WirelessWerx IP LLC v. Google LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wirelesswerx IP LLC (Texas)
  • Defendant: Google LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:22-cv-01056, W.D. Tex., 10/07/2022
• Venue Allegations: Venue is alleged to be proper based on Defendant’s regular and established places of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s Google Map products infringe a patent related to creating maps in multi-dimensional spaces, such as multi-story buildings.
• Technical Context: The technology addresses limitations of traditional GPS in complex environments by using a network of local nodes to determine a user's precise location, including on different floors of a building.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer. Subsequent to the filing of this complaint, an Inter Partes Review (IPR) proceeding, IPR2023-00850, was instituted against the patent. The IPR concluded with a certificate issued on February 28, 2025, cancelling all claims (1-30) of the patent. This post-filing development presents a significant challenge to the viability of the asserted claims.

Case Timeline

Date	Event
2004-11-05	U.S. Patent No. 8,315,203 Priority Date
2012-11-20	U.S. Patent No. 8,315,203 Issue Date
2022-10-07	Complaint Filing Date
2023-05-12	IPR2023-00850 Filed against U.S. Patent No. 8,315,203
2025-02-28	IPR Certificate Issued Cancelling All Claims (1-30)

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

U.S. Patent No. 8,315,203 - Mapping in a Multi-Dimensional Space

Issued: November 20, 2012 (the “’203 Patent”)

The Invention Explained

• Problem Addressed: The patent describes that conventional GPS-based tracking systems are limited in their ability to provide a precise location within complex structures, such as a building with multiple floors, as they may not be able to distinguish which floor a device is on (’203 Patent, col. 1:41-54).
• The Patented Solution: The invention proposes a system using a plurality of stationary nodes (e.g., Bluetooth transceivers) arranged in a "multi-dimensional sense," such as on different floors of a building. A user's mobile device determines its location by identifying the "most practically near node." This concept is distinguished from the physically closest node; for instance, a device on a second floor would identify a node on the same floor as "most practically near," even if a node on the first floor's ceiling is physically closer in raw distance, thereby resolving vertical ambiguity (’203 Patent, col. 5:61-col. 6:2; col. 6:55-68).
• Technical Importance: The technology aimed to extend the utility of location-based services from outdoor environments to indoor and multi-level spaces where GPS signals may be unavailable or imprecise (’203 Patent, col. 5:29-34).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶16).
• The essential elements of independent claim 1 include:
  • A method for developing a map for a user, using a preconfigured geographical zone containing a plurality of spaced-apart nodes.
  • The nodes are arranged in a "multi-dimensional sense" and placed within a "structure attached to the ground," which is a building with different elevational levels.
  • Data communications are sent between nodes, users, and control stations.
  • The system affects a "multi-dimensional mapping" in three dimensions (x, y, z).
  • The system narrows the plurality of nodes to the "most practically near node to the user," which involves a specific selection process where a node that is physically closer but on a different elevational level is excluded in favor of a different node on the user's same elevational level.
• The complaint reserves the right to assert additional claims (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Google's Map products" (Compl. ¶14).

Functionality and Market Context

• The complaint does not provide a specific technical description of how Google's Map products allegedly function. It identifies the products by category and provides a URL to a "partners" webpage (Compl. ¶14). There are no allegations detailing the specific features, architecture, or algorithms of Google Maps that are accused of practicing the claimed methods.
• The complaint makes no specific allegations regarding the accused products' commercial importance, though the defendant's identity and the product's name imply a significant market presence.

IV. Analysis of Infringement Allegations

The complaint states that an attached claim chart, designated as Exhibit B, describes how claim 1 of the ’203 Patent is infringed (Compl. ¶21). However, this exhibit was not included with the provided complaint. The body of the complaint itself does not contain any substantive factual allegations that map the limitations of claim 1 to specific features or operations of the Accused Products. As such, there is insufficient detail to construct a claim chart or provide a narrative summary of the infringement theory.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "most practically near node"

  • Context and Importance: This term is central to the patent's claimed solution for resolving locational ambiguity in multi-level structures. The infringement analysis will likely depend on whether the accused system performs the specific exclusionary selection process embedded in this term, as opposed to simply identifying the node with the strongest signal or closest proximity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide a standalone lexicographical definition, which might allow for an interpretation closer to a plain and ordinary meaning related to general accessibility or usefulness.
    • Evidence for a Narrower Interpretation: The specification provides a specific, clarifying example: a device on a second floor will select a node on the second floor as "most practically near," even if a node on the first floor is "actually closer in distance" (’203 Patent, col. 6:55-68). Claim 1 itself codifies this by requiring the exclusion of a "physically closer" node on another elevational level in favor of a "different node at the elevational level of the user" (’203 Patent, col. 41:31-37). This evidence strongly supports a narrow construction tied to same-floor or same-level accessibility.

• The Term: "multi-dimensional sense"

  • Context and Importance: This term describes the required arrangement of the nodes and is foundational to the patent's assertion of novelty over conventional two-dimensional mapping systems. Its construction will determine the types of node layouts that fall within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the mapping is affected in a "three-dimensional sense in the x, y, and z axes or coordinates" (’203 Patent, col. 2:5-7), which could be argued to encompass any non-coplanar arrangement of nodes.
    • Evidence for a Narrower Interpretation: The patent consistently frames the invention as a solution to the multi-floor problem. The abstract, summary, and claims repeatedly link the "multi-dimensional sense" to "different elevational levels" and "different floors" of a building (’203 Patent, col. 41:20-27; Abstract). This suggests the term may be construed more narrowly to require an arrangement specifically intended to resolve vertical, or elevational, ambiguity within a structure.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead any specific facts to support a claim of indirect infringement. It contains only a general statement that Defendant "indirectly develops, designs, manufactures, distributes, markets, offers to sell and/or sells infringing products" (Compl. ¶2).
• Willful Infringement: The complaint alleges willfulness on the basis that Defendant "made no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims of the '203 Patent were invalid" (Compl. ¶¶17-18). These are conclusory allegations made without supporting facts, such as allegations of pre-suit knowledge of the patent.

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

• Viability of the Action: The central and likely dispositive issue is the legal status of the patent-in-suit. Given that all asserted claims were cancelled in an Inter Partes Review proceeding that concluded after the complaint was filed, the primary question is whether the lawsuit has any basis to proceed.
• Pleading Sufficiency: Should the case move forward, a threshold legal question will be whether the complaint satisfies the plausibility pleading standards. The complaint’s infringement theory appears to rely entirely on an external exhibit that was not provided, raising the question of whether it contains sufficient factual content on its face to state a claim for relief.
• Claim Scope and Infringement: A key technical question would be one of definitional scope: whether the term "most practically near node," as defined by the patent’s specific exclusionary logic for resolving vertical ambiguity, can be construed to read on the complex, multi-faceted algorithms that a sophisticated commercial product like Google Maps uses for location determination.