IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`INTELLECTUAL VENTURES II LLC,
`
`v.
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`TESLA, INC.,
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`Plaintiff,
`
`Defendant.
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`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
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`C.A. No. 6:24-cv-00188
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`JURY TRIAL DEMANDED
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Intellectual Ventures II LLC (“Intellectual Ventures” or “Plaintiff”), in their
`
`Complaint of patent infringement against Defendant Tesla, Inc. (“Tesla” or “Defendant”), hereby
`
`alleges as follows:
`
`NOTICE OF RELATED CASE
`
`Intellectual Ventures respectfully informs the Court that the present case involves the
`
`infringement of multiple patents already in suit in the case styled as Intellectual Ventures I LLC,
`
`et al. v. Volvo Car Corporation, et al., Case No. 6:23-cv-00429-ADA (the “429 Case”) and the
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`infringement of multiple patents related to the patents-in-suit in the 429 Case.
`
`Specifically, the following patents asserted in this litigation overlap with the patents
`
`asserted in the 429 Case: United States Patent No. 10,292,138 (“the ’138 Patent”) and United
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`States Patent No. 9,232,158 (“the ’158 Patent”), (collectively “429 Related Patents”).
`
`In this case, Intellectual Ventures asserts two of the same patents that were previously filed
`
`in the Waco Division are currently being litigated in the 429 Case, although on a different set of
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`infringing systems and methods, which will implicate overlapping questions of law and fact. The
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`parties in the 429 Case are in the process of briefing claim construction in anticipation of the Court
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`1
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`in the Waco Division construing claims of each of the 429 Related Patents at a Markman hearing,
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`currently set for May 24, 2024.
`
`NATURE OF THE ACTION
`
`1.
`
`This is a civil action for the infringement of United States Patent No. 7,336,805
`
`(“the ’805 Patent”), United States Patent No. 9,706,500 (“the ’500 Patent”), United States Patent
`
`No. 10,292,138 (“the ’138 Patent”), United States Patent No. 10,952,153 (“the ’153 Patent”),
`
`United States Patent No. 8,898,395 (“the ’395 Patent”), United States Patent No. 10,136,416 (“the
`
`’416 Patent”), United States Patent No. 7,916,180 (“the ’180 Patent”), United States Patent
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`No. 9,232,158 (“the ’158 Patent”), United States Patent No. 7,181,743 (“the ’743 Patent”),
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`U.S. Patent No. 6,894,639 (“the ’639 Patent”), United States Patent No. 11,206,670 (“the ’670
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`Patent”), and United States Patent No. 11,664,889 (“the ’889 Patent”) (collectively, the “Patents-
`
`in-Suit”) under the Patent Laws of the United States, 35 U.S.C. § 1 et seq.
`
`THE PARTIES
`
`Intellectual Ventures
`
`2.
`
`Plaintiff Intellectual Ventures II LLC (“Intellectual Ventures II”) is a Delaware
`
`limited liability company having its principal place of business located at 3150 139th Avenue SE,
`
`Bellevue, Washington 98005.
`
`3.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’805, ’500, ’138, ’153, ’395, ’416, ’180, ’158, ’639, ’670 and ’889 Patents.
`
`4.
`
`Intellectual Ventures II is the exclusive licensee of the ’743 Patent, and holds all
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`substantial rights therein, including the right to grant licenses, to exclude others, and to enforce
`
`and recover past damages for infringement of the ’743 Patent.
`
`2
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`

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`Tesla
`
`5.
`
`Upon information and belief, Defendant Tesla, Inc. is a Delaware corporation with
`
`its principal place of business at 1 Tesla Road, Austin, Texas 78725. Tesla may be served with
`
`process through its registered agent, CT Corporation, at 1999 Bryan Street, Suite 900, Dallas,
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`Texas 75201-3136. Tesla is registered to do business in the State of Texas and has been since at
`
`least 2011. On information and belief, Tesla does business in the State of Texas and the Western
`
`District of Texas.
`
`6.
`
`Upon information and belief, Tesla designs, develops, makes, manufactures, uses,
`
`distributes, imports, provides, markets, offers for sale, and/or sells in the State of Texas and the
`
`Western District of Texas automotive vehicles and components thereof (“Accused Products”) that
`
`infringe the Patents-in-Suit, contribute to the infringement by others, and/or induces others to
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`commit acts of patent infringement in the State of Texas and the Western District of Texas in
`
`connection with the Accused Products.
