DCT

1:25-cv-00877

WirelessWerx IP LLC v. Mazemap Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00877, D. Del., 07/15/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and therefore resides in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s indoor mapping and navigation products and services infringe a patent related to systems for remotely controlling movable entities using defined geographical zones.
  • Technical Context: The patent relates to "geofencing" technology, where a device on a movable entity is programmed with geographical boundaries and can autonomously trigger actions when those boundaries are crossed, a key function in modern asset tracking and fleet management systems.
  • Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It also discloses that Plaintiff and its predecessors have entered into prior settlement licenses and makes arguments that these agreements do not trigger a patent marking requirement under 35 U.S.C. § 287(a) because infringement was not admitted and the licenses were not for producing a patented article.

Case Timeline

Date Event
2004-11-05 '982 Patent Priority Date
2008-01-29 '982 Patent Issue Date
2025-07-15 Complaint Filing Date

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

U.S. Patent No. 7,323,982 - "Method and System to Control Movable Entities"

  • Patent Identification: U.S. Patent No. 7,323,982, "Method and System to Control Movable Entities," issued January 29, 2008.

The Invention Explained

  • Problem Addressed: The patent asserts that prior art GPS vehicle tracking systems were "limited to relaying the GPS information to a control center or a web server and plotting the position of the vehicle on a computer map," which did not maximize the potential benefits of such technology (’982 Patent, col. 1:47-54).
  • The Patented Solution: The invention describes an intelligent "transponder" on a movable entity that does more than passively report its location. The system allows a user to define a "geographical zone" and program the transponder to recognize the occurrence of an "event" (e.g., the entity entering or leaving the zone) and, in response, autonomously execute a "configurable operation" (e.g., turning on an indicator light, locking a door, or sending an alert) (’982 Patent, Abstract; col. 2:56-col. 3:4). The system architecture moves decision-making logic to the remote device itself (’982 Patent, Fig. 1A).
  • Technical Importance: This approach shifts intelligence from a centralized server to the end-point device, enabling more responsive, autonomous control over a remote entity rather than just passive monitoring.

Key Claims at a Glance

  • The complaint asserts claims 1-61 of the ’982 Patent (Compl. ¶18). Independent claims 1, 20, and 43 are foundational.
  • Independent Claim 1: A method comprising the steps of:
    • loading a plurality of coordinates to a transponder
    • programming a microprocessor in the transponder to define a geographical zone by creating an enclosed area on a "pixilated image" using the coordinates
    • programming the microprocessor to determine the occurrence of an event based on the entity's status relative to the zone
    • configuring the microprocessor to execute a configurable operation if the event occurs
  • Independent Claim 20: A method comprising the steps of:
    • defining a geographical zone using a plurality of "waypoints", with each waypoint defined by a "geographical coordinate and a radius"
    • loading the waypoints to a transponder
    • programming a microprocessor in the transponder to determine the occurrence of an event based on the entity's status relative to the zone
    • configuring the microprocessor to execute a configurable operation if the event occurs
  • Independent Claim 43: A method comprising the steps of:
    • using a computing device to identify a "geometrical area" divided into a grid
    • defining a geographical zone by selecting one or more sections of the grid
    • loading a "pixilated computer image" representing the zone into the transponder's memory
    • programming the microprocessor to determine the occurrence of an event
    • configuring the microprocessor to execute a configurable operation if the event occurs
  • The complaint reserves the right to assert all dependent claims (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies "Defendant's products (e.g., MazeMap)" as the Accused Instrumentalities (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges that Defendant "maintains, operates, and administers a system with methods and user interface for controlling an entity having an attached transponder" (Compl. ¶18). Based on Defendant's public-facing business, the accused system appears to be an indoor mapping and navigation service. In this context, the "movable entity" is likely a user with a mobile device, the "transponder" is the software on that device, and the "geographical zone" is a defined indoor area (e.g., a room or restricted corridor). The complaint does not provide further detail on the technical operation or market position of the accused products.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary table attached as Exhibit B" to support its infringement allegations, but this exhibit was not included with the complaint filing (Compl. ¶19). Therefore, a claim chart summary cannot be provided. The narrative infringement theory suggests that Defendant's system allows for defining areas within its indoor maps (the claimed "geographical zone") and that software on a user's device (the claimed "transponder") detects when the user enters or exits these zones (the claimed "event") to trigger an action (the claimed "configurable operation") (Compl. ¶18).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the term "transponder", which is described in the ’982 Patent’s specification as a dedicated hardware unit installed in a vehicle (’982 Patent, Fig. 2-3A), can be construed to read on software operating on a general-purpose device like a smartphone, as is likely the case for the accused system. A related question is whether an indoor, non-GPS-based mapping system falls within the scope of an invention whose embodiments are described in the context of outdoor, GPS-based vehicle tracking (’982 Patent, col. 1:29-34).
    • Technical Questions: A factual question will be whether the method used by the accused system to define indoor areas constitutes defining a "geographical zone" by creating a "pixilated image" (as required by claim 1) or by using "waypoints" defined by a "coordinate and a radius" (as required by claim 20). The specific data structures and algorithms used by Defendant will be determinative. Another question is what evidence the complaint provides that the accused system performs a "configurable operation" beyond a simple user notification, given the patent’s emphasis on operations that physically control the entity, such as locking doors or disabling an ignition (’982 Patent, col. 2:40-48).

