DCT
1:20-cv-00879
Geographic Location Innovations LLC v. Delsey Luggage Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: Delsey Luggage, Inc. (Delaware)
- Plaintiff’s Counsel: Chong Law Firm, P.A.; Kizzia Johnson, PLLC
- Case Identification: 1:20-cv-00879, D. Del., 06/29/2020
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and is therefore deemed to be a resident of the district.
- Core Dispute: Plaintiff alleges that Defendant’s Delsey store locator system and mobile application infringes a patent related to remotely entering location information into a positional device for navigation.
- Technical Context: The technology at issue involves systems and methods for offloading the task of address entry from a local navigation device (like a GPS or smartphone) to a remote server, which then transmits the determined location back to the device for route guidance.
- 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 |
|---|---|
| 2006-04-28 | Earliest Priority Date for U.S. Patent No. 7,917,285 |
| 2011-03-29 | U.S. Patent No. 7,917,285 Issued |
| 2020-06-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,917,285 - Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device
- Patent Identification: U.S. Patent No. 7,917,285, "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued March 29, 2011.
The Invention Explained
- Problem Addressed: The patent describes several problems with then-current GPS devices, including the difficulty of programming addresses while driving, inconsistencies in how different devices recognize city or street names, and the inefficiency of manually entering the same addresses into multiple devices owned by one user (’285 Patent, col. 1:43-65; col. 2:4-13).
- The Patented Solution: The invention proposes a system where a user interacts with a remote service (e.g., a website or a live operator) to request a location. A central server resolves this request into geographic coordinates and transmits them directly to the user's positional information device (such as a vehicle's GPS unit or a handheld device), which then calculates and displays the route (’285 Patent, Abstract; col. 2:32-48). The system architecture, involving a positional device, a communications network, and a remote server, is illustrated in Figure 3 (’285 Patent, Fig. 3).
- Technical Importance: This technical approach sought to make navigation systems safer and more user-friendly by offloading the complex and potentially distracting task of manual address entry from the end-user device to a remote server (’285 Patent, col. 2:26-31).
Key Claims at a Glance
- The complaint asserts at least independent claim 13 of the ’285 Patent (Compl. ¶13).
- Independent Claim 13 recites a system comprising three main components:
- A server configured to receive a location request, determine the address, and transmit it.
- A positional information device (including a locational module, communication module, processing module, and display module).
- A communications network coupling the server and the device.
- The complaint does not explicitly reserve the right to assert other claims but states infringement of "one or more claims, including at least Claim 13" (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant's "Delsey store locator system and mobile application (the "System")," which includes a mobile website and associated hardware and software (Compl. ¶13).
Functionality and Market Context
- The System is described as a "route planner mobile application" that allows a user on a device like a smartphone to find Delsey store locations and receive route guidance (Compl. ¶14). The complaint alleges that when a user requests a destination, a remote server determines the address of the location and transmits it to the user's device (Compl. ¶15). The user's device then displays the destination on a map and provides route guidance (Compl. ¶¶16, 19). One of the screenshots provided in the complaint shows turn-by-turn directions from a starting point to a Delsey store location (Compl. p. 4).
- The complaint does not contain allegations regarding the specific commercial importance or market positioning of the Delsey store locator system.
IV. Analysis of Infringement Allegations
'285 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for remotely entering location information into a positional information device, the system comprising: a server configured to receive a request for an address...to determine the address...and to transmit the determined address...; | The System includes one or more servers that receive a request for a destination, determine the address of that location, and transmit the determined address to the positional information device (smartphone) (Compl. p. 4). | ¶15 | col. 10:33-40 |
| the positional information device including a locational information module for determining location information of the positional information device; | The user's smartphone is the positional information device, and it utilizes its GPS location capability to determine its own location. | ¶17 | col. 5:5-14 |
| a communication module for receiving the determined address of the at least one location from the server; | The smartphone uses its cellular network communication transceiver to receive the determined address from the server. | ¶18 | col. 6:40-44 |
| a processing module configured to receive the determined address...and determine route guidance based on the location of the positional information device and the determined address; | The mapping software and mobile website on the smartphone receive the determined address and determine route guidance based on the device's location and the received destination address. A provided screenshot depicts a map with a route between two points (Compl. p. 5). | ¶19 | col. 4:1-6 |
| a display module for displaying the route guidance; | The screen on the smartphone displays the route guidance. | ¶20 | col. 4:18-24 |
| a communications network for coupling the positional information device to the server, | A cellular network couples the smartphone to the server(s). | ¶21 | col. 8:15-18 |
| wherein the server receives a time and date associated with the requested at least one location and transmits the associated time and date with the determined address...and the positional information device displays the determined address at the associated time and date. | The complaint alleges that the "time and date of the request must be sent to the server so that the server can determine the drop off time" and offers a code snippet from the accused website's source code as evidence (Compl. p. 8). | ¶22 | col. 10:56-62 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the final "time and date" limitation of claim 13. The complaint's evidence for this element is a screenshot of a Google Tag Manager script containing the JavaScript function
new Date().getTime()(Compl. ¶22, p. 8). A question for the court will be whether a standard web analytics timestamp, used for tracking user interactions, satisfies the claim requirement of receiving and transmitting a "time and date associated with the requested...location" for the purpose of displaying the address at that time. - Technical Questions: The complaint alleges that the server uses the request time and date to "determine the drop off time" (Compl. ¶22). A technical question is what evidence exists that the accused system actually uses this timestamp for calculating a "drop off time" or for any scheduling purpose contemplated by the patent, as opposed to its use for routine web analytics, logging, or session management.
V. Key Claim Terms for Construction
- The Term: "a time and date associated with the requested at least one location"
- Context and Importance: The construction of this term appears central to the infringement analysis for claim 13. Plaintiff's infringement theory, as presented in the complaint, requires this phrase to be broad enough to encompass a real-time timestamp generated by a web analytics script. Defendant may argue for a narrower construction requiring a more explicit, user-defined time and date for future scheduling. Practitioners may focus on this term because the infringement allegation for this element appears to rely on a function common to many modern websites (analytics tracking), and its construction could be dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint's allegation itself suggests a broad interpretation where any timestamp captured with a location request meets the limitation (Compl. ¶22). The claim language itself does not explicitly state the purpose of the time and date, which could support an argument that any associated time and date suffices.
- Evidence for a Narrower Interpretation: The patent specification describes an embodiment where a user plans a multi-stop "trip itinerary" and the system transmits "the latitude and longitude coordinates of each planned stop to the memory of the user's GPS device along with the suggested time and/or date for each stop" (’285 Patent, col. 12:53-62). This context suggests the "time and date" feature is for scheduling future travel, not merely logging an instantaneous request.
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of contributory infringement and inducement (Compl. ¶13). It does not plead specific facts to support the knowledge and intent elements of these claims, such as alleging that Defendant provides instructions or user manuals that actively encourage an infringing use of the system.
- Willful Infringement: The complaint does not include an explicit allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may depend on the answers to two central questions:
- A core issue will be one of definitional scope: can the claim term "a time and date associated with the requested at least one location" be construed to cover a real-time timestamp generated by a third-party web analytics script, or does the patent’s context limit the term to a user-defined time and date for scheduling a future trip?
- A key evidentiary question will be one of functional operation: what evidence will show that the accused system uses the alleged "time and date" information for the claimed purpose of associating it with the destination address for display, as opposed to using it for a technically distinct purpose such as web analytics or server logging? The complaint alleges a functional link but provides evidence that, on its face, points to a common web tracking tool.