`
`7.
`
`On information and belief, Tesla has derived substantial revenue from infringing
`
`acts in the Western District of Texas, including from the sale and use of the Accused Products as
`
`described in more detail below.
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`JURISDICTION AND VENUE
`
`8.
`
`This is an action for patent infringement arising under the patent laws of the United
`
`States. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`9.
`
`This Court has personal jurisdiction over Tesla because Tesla conducts business in
`
`and has committed acts of patent infringement, contributed to infringement by others, and/or
`
`induced others to commit acts of patent infringement in this District, the State of Texas, and
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`elsewhere in the United States and has established minimum contacts with this forum state such
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`that the exercise of jurisdiction over Tesla would not offend the traditional notions of fair play and
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`substantial justice. Upon information and belief, Tesla transacts substantial business with entities
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`and individuals in the State of Texas and the Western District of Texas, by, among other things,
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`importing, distributing, offering to sell, and selling products that infringe the Patents-in-Suit,
`
`including the infringing automotive vehicles and components thereof that Tesla purposefully
`
`directs into the State of Texas and this District as alleged herein, as well as by providing service
`
`and support to its customers in this District. Tesla places the accused automotive vehicles and
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`components thereof into the stream of commerce with the knowledge and expectation that they
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`will be sold in the State of Texas, including this District.
`
`10.
`
`Tesla is subject to this Court’s general and specific jurisdiction pursuant to due
`
`process and/or the Texas Long Arm Statute due at least to Tesla’s substantial business in the State
`
`of Texas and this District, including maintaining its principal place of business at 1 Tesla Road,
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`Austin, Texas 78725, through its past infringing activities, because Tesla regularly does and
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`solicits business herein, and/or because Tesla has engaged in persistent conduct and/or has derived
`
`substantial revenues from goods and services provided to customers in the State of Texas and this
`
`District
`
`11.
`
`Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b)-(c) and 1400(b).
`
`For example, venue is proper in this District under 28 U.S.C. § 1400(b) because Tesla maintains
`
`its principal place of business at 1 Tesla Road, Austin, Texas 78725 in this District, and has
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`committed acts of patent infringement in this District and/or have contributed to or induced acts
`
`of patent infringement by others in this District. In addition to its corporate headquarters at 1 Tesla
`
`Road, Austin, Texas 78725, Tesla also maintains several permanent physical places within this
`
`District from which it conducts business relating to the Accused Products. For example, Tesla has
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`4
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`stores and service centers in this District at least at the following locations: 500 E St Elmo Road,
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`Austin, Texas 78745; 12845 Research Boulevard, Austin, Texas 78759; 11600 Century Oaks
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`Terrace, Suite 123, Austin, Texas 78758; 7825 Helen of Troy Drive, El Paso, Texas 79912; 5865
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`E Hwy 290 Fredericksburg, Texas 78624; 23011 IH-10 West, San Antonio, Texas 78257; and
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`8320-8434 Airport Boulevard, San Antonio, Texas 78216.
`
`12.
`
`Tesla is “at home” in this District, see Daimler AG v. Bauman, 571 U.S. 117, 127-
`
`30 (2014), because Tesla has admitted that its principal place of business is in this District. See
`
`Sare v. Tesla, Inc., et al., No. 2:22-cv-00547-JAM-CKD, 2022 WL 2817422, at *2 (E.D. Cal.
`
`July 19, 2022). (“Defendant contends that it officially moved its global headquarters from Palo
`
`Alto, California to Austin, Texas on December 1, 2021, over two months before this action was
`
`filed… Defendant has met its burden of demonstrating through competent evidence that at the time
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`this suit was filed, Tesla’s principal place of business was in Austin, Texas, as that is where its
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`high level officers directed, controlled, and coordinated the corporation’s activities”) (internal
`
`citations omitted). Tesla also manufactures the Accused Products within the Western District of
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`Texas. For example, Tesla manufactures its Model Y cars and Cybertrucks at its Gigafactory Texas
`
`plant located at 1 Tesla Road, Austin, Texas 78725 in the Western District of Texas.1
`
`13.
