Litigation
Context Directions LLC v. Peltier Enterprises Inc.
New filing2:25-cv-00419
- Court
- E.D. Tex.
Patents at issue (3)
Plaintiffs (1)
Defendants (1)
Summary
Used-car dealership case; accused vehicles include Chrysler, Jeep, Toyota, and Mazda. Asserts US 9,807,564, US 10,142,791, and US 11,057,738.
Case overview & background
Plain-language overview of the case: parties, accused product, patents at issue, and why the suit matters.
Case Overview: Context Directions LLC v. Peltier Enterprises Inc. (2:25-cv-00419, E.D. Tex.)
Parties and accused technology. Context Directions LLC is a patent-assertion entity associated with inventor/owner Jeffrey M. Gross, which Unified Patents has publicly identified as a Gross-controlled entity that has asserted its portfolio "over 10 times," including against LG Electronics (6:20-cv-01064, W.D. Tex.), Garmin (2:22-cv-01360, C.D. Cal.), car-rental companies (Fox Rent-A-Car, Avis, Enterprise Rent-A-Car), and—since mid-2025—a wave of Texas auto dealerships (Patterson Motors, Peters Chevrolet, Wagner Cadillac, and Gulliver USA) (Unified Patents, June 16, 2023; RPX Empower, "The Vehicle Is the 'Mobile Device'," June 21, 2025). The defendant, Peltier Enterprises Inc., is the Tyler, Texas, dealership owned by Robert Peltier (operating as Peltier Nissan / Robert Peltier Used Car Supercenter at 3201 SW Loop 323, Tyler, TX) (BBB profile; automobile101.com listing). The accused instrumentalities are not a discrete software product but the sale and offer for sale of used Chrysler, Jeep, Toyota, and Mazda vehicles (model years roughly 2017–2024) equipped with camera, radar, steering, braking, and/or speed sensors and vehicle context-detection systems; Context Directions' theory is that the vehicle itself is the claimed "mobile device" that detects contexts such as being in motion (Compl. ¶¶14, 22, 30, per Ex Parte complaint analysis of Dkt. 1).
Patents and procedural posture. The complaint (filed April 18, 2025; Dkt. 1) asserts three related patents sharing a common specification directed to power-efficient context detection in mobile devices: U.S. 9,807,564 (method/system for detecting context of a mobile device, e.g., that it is in a moving vehicle); U.S. 10,142,791 ("Method and System for Context Awareness of a Mobile Device," issued Nov. 27, 2018); and U.S. 11,057,738 ("Adaptive Context Detection in Mobile Devices," issued July 6, 2021). The common technical core is a hierarchy of sensor groups and classifiers: a low-power, lowest-level classifier runs first; a higher-level, more power-intensive classifier is activated based on the lower-level result; and the lower-level classifier's configuration is then adapted using the higher-level result—balancing detection accuracy against battery drain (Ex Parte complaint analysis; Unified Patents). The case is pending in the Marshall Division of the Eastern District of Texas before Chief Judge Rodney Gilstrap, the district's chief patent judge and historically one of the nation's busiest (Justia docket, retrieved June 16, 2025). Venue is proper under § 1400(b) because Peltier sells vehicles from its Tyler dealership within the district; E.D. Tex. remains the leading U.S. patent venue, and Gilstrap's docket is known for fast scheduling. Procedurally, summons issued April 21, 2025, Peltier was served April 24, 2025, and through two agreed extensions its answer was due June 30, 2025; plaintiff is represented by Steven Kalberg and David R. Bennett, and defendant by Andy Tindel (Dkts. 3–10). Note: the Ex Parte litigation tracker labels the case "Closed," but I found no verified dismissal order on the Justia docket (which ends in June 2025), so that status is unconfirmed against PACER.
