ITC Institutes 337 Complaint Accusing Toyota Vehicles of Infringing Infotainment Chip Patents

On Thursday, June 7th, the U.S. International Trade Commission (ITC) announced that it was instituting a Section 337 patent infringement investigation of automobile infotainment systems being imported into the U.S. based on infringement claims asserted by major semiconductor maker Broadcom. Broadcom is alleging that a group of Japanese automakers and tech companies are infringing infotainment chip patents, including Toyota, Panasonic and Denso Ten, relating to the sale of rear seat entertainment units for displaying information or entertainment, as well as cameras and other processing components used in those units and the automobiles containing such units.

In the original complaint filed by Broadcom with the ITC back on May 7th, the chipmaker is asserting a series of six patents, including:

  • U.S. Patent No. 6937187, titled Method and Apparatus for Forming a Dynamic Model to Locate Position of a Satellite Receiver. Issued in August 2005, it covers a method of estimating a plurality of states associated with a satellite signal receiver, including a time tag error state which relates a local time associated with the receiver and an absolute time associated with a plurality of satellite signals; and forming a dynamic model that computes the position of the satellite receiver.
  • U.S. Patent No. 8902104, titled Method and Apparatus for Combining Measurements and Determining Clock Offsets Between Different Satellite Positioning Systems. Issued in December 2014, it claims a method for determining a position of a mobile receiver using multiple satellite positioning systems while accounting for differences in system times used by each system.
  • U.S. Patent No. 7512752, titled Systems, Methods, and Apparatus for Pixel Fetch Request Interface. Issued in March 2009, it claims a memory access unit for accessing data for a module, the unit having an output port for providing access requests for lists of addresses in a memory over a link to a memory controller; and a queue for queuing the access requests.
  • U.S. Patent No. 7530027, titled Graphics Display System with Graphics Window Control Mechanism. Issued in May 2009, it claims a method of processing graphics images in a display engine for display by organizing graphics images into windows in which the images appear on a screen, obtaining data describing the windows, sorting the data according to the depth of the window on the screen, transferring graphics images from memory and blending the graphics images.
  • U.S. Patent No. 8284844, titled Video Decoding System Supporting Multiple Standards. Issued in October 2012, it covers a digital media decoding system including a processor and a hardware accelerator which provide an efficient and cost-effective to accommodate a variety of encoded bitstream formats for digital video decoders.
  • U.S. Patent No. 7437583, titled Method and System for Flexible Clock Gating Control. It claims a method for distributing clock signals within an electronic device which provides more flexible clock gating control for integrated circuits.

Broadcom’s Section 337 complaint notes that the six asserted patents cover three different fields of technology. The ‘187 and ‘104 patents cover valuable technologies in the field of Global Navigation Satellite System (GNSS) geopositioning systems. The ‘844 and ‘027 patents cover video and graphics processing technologies, and the ‘844 and ‘583 patents cover power and memory management tech. Broadcom alleges that these patents have been infringed upon by the sale of infotainment systems which have been incorporated into automobiles and include infotainment application processors, Global Positioning System (GPS) receivers and allow users to perform tasks like navigation, communications and video playing.

Among the products which Broadcom accuses of infringing upon its patents are Toyota’s Prius automobiles as well as navigation systems and receivers incorporated into certain of Toyota’s Camry, Sienna, Highlander and Corolla vehicles. Allegedly infringing products which have been produced by either Panasonic or Denso Ten include head units incorporated into Toyota navigation units.

At least one of the patents asserted by Broadcom in this Section 337 action has survived an inter partes reexamination proceeding. Broadcom attached a reexamination certificate for the ‘187 patent, noting that this patent survived the reexamination proceeding which concluded in May 2012 when all claims were confirmed as patentable without any amendments.

Along with Toyota, Panasonic and Denso Ten, Broadcom also lists Japanese electronics makers Renesas and JRC as respondents in the Section 337 patent infringement action. Broadcom alleges that mobile application processors produced by Renesas and GPS receivers produced by JRC, both of which are incorporated into Denso Ten head units, infringe upon Broadcom’s asserted patents.

On May 21st, respondent Renesas filed an answer to Broadcom’s ITC complaint. The answer makes notice of Renesas’ contributions to the U.S. economy from domestic operations within the country, including the employment of 1,000 people in the U.S. and investing hundreds of millions of dollars into research and development during 2017; Renesas also notes its acquisition of U.S. semiconductor company of Intersil which it purchased in February 2017. Renesas argues that Broadcom should not be granted an exclusion order because the accused automotive system and products cannot be replaced simply by sourcing from another supplier, it would threaten the jobs of workers employed in the U.S. domestic production of Toyota vehicles and it would result in significant harm to public safety because the accused products enable critical advanced safety features such as advanced emergency braking, collision avoidance and lane assist technologies.

Prior to the ITC’s decision to institute the Section 337 investigation, it also received responses from both the Alliance of Automobile Manufacturers and Global Automakers as well as U.S. chip supplier Texas Instruments. The Global Automakers Alliance argues that Broadcom has failed to show that consumers are willing to divert their purchase of potentially-barred Toyota vehicles to other automakers given that automobiles are expensive purchases which are carefully considered and often involve decisions based on brand loyalty. Further, the Alliance argues that the exclusion of an entire vehicle based on computer chip-level components runs counter to precedence set by both the ITC and the Court of Appeals for the Federal Circuit. In Texas Instruments’ filing, it notes that Broadcom identified one of its infotainment application processors in its description of a potentially infringing navigation system kit. TI argues against Broadcom receiving an exclusion order from the ITC as it would exclude more than half of the U.S. hybrid car market. TI, like the Alliance, also argued that Broadcom failed to disclose the potential public safety concerns that would arise from the exclusion of chip components vital to automotive safety features.


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