`
`Tesla placed and/or contributed to placing the Accused Products into the stream of
`
`commerce knowing or understanding that such Accused Products would be imported into, sold,
`
`provided, distributed, and/or used in the United States, including in the Western District of Texas.
`
`14.
`
`The Austin Division is an appropriate venue for this case because, pursuant to Fed.
`
`R. Civ. P. 11(b)(3), Tesla has its headquarters in this division at 1 Tesla Road, Austin, TX 78725
`
`
`1 https://www.tesla.com/giga-texas (“Covering 2,500 acres along the Colorado River with over
`10 million square feet of factory floor, Gigafactory Texas is a U.S. manufacturing hub for Model
`Y and the home of Cybertruck.”) (last accessed April 10, 2024).
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`5
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`and Tesla manufactures in this division the Accused Products, including the Model Y and
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`Cybertruck vehicles.
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`15.
`
`Upon information and belief, in December 2022 and January 2023 Tesla filed plans
`
`with the Texas Department of Licensing and Regulation to begin construction in 2023 of six
`
`additional campuses in Austin, Texas.2 Tesla plans to spend more than $800 million to construct
`
`approximately 1.7 million square feet of additional space at these campuses.3
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`FACTUAL BACKGROUND
`
`16.
`
`Intellectual Ventures Management, LLC (“Intellectual Ventures Management”)
`
`was founded in 2000. Since then, Intellectual Ventures Management has been involved in the
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`business of inventing. Intellectual Ventures Management facilitates invention by inventors and the
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`filing of patent applications for those inventions, collaboration with others to develop and patent
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`inventions, and the acquisition and licensing of patents from individual inventors, universities,
`
`corporations, and other institutions. A significant aspect of Intellectual Ventures Management’s
`
`business is managing the Plaintiff in this case, Intellectual Ventures II.
`
`17.
`
`One of the founders of Intellectual Ventures Management is Nathan Myhrvold, who
`
`worked at Microsoft from 1986 until 2000 in a variety of executive positions, culminating in his
`
`appointment as the company’s first Chief Technology Officer (“CTO”) in 1996. While at
`
`Microsoft, Dr. Myhrvold founded Microsoft Research in 1991 and was one of the world’s foremost
`
`software experts. Between 1986 and 2000, Microsoft became the world’s largest technology
`
`company.
`
`
`2 https://austin.culturemap.com/news/city-life/tesla-s-austin-headquarters-files-for-800-million-
`campus-expansion/ (last accessed April 8, 2024).
`3 Id.
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`6
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`18.
`
`Under Dr. Myhrvold’s leadership, Intellectual Ventures acquired more than 70,000
`
`patents covering many important inventions of the Internet era. Many of these inventions coincided
`
`with Dr. Myhrvold’s successful tenure at Microsoft.
`
`19.
`
`One of the most significant accomplishments of the Internet era is the emergence
`
`of wireless technologies for vehicles. Wireless connectivity systems in vehicles enable
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`communication channels within vehicles as well as with other external networks. Intellectual
`
`Ventures’ Patents-In-Suit provide improvements to wireless communications used in vehicles.
`
`20.
`
`According to its Form 10-K for the year ending December 31, 2022, Tesla asserts:
`
`“We design, develop, manufacture, sell and lease high-performance fully electric vehicles and
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`energy generation and storage systems, and offer services related to our products. We generally
`
`sell our products directly to customers, and continue to grow our customer-facing infrastructure
`
`through a global network of vehicle service centers, Mobile Service, body shops, Supercharger
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`stations and Destination Chargers to accelerate the widespread adoption of our products.”4
`
`21.
`
`Tesla provides several types of wireless communication system solutions and
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`services to its customers. Tesla’s product offerings include but are not limited to Standard
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`Connectivity, Premium Connectivity, and infotainment systems, including connectivity features
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`over Wi-Fi, maps and navigation and music streaming over Bluetooth®.5 With Premium
`
`Connectivity, users have access to all connectivity features over cellular, in addition to Wi-Fi.
