DCT
1:18-cv-00308
Location Based Services LLC v. Cobra Electronics Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Location Based Services, LLC (Texas)
- Defendant: Cobra Electronics Corporation (Delaware)
- Plaintiff’s Counsel: Bayard, P.A.; Ni Wang & Massand, PLLC
- Case Identification: 1:18-cv-00308, D. Del., 02/23/2018
- Venue Allegations: Venue is alleged to be proper based on Defendant being a Delaware corporation.
- Core Dispute: Plaintiff alleges that Defendant’s Drive HD Player software, used for managing dashcam video, infringes a patent related to interactive systems for mapping images.
- Technical Context: The technology concerns the integration of digital media (images or video) with geographic map data and interactive timelines, a common feature in modern geotagging and dashcam applications.
- Key Procedural History: The complaint notes that the patent was filed in 2005, before hardware with the necessary capabilities, such as cameras with built-in GPS, became widely available to consumers in 2008, suggesting the invention was unconventional for its time.
Case Timeline
| Date | Event |
|---|---|
| 2005-02-15 | U.S. Patent No. 8,311,733 Priority Date |
| 2008-08-01 | Alleged release date of first consumer GPS-enabled camera |
| 2012-11-13 | U.S. Patent No. 8,311,733 Issue Date |
| 2018-02-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- U.S. Patent No. 8,311,733, “Interactive Key Frame Image Mapping System and Method,” issued November 13, 2012
- The Invention Explained:
- Problem Addressed: The patent addresses the need for a more integrated and intuitive way to browse geographically-tagged images. Prior art systems are implicitly presented as static, lacking a method to dynamically correlate a collection of images with both their location on a map and their position along a timeline (US 8,311,733 B2, col. 1:10-15; col. 6:41-48).
- The Patented Solution: The invention proposes a system that organizes a catalog of images according to their map locations and associates metadata (such as time and location) with each image in a "table." This structure allows a user to interact with a timeline (e.g., by moving a cursor or scrolling), which in turn instantiates or displays the corresponding image from the correct location on the map, effectively replaying a journey or event chronologically and geographically (’733 Patent, Abstract; col. 6:7-23; Fig. 3).
- Technical Importance: The invention describes a method for creating a "personalized iconographic map" that links a user's own photos or videos to a map and timeline, an approach that became central to dashcam, travel-logging, and photo management software (’733 Patent, col. 6:50-57).
- Key Claims at a Glance:
- The complaint asserts independent claim 1 (Compl. ¶11).
- The essential elements of independent claim 1 are:
- A computer system comprising: a processor; a memory coupled to the processor; and a mapping module coupled to the memory.
- The mapping module including: a data store configurable to organize multiple images according to one or more locations on a map.
- And a table coupled to the data store, the table configurable to associate metadata for the multiple images with a time line, an image history and a location.
- The association to enable an instantiation of time-related images from the multiple images at the one or more locations on the map in response to an instantiation of a curser positioned at different locations along an instantiation of the time line.
- The complaint does not explicitly reserve the right to assert dependent claims but refers generally to infringement of "one or more claims" (Compl. ¶11).
- The Invention Explained:
III. The Accused Instrumentality
- Product Identification: The accused instrumentality is Defendant's "Drive HD Player for PC and Mac" software (Compl. ¶11).
- Functionality and Market Context: The complaint alleges the Drive HD Player is software for use with dashcams that allows users to view and manage recorded video (Compl. ¶¶11, 13). Its core accused functionality involves correlating video information with GPS map data. The software allegedly organizes video frames based on this correlated map data and associates the video metadata with a timeline. This enables a user to click on a point on the timeline, which then displays the corresponding video frame alongside the vehicle's location on a map at that moment in time (Compl. ¶13). The complaint describes this user interaction with reference to figures that allegedly depict the software's user interface (Compl. ¶13).