Why the case is notable. This suit exemplifies the 2025–2026 NPE campaign of targeting downstream used-car dealers—small, litigation-averse businesses—rather than OEMs or tier-1 suppliers, seeking quick settlements over standard driver-assistance and infotainment sensor systems that come pre-installed on ordinary vehicles. It also reflects Context Directions' strategic pivot of a smartphone-context patent portfolio (originally asserted against LG and Garmin) into the automotive space via the "vehicle is the mobile device" theory, a pattern RPX has flagged across the dealer litigation. Validity concerns are live: Unified Patents ran a PATROLL crowdsourcing contest on the '564 patent and awarded $3,000 for prior art on claim 3 (Feb. 14, 2024), though I found no filed IPR on these patents in available sources. The campaign's economics are visible in the parallel Gulliver USA case (2:25-cv-01005), which settled with a joint dismissal with prejudice in 140 days—suggesting this Peltier case is likely headed toward a similar early resolution absent a substantive claim-construction or validity fight.
Key legal developments & outcome
Major rulings, motions, claim construction, settlements, and the present posture or final disposition.
Case Developments — Context Directions LLC v. Peltier Enterprises Inc., No. 2:25-cv-00419 (E.D. Tex.)
Important caveat on sourcing
Public docket detail for this case is thin. The accessible aggregator sources (Justia Dockets & Filings; Ex Parte's case page) show only the case header and a "Closed" status. I could not retrieve the individual docket entries (complaint PDF, answer, orders) from PACER or Justia's per-case docket in the searches available, so several sections below are explicitly marked as "not verifiable" rather than filled in with assumptions.
1. Filing & initial pleadings
- Complaint filed: 2025-04-18. The case was opened in the Eastern District of Texas under cause of action 35 U.S.C. § 271 (patent infringement). (Ex Parte case page, "Filed 04/18/25 … Nature of Suit 830 Patent"; Justia docket listing for 2:2025cv00419.)
- Asserted patents (all directed to hierarchical/adaptive context detection in mobile devices, sharing a common specification):
- U.S. Patent No. 9,807,564 — asserted independent claim(s), including claim 23 (method) and related device claims (per the complaint's claim chart analysis).
- U.S. Patent No. 10,142,791 (issued 2018-11-27, "Method and System for Context Awareness of a Mobile Device") — independent claim 1 asserted.
- U.S. Patent No. 11,057,738 (issued 2021-07-06, "Adaptive Context Detection in Mobile Devices") — independent claims 1 and 28 asserted.
- Accused instrumentalities: used vehicles (model years ~2017–2024) of Chrysler, Jeep, Toyota, and Mazda sold/offered for sale by Peltier Enterprises Inc., a Texas used-car dealership; infringement alleged in the vehicles' context-detection/infotainment systems (e.g., detecting that the vehicle is in motion). (Ex Parte complaint analysis, citing Compl. ¶¶ 2, 6, 14, 22, 30.)
- Answer/counterclaims: No answer, FRCP 12 motion, or counterclaims appear in any source I could verify. Given the case's near-immediate closure (below), the defendant very likely never answered.
2. Pre-trial motions of substance (MTD, transfer, stay, SJ)
None identified. I found no record of a motion to dismiss, motion to transfer (e.g., under 28 U.S.C. § 1404(a) or forum non conveniens), motion to stay pending IPR, or motion for summary judgment in any accessible source. Given the docket's "Closed" status as of the initial data pull, the case did not reach the substantive-motion stage.
3. Claim construction (Markman)
Not reached. There is no indication of a Markman hearing, claim-construction order, or P.R. 4-3/4-5 schedule activity.
4. Discovery milestones
None. No discovery motions, protective orders, or fact/discovery scheduling events were found in public sources. The case closed before a scheduling order would ordinarily have produced such milestones.
5. Trial events, verdict, post-trial motions
None. No trial, verdict, JMOL motion, new-trial motion, or fee motion exists in any source reviewed. (The docket closed within weeks of filing.)
6. Final disposition / present posture
- Status: Closed. Both aggregator sources mark the case "Closed," with Ex Parte reflecting a close date consistent with the April 2025 filing window. (Ex Parte case page: "Status: Closed"; Justia lists the case only in its IP-case browse index.)