`
`Tesla markets and sells these wireless communication system solutions and services in several
`
`Tesla models throughout the world, including in the United States and Texas, as shown below:
`
`
`4 https://www.sec.gov/Archives/edgar/data/1318605/000095017023001409/tsla-
`20221231.htm#business (Tesla, Inc. Form 10-K, p. 4) (last accessed April 10, 2024).
`5 https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
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`7
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`Connectivity
`
`Connectivity is an important part of all Tesla vehicles, further enhancing the driving
`experience by providing access to features that require data usage — including streaming
`music and media,live traffic visualization and more.
`
`All Tesla vehicles come with access to Standard Connectivity. Standard Connectivityis
`included in your vehicle, at no additional cost, for eight years beginning on the first day
`your vehicle was delivered as new by Tesla or the first day it is put into service (for
`example, used as a demonstrator or service vehicle), whichever comesfirst. If you are
`purchasing a used vehicle, you will be notified of how long your vehicle will include
`access to Standard Connectivity. With Standard Connectivity, you have access to most
`connectivity features over Wi-Fi, in addition to basic maps and navigation and music
`streaming over Bluetooth®.
`
`Premium Connectivity provides the ability to access all connectivity features over cellular,
`in addition to Wi-Fi, for the most intuitive and engaging ownership experience. Premium
`Connectivity is currently available as a monthly subscription of $9.99 plus applicable tax
`or as an annual subscription of $99 plus applicable tax and can be purchased at any time
`from your vehicle touchscreen or the Tesla app. Orders of Model S, Model X, ModelY,
`Model 3 and future variants of Cybertruck will receive a Premium Connectivity trial at
`delivery.
`
`If you own a Tesla vehicle for personal use, you can subscribe to Premium Connectivity
`from your vehicle touchscreen or the Tesla app. If you are driving a company vehicle,
`contact your vehicle provider for more information.
`
`
`
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
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`Connectivity Packages
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`Connectivity Packages
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`Standard
`
`Premium
`
`Navigation
`
`vw
`
`Live Traffic Visualization
`
`Sentry Mode - View Live
`Camera
`
`Satellite-View Maps
`
`Video Streaming**
`
`Caraoke*
`
`Music Streaming**
`
`Internet Browser*
`
`vw
`
`v
`
`we
`
`wv
`
`wv
`
`~
`
`wv
`
`vw
`
`Features subject to change and may vary based on hardware configuration
`‘Currently available over Wi-Fi for Standard Connectivity
`"SA paid subscription to streaming services is required to access music and media streaming
`
`For Model S, Model X and Cybertruck with second row display, this includes second row
`in-drive video streaming. Some features, such as Caraoke and video streaming, are not
`supported on some vehicles based on hardware configuration. Review your vehicle
`firmware release notes to confirm feature availability for your vehicle.
`
`
`
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`
`~ Does Standard Connectivity include in-car maps and navigation functionality?
`
`Yes, All vehicles with Standard Connectivity will continue to receive the same core
`maps & navigation functionality as vehicles with Premium Connectivity, including
`traffic-based routing, Trip Planner and Supercharger stall availability. Standard
`Connectivity Is included in your vehicle, at no additional cost, for eight years
`beginning on the first day your vehicle was delivered as new by Tesla or the first
`day it is put into service (for example, used as a demonstrator or service vehicle),
`whichever comes first. If you are purchasing a used vehicle, you will be notified of
`how long your vehicle will include access to Standard Connectivity. Premium
`Connectivity will add satellite-view maps and live traffic visualization.
`
`
`
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
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`What music & media are available with Standard Connectivity?
`
`Standard Connectivity offers Bluetooth® pairing, FM radio, Sirius XM capability in
`North America (for XM-enabled and configured vehicles) and playback from a USB
`drive.
`
`Premium Connectivity is required for in-car streaming music & media over cellular.
`
`A paid subscription to third-party streaming services is required to access music
`and media streaming for both Standard and Premium Connectivity.
`
`
`
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`Ex. 1, https://www.tesla.com/support/connectivity (last accessed April 10, 2024).
`
`Mobile App
`
`The Tesla mobile app allows you to communicate with Model 3 remotely using your iPhone® or Android™
`phone.
`
`
`
`To Use the Mobile App
`
`To set up the Tesla mobile app to communicate with your Model 3:
`1. Download the Tesla mobile app to your phone.
