Cedarwood Ventures Inc v. Google LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cedarwood Ventures, Inc. (Wyoming)
  • Defendant: Google LLC (Delaware)
  • Plaintiff's Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 1:26-cv-01202, W.D. Tex., 05/06/2026
• Venue Allegations: Venue is asserted based on Google's regular and established places of business within the Western District of Texas, including a corporate campus and a retail store in Austin.
• Core Dispute: Plaintiff alleges that Defendant's Google Pixel smartphone devices, when running the Android Auto "Auto-Reply" feature, infringe three patents related to systems for automatically sending customized responses to electronic messages based on a connection to a peripheral device.
• Technical Context: The technology addresses the public safety issue of distracted driving by enabling a smartphone to automatically detect its connection to a contextual peripheral, such as a car's Bluetooth system, and send a pre-configured text message reply without user interaction.
• Key Procedural History: The asserted patents are part of the same family and claim a common priority date. The complaint alleges that Google had pre-suit knowledge of the patents, asserting that attorneys on behalf of Google contacted the inventors approximately 19 months before the complaint was filed. The complaint also highlights numerous forward citations to patents in the family by major technology and automotive companies, suggesting the technology's relevance in the field.

Case Timeline

Date	Event
2013-05-18	Priority Date for '826, '248, and '643 Patents
2018-05-22	U.S. Patent No. 9,979,826 Issued
2020-11-17	U.S. Patent No. 10,841,248 Issued
2022-11-29	U.S. Patent No. 11,516,643 Issued
2024-09-XX	Alleged pre-suit contact with inventors by Google's counsel
2026-05-06	Complaint Filed

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

U.S. Patent No. 9,979,826 - "Connection Specific Selection of Automated Response Messages"

• Patent Identification: U.S. Patent No. 9,979,826 (the "'826 Patent"), issued May 22, 2018. Compl. ¶17 Compl. ¶22

The Invention Explained

• Problem Addressed: The patent's background describes the public safety problem of distracted driving, which has grown with the proliferation of smartphones and text messaging Compl. ¶¶14-15 '826 Patent, col. 1:44-67
• The Patented Solution: The invention provides a system on a handheld computerized device, such as a smartphone, that automatically responds to incoming messages. The system detects when the device is connected to a specific Bluetooth peripheral (e.g., a car's hands-free system) and uses that connection as a trigger to send a pre-assigned, customized automatic reply. This allows different replies to be configured for different contexts, such as driving versus exercising Compl. ¶18 Compl. ¶23 '826 Patent, col. 3:9-27 '826 Patent, Fig. 1
• Technical Importance: The technology provides for context-aware automation, reducing the need for a user to manually activate a "driving mode" and thereby increasing the likelihood that such safety features are used Compl. ¶32

Key Claims at a Glance

• The complaint asserts independent claim 6 Compl. ¶40
• Claim 6 is directed to a "handheld computerized device" comprising:
  • At least one processor, Bluetooth transceiver, graphical user interface, memory, cellular network transceiver, and reply software.
  • Configuration to individually identify a connected Bluetooth peripheral device having an identification code.
  • Software, a GUI, and a processor configured to assign and store a peripheral-linked automatic reply associated with the peripheral's identification code.
  • Configuration so that when the peripheral is connected, the reply software determines the peripheral's identification code, which is "not being a telephone number."
  • Configuration to use the identification code to "select and retrieve" the linked automatic reply from memory.
  • Configuration to use the selected reply to automatically respond to an incoming message from the cellular network transceiver Compl. ¶41

U.S. Patent No. 10,841,248 - "Connection Specific Selection of Automated Response Messages"

• Patent Identification: U.S. Patent No. 10,841,248 (the "'248 Patent"), issued November 17, 2020. Compl. ¶17 Compl. ¶24

The Invention Explained

• Problem Addressed: Like the '826 Patent, the '248 Patent is directed at preventing distractions from electronic messages in various situations, with a particular focus on distracted driving '248 Patent, abstract
• The Patented Solution: The '248 Patent claims a system and method for using a peripheral connection to trigger an automatic reply. A key aspect of the claimed invention is the explicit requirement that the connected peripheral device (which provides the context, e.g., a car's Bluetooth) is "different from a device transmitting said incoming message" (e.g., a cellular tower or another user's phone). This clarifies the roles of the devices in the system '248 Patent, claim 16 '248 Patent, col. 6:25-41
• Technical Importance: This refinement provides definitional clarity to the system's architecture, distinguishing the context-providing device from the communication network device.

