Geographic Location Innovations LLC v. Tajima America Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations, LLC (Texas)
  • Defendant: Tajima America Corp. (New Jersey)
  • Plaintiff’s Counsel: SML AVVOCATI P.C.
• Case Identification: 2:21-cv-02626, C.D. Cal., 03/25/2021
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed a resident of the district and/or has a regular and established place of business within the district where acts of infringement have occurred.
• Core Dispute: Plaintiff alleges that Defendant’s website store locator system infringes a patent related to remotely providing location information and route guidance to a user's device.
• Technical Context: The technology operates in the domain of client-server systems for online mapping and navigation, a commercially significant field for retailers seeking to direct online customers to physical store locations.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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"

The Invention Explained

• Problem Addressed: The patent describes the process of manually inputting destination addresses into then-contemporary GPS devices as inefficient, difficult, and potentially unsafe if attempted while driving. Specific problems included inconsistencies in how different devices recognized addresses and the need to individually program multiple devices for the same destination (’285 Patent, col. 1:43-2:13).
• The Patented Solution: The invention proposes a client-server system to offload the work of finding and entering an address. A user can request a location from a remote server, which then determines the location's coordinates and transmits them directly to the user's "positional information device." The device then uses this data to calculate and display route guidance, automating a previously manual process (’285 Patent, col. 2:32-46, Fig. 4).
• Technical Importance: The claimed invention sought to simplify the user experience for navigation systems by centralizing the address lookup function on a server and pushing data to the user's device, rather than requiring the user to perform the lookup and data entry on the device itself (’285 Patent, col. 2:26-30).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 13 (’285 Patent, Compl. ¶22).
• Essential elements of independent claim 13 include:
  • A server that receives a request for an address, determines the address, and transmits it to a positional information device.
  • A positional information device comprising a location module (to find its own position), a communication module (to receive data from the server), a processing module (to determine route guidance), and a display module.
  • A communications network coupling the server and the device.
  • A specific requirement that the server receives a time and date associated with the request, transmits this time and date with the address to the device, and the device displays the address at that time and date.
• The complaint's phrasing "including at least Claim 13" suggests a reservation of the right to assert other claims, including dependent claims (Compl. ¶22).

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's "store locator system," a feature of its website "https://www.tajimatool.com/store-locator/" (Compl. ¶22).

Functionality and Market Context

• The complaint describes the system as a web-based application that allows users to find nearby retailers of Defendant's products (Compl. ¶23). A user can enter a location or allow the system to detect their current location to search for stores within a specified radius (Compl. ¶24). The system allegedly displays results in a list and on a map, and provides turn-by-turn route guidance to a selected store on the user's device, which the complaint identifies as a computer or smartphone (Compl. ¶¶25, 28-29). This screenshot shows the store locator interface where a user can input a location to begin a search. (Compl. p. 7). Such store locators are a common feature for businesses with physical retail partners, used to convert online interest into in-person sales.

IV. Analysis of Infringement Allegations

Claim Chart Summary

Identified Points of Contention

• Technical Question: A significant technical question arises from the "time and date" limitation. The complaint points to JavaScript code ("gtag('js', new Date());") as evidence (Compl. p. 14). This raises the question of whether this client-side code, which may send data to a third-party analytics server, satisfies the claim requirement that Defendant's server "receives" the time and date. A further critical question is whether the complaint provides evidence that the server then "transmits" this time and date back to the user's device for display, as the claim language explicitly requires.
• Scope Question: The infringement theory depends on whether a user's general-purpose smartphone or computer running a web browser constitutes the claimed "positional information device." The defense may argue for a narrower construction limited to the dedicated GPS hardware described in parts of the patent, questioning whether a web browser displaying remote content can be considered an integrated part of the "device" itself.

V. Key Claim Terms for Construction

• The Term: "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"

• Context and Importance: This limitation is a multi-part requirement that appears to be a focal point of the infringement allegation. Practitioners may focus on this term because the complaint's evidence for it—a line of client-side JavaScript—presents a potential mismatch with the claim language, which requires specific actions by the server (receiving and then re-transmitting). Failure to prove both actions would be fatal to the infringement claim for Claim 13.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue that "receives" does not specify the mechanism and that any system architecture where the server infrastructure is made aware of the request time satisfies the first part of the limitation.
  • Evidence for a Narrower Interpretation: The plain language requires two distinct steps: the server receives the data, and then the server transmits the data. The specification describes a user transmitting a request for an address, and the "server will use computer processing power... to resolve the multiple addresses" and then transmit coordinates to the device (’285 Patent, col. 10:50-55). This description frames the server as the central actor that processes information and sends a resulting data package, potentially supporting a narrower view that the server must actively handle and send the time/date data itself, not merely be a pass-through or have the data sent to an ancillary analytics service.

• The Term: "positional information device"

• Context and Importance: The definition of this term is critical because the accused system is a website running on general-purpose hardware (a smartphone or computer), not necessarily a dedicated navigation unit.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly states that the invention may be applied to "any type of navigation or positional information device including but not limited to a vehicle-mounted device, a GPS receiver coupled to a desktop computer or laptop, etc." (’285 Patent, col. 4:5-8). This language provides strong support for a broad definition that includes smartphones and computers.
  • Evidence for a Narrower Interpretation: A party could argue that the patent's consistent use of the term "GPS device" and its depiction of a self-contained unit (e.g., Fig. 1) imply that the "positional information device" must be a more integrated piece of hardware. This argument would suggest that a standard phone merely accessing a website does not meet the definition of the claimed device, which includes specific, coupled modules for location, communication, and processing.

VI. Other Allegations

• Indirect Infringement: The complaint includes conclusory recitations of contributory and induced infringement (Compl. ¶22). However, it does not plead specific facts to support the requisite knowledge and intent for these claims, such as evidence that Defendant instructs or encourages its users to infringe in a way that would give rise to liability separate from Defendant's own operation of the system.
• Willful Infringement: The complaint does not allege that Defendant had pre-suit knowledge of the ’285 Patent, nor does it plead facts suggesting egregious or reckless behavior that would typically support a claim for willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

• A central issue will be one of evidentiary proof related to a technical function: Can the Plaintiff demonstrate that the accused system performs the specific two-step process required by the "time and date" limitation in Claim 13? The case may turn on whether client-side JavaScript code sending information to an analytics platform satisfies the requirement that Defendant's server both "receives" and then "transmits" the time and date back to the user's device.
• The case also presents a key question of definitional scope: Can the term "positional information device," which the patent at times describes as a "GPS device," be construed to cover a general-purpose smartphone or computer that is simply executing code from a remote website? The resolution will depend on whether the combination of the user's hardware and the accused website's software is found to constitute the integrated system of modules recited in the claim.