`2. Log in to the Tesla mobile app by entering your Tesla account credentials.
`3. Enable mobile access to your Model 3 by touching Controls > Safety > Allow Mobile Access.
`4. Turn your phone's Bluetooth setting ON and ensure that Bluetooth is turned on within your phone's glabal
`settings for the Tesla mobile app. For example, on your phone, navigate to Settings, choose the Tesla
`mobile app, and ensure the Bluetooth setting is enabled.
`
`Your phone and vehicle must both be actively connected to cellular service or Wi-Fi for the mobile app to
`communicate with your vehicle. Tesla recommends that you always have a functional physical key readily
`available if parking in an area with limited or absent cellular service, such as an indoor parking garage.
`
`
`Ex. 2, https://www.tesla.com/ownersmanual/model3/en_us/GUID-F6E2CD5E-F226-4167-
`Ex. 2, https://www.tesla.com/ownersmanual/model3/en_us/GUID-F6E2CDS5E-F226-4167-
`AC48-BD021D1FFDAB.html (last accessed April 10, 2024).
`AC48-BD021D1FFDAB.html(last accessed April 10, 2024).
`
`Overview
`
`When both your phone and the vehicle have internet service, the Tesla mobile app’s home screen allows
`you to:
`« Lock or unlock your vehicle.
`
`« Enable or disable the heating or air conditioning and monitor the cabin climate.
`
`« Check your vehicle's charging information. Charging details also appear when a charging cable is plugged
`in.
`
`* Open or close the charge port.
`
`
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`
`
`Ex. 2, https://www.tesla.com/ownersmanual/model3/en_us/GUID-F6E2CD5E-F226-4167-
`AC48-BD021D1FFDAB.html (last accessed April 10, 2024).
`
`22.
`
`Tesla also provides an Autopilot feature that it describes as an advanced driver
`
`assistance system to enhance safety and convenience for the driver and to reduce the overall
`
`workload of the driver.6 Each new Tesla vehicle is equipped with multiple external cameras and
`
`powerful vision processing to provide an additional layer of safety. Tesla markets and sells these
`
`autopilot features in Tesla models throughout the world, including in the United States and Texas,
`
`as shown below:
`
`
`6 https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
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`11
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`Autopilot and Full Self-Driving
`Capability
`
`Autopilot is an advanced driver assistance system that enhances safety and convenience
`behind the wheel. When used properly, Autopilot reduces your overall workload as a
`driver. Each new Tesla vehicle is equipped with multiple external cameras and powerful
`vision processing to provide an additional layer of safety. All vehicles built for the North
`American market now use our camera-basedTesla Vision to deliver Autopilot features,
`rather than radar.
`
`Autopilot comes standard on every new Tesla. For owners who took delivery of their
`vehicle without Autopilot, there are multiple packages available for purchase, depending
`
`on when your vehicle was built: Autopilot, Enhanced Autopilot and Full Self-Driving
`Capability.
`
`Autopilot, Enhanced Autopilot and Full Self-Driving Capability are intended for use with a
`fully attentive driver, who has their hands on the wheel andis prepared to take over at
`any moment. While these features are designed to become more capable over time, the
`currently enabled features do not make the vehicle autonomous.
`
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`
`Autopilot
`Autopilot includes the following functionality and features:
`
`* Traffic-Aware Cruise Control: Matches the speed of your vehicle to that of the
`surrounding traffic
`
`* Autosteer: Assists in steering within a clearly markedlane, and uses traffic-aware
`cruise control
`
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`
`Enhanced Autopilot
`In addition to the functionality and features of Autopilot, Enhanced Autopilot also
`includes:
`
`» Navigate on Autopilot: Actively guides your vehicle from a highway’s on-rampto off-
`ramp, including suggesting lane changes, navigating interchanges, automatically
`engaging the turn signal and taking the correct exit.
`
`* Auto Lane Change: Assists in moving to an adjacent lane on the highway when
`Autosteer is engaged.
`
`- Autopark: Helps automatically parallel or perpendicular park your vehicle, with a
`single touch.
`
`«= Summon: Moves your vehicle in and out of a tight space using the mobile app or key.