V. Key Claim Terms for Construction

  • The Term: "transponder"

    • Context and Importance: The infringement analysis may depend heavily on whether software on a general-purpose smartphone can be considered a "transponder". Practitioners may focus on this term because the patent’s figures and detailed description consistently depict a dedicated hardware box installed in a vehicle (’982 Patent, Fig. 2, 105), whereas the accused product is alleged to be a software-based service.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term is not explicitly defined in the patent, which could support an argument for applying its plain and ordinary meaning, potentially covering any device that receives and transmits signals in response.
      • Evidence for a Narrower Interpretation: The specification describes the "transponder" as a physical unit with specific hardware components, including a "housing 335," "internal board 240," multiple "external communication ports," and various connectors (’982 Patent, col. 10:11-24). This detailed description of a specific physical embodiment could be used to argue for a narrower construction limited to dedicated hardware.

  • The Term: "configurable operation"

    • Context and Importance: This term is critical because its scope will determine whether the accused system’s alleged actions (likely software-based user alerts) meet the claim limitation. A mismatch may exist between the patent’s examples of physical control and the accused system's functionality.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent provides a non-exhaustive list of operations, including "turning on a light indicator" (’982 Patent, col. 2:47), which is an informational output rather than direct physical control of the entity's movement. This could support construing the term to include software-based notifications.
      • Evidence for a Narrower Interpretation: The majority of examples in the specification relate to operations that directly alter the physical state or control of the entity, such as "turning off the ignition," "locking a door or latch," and "chang[ing] tire air pressure" (’982 Patent, col. 2:40-48). This context may support a narrower definition limited to actions that physically manipulate the movable entity itself.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by asserting that Defendant actively encourages and instructs its customers on how to use its products and services in an infringing manner. It also alleges contributory infringement, stating that the accused products are not staple commercial goods and that their only reasonable use is an infringing one (Compl. ¶20-21).
  • Willful Infringement: The complaint alleges that Defendant has had knowledge of the ’982 Patent and its infringement from "at least the filing date of the lawsuit," which may support a claim for post-suit willful infringement (Compl. ¶20). The prayer for relief also seeks a finding of willfulness if pre-suit knowledge is found in discovery (Compl. p. 8, ¶e).

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

  • A core issue will be one of definitional scope: can the term "transponder," rooted in the patent’s disclosure of a dedicated hardware box for vehicles, be construed to cover software operating on a general-purpose smartphone within an indoor mapping system?
  • A central dispute will likely be one of technical application: does the accused system's method for defining an indoor space meet the specific claim requirements for creating a "geographical zone", either through a "pixilated image" (Claim 1) or through "waypoints" defined by a "coordinate and a radius" (Claim 20)?
  • A key evidentiary question will be one of functional scope: does a software-based notification or alert generated by the accused system constitute the "configurable operation" recited in the claims, or is that term limited by the specification's disclosure to actions that physically control the movable entity?