DCT
1:25-cv-01395
Navog LLC v. Motive Tech Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Navog LLC (New Mexico)
- Defendant: Motive Technologies, Inc. (Delaware)
- Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
- Case Identification: 1:25-cv-01395, D. Del., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a GPS-based warning system designed to alert drivers of large vehicles to low-clearance obstacles.
- Technical Context: The technology at issue falls within the domain of vehicle telematics and safety systems, which use GPS and databases to provide real-time alerts and navigation assistance to prevent accidents.
- Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2015-12-13 | ’205 Patent - Earliest Priority Date |
| 2016-12-12 | ’205 Patent - Application Filing Date |
| 2020-03-17 | ’205 Patent - Issue Date |
| 2025-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 10,593,205, titled "GPS and Warning System," issued on March 17, 2020 (the “’205 Patent”).
U.S. Patent No. 10,593,205 - GPS and Warning System
The Invention Explained
- Problem Addressed: The patent addresses the problem faced by drivers of high-profile vehicles, such as commercial trucks, buses, and RVs, who risk colliding with low-clearance structures like bridges, tunnels, and underpasses because they may not know the vehicle's total height or see warning signs in time to stop or find an alternate route (’205 Patent, col. 1:56-68).
- The Patented Solution: The invention is a dedicated GPS device that contains a database of structure locations and their clearance heights. A computer module within the device uses a GPS module to track the vehicle's position and compares it against the database. If the vehicle approaches a structure with insufficient clearance, a warning mechanism provides a "loud audible sound and flashing light" to alert the driver, and a display screen can show alternate routes (’205 Patent, col. 2:31-49, col. 4:50-54). The system is described as being embodied in a physical "main body" containing these components (’205 Patent, col. 4:40-43).
- Technical Importance: The technology aims to provide a reliable, automated system to prevent dangerous and costly low-clearance collisions, which are a persistent issue for commercial and recreational vehicle operators (’205 Patent, col. 2:12-18).
Key Claims at a Glance
- The complaint asserts infringement of "exemplary claims" without specifying claim numbers in the body of the complaint (Compl. ¶11). The analysis below focuses on independent claim 1.
- Independent Claim 1:
- A GPS and warning system for an automobile comprising:
- (a) a main body, wherein the main body forms a hollow interior volume;
- (b) a computer module, located within the hollow interior volume and adapted to be programmed with information pertaining to existing roads, bridges, viaducts, and underpasses;
- (c) a GPS module, located within the hollow interior volume and adapted to provide location information of the existing roads, bridges, viaducts, and underpasses;
- (d) at least one warning mechanism, electrically connected to the computer module and adapted to provide a loud audible sound to warn a driver of impending danger;
- (e) a display screen on an outer surface of the main body, adapted to provide visual information including the height of an approaching bridge or underpass and display alternate routes;
- wherein the computer module is adapted to process location information, determine when to send a signal to the warning mechanism, and initiate the warning when the device is within a predetermined distance of a danger.
- The complaint reserves the right to assert other claims, including by the doctrine of equivalents (Compl. ¶11).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" detailed in charts referenced as Exhibit 2 (Compl. ¶11, ¶16). However, Exhibit 2 was not filed with the complaint.
Functionality and Market Context
- The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '205 Patent" (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the specific technical functionality or market positioning of the accused products.
IV. Analysis of Infringement Allegations
The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2, which is incorporated by reference but not attached to the public filing (Compl. ¶16, ¶17). The narrative allegation is that Defendant's products "satisfy all elements of the Exemplary '205 Patent Claims" (Compl. ¶16). A summary table based on the primary independent claim is presented below, noting where the complaint directs the reader to the unprovided exhibit for detailed evidence.
No probative visual evidence provided in complaint.
’205 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a main body, wherein the main body forms a hollow interior volume | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:14-16 |
| a computer module...located within the hollow interior volume and...programmed with information pertaining to existing...underpasses | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:17-21 |
| a GPS module...located within the hollow interior volume and...adapted to provide location information | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:22-26 |
| at least one warning mechanism...adapted to provide a loud audible sound | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:27-33 |
| a display screen located upon an outer surface of the main body... adapted to provide visual information...and...display alternate routes | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:34-43 |
| wherein the computer module is further adapted to initiate the at least one warning mechanism when the GPS and warning device is within a predetermined distance from an existing...underpass | The complaint does not specify the accused functionality for this element; it is presumably detailed in the unprovided Exhibit 2. | ¶16, ¶17 | col. 6:50-55 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether Defendant's accused products, which may be software-based fleet management systems, can meet the claim limitation of "a main body" that "forms a hollow interior volume" containing the other recited modules. The patent specification and figures appear to describe a self-contained hardware unit (’205 Patent, FIG. 1-3). The dispute may focus on whether this language can be construed broadly enough to cover a system where software on a general-purpose device (like a phone or in-dash computer) performs the claimed functions.
- Technical Questions: The complaint does not provide evidence regarding how the accused products function. Key technical questions will include whether the accused products are "programmed with information pertaining to...underpasses" as claimed, or merely use general mapping data, and whether they provide a specific "loud audible sound" for clearance warnings as distinct from general navigation alerts.
V. Key Claim Terms for Construction
- The Term: "a main body...form[ing] a hollow interior volume"
- Context and Importance: This term appears in the preamble of claim 1 and is foundational to the claimed system's physical structure. Its construction will be critical in determining whether the claim is limited to a dedicated hardware device or can read on software-based systems that run on third-party hardware (e.g., smartphones, tablets, or integrated vehicle systems). Practitioners may focus on this term because of the potential mismatch between the patent's hardware-centric disclosure and the likely software/service nature of the accused products.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for a broader construction might contend that "main body" is a generic term for the housing of the system's core components and that in a modern system, a smartphone or vehicle dashboard computer could serve as the "main body."
- Evidence for a Narrower Interpretation: The specification consistently refers to "main body 110" having a "hollow interior volume 114" that contains the "computer module 120" and "GPS module 130" (’205 Patent, col. 4:40-50). The patent figures exclusively depict a distinct, self-contained physical device, which may support a narrower construction limited to such an apparatus (’205 Patent, FIG. 1-3).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells its products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in a manner that allegedly infringes the ’205 Patent (Compl. ¶14, ¶15).
- Willful Infringement: The complaint does not use the term "willful." It alleges Defendant has "Actual Knowledge of Infringement" based on the service of the complaint and its attached claim charts (Compl. ¶13). This allegation supports a claim for post-suit, but not pre-suit, enhanced damages.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "a main body...form[ing] a hollow interior volume," which is described and depicted in the patent as a discrete physical device, be construed to cover a modern, software-based fleet management or telematics system that operates on general-purpose hardware?
- A key evidentiary question will be whether Plaintiff can demonstrate, through the evidence referenced in its unprovided claim charts, that Defendant's system performs the specific functionalities required by the claims—such as initiating a "loud audible sound" warning at a "predetermined distance" from a low-clearance obstacle—as opposed to providing more generic navigation and alert features.