DCT

3:22-cv-04807

Traxcell Tech LLC v. Google LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Traxcell Technologies, LLC v. Google LLC, 3:22-cv-04807, N.D. Cal., 12/07/2022
  • Venue Allegations: Venue is alleged based on Defendant Google's principal place of business in Mountain View, California, and its continuous and systematic business contacts within the Northern District of California, including acts of infringement.
  • Core Dispute: Plaintiff alleges that Defendant’s Google Maps service, when used on various mobile devices, infringes a patent directed to a hybrid navigation system that provides both online and offline mapping and uses network-based traffic data to optimize routes.
  • Technical Context: The technology relates to mobile navigation and location-based services, a core feature of modern smartphones and a significant market for application-based advertising and data services.
  • Key Procedural History: The complaint alleges that Google knew or should have known of the patent family at least as of June 5, 2019, when a Google software engineer was deposed in a prior litigation involving a related Traxcell patent in the Eastern District of Texas.

Case Timeline

Date Event
2001-10-04 Earliest Priority Date for U.S. Patent No. 10,820,147
2019-06-05 Deposition of Google software engineer in related litigation
2020-10-27 U.S. Patent No. 10,820,147 Issued
2022-12-07 Plaintiff's Second Amended Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,820,147 - "Mobile wireless device providing off-line and on-line geographic navigation information"

  • Issued: October 27, 2020.

The Invention Explained

  • Problem Addressed: The patent describes a need for a more robust method for providing navigation and location services on mobile devices, which may have intermittent or no connection to a wireless network. (’147 Patent, col. 1:55-68). It also addresses the need to leverage network-side data, such as traffic congestion, to provide optimized routing. (’147 Patent, Abstract).
  • The Patented Solution: The invention is a wireless communication system that combines on-device and network-side processing to provide navigation. A mobile device can operate in an "on-line" mode, communicating with the network, or an "off-line" mode using maps stored locally on the device. (’147 Patent, Abstract). When connected, the device sends its location information to the network; a network processor then analyzes traffic congestion and sends updated, optimized route information back to the device. (’147 Patent, col. 110:29-111:15; Fig. 80). The system also incorporates a "privacy flag" to allow users to control whether their location is tracked by the network. (’147 Patent, col. 23:14-25).
  • Technical Importance: This hybrid architecture aimed to provide the reliability of offline maps with the advanced, real-time functionality of online services, making navigation more seamless and efficient for users moving through areas with variable network coverage. (’147 Patent, col. 2:48-53).

Key Claims at a Glance

  • The complaint asserts claims 1-24, with a detailed analysis provided for independent claim 1. (Compl. ¶13).
  • Independent Claim 1 is a system claim with the following essential elements:
    • A wireless mobile device containing a first radio-frequency (RF) transceiver and a first processor.
    • The first processor is programmed to receive location information and generate a display of the device's location with respect to geographic features based on mapping information stored on the device.
    • The first processor sends user navigation information (as segments) to the network.
    • At least one "other processor outside the network" computes numerical values for the segments based on traffic congestion, updates the navigation information, and sends it back to the mobile device.
    • A wireless communications network containing at least one second RF transceiver and a second processor.
    • The second processor is programmed to acquire the device's location information.
    • The second processor "selectively acquires" this location information dependent on the setting of "preference flags" that permit or prohibit tracking.
  • The complaint reserves the right to assert other claims, including dependent claims. (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

  • The "Accused System" is identified as the combination of the Google Maps application, the Google Maps server-side/cloud infrastructure, and the various mobile devices (e.g., Google Pixel series, Samsung Galaxy series) on which the application runs. (Compl. p. 5).

Functionality and Market Context

  • The complaint alleges that the Accused System provides both online and offline navigation. Users can download maps for offline use, and when connected, the system uses real-time traffic data to provide turn-by-turn directions and suggest faster alternative routes. (Compl. ¶¶ 19, 52, 57).
  • Location is determined using a combination of GPS, Wi-Fi networks, and cellular tower data. (Compl. ¶¶ 24, 27). The complaint provides a screenshot from a Google help page showing how Google Maps "finds your current location" from these sources. (Compl. p. 24, Attachment 8).
  • The system's location accuracy settings (e.g., "High accuracy," "Device only") are alleged to function as the "preference flags" of the patent claims. (Compl. ¶¶ 82, 97).

