Omnitracs, LLC v. Platform Science, Inc.

District Court, S.D. California·Decided December 23, 2024·No. 3:20-cv-00958·Unknown

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 SOUTHERN DISTRICT OF CALIFORNIA 7 8 OMNITRACS, LLC AND XRS Case No.: 20-cv-958-CAB-DDL CORPORATION, 9 ORDER ON PLAINTIFF’S MOTION Plaintiffs, 10 FOR RENEWED JMOL OR NEW v. 11 TRIAL PLATFORM SCIENCE, INC., 12 [Doc. No. 605] Defendant. 13

14 15 I. Background 16 At trial, Plaintiffs Omnitracs, LLC and XRS Corporation (jointly Omnitracs) alleged 17 that defendant Platform Science, Inc. infringed various claims of four patents in this 18 litigation: U.S. Patent No. 6,925,308 claims 1 and 5; U.S. Patent No. 9,262,934 claim 23; 19 U.S. Patent No. 10,255,575 claims 1 and 11; and U.S. Patent No. 8,626,568 claims 11 and 20 23. [Doc. No. 513.]1 Before the case went to the jury, Omnitracs moved for Judgment as 21 a Matter of Law (JMOL), pursuant to Fed.R.Civ.P. 50(a), on its allegations of direct and 22 indirect infringement of each of the asserted claims, a finding of willful infringement of 23 each asserted claim, validity of the asserted claims,2 and its claims for lost profits and a 24 reasonable royalty. [Doc. No. 557.] 25

26 1 Document numbers and page references are to those assigned by CM/ECF for the docket entry. 27 2 Platform Science withdrew its affirmative defenses of invalidity as to the ‘934, ‘575, and ‘568 patents on the first day of trial. [Doc. No. 571, Trial Transcript, at 4-5.] Only the validity of the ‘308 patent was 28 1 The Court denied Omnitracs’ motions for a finding of infringement as to the asserted 2 claims of the ‘308 patent, the ‘934 patent and the ‘575 patent, for a finding of validity of 3 the ‘308 patent, for a finding of willful infringement, and on the claims for damages. Those 4 issues were all sent to the jury. The Court however entered Platform Science’s motion for 5 JMOL [Doc. No. 555] on the asserted claims of the ‘568 patent and removed that patent 6 from the case. 7 The jury returned a verdict finding willful infringement of claims 1 and 5 of the ‘308 8 patent and non-infringement of the claims of the ‘934 patent and the ‘575 patent. The jury 9 found that Platform Science did not establish it claims of invalidity of the ‘308 patent. 10 Finally, the jury awarded Omnitracs lost profits and a reasonable royalty for the 11 infringement of the ‘308 patent. [Doc. No. 564.] 12 II. Omnitracs’ Renewed Motion for JMOL and for New Trial 13 Omnitracs now moves for renewed JMOL under Fed.R.Civ.P. 50(b), or in the 14 alternative a new trial, under Fed.R.Civ.P. 59. [Doc. No. 605.] 15 Omnitracs’ motion for JMOL seeks to set aside the jury’s verdicts of non- 16 infringement of the asserted claims of the ‘934 patent and the asserted claims of ‘575 17 patent. Omnitracs also seeks a new trial, pursuant to Fed.R.Civ.P. 59(1)(a), on the ‘568 18 patent and a new trial on damages. 19 A. Legal Standard for JMOL 20 At the close of evidence in this case, Omnitracs moved pursuant to Fed.R.Civ.P. 21 50(a) for JMOL on its claim of infringement of the asserted claims of the ‘934 and ‘575 22 patents. [Doc. No. 557.] The Court did not grant the motion and submitted these claims 23 to the jury. The jury found that Omnitracs did not prove infringement of these two patents. 24 [Doc. No. 564.] 25 Omnitracs now renews its motion for JMOL pursuant to Fed.R.Civ.P. 50(b). A 26 renewed motion for JMOL is properly granted “if the evidence, construed in the light most 27 favorable to the nonmoving party, permits only one reasonable conclusion, and that 28 conclusion is contrary to the jury’s verdict.” Escriba v. Foster Poultry Farms, Inc., 743 1 F.3d 1236, 1242 (9th Cir. 2014), quoting Pavao v. Pagay, 307 F.3d 915, 918 (9th Cir. 2 2002). A jury’s verdict must be upheld if it is supported by substantial evidence that is 3 adequate to support the jury’s findings, even if contrary findings are also possible. Harper 4 v. City of Los Angeles, 533 F.3d 1010, 1021 (9th Cir. 2008). 5 Reviewing a renewed motion for JMOL requires scrutiny of the entire 6 evidentiary record, but the court must not weigh the evidence, and instead 7 should simply ask whether the nonmoving party has presented sufficient evidence to support the jury’s conclusion. In so doing, the court must draw 8 all reasonable inferences in favor of the nonmoving party and disregard all 9 evidence favorable to the moving party that the jury is not required to believe. 10 11 Escriba, 743 F.3d at 1242-43 (internal cites omitted.) B. Sufficient Evidence Supports the Jury’s Verdicts of Noninfringement. 12 Omnitracs asserted dependent claim 233 of the ‘934 patent which included the 13 following limitation: 14 15 the data acquisition device is in communication with an engine control module of the vehicle and automatically adapts to a detected type of communication 16 protocol employed by the engine control module.