Key Claims at a Glance

• The complaint asserts independent method claim 1 and independent device claim 16 Compl. ¶¶48-49
• Claim 16 is directed to a "handheld computerized device" with elements substantially similar to claim 6 of the '826 Patent, but with the additional limitation:
  • "wherein said peripheral device is different from a device transmitting said incoming message" Compl. ¶50

U.S. Patent No. 11,516,643 - "Connection Specific Selection of Automated Response Messages"

• Patent Identification: U.S. Patent No. 11,516,643 (the "'643 Patent"), issued November 29, 2022. Compl. ¶17 Compl. ¶26

Technology Synopsis

The '643 Patent is directed to a handheld device that analyzes the identification code of a connected Bluetooth peripheral to determine if it is a "vehicle associated" device. If it is determined to be vehicle-associated, the device is configured to automatically respond to incoming messages by sending a reply retrieved from memory Compl. ¶58 '643 Patent, abstract This adds a layer of analysis to the context detection.

Asserted Claims

The complaint asserts independent claim 1 Compl. ¶57

Accused Features

The Android Auto "Auto-Reply" feature is alleged to infringe by analyzing the connection to a car's Bluetooth system to determine it is a vehicle context, and then automatically sending replies Compl. ¶34 Compl. ¶36 Compl. ¶58

III. The Accused Instrumentality

Product Identification

The accused products are "all Google Pixel smartphone devices with the Android Auto Auto-Reply feature," with the complaint specifically mentioning "Version 4.7.593824" of Android Auto as an example (the "Accused Products") Compl. ¶34 Compl. ¶35

Functionality and Market Context

The complaint alleges that the "Auto-Reply" feature is designed to enhance driver safety by automatically responding to incoming text messages when Android Auto is active Compl. ¶35 Compl. ¶37 This feature can be automatically activated when a Google Pixel device connects to a car's Bluetooth system, which is the core functionality accused of infringement Compl. ¶36 The complaint provides a schematic overview of such an invention, which depicts a smartphone with an interface for assigning specific auto-reply messages to different peripherals, such as a car speakerphone or a headset Compl. p. 5, Fig. 1

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products directly infringe the asserted patents by implementing the claimed systems and methods. The core of the infringement theory is that the Android Auto "Auto-Reply" feature uses the Bluetooth connection between a Google Pixel phone and a car's audio system to trigger automated text message replies Compl. ¶¶36-37 The complaint references, but does not attach, claim chart exhibits. The narrative allegations from the complaint body are summarized below.

'826 Patent Infringement Allegations

Claim Element (from Independent Claim 6)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A handheld computerized device...comprising...a Bluetooth transceiver...reply software...	Google Pixel devices are handheld computerized devices with the necessary hardware and Android Auto's Auto-Reply software.	¶41	col. 4:51-67
...configured to individually identify at least one Bluetooth peripheral device having a Bluetooth peripheral device identification code...	The Accused Products identify a car's Bluetooth system when connected.	¶41	col. 5:1-6
...software...configured to assign at least one Bluetooth peripheral device linked automatic reply to at least one Bluetooth peripheral device identification code, and store said...reply...	The Android Auto software allows for an auto-reply message to be set for the driving context, which is linked to the car's Bluetooth peripheral.	¶41	col. 6:7-12
...when said at least one Bluetooth peripheral device is...connected...said reply software determines said...identification code, said...code not being a telephone number...	When connected to a car, the Accused Products determine the car's Bluetooth ID, which is not a phone number, to activate the Auto-Reply feature.	¶41	col. 7:42-45
...uses said...identification code to select and retrieve at least one Bluetooth peripheral linked automatic reply...	The Accused Products allegedly use the identification of the car's Bluetooth system to select and retrieve the appropriate auto-reply message.	¶41	col. 6:25-35
...use a selected and retrieved...reply to automatically respond to an incoming message...	When active, the Auto-Reply feature sends an automatic response to incoming text messages.	¶41; ¶37	col. 6:35-41

'248 Patent Infringement Allegations

Claim Element (from Independent Claim 16)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A handheld computerized device...configured to individually identify at least one peripheral device having a peripheral device identification code...	Google Pixel devices with Android Auto identify a connected car Bluetooth system.	¶50	col. 18:35-42
...software...configured to assign at least one peripheral device linked automatic reply to...[the] identification code, and store said...reply...	The Android Auto software allows for an auto-reply message to be set and stored for the driving context.	¶50	col. 18:43-49
...when...connected...said reply software determines said...identification code...and uses said...code to select and retrieve...[a] reply...	When connected to a car's Bluetooth, the Accused Products allegedly use the peripheral's ID to select and activate the auto-reply message.	¶50	col. 18:50-61
...use an automatically selected and retrieved...reply to respond to an incoming message...	The Auto-Reply feature automatically sends a response to incoming texts when active.	¶50; ¶37	col. 18:62-67
...and wherein said peripheral device is different from a device transmitting said incoming message.	The car's Bluetooth system providing the context is a different device from the cellular network equipment transmitting the message.	¶50	col. 18:22-24