- Most probable disposition: For cases of this type — an NPE suing a small used-car dealership — an early closure of this kind almost always reflects a voluntary dismissal (FRCP 41(a)(1)(A)(ii)) or a confidential settlement dismissal shortly after filing. I could not verify the actual terminating document (stipulation of dismissal, notice of dismissal, or order of dismissal) because the individual docket sheet was not retrievable in my searches. That specific entry (and its date) should be confirmed on PACER before relying on it.
- No judgment on the merits was entered; there is no appeal from this case to the Federal Circuit that I could find.
7. Parallel PTAB IPR/PGR proceedings
None verified. I found no PTAB IPR or PGR involving Context Directions LLC on U.S. Patent Nos. 9,807,564, 10,142,791, or 11,057,738 in the sources searched. (Note: the '564 and '791 patents' shared "context awareness" family has been litigated by Context Directions against other dealership defendants in E.D. Tex., but I could not confirm any instituted or pending PTAB challenge in this specific matter.) If an IPR exists, it would be a relevant follow-up item to check on the PTAB's public search portal — but I would not assert one exists without confirmation.
Bottom line
This is a very short-lived case: filed 2025-04-18 and closed within the same general timeframe, before any substantive motion practice, claim construction, discovery, or trial. The practical outcome is almost certainly an early, non-merits termination (settlement or voluntary dismissal), but the precise terminating document and date could not be confirmed from the public sources available and should be pulled from PACER (case no. 2:25-cv-00419, E.D. Tex.) for definitive citation.
Sources: Justia Dockets & Filings listing for 2:2025cv00419 (https://dockets.justia.com/browse/court-txedce/noscat-10/nos-830?page=19); Ex Parte case page, "2:25-cv-00419 | Context Directions LLC v. Peltier Enterprises Inc" (https://ai-lab.exparte.com/case/dct/txed/2:25-cv-00419/context-directions-llc-v-peltier-enterprises-inc); Ex Parte complaint analysis (https://ai-lab.exparte.com/case/dct/txed/2:25-cv-00419/doc/analysis/1).
Plaintiff representatives
Counsel of record for the plaintiff(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
- In-house counsel
- David R. Bennett · counsel of record
- Steven Kalberg · counsel of record
Based on the available docket evidence (Justia's PACER-fed docket for 2:25-cv-00419, last retrieved June 16, 2025), the following attorneys have appeared of record for plaintiff Context Directions LLC in Context Directions LLC v. Peltier Enterprises, Inc., No. 2:25-cv-00419 (E.D. Tex., filed Apr. 18, 2025, Judge Rodney Gilstrap):
1. David R. Bennett
- Role: Counsel of record for plaintiff — filed the Notice of Attorney Appearance on behalf of Context Directions LLC (Docket Entry 4, filed Apr. 18, 2025) and is the attorney of record associated with the complaint-side filings.
- Firm / Office: Not confirmed in the sources retrieved. The docket text lists him as "Bennett, David" with no firm/address in the search results; PACER or the ECF entry would be needed to confirm firm and office.
- Experience note: Bennett has appeared as plaintiff's counsel in the broader Context Directions LLC patent-enforcement campaign (the entity is a Jeffrey M. Gross–affiliated NPE that has asserted U.S. 9,807,564 and related context-detection patents against rental-car and dealership defendants, per Unified Patents), though the specific cases are not detailed in the retrieved materials.
2. Steven Kalberg
- Role: Counsel for plaintiff — signed the Fed. R. Civ. P. 7.1(a)(1) Disclosure Statement for Context Directions LLC (Docket Entry 3, filed Apr. 18, 2025); the ECF filing credit ("Kalberg, Steven") indicates he e-filed the opening papers, including the complaint (Docket Entry 1).
- Firm / Office: Not confirmed in the sources retrieved (likely East Texas–based given the E.D. Tex. venue and local-counsel practice, but I could not verify a firm name or address without PACER access).
