2BCOM, LLC v. FCA US LLC et al DC

2BCom LLC, an NPE that has targeted automakers as well as networking companies with litigation over former Toshiba patents, has received yet more patents from the Japanese conglomerate. The recent assignment, executed earlier this month, could signal a plan to “refresh” a campaign that saw a string of dismissals in late 2020.

NPE litigation in the Automotive market sector during the first four months of 2020 was up nearly threefold from the same time period last year. Most recently, 21ST CENTURY GARAGE LLC and Sisvel International S.A. (d/b/a Sisvel Group) have taken aim at companies operating in the sector, but the year so far has seen new campaigns launched by plaintiffs ranging from relatively recent entrants to patent monetization (e.g., Quartz Auto Technologies, LLC) to established players (e.g., Conversant Wireless Licensing, S.à.r.l.), as well as additional cases filed in existing campaigns waged by inventor-controlled Omega Patents, L.L.C. and frequent plaintiff Leigh M. Rothschild. From wireless connectivity to more traditional automotive technologies, something about 2020 has drawn more litigation to the sector.

Amazon (8:20-cv-00822) has asked the Central District of California for declaratory judgments of noninfringement and invalidity four patents asserted by 2BCom LLC in a litigation campaign begun this past January. The patents broadly relate to wireless communications, with an April 15, 2020 letter, a draft complaint, and other materials attached to Amazon’s complaint indicating that 2BCom has targeted various Amazon eero routers, the Amazon Tap Bluetooth speaker, various Amazon Echo smart speakers, and various Kindle Fire tablets with them. Defendants named in 2BCom’s earlier affirmative complaints include BMW, D-Link, Fiat Chrysler Automobiles (FCA US, Chrysler), Kia Motors, and TP-Link.

2BCom LLC has followed up its first lawsuit, filed against Fiat Chrysler Automobiles (FCA US, Chrysler) in the Eastern District of Michigan, with three additional cases, this time filed in the Central District of California, also accusing D-Link (8:20-cv-00686), Kia Motors (8:20-cv-00676), and TP-Link (8:20-cv-00708) of infringing patents from among those received from Toshiba last fall. Kia Motors is alleged to infringe four of those patents through the provision of the Kia UVO smartphone app over features related to hybrid/electric battery monitoring and certain infotainment systems installed in Kia-branded vehicles, “including the Kia Bluetooth system”, which is allegedly sold “in all models of Kia vehicles” and is targeted over various Bluetooth pairing and connectivity features. D-Link is accused of infringing four patents through certain Wi-Fi routers, with various features related to beamforming and QoS (Quality of Service) at issue; while TP-Link is alleged to infringe five patents through Wi-Fi routers offering similar features, as well as through certain Bluetooth music receivers.

2BCom LLC, a new Delaware entity, has filed its first lawsuits, accusing Fiat Chrysler Automobiles (FCA US, Chrysler) (2:20-cv-10023) of infringing five patents received from Toshiba last fall. The defendant is targeted in 2BCom’s Eastern District of Michigan complaint for the provision of the Uconnect vehicle infotainment systems installed in various Chrysler, Fiat, Dodge, Jeep, Ram, and Alpha Romeo vehicles, with particular focus on external device connectivity and information display.