DCT
2:19-cv-03211
Geographic Location Innovations LLC v. Condor Outdoor Product Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations, LLC (Texas)
- Defendant: Condor Outdoor Product, Inc. (California)
- Plaintiff’s Counsel: Budo Law, LLP
- Case Identification: 2:19-cv-03211, C.D. Cal., 04/23/2019
- Venue Allegations: Venue is alleged to be proper as Defendant is a resident of the district, has a regular and established place of business in the district, and because alleged acts of infringement occur in the district.
- Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to systems for remotely providing location information and route guidance to a positional device.
- Technical Context: The technology concerns server-assisted navigation, where a user device offloads the task of address lookup and coordinate resolution to a remote server, which then returns the data for routing.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or specific licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | U.S. Patent No. 7,917,285 Priority Date |
| 2011-03-29 | U.S. Patent No. 7,917,285 Issue Date |
| 2019-04-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,917,285 - "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued March 29, 2011
The Invention Explained
- Problem Addressed: The patent identifies several problems with contemporary GPS devices: manual address entry is "extremely difficult or impossible" while driving; different devices have inconsistent user interfaces and address databases; and users with multiple devices must enter the same destination information into each one individually ('285 Patent, col. 1:42-61, col. 2:5-13).
- The Patented Solution: The invention describes a system where a positional information device (e.g., a GPS unit) communicates with a remote server over a network ('285 Patent, Fig. 3). Instead of manual entry on the device, a user can provide a desired address to the server (e.g., through a live operator or a web interface), which then "resolves the address into exact longitude and latitude coordinates" and transmits them back to the user's device for route guidance ('285 Patent, col. 9:42-50). This architecture centralizes the address lookup process, simplifying the user's task.
- Technical Importance: The described system sought to improve the safety and convenience of in-vehicle navigation by offloading complex data entry from the driver to a remote, automated or operator-assisted service ('285 Patent, col. 2:27-30).
Key Claims at a Glance
- The complaint asserts independent claim 13 (Compl. ¶13).
- The essential elements of independent claim 13 are:
- A server configured to receive a request for an address, determine the address, and transmit it to a positional information device.
- A positional information device comprising a locational module, a communication module, a processing module (to determine route guidance), and a display module.
- A communications network coupling the server and the device.
- The server receives a time and date with the location request and transmits the time and date with the determined address to the device, which in turn "displays the determined address at the associated time and date."
- The complaint does not explicitly reserve the right to assert dependent claims but states infringement of "one or more claims, including at least Claim 13" (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant’s "System," comprising its mobile website with a store locator service, and associated hardware and software (Compl. ¶¶13, 16-19).
Functionality and Market Context
- The complaint alleges the System allows a user of a positional information device, such as a smartphone or tablet, to find store locations (Compl. ¶14). When a user accesses the store locator, the System uses the device's GPS hardware to determine the user's location and automatically loads nearby stores (Compl. ¶17). The System can then determine and display route guidance to a selected store on the device's screen (Compl. ¶¶19-20). The screenshot in the complaint shows the store locator interface on a mobile device, including a list of nearby retail locations and an interactive map. (Compl. p. 4).
IV. Analysis of Infringement Allegations
’285 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a server configured to receive a request for an address of at least one location not already stored in the positional information device, to determine the address of the least one location and to transmit the determined address to the positional information device; | Defendant’s server(s) receive a request for a store location from a user's device and transmit the determined store address(es) to that device. | ¶15-16 | col. 8:13-24 |
| the positional information device including a locational information module for determining location information of the positional information device; | A user's device (e.g., smartphone) includes GPS hardware that determines the device's location. The complaint includes a screenshot of a browser prompt requesting location access. (Compl. p. 7). | ¶17 | col. 8:16-18 |
| a communication module for receiving the determined address of the at least one location from the server; | The device's cellular or WiFi components receive the determined store address(es) from the server. | ¶18 | col. 8:18-20 |
| a processing module configured to receive the determined address from the communication module and determine route guidance based on the location of the positional information device and the determined address; | Mapping software and the mobile website on the user's device receive the store address and determine a route from the user's current location. | ¶19 | col. 8:20-23 |
| and a display module for displaying the route guidance; | The screen on the user's device displays the calculated route guidance. The complaint provides a screenshot of a map with a highlighted route. (Compl. p. 8). | ¶20 | col. 8:23-24 |
| a communications network for coupling the positional information device to the server, | A cellular network provides the connection between the user's device and the server(s). | ¶21 | col. 8:25-28 |
| wherein the server receives a time and date associated with the requested at least one location and transmits the associated time and date with the determined address to the positional information device and the positional information device displays the determined address at the associated time and date. | The server allegedly receives a time and date with the request to determine traffic conditions, and the device displays the address and route conditions corresponding to that time. The complaint includes a screenshot showing a "Moderate traffic" indicator. (Compl. p. 9). | ¶22 | col. 10:52-62 |
Identified Points of Contention
- Technical Question: The final "time and date" limitation of claim 13 requires the server to receive a time/date, transmit it back to the device, and for the device to display the address "at the associated time and date." The complaint alleges this is met by using the request time to determine traffic conditions (Compl. ¶22). A potential point of dispute is whether the accused system actually transmits the time/date back to the device for display, or merely uses it on the server-side to calculate traffic, and what evidence supports the allegation.
- Scope Question: A central question may be the proper construction of "displays the determined address at the associated time and date." The patent specification describes a possible embodiment where an itinerary is planned and an address is displayed at a future, pre-set time and date, which may suggest a scheduling function (e.g., '285 Patent, col. 10:52-62). The complaint's theory appears to be that displaying time-sensitive traffic information meets this limitation. The court will need to determine if the claim language covers the display of real-time conditions or is limited to a more explicit scheduling feature.
V. Key Claim Terms for Construction
- The Term: "displays the determined address at the associated time and date"
- Context and Importance: This limitation appears at the end of claim 13 and adds a specific functional requirement beyond simple route guidance. The viability of the infringement claim may depend entirely on whether the accused system’s functionality (displaying traffic conditions) falls within the scope of this phrase. Practitioners may focus on this term because it appears to be the most specific and potentially distinguishing feature of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not explicitly require a future time or a scheduling function. A party could argue that displaying an address with any time-dependent information (like current traffic) constitutes displaying the address "at the associated time." The patent's general goal of providing timely and useful navigation data could be cited to support a construction that includes real-time conditions.
- Evidence for a Narrower Interpretation: The specification discusses a user transmitting "the time and date that each address will be utilized," after which the "GPS device will then display the address at the specified date and time" ('285 Patent, col. 10:52-58). This language may support an argument that the claim requires a specific scheduling function for a future event or a multi-stop itinerary, rather than just using the current time to check traffic.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of contributory and inducement infringement (Compl. ¶13) but does not plead specific facts to support the requisite knowledge and intent beyond alleging Defendant provides the System for use by its customers.
- Willful Infringement: The complaint does not contain a separate count for willful infringement or allege pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may turn on two primary questions:
- A core issue will be one of claim construction: how should the phrase "displays the determined address at the associated time and date" be interpreted? Does it encompass the display of real-time, time-sensitive information like traffic conditions, as alleged by the Plaintiff, or does intrinsic evidence limit it to a more specific scheduling function for future travel, as a defendant might argue?
- A key evidentiary question will be one of technical proof: what evidence will be presented to demonstrate that the accused system’s server actually "receives a time and date... and transmits the associated time and date" back to the user's device, as required by the plain language of Claim 13, and not just that the server uses time/date information internally to calculate route conditions?