`
`* Smart Summon: Your vehicle will navigate more complex environments and parking
`spaces, maneuvering around objects as necessary to come find you in a parking lot.
`
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`
`12
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`Full Self-Driving Capability
`Your vehicle will be able to drive itself almost anywhere with minimal driver intervention
`and will continuously improve. In addition to the functionality and features of Autopilot
`and Enhanced Autopilot, Full Self-Driving Capability also includes:
`
`+» Autosteer on City Streets
`
`: Traffic and Stop Sign Control: Identifies stop signs and traffic lights and
`automatically slows your vehicle to a stop on approach, with your active supervision
`
`The currently enabled Autopilot, Enhanced Autopilot and Full Self-Driving features
`require active driver supervision and do not make the vehicle autonomous. Full autonomy
`will be dependent on achieving reliability far in excess of human drivers as demonstrated
`by billions of miles of experience, as well as regulatory approval, which may take longer
`in some jurisdictions. As Tesla’s Autopilot, Enhanced Autopilot and Full Self-Driving
`capabilities evolve, your vehicle will be continuously upgraded through over-the-air
`software updates.
`
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`Ex. 3, https://www.tesla.com/support/autopilot (last accessed April 10, 2024).
`
`Your Model 3 includes the following Autopilot components that actively monitor the surrounding roadway:
`
`o
`
`° 9
`
`6 oO
`
`. A camera is mounted above the rear license plate.
`. Ultrasonic sensors are located in the front and rear bumpers.
`. A camera is mountedin each doorpillar.
`. Three cameras are mounted to the windshield above the rear view mirror.
`. A camera is mounted to each front fender.
`
`OuhwWNa . Radar is mounted behind the front bumper.
`
`Ex. 4, https://www.greencarreports.com/news/1137379_tesla-bets-on-camera-sensing-drops-
`Ex.4, https://Awww.greencarreports.com/news/1137379_tesla-bets-on-camera-sensing-drops-
`
`ultrasonic-sensors-pauses-features (last accessed April 10, 2024).
`ultrasonic-sensors-pauses-features (last accessed April 10, 2024).
`
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`Your Model 3 includes the following components that actively monitor the surrounding area:
`
`
`
`« A camera is mounted abovethe rear license plate.
`
`« A camera is mounted in each door pillar.
`«= Two cameras are mounted to the windshield above the rear view mirror.
`
`« A camera is mounted to each front fender.
`
`Model 3 is also equipped with high precision electronically-assisted braking and steering systems.
`
`
`Ex. 5, https://www.tesla.com/ownersmanual/model3/en_us/GUID-682FF4A7-D083-4C95-925A-
`Ex.5, https://www.tesla.com/ownersmanual/model3/en_us/GUID-682FF4A7-D083-4C95-925A-
`
`5EE3752F4865.html (last accessed April 10, 2024).
`5EE3752F4865.html (last accessed April 10, 2024).
`
`How does Autopilot work?
`Built on a deep neural network, Autopilot uses cameras, ultrasonic sensors and radar to see
`and sense the environment around the car. This robust sensor and camera suite provides
`drivers with an awareness of their surroundings that a driver alone would not otherwise
`have. A powerful onboard computer processes these inputs in a matter of milliseconds to
`help make your driving safer and less stressful.
`
`
`Ex. 6, https://www.tesla.com/support/autopilot#capability-features (last accessed April 10,
`Ex. 6, https://www.tesla.com/support/autopilot#capability-features (last accessed April 10,
`2024).
`2024).
`
`How does Autopilot work?
`
`As of mid-February 2022, all vehicles built for the North American market will
`feature Tesla Vision, which uses multiple cameras and powerful neural net
`processing to see the environment around the vehicle and deliver Autopilot
`features. This camera suite provides occupants with an awareness of their
`surroundings that a driver alone would not otherwise have. A powerful onboard
`computer processes these inputs in a matter of milliseconds to help make driving
`safer and less stressful.
`
`
`Ex. 6, https://www.tesla.com/support/autopilot#capability-features (last accessed April 10,
`Ex. 6, https://www.tesla.com/support/autopilot#capability-features (last accessed April 10,
`2024).
`2024).
`
`14
`14
`
`Ex.1010/ Page 14 of 58
`TESLA, INC.
