DCT
1:19-cv-01381
Metataste General Trading LLC v. Navigine Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Metataste General Trading LLC (United Arab Emirates)
- Defendant: Navigine Corporation (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Budo Law, LLP
- Case Identification: 1:19-cv-01381, D. Del., 07/24/2019
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in the state, has transacted business in the district, and has committed acts of alleged infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s indoor navigation and positioning technologies infringe a patent related to determining a user's location within a multistory building using a system of distributed transmitters.
- Technical Context: The technology addresses the limitations of GPS for indoor environments by providing a method for location and floor-level detection within complex structures like malls, airports, and offices.
- 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
| Date | Event |
|---|---|
| 2012-06-21 | ’487 Patent Priority Date |
| 2017-03-28 | ’487 Patent Issue Date |
| 2019-07-24 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,609,487 - “System for providing location relevant information”
- Patent Identification: U.S. Patent No. 9,609,487, issued March 28, 2017.
The Invention Explained
- Problem Addressed: The patent seeks to solve the problem of providing accurate location information inside multistory buildings where GPS is unreliable or inoperable due to signal obstruction and an inability to distinguish between different elevations (’487 Patent, col. 1:35-56).
- The Patented Solution: The invention proposes a system comprising multiple transmitters placed across different floors of a building. Each transmitter sends a signal identifying its location. To determine a user's floor, signals from transmitters on the same floor share a "common floor identification artifact." A mobile device receives these signals, determines its floor by selecting the one associated with the "highest number of detected common floor identification artifacts," and then identifies the closest transmitter on that floor to pinpoint its location and display relevant information (’487 Patent, col. 2:5-14; col. 6:21-30).
- Technical Importance: The described approach provides a framework for indoor navigation that is contextually relevant and can distinguish between floors, a critical capability for applications in large, vertical commercial or public spaces (’487 Patent, col. 2:38-51).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶16).
- The essential elements of Claim 1 are:
- A system with a plurality of transmitters located across multiple floors of a building.
- Each transmitter sends a signal to identify its location.
- Signals from transmitters on the same floor share at least one common transmission parameter and a common floor identification artifact.
- Software on a mobile device that:
- Identifies signals from two or more transmitters.
- Determines the closest transmitter on the same floor based on the common transmission parameter.
- Identifies the mobile device's floor by selecting the floor associated with the highest number of detected common floor identification artifacts.
- Displays location-relevant information associated with the determined closest transmitter.
- The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringement of "one or more claims" (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant's "Navigine integrated positioning technologies," including the "Navigine Indoor Positioning system" and the "Navigine Indoor Positioning Platform" (Compl. ¶¶10, 17, 19).
Functionality and Market Context
- The complaint alleges that the accused system enables high-accuracy indoor navigation for mobile users in large, multistory buildings such as malls and airports (Compl. ¶17). It allegedly uses external infrastructure like Bluetooth beacons (iBeacon/Wi-Fi) placed throughout a building, which transmit signals to a user's mobile device running Navigine software (Compl. ¶¶17-18). Figure 1 of the complaint depicts a mobile phone displaying a multistory map, described as "Defendant's multistory location tracking software" (Compl. p. 1, Fig. 1). The system is also alleged to use these beacons to push location-based advertisements and marketing messages to users' devices (Compl. ¶21; Fig. 15).
