DCT
4:14-cv-05298
American Navigation Systems Inc v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: American Navigation Systems, Inc. (Florida)
- Defendant: Samsung Electronics Co., Ltd. (South Korea); Samsung Electronics America, Inc. (New York); Samsung Telecommunications America, LLC (Delaware)
- Plaintiff’s Counsel: Susman Godfrey L.L.P.; Fee & Jeffries, P.A.
- Case Identification: 4:14-cv-05298, M.D. Fla., 05/12/2014
- Venue Allegations: Venue is asserted based on Defendants’ sales of accused products within the Middle District of Florida and Plaintiff’s residence within the district.
- Core Dispute: Plaintiff alleges that Defendant’s smartphones, tablets, and other mobile devices that include the Google Maps application infringe a patent related to hand-held GPS mapping devices.
- Technical Context: The technology concerns portable electronic devices that integrate GPS-derived location data with stored map imagery for real-time navigation.
- Key Procedural History: The patent-in-suit was the subject of two Inter Partes Review (IPR) proceedings (IPR2015-00849, IPR2015-00851) filed after the complaint. An IPR certificate issued on February 6, 2018, confirmed the cancellation of claims 5-10 of the patent. This cancellation post-dates the complaint and may significantly narrow the scope of claims available for assertion in this litigation.
Case Timeline
| Date | Event |
|---|---|
| 1996-11-19 | '347 Patent Priority Date |
| 1999-05-11 | '347 Patent Issued |
| 2009-06-01 | Samsung Galaxy line of devices launched (approx. date) |
| 2014-05-12 | Complaint Filed |
| 2015-03-06 | IPRs filed against '347 Patent |
| 2018-02-06 | IPR Certificate issues, cancelling claims 5-10 |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 5,902,347 - "Hand-Held GPS-Mapping Device"
- Patent Identification: U.S. Patent No. 5,902,347, "Hand-Held GPS-Mapping Device", issued May 11, 1999.
The Invention Explained
- Problem Addressed: The patent identifies two primary issues with hand-held navigation devices of the time: first, conventional LCD screens were "virtually unusable in direct sunlight," and second, the large data size of detailed maps limited the resolution and selection of maps available on portable devices with constrained storage ('347 Patent, col. 1:19-28).
- The Patented Solution: The invention proposes a device with two key improvements. The first is an "optical viewport" display system, which uses a small internal display chip and a lens system within a "light excluding barrel" to present a magnified image to the user, ensuring clarity in all lighting conditions ('347 Patent, col. 1:30-32, col. 2:4-9). The second is a data storage and retrieval method where map data is compressed and organized into "tiles," allowing the device to efficiently access and display only the necessary portion of a map for panning and zooming without decompressing the entire file ('347 Patent, col. 1:32-35, col. 4:12-24).
- Technical Importance: The invention sought to solve critical usability and performance bottlenecks that hindered the adoption of portable digital mapping by improving screen visibility and enabling the use of high-resolution maps on memory-constrained devices ('347 Patent, col. 1:29-35).
Key Claims at a Glance
- The complaint does not specify which claims are asserted, alleging infringement of the patent generally (Compl. ¶18). The patent contains three independent claims: 1, 5, and 11. However, claims 5-10 have been cancelled by an IPR certificate, leaving claims 1 and 11 as the likely basis for the suit ('347 Patent IPR Certificate, p. 2).
- Independent Claim 1: A device for personal mapping and navigation, comprising:
- a case
- a digital computer mounted in the case
- a location receiver unit
- an image storage unit
- a display unit having an "optical viewport assembly" which includes a "light excluding barrel," a "solid-states video display chip," a "viewing aperture," and a "lens system" to present an "enlarged version of the image"
- a computer program to control the device and display the user's location on the map image
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are Samsung's "smartphones, phablets, tablets, and Chromebooks," including a lengthy list of specific models from the Galaxy line, that include the Google Maps application (Compl. ¶¶15, 18).