IV. Analysis of Infringement Allegations

10,820,147 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first radio-frequency transceiver within a wireless mobile communications device and an associated first antenna to which the first radio-frequency transceiver is coupled... The accused mobile devices (e.g., Google Pixel, Samsung Galaxy S20) contain RF transceivers and antennas for communication with cellular and WLAN networks. A teardown image of a Google Pixel 4XL shows an antenna connector. ¶¶ 5-13 col. 20:25-36
a first processor within the wireless mobile communications device...programmed to...generate an indication of a location...with respect to geographic features according to mapping information stored within the wireless mobile communications device, The processor in an accused device, running the Google Maps app, generates a "blue dot" on the screen to show the user's current location relative to streets and landmarks from map data stored on the device (either cached or downloaded for offline use). A screenshot shows this blue dot on a map. ¶¶ 18-25 col. 7:35-49
wherein the first processor further sends the user navigation information to the network as a number of segments, The Google Maps app sends the user's route information to Google's servers to receive traffic information for the segments of the route. ¶51 col. 22:15-26
wherein at least one other processor outside the network updates the user navigation information in conformity with traffic congestion information...and sends the updated user navigation information to the wireless mobile communications device; Google's servers (alleged to be the "other processor") receive route data, analyze real-time traffic, compute updated travel times, and send updated route suggestions back to the Google Maps app on the user's device. A screenshot shows Google Maps displaying a faster route due to traffic. ¶52, ¶58 col. 110:29-111:15
a second processor coupled to the at least one second radio-frequency transceiver programmed to acquire the information indicative of a location of the wireless mobile communications device, Processors within the wireless network (e.g., at cell towers or Wi-Fi access points controlled by carriers like Verizon, or on Google's own location servers) are programmed to determine the device's location using signals from the device's transceiver. ¶¶ 62-70 col. 23:1-13
wherein the second processor selectively acquires the information...dependent on the setting of preference flags...that permits tracking of the wireless mobile communications device, The Android OS on accused devices provides location settings ("High accuracy," "Device only," Location "On/Off"). The complaint alleges these settings function as "preference flags" that control whether network-based services (the "second processor") can acquire the device's location to provide location-based services. A screenshot shows these settings. ¶¶ 82, 87, 97 col. 23:14-25

Identified Points of Contention

  • Divided Infringement: The asserted system claim involves elements controlled by different entities: the end-user (operating the mobile device), Google (providing the app and backend servers), and wireless carriers (operating the network). A central question for the court will be whether Google "directs or controls" the other parties' performance of the claim steps to such a degree that it can be held liable for infringing the entire system, as required by law. The complaint argues Google "controls" the system as a whole and "derives benefits" from all its parts. (Compl. ¶¶ 14, 16).
  • Scope Questions: The claim requires "at least one other processor outside the network." The complaint's infringement theory identifies this as Google's servers. (Compl. ¶52). However, the complaint also repeatedly describes Google's servers as being part of the "Accused System" and the "wireless communication network." This creates a potential contradiction that will require judicial construction of the term "network" and the phrase "outside the network."
  • Technical Questions: A key technical question is whether the general location permission settings in the Android OS (e.g., Location On/Off, High Accuracy mode) are equivalent to the "preference flags" that "permit tracking" as described in the patent. The patent describes a specific "privacy flag" for tracking. (’147 Patent, col. 23:14-25). The court will need to determine if the accused functionality is structurally and functionally the same. The complaint's visual evidence, such as the screenshot of the "Location" settings page, will be central to this inquiry. (Compl. p. 26, Attachment 45).

V. Key Claim Terms for Construction

  • The Term: "preference flags"
  • Context and Importance: This term is critical because it links the device's location tracking to user control, a key feature of the claim. The infringement case hinges on whether the standard location settings in Android meet this limitation. Practitioners may focus on this term because its construction could determine whether Google’s system, which relies on general OS-level permissions, falls within the scope of a claim that appears to describe a more specific, application-level privacy control.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that the system "may apply to allow a user an ‘anonymous’ Privacy Flag," suggesting this is one possible implementation, not the only one. (’147 Patent, col. 23:22-24). This could support an argument that any user-controlled setting that enables or disables location acquisition for a service meets the definition.
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to a specific "privacy flag" that a user can set to "inactive" if the user "intends to not allow his/her location be tracked by the ULDM 904." (’147 Patent, col. 23:14-19). The abstract nature of "preference flags" is not otherwise defined, and this specific embodiment may be used to argue for a narrower construction limited to an explicit tracking permission, rather than a general location services toggle.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by asserting that Google provides instructions on its support website and in user manuals that actively encourage customers to use Google Maps in an infringing manner (e.g., by enabling location services and using traffic-based navigation). (Compl. ¶¶ 20, 108). It also alleges contributory infringement, stating that the Google Maps application and servers are not staple articles of commerce and are specifically designed to be used in the infringing system. (Compl. ¶25).
  • Willful Infringement: Willfulness is alleged based on Google’s purported knowledge of the patent family since at least June 5, 2019. (Compl. ¶27). The complaint cites a deposition of a Google software engineer in a separate lawsuit involving a parent patent, arguing that a "reasonable corporation would investigate the patent family upon notice of its existence." (Compl. ¶21, fn. 4).

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

  • A core issue will be one of liability for a distributed system: Can Traxcell prove that Google "directs or controls" the actions of end-users and third-party wireless carriers to the extent necessary to be held liable for infringing a system claim whose elements it does not wholly own or operate?
  • A key question of claim scope will be whether the general-purpose location permissions in the Android operating system constitute the specific "preference flags" required by the claims, which the patent specification describes as a dedicated "privacy flag" to permit or prohibit tracking.
  • An evidentiary and legal challenge will be to resolve the consistency of the infringement theory: The complaint alleges a key processing step occurs on a processor "outside the network," while simultaneously characterizing Google's servers, which allegedly perform this step, as being part of the accused wireless network. The court's construction of "network" will be decisive for this element.