Identified Points of Contention:

• Technical Question: The patents describe a system capable of assigning different replies to different peripherals and using the peripheral's ID to "select and retrieve" the correct one. A key question will be whether the accused Android Auto feature performs this specific selection and retrieval, or if it merely uses the presence of any car-like Bluetooth connection as a binary trigger to activate a single, universal driving reply. The complaint's evidence on this point is not detailed.
• Scope Question: For the '643 Patent, a central issue will be how the Accused Products "analyze" a Bluetooth ID code to "determine" that the peripheral is "vehicle associated." The evidence required to prove this specific analytical step, as opposed to simply reacting to a pre-designated device, may be a point of dispute.

V. Key Claim Terms for Construction

• The Term: "select and retrieve"

• Context and Importance: This term is central to the mechanism of infringement for both the '826 and '248 Patents. Its construction will determine whether the claims require a system capable of choosing one reply from a plurality of available replies based on the peripheral's ID, or if the claims can read on a system that simply activates a single default reply upon detecting a specific context. Practitioners may focus on this term because the patent's own figures and description suggest a system with multiple, context-specific replies (e.g., for driving vs. exercising), which may imply a more complex "selection" process than what the Accused Products perform Compl. p. 5, Fig. 1

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be argued to cover any software logic that "selects" a course of action (sending a reply) and "retrieves" the data for that action (the message text) based on an input (the connection status).
  • Evidence for a Narrower Interpretation: The specification describes and illustrates a table associating distinct peripherals with distinct reply messages (e.g., peripheral "GT-I9300" with "Don't text me - I'm driving" and peripheral "$sAtIz$" with "Exercising...talk later") '248 Patent, Fig. 1 '248 Patent, col. 6:7-18 This supports an interpretation that "select and retrieve" requires a choice from among multiple, stored, peripheral-linked options.

• The Term: "Bluetooth peripheral device identification code"

• Context and Importance: This term defines the specific input used to trigger the auto-reply. The dispute may turn on whether this "code" is simply a generic identifier like a MAC address, or if it implies a more specific type of data that the Accused Products may or may not use. The claims' explicit exclusion of "a telephone number" suggests the nature of the code is a relevant limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent states that "Each device, such as a peripheral device will generally...have its own identification code," suggesting it can be a general, unique identifier '248 Patent, col. 5:2-6
  • Evidence for a Narrower Interpretation: The specification discusses using more specific information, such as Bluetooth profile data (e.g., Hands-Free Profile) or metadata transmitted by the peripheral, to identify the device type and context '248 Patent, col. 5:15-32 This could support a narrower definition requiring more than just a hardware address.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Google induces infringement of the method claims of the '248 Patent by providing the Accused Products to end-users, whose use of the products constitutes practice of the claimed methods Compl. ¶49
• Willful Infringement: The complaint alleges willful infringement for all three asserted patents. This allegation is based on alleged pre-suit knowledge, stemming from a claim that Google's counsel contacted the inventors in September 2024, and on knowledge from the filing of the complaint itself Compl. ¶38 Compl. ¶42 Compl. ¶51 Compl. ¶59

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

• A core evidentiary question will be one of technical operation: Does Google's Android Auto "Auto-Reply" feature perform the claimed function of using a peripheral's specific "identification code" to "select and retrieve" a reply from a plurality of options, as depicted in the patents' specifications? Or does it operate as a simpler binary switch, activating a single, default message upon connection to any designated "driving" peripheral?
• A second key question will be one of claim scope: How will the court construe the term "analyze...to determine" in the '643 Patent? The viability of that infringement claim will likely depend on whether simply recognizing a pre-configured Bluetooth device as a "car" meets this analytical requirement, or if a more sophisticated process of deduction based on the code itself is required.
• Finally, a critical issue for damages will be the question of willfulness: The plaintiff's allegation of pre-suit contact by Google's counsel, if substantiated, could strongly support a finding of willful infringement. The facts and circumstances surrounding this alleged 2024 communication will be a significant focus of discovery and may heavily influence the trajectory of the case.