17 [Doc. No. 1-2, at 43, Col. 41:1-5, emphasis added.] 18 Omnitracs also asserted independent claim 1 and dependent claim 11 of the ‘575 19 patent, which included the following limitation: 20 An electronic onboard recorder mounted to a vehicle and comprising: 21 control circuitry to detect one or more protocols and to automatically adapt to the detected one or more protocols to communicate with an engine control module of 22 the vehicle. 23 24 [Doc. No. 1-2, at 108, Col. 22:31-36, emphasis added.] 25 26 27 28 1 The Court construed “automatically” which modifies “adapt” in these claims as “a 2 self-acting response” to the identification of the particular protocol. [Doc. No. 295, at 3- 3 4.] 4 In a vehicle, the Engine Control Module (ECM) collects data from the vehicle such 5 as speed, rpm, odometer readings. [Doc. No. 581, Trial Transcript (“TT”), at 87.] The 6 electronic onboard recorder (EOBR) of the ‘575’s claim 1, or data acquisition device of the 7 ‘934’s claim 23, communicates with the ECM to obtain that vehicle data. ECMs however 8 communicate in more than one language or protocol. [Doc. No. 596, TT, at 72; Doc. No. 9 675, TT, at 66.] For the EOBR to obtain data from the ECM it must be able to read the 10 language or protocol the ECM uses. This required providing an EOBR that can read the 11 particular protocol used by the ECM. [Doc. No. 581, TT, at 89.] 12 Christopher Sekula, an Omnitracs engineer and inventor on the ‘934 and ‘575 13 patents, testified that the patents introduced a feature for automatic adaptation to ECM 14 communication protocols. [Id., at 88.] The claimed EOBR detects the protocol of the 15 vehicle’s ECM and automatically adapts to that protocol thereby eliminating the need to 16 stock different types of EOBRs to communicate with different ECM protocols. “You could 17 plug into Truck A, be able to read the data, or you can take the same box without 18 reprogramming it and put it into Truck B and read the data from that other protocol.” [Id., 19 at 89.] 20 Omnitracs identified the Connected Vehicle Device (CVD) of Platform Science’s 21 telematics system as the EOBR component and contended that the CVD automatically 22 adapts to whatever protocol is detected when connected to an ECM, thereby meeting the 23 ‘934 and ‘575 claim limitation.

Free access — add to your briefcase to read the full text and ask questions with AI

Omnitracs, LLC v. Platform Science, Inc., (S.D. Cal. 2024).

Omnitracs, LLC v. Platform Science, Inc. (Omnitracs, LLC v. Platform Science, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related