Functionality and Market Context
The complaint alleges that these devices use GPS technology to determine a user's location and the Google Maps application to provide a visual report of that location on a map (Compl. ¶¶8-9, 15). The ability to perform this function is alleged to account for "much of the value of those devices," with the complaint citing a 2013 survey that found Google Maps to be a highly popular application (Compl. ¶16).
IV. Analysis of Infringement Allegations
The complaint does not contain a claim chart or detailed infringement contentions. The following chart summarizes a potential infringement theory for Claim 1 based on the general allegations against the accused Samsung devices.
'347 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a case | The physical housing of the Samsung smartphones and tablets. | ¶18 | col. 5:14 |
| a digital computer mounted in the case | The processor(s) contained within the Samsung devices. | ¶18 | col. 5:15 |
| a location receiver unit associated with the case and adapted to provide user location information to the computer | The GPS receiver integrated into the Samsung devices. | ¶15 | col. 5:16-18 |
| an image storage unit adapted to store image data | The internal non-volatile memory (e.g., flash storage) of the Samsung devices. | ¶15 | col. 5:19-20 |
| a display unit...having an optical viewport assembly including a light excluding barrel, a solid-states video display chip...a viewing aperture...and a lens system...to present an enlarged version of the image | The complaint alleges infringement by devices with standard direct-view screens (e.g., AMOLED), which would need to be construed as meeting these limitations. | ¶¶15, 18 | col. 5:21-30 |
| a computer program adapted to control the computer...to present the user location information and the image data to the display unit | The Android operating system in conjunction with the Google Maps application. | ¶¶15, 18 | col. 5:31-38 |
No probative visual evidence provided in complaint.
Identified Points of Contention
- Scope Questions: A central dispute will concern the "optical viewport assembly" limitation in claims 1 and 11. The core question is whether a conventional, direct-view smartphone screen can be construed as an "optical viewport assembly" that includes a "light excluding barrel" and a "lens system" as described in the patent. The patent specification appears to describe an enclosed, viewfinder-like apparatus distinct from a modern smartphone display ('347 Patent, col. 2:63-67, Fig. 3).
- Technical Questions: What evidence will be presented to suggest that a standard smartphone display performs the functions of the claimed "lens system" to present an "enlarged version of the image"? The patent describes physical lenses expanding an image from a small chip, a mechanically different operation from how a direct-view screen renders pixels ('347 Patent, col. 2:4-9).
V. Key Claim Terms for Construction
- The Term: "optical viewport assembly"
Context and Importance
This term is the lynchpin of independent claims 1 and 11. The infringement case appears to depend on this term being construed broadly enough to read on a standard smartphone display. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of evidence supporting a broader interpretation. A party might argue the term should be viewed functionally as any system that presents a visual map to a user, though the claim language is highly specific.
- Evidence for a Narrower Interpretation: The specification provides substantial evidence for a narrow construction, describing the assembly as taking "a small (nominally 18 mm diagonal) LCD or equivalent display and expand[ing] the image such that it appears to the user as a full-size...computer display" ('347 Patent, col. 2:4-8). It also describes a "rubber bellows similar in nature to a camera light shield" to reduce external light and a "system of plastic, polycarbonate, or glass lenses" ('347 Patent, col. 2:63-67).
VI. Other Allegations
Indirect Infringement
The complaint does not provide sufficient detail for analysis of indirect infringement. It does not plead specific facts to support the knowledge and intent elements required for induced infringement, nor does it allege facts related to contributory infringement.
Willful Infringement
The complaint does not contain an explicit allegation of willful infringement or plead facts suggesting Defendants had pre-suit knowledge of the '347 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "optical viewport assembly", which the patent describes as a specific, enclosed, magnifying optical apparatus, be construed to cover the open, direct-view screen of a modern smartphone? The outcome of this claim construction battle will likely determine the viability of infringement contentions for the remaining asserted claims.
- A second key question is one of case strategy and viability: following the IPR cancellation of claims directed at the potentially more applicable data-tiling and software methods (claims 5-10), can the Plaintiff's case succeed by relying solely on hardware-focused claims (1 and 11) that appear to describe a physical device structure that is arguably absent from the accused products?