IV. Analysis of Infringement Allegations
’487 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of transmitters located in different locations across multiple floors of the building... | Defendant's system uses a plurality of transmitters, such as Bluetooth beacons, located across multiple floors. The complaint includes a figure showing a sample beacon layout on a single floor plan. | ¶18; Fig. 4 | col. 5:16-21 |
| wherein signals transmitted by transmitters located on the same floor share at least one common transmission parameter... | Beacons on the same floor allegedly transmit signals of the same strength (TX Power), which serves as a common transmission parameter. | ¶18; Fig. 5 | col. 5:28-34 |
| and a common floor identification artifact for identifying the floor on which the respective transmitters are located... | The iBeacon "Major" value is allegedly used as a "common floor identification artifact," where all beacons on a certain floor are assigned a unique major value to distinguish that floor from others. | ¶18; Fig. 6 | col. 6:21-25 |
| software for... identifying signals received substantially concurrently from two or more of the plurality of transmitters... | The Navigine software on a user's mobile device is allegedly enabled to identify signals received from multiple Bluetooth beacons. | ¶20 | col. 8:19-21 |
| determining the closest transmitter on the same floor as the mobile device based at least in part on the at least one common transmission parameter... | The system allegedly determines the nearest Bluetooth beacon based on signal strength (RSSI), which the complaint maps to the "common transmission parameter." | ¶21 | col. 8:30-35 |
| and by identifying the floor on which the mobile device is located by selecting the floor associated with the highest number of detected common floor identification artifacts from the signals received... | The complaint alleges the system detects the floor level based on receiving the "highest number of signals" from beacons on the same floor, which it equates to detecting the highest number of artifacts. | ¶21 | col. 8:24-29 |
| and displaying on the mobile device location relevant information associated with the location of the determined closest transmitter. | The Navigine software allegedly displays the mobile device's location in relevance to the nearest beacon and can push location-based notifications. | ¶22; Fig. 10 | col. 8:29-33 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the accused system's use of an iBeacon "Major" value to designate a floor (Compl. Fig. 6) meets the claim limitation of a "common floor identification artifact." The interpretation of "artifact" will be critical.
- Technical Questions: The complaint alleges that the floor is identified "based on the highest number of signals received from multiple Bluetooth beacons of the same floor" (Compl. ¶21). A key technical question is whether this alleged functionality is equivalent to the specific claim requirement of "selecting the floor associated with the highest number of detected common floor identification artifacts." The court may need to determine if counting signals is the same as counting "artifacts" within those signals, as required by the claim.
V. Key Claim Terms for Construction
- The Term: "common floor identification artifact"
- Context and Importance: This term is central to the patent's method for distinguishing between floors, which is a core part of the invention. The infringement case hinges on whether the data used by Navigine's system (allegedly the iBeacon "Major" value) qualifies as this "artifact." Practitioners may focus on this term because its construction will likely determine whether the accused system's floor-detection mechanism falls within the scope of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide a narrow, explicit definition, which may support a broader construction covering any data field or signal component that serves to identify a floor. The patent states that this feature "allows signals originating from the same floor to be easily identified" (’487 Patent, col. 5:37-38), suggesting a functional definition.
- Evidence for a Narrower Interpretation: A defendant might argue that the term implies something more specific than a pre-existing field in a standard protocol like iBeacon. The patent’s description of using the artifacts to "determine that four signals originate from second floor transmitters, whereas only a single transmission originates from the first floor" (’487 Patent, col. 6:25-29) could be argued to imply a specific counting mechanism that differentiates the "artifact" from the signal itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement based on Defendant's advertising of its "powerful and precise indoor positioning engine" and encouraging customers and end-users to use the technology through its website and demo requests (Compl. ¶¶24-25). Contributory infringement is alleged on the basis that the accused functionality has no substantial non-infringing uses (Compl. ¶27).
- Willful Infringement: The complaint alleges willful infringement based on Defendant’s knowledge of the patent "at least the filing and service of this complaint" (Compl. ¶28). It also makes a general allegation of pre-suit knowledge based on "due diligence and freedom to operate analyses," though no specific facts supporting pre-suit knowledge are provided (Compl. ¶28).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the court's interpretation of specific claim language and the underlying operation of the accused technology. The key questions are:
A core issue will be one of definitional scope: Can the term "common floor identification artifact," as described in the patent, be construed to read on a standardized data field like the "Major" value within the iBeacon protocol, or does the patent require a more distinct or proprietary identifier?
A second key issue will be one of functional correspondence: Does the accused Navigine system’s method for identifying a user's floor operate in a manner equivalent to the specific algorithm recited in Claim 1—namely, "selecting the floor associated with the highest number of detected common floor identification artifacts"? The case may turn on evidence showing whether the accused system counts signals from a floor or specifically counts the "artifacts" themselves to make a floor determination.