be central to the infringement analysis. Another technical question arises from the '696 Patent, which claims "machine learning capability"; the analysis will require evidence of whether the accused system's adaptive nature rises to the level of machine learning as that term is construed.

V. Key Claim Terms for Construction

• The Term: "automatically activate" (e.g., '916 Patent, Claim 33)

• Context and Importance: This term is central to the infringement analysis across multiple patents. Its construction will determine the requisite level of automation. Practitioners may focus on this term because the Super Cruise "Automatic Lane Change" feature is initiated or "activated" by the driver, after which the maneuver is performed "autonomously" Compl. ¶61 The dispute may turn on whether "automatically activate" refers to the system's independent decision to illuminate the signal based on sensor data, even if the driver first initiates the overall maneuver.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The background of the shared specification criticizes drivers for failing to use signals, suggesting the invention is intended to replace the manual driver action of engaging the turn signal stalk for a specific maneuver '916 Patent, col. 1:35-41 This may support a construction where the system's processor, not the driver, makes the decision to signal.
  • Evidence for a Narrower Interpretation: The specification discloses embodiments with a switch for activating and deactivating the entire automatic system, implying a level of driver oversight '916 Patent, Fig. 9A '916 Patent, col. 9:8-12 This could support a construction where the system is "automatic" once armed by the driver, even if the driver provides the initial command to begin a lane change.

• The Term: "boundary of a lane" (e.g., '916 Patent, Claim 33)

• Context and Importance: The definition of this term is critical because it defines the spatial trigger for the claimed automatic activation. The accused Super Cruise system uses both "lane geometry detected using cameras" and "road curvature obtained from LiDAR map data" (Compl. p. 15, l. 24; Compl. p. 16, l. 1). The dispute will likely involve whether a "boundary" can be a virtual line derived from map data, or if it is limited to a physical, visually-sensed road marking.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language does not specify that the boundary must be physical or visible, which may support a construction covering virtual boundaries derived from map data. The term itself is not explicitly defined, suggesting it could be given its plain and ordinary meaning.
  • Evidence for a Narrower Interpretation: The patent figures consistently depict painted lane markings (items 62, 64 in Fig. 1) as the lane boundaries '916 Patent, Fig. 1 The detailed description focuses heavily on a sensor (like a camera) capturing an "image" of the lane and its boundaries, which suggests the "boundary" is a feature that can be visually imaged '916 Patent, col. 3:35-40

VI. Other Allegations

• Indirect Infringement: The complaint does not allege specific facts to support pre-suit indirect infringement. For each count, it alleges knowledge "at least as of the service of the present complaint" (e.g., Compl. ¶64; Compl. ¶78), which would support a claim for post-suit indirect infringement only.
• Willful Infringement: The complaint does not plead facts supporting pre-suit willfulness. The allegations of knowledge are tied to the date of service of the complaint, which may support a claim for post-suit willful infringement if infringement continues after Defendant becomes aware of the lawsuit.

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

• Definitional Scope: A core issue will be whether the term "boundary of a lane," which is described in the patents in the context of camera-based image analysis of road markings, can be construed to cover virtual lane boundaries derived from "LiDAR map data" as allegedly used by the accused Super Cruise system.
• Technological Congruence: A central question will be one of claim scope versus technological complexity: can the claimed systems, which focus on the specific function of automatically activating a turn signal based on lane position, be read to cover a multifaceted ADAS platform that integrates numerous data sources to execute a complete, autonomous steering and signaling maneuver?
• Element-by-Element Infringement: Given the assertion of eight patents with varied claim language (e.g., requiring a "laser device," "machine learning," or user controls for system activation), a key battleground will be whether the single accused Super Cruise platform can be shown to practice the specific and distinct combination of elements required by each asserted independent claim.