IV. Analysis of Infringement Allegations
’733 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A computer system comprising: a processor; a memory coupled to the processor; and a mapping module coupled to the memory... | The Accused Instrumentalities are computer programs operating on a Windows PC or Mac, which provide the required processor and memory, and the software itself constitutes the mapping module. | ¶13 | col. 10:11-13 |
| ...the mapping module including: a data store configurable to organize multiple images according to one or more locations on a map... | The software includes a data store that organizes multiple video frames according to locations on a map, based on correlated GPS information. | ¶13 | col. 10:15-18 |
| ...and a table coupled to the data store, the table configurable to associate metadata for the multiple images with a time line, an image history and a location... | The software associates metadata from multiple video frames with a timeline, image history, and location. | ¶13 | col. 10:19-22 |
| ...the association to enable an instantiation of time-related images...at the one or more locations on the map in response to an instantiation of a curser positioned at different locations along...the time line. | The software displays the corresponding video frame and map data when a user clicks on a location on the timeline. The complaint references figures that allegedly show the software's user interface displaying a timeline, video frame, and map that are interactively linked (Compl. ¶13). | ¶13 | col. 10:22-29 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the combination of Defendant's "Drive HD Player" software and a user's general-purpose PC or Mac constitutes the claimed "computer system." The complaint alleges the user's computer provides the "processor" and "memory," a common theory for system claim infringement by software (Compl. ¶13). Resolution will depend on how the court construes the claim term "computer system."
- Technical Questions: The complaint provides a specific factual allegation for the "time line" element by describing the user-clickable timeline feature (Compl. ¶13). However, it alleges the "image history" element is met without providing distinct supporting facts. A key technical question will be what constitutes an "image history" under the patent and whether the accused software provides functionality that meets this limitation, separate from simply organizing images by time and location.
V. Key Claim Terms for Construction
The Term: "a table"
- Context and Importance: Claim 1 requires "a table" that associates metadata with a timeline, image history, and location. The viability of the infringement claim depends on whether the specific data structure used by the Drive HD Player software to link video frames, GPS data, and timestamps can be properly characterized as a "table." Practitioners may focus on this term because its construction could either broadly cover various relational data structures or be narrowly limited to a more traditional format.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests "table" may be interpreted broadly, listing it alongside other data organization methods: "tables, files, fields, columns and other method of organizing data" (’733 Patent, col. 6:5-7). This language may support an argument that any structure that logically relates the required data elements satisfies the limitation.
- Evidence for a Narrower Interpretation: Figure 3 depicts distinct blocks for "TABLE INCLUDING METADATA" (314, 324), separate from the "DATA STORE" (312, 322). An argument could be made that this separation implies a more formally defined table structure, rather than just any form of embedded or linked metadata.
The Term: "image history"
- Context and Importance: The claim requires the "table" to associate metadata with a "time line, an image history and a location." While the complaint focuses on the timeline feature, infringement requires all limitations to be met. The meaning of "image history" and how it differs from a "time line" or "location" will be critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent frequently lists "time, location, and/or image history" as a group, suggesting they are related parameters for organizing images (’733 Patent, col. 1:12-13; col. 2:12-13). This could support a reading where "image history" is a general term encompassing the chronological and locational sequence of images.
- Evidence for a Narrower Interpretation: The use of the conjunction "and" in the list "a time line, an image history and a location" in Claim 1 suggests each term has an independent meaning. A party could argue "image history" requires a specific parameter beyond just time or location, such as metadata about the image's creation, edits, or relationship to other images, which may not be present in the accused software.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b). The factual basis for this claim is the allegation that Defendant provides "instruction manuals, advertisement... and support" for the accused software, thereby encouraging and instructing its customers to use the software in an infringing manner (Compl. ¶¶ 20, 22).
- Willful Infringement: The complaint includes a claim for willful infringement, asserting that Defendant has had knowledge of the ’733 patent "since at least the filing of this complaint" and is therefore aware that its continued activities would constitute infringement (Compl. ¶¶ 21, 23).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the elements of the claimed "computer system," specifically the "mapping module" and "table," be read to cover Defendant's software application when it is installed and operated on a user's separate, general-purpose computer?
- A second key question will be definitional: what technical feature or data constitutes an "image history" as required by claim 1, and does this term impart a limitation distinct from the "time line" and "location" elements? The outcome may depend on whether the accused software provides functionality beyond simply organizing video clips chronologically and geographically.
- Finally, an evidentiary question will be whether the data structures within the Drive HD Player software function as the "table" recited in the claim, or if there is a fundamental mismatch between the patent's description and the accused product's technical implementation.