`
`

`

`
`Source: Compute Solution for Tesla’s Full Self-Driving Computer, Autopilot Hardware, Tesla,
`Feb 2020.
`
`United States Patent No. 7,336,805
`
`THE PATENTS-IN-SUIT
`
`23.
`
`On February 26, 2008, the PTO issued the ’805 Patent, titled “Docking Assistant.”
`
`The ’805 Patent is valid and enforceable. A copy of the ’805 Patent is attached as Exhibit 7.
`
`24.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’805 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’805 Patent.
`
`United States Patent No. 9,706,500
`
`25.
`
`On July 11, 2017, the PTO issued the ’500 Patent, titled “Power Control in a
`
`Wireless Network.” The ’500 Patent is valid and enforceable. A copy of the ’500 Patent is attached
`
`as Exhibit 8.
`
`26.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’500 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’500 Patent.
`
`15
`
`

`

`United States Patent No. 10,292,138
`
`27.
`
`On May 14, 2019, the PTO issued the ’138 Patent, titled “Determining Buffer
`
`Occupancy and Selecting Data for Transmission on a Radio Bearer.” The ’138 Patent is valid and
`
`enforceable. A copy of the ’138 Patent is attached as Exhibit 9.
`
`28.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’138 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’138 Patent.
`
`United States Patent No. 10,952,153
`
`29.
`
`On March 16, 2021, the PTO issued the ’153 Patent, titled “Power Control in a
`
`Wireless Network.” The ’153 Patent is valid and enforceable. A copy of the ’153 Patent is attached
`
`as Exhibit 10.
`
`30.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’153 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’153 Patent.
`
`United States Patent No. 8,898,395
`
`31.
`
`On November 25, 2014, the PTO issued the ’395 Patent, titled “Memory
`
`Management for Cache Consistency.” The ’395 Patent is valid and enforceable. A copy of the ’395
`
`Patent is attached as Exhibit 11.
`
`32.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’395 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’395 Patent.
`
`16
`
`

`

`United States Patent No. 10,136,416
`
`33.
`
`On November 20, 2018, the PTO issued the ’416 Patent, titled “Communicating
`
`on a Shared Channel in a Wireless Network.” The ’416 Patent is valid and enforceable. A copy of
`
`the ’416 Patent is attached as Exhibit 12.
`
`34.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’416 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’416 Patent.
`
`United States Patent No. 7,916,180
`
`35.
`
`On March 29, 2011, the PTO issued the ’180 Patent, titled “Simultaneous Multiple
`
`Field of View Digital Cameras.” The ’180 Patent is valid and enforceable. A copy of the ’180
`
`Patent is attached as Exhibit 13.
`
`36.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’180 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’180 Patent.
`
`United States Patent No. 9,232,158
`
`37.
`
`On January 5, 2016, the PTO issued the ’158 Patent, titled “Large Dynamic Range
`
`Cameras.” The ’158 Patent is valid and enforceable. A copy of the ’158 Patent is attached as
`
`Exhibit 14.
`
`38.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`
`’158 Patent, and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’158 Patent.
`
`17
`
`

`

`United States Patent No. 7,181,743
`
`39.
`
`On February 20, 2007, the PTO issued the ’743 Patent, titled “Resource Allocation
`
`Decision Function for Resource Management Architecture and Corresponding Programs
`
`Therefor.” The ’743 Patent is valid and enforceable. A copy of the ’743 Patent is attached as
`
`Exhibit 15.
`
`40.
`
`Intellectual Ventures II is the exclusive licensee of the ’743 Patent, and holds all
`
`substantial rights therein, including the right to grant licenses, to exclude others, and to enforce
`
`and recover past damages for infringement of the ’743 Patent.
`
`United States Patent No. 6,894,639
`
`41.
`
`On May 17, 2005, the PTO issued the ’639 Patent, titled “Generalized Hebbian
`
`Learning for Principal Component Analysis and Automatic Target Recognition, Systems and
`
`Method.” The ’639 Patent is valid and enforceable. A copy of the ’639 Patent is attached as
`
`Exhibit 16.
`
`42.
`
`Intellectual Ventures II is the owner of all rights, title, and interest in and to the
`