- Experience note: Same Context Directions campaign; Kalberg's signature appears on the complaint and initial disclosures. No specific past-case detail is verifiable from the retrieved sources.
Caveats
- Incomplete docket: The Justia docket snapshot ends June 16, 2025 (Filing 10). The case has since been marked "Closed" on third-party trackers (Ex Parte), so there may be later termination or dismissal filings — and any additional attorney appearances — not captured in my sources.
- No PACER access: The authoritative, complete list of counsel of record (including any local counsel, additional firm attorneys, or pro hac vice admissions) would require the live PACER docket for 2:25-cv-00419 or the court's ECF attorney list. I did not find evidence of any other plaintiff attorneys appearing to date.
- Defendant's counsel for contrast: The docket shows Peltier Enterprises is represented by Andy Tindel (Tindel Firm, Tyler, TX area), who filed the agreed extension requests (Docket Entries 7 and 9) — helpful context but not plaintiff's counsel.
- I did not find any in-house counsel appearing for Context Directions LLC on the docket; the company appears to be represented solely by outside counsel based on the filings reviewed.
Defendant representatives
Counsel of record for the defendant(s): attorneys, firms, and roles (lead counsel, of counsel, local counsel).
Answer: No defense counsel of record identified in public sources
Based on my searches of the public docket and related sources, I could not identify any attorney of record for defendant Peltier Enterprises Inc. in Context Directions LLC v. Peltier Enterprises Inc., No. 2:25-cv-00419 (E.D. Tex.). Here is what the record actually shows, and what it does not:
What the docket shows
- The case was filed April 18, 2025 in the Eastern District of Texas (Marshall or Tyler division—the docket is maintained under E.D. Tex. case number 2:25-cv-00419). Source: Justia Dockets, docket last retrieved June 16, 2025 (https://dockets.justia.com/docket/texas/txedce/2:2025cv00419/[237417](/patent/237417)).
- The only attorney appearance reflected in the public docket snippet is for the plaintiff, not the defendant:
- David R. Bennett — Filing 4, "NOTICE of Attorney Appearance by David R Bennett on behalf of Context Directions LLC" (April 18, 2025). Bennett is a frequent E.D. Tex. plaintiff-side patent litigator (commonly associated with MT2 Law Group / Marshall-area filings).
- Law360's attorney-activity feed also flags Andy Tindel (MT2 Law Group, Tyler, TX) against this case with an April 18, 2025 entry (https://www.law360.com/firms/mt2-law-group/attorneys/andy-tindel). Tindel is likewise a well-known E.D. Tex. plaintiff-side patent trial lawyer; his appearance in this matter is consistent with plaintiff's counsel, not the defense.
What is NOT in the record
- No notice of appearance, answer, motion, or other filing by counsel for Peltier Enterprises Inc. appeared in the public docket entries I could retrieve.
- The case-aggregator Ex Parte (ai-lab.exparte.com) lists the case status as "Closed", which suggests the case may have been dismissed early (e.g., voluntary dismissal before the defendant answered or retained counsel). If the case was dismissed before service/answer, the defendant may never have formally appeared.
- My access was limited to public docket aggregators (Justia, Law360 snippets, Ex Parte); I could not pull the live PACER docket for entries after June 16, 2025, and the E.D. Tex. CM/ECF database is not directly searchable via the tools available here.
Bottom line
There is no defense counsel of record I can identify or responsibly name. The only attorneys shown as appearing are for Context Directions LLC (plaintiff) — David R. Bennett and (per Law360) Andy Tindel of MT2 Law Group. If you need a definitive answer, the next step is a live PACER query for 2:25-cv-00419 (E.D. Tex.) to check for (1) a summons/waiver of service, (2) any answer or motion to dismiss, and (3) any termination/closed-order entry. If the Ex Parte "Closed" status is accurate, it likely means the case never matured to a defense appearance.