IP Law Daily, PATENT—Fed. Cir.: Summary judgment of noninfringement affirmed in cruise control system patent suits against Ford and BMW, (Oct 15, 2025)

By Kevin M. Finson, J.D.

Summary judgment decisions of non-infringement were not subject to reversal because the trial court did not err in the claim constructions which led to the non-infringement decisions.

A technology company failed to show any error in a district court’s claim construction regarding adaptive cruise control, the U.S. Court of Appeals for the Federal Circuit has held. The district court’s constructions were consistent with the specification, claim language, and prosecution history. The district court entered partial summary judgment of non-infringement in the patent owner’s suits against automakers Ford and BMW (Carrum Technologies, LLC v. Ford Motor Company, Nos. 24-1183, 24-1480, (Fed. Cir., Oct. 15, 2025)).

Carrum Technologies, LLC (Carrum) was the owner of U.S. Patents Nos. 7,512,475 (the ’475 patent) and 7,925,416 (the ’416 patent) both of which shared a specification and were directed to improving adaptive cruise control performance when a vehicle is in a curve. Carrum brought suit for infringement against Ford Motor Company, as well as BMW, in two separate suits in the federal district court in Wilmington, Delaware, which were consolidated on appeal. The district court entered summary judgment of non-infringement based on claim construction in both suits. Carrum appealed the judgments, challenging that claim construction.

“Controller.” With regard to the Ford case, Carrum challenged the trial court’s construction of the term “a controller” as requiring one or more controllers to carry out each of a list of enumerated controller functions, which included being in communication with a cruise control system, determining when the vehicle was in a turn, reducing the vehicle speed according to position in the turn, and being in communication with a lateral acceleration sensor and an object detection sensor. It was undisputed that the Ford product did not have a single controller which carried out all of these functions, but instead distributed them among several controllers.

The Federal Circuit found that the plain language of the claims required that at least one controller be capable of performing all of the recited functions, so there was no error in the trial court’s finding of non-infringement.

“Change.” With regard to both cases, Carrum argued that the district court erred by construing the term “change in... vehicle lateral acceleration” as requiring two different measurements of a vehicle’s lateral acceleration. Carrum argued the court should have allowed as falling within that term the situation where a change was identified by comparison to a predetermined threshold rather than by comparison to a measurement of the vehicle’s actual lateral acceleration.

The Federal Circuit found that the specification, claim language, and prosecution history all supported the district court’s construction that a comparison to a predetermined value is not the same as a measurement of a change in acceleration.

The appellate court affirmed the trial court’s claim constructions and the summary judgments which flowed therefrom.

The case is Nos. 24-1183, 24-1480.

Judge: Lourie, A.

Attorneys: Taylor James Kelson (Bartlit Beck LLP) for Carrum Technologies, LLC. Justin Weiner (Bush Seyferth PLLC) for Ford Motor Co. Lionel M. Lavenue (Finnegan, Henderson, Farabow, Garrett & Dunner, LLP) for BMW of North America, LLC, BMW Manufacturing Co., LLC, and Bayerische Motoren Werke AG.

Companies: Carrum Technologies, LLC; BMW of North America, LLC; BMW Manufacturing Co., LLC; Bayerische Motoren Werke AG

Cases: Patent TechnologyInternet FedCirNews DelawareNews