DCT

1:26-cv-00033

Navog LLC v. Trucker Path Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-00033, D. Del., 01/12/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and maintains an established place of business 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 upcoming low-clearance structures.
  • Technical Context: The technology addresses the safety-critical need for commercial trucks, buses, and recreational vehicles to avoid collisions with low-clearance obstacles such as bridges, tunnels, and underpasses.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2015-12-13 ’205 Patent Priority Date
2016-12-12 ’205 Patent Application Filing Date
2020-03-17 ’205 Patent Issue Date
2026-01-12 Complaint Filing Date

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

U.S. Patent No. 10,593,205 - *"GPS and Warning System"*

  • Patent Identification: U.S. Patent No. 10,593,205, “GPS and Warning System,” issued March 17, 2020 (’205 Patent).

The Invention Explained

  • Problem Addressed: The patent addresses the problem faced by drivers of high-profile vehicles, such as commercial trucks and RVs, who risk colliding with low-clearance structures like bridges and tunnels. Drivers may not know the vehicle's exact height or the clearance of an upcoming structure, and stopping a large vehicle at highway speeds is difficult if a hazard is identified too late (’205 Patent, col. 1:56-68).
  • The Patented Solution: The invention is a dedicated GPS device for a vehicle that contains a computer module programmed with a database of structure locations and their clearance measurements. The system uses a GPS module to track the vehicle's location and compares it to 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, Abstract; col. 2:31-49). The system may also be configured to prevent the vehicle from being operated until the device is activated (’205 Patent, col. 2:50-53).
  • Technical Importance: The technology provides an automated, proactive safety system intended to prevent costly and dangerous collisions by giving drivers of large vehicles advance warning of height-related obstacles (’205 Patent, col. 2:12-18).

Key Claims at a Glance

  • The complaint asserts infringement of "one or more claims" of the ’205 Patent (Compl. ¶11). The patent contains two independent claims, Claim 1 and Claim 6. Claim 1 is directed to a GPS and warning system, and its essential elements are:
    • A main body with a hollow interior volume;
    • A computer module within the body, programmed with information about roads, bridges, viaducts, and underpasses;
    • A GPS module within the body to provide location information;
    • At least one warning mechanism connected to the computer module to provide a loud audible sound;
    • A display screen on the main body's outer surface to provide visual information, including the height of an approaching structure and alternate routes;
    • The computer module processes location information to determine when to send a signal to the warning mechanism; and
    • The computer module initiates the warning when the device is within a "predetermined distance" from a hazardous structure.
  • The complaint does not specify which dependent claims may be asserted (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as the "Exemplary Defendant Products" detailed in charts incorporated into the complaint as Exhibit 2 (Compl. ¶¶11, 16). Exhibit 2 was not attached to the publicly filed complaint.

Functionality and Market Context

The complaint does not provide a specific description of the accused products' functionality. It alleges that the products "practice the technology claimed by the '205 Patent" and that they satisfy all elements of the asserted claims (Compl. ¶16). No allegations are made regarding the products' specific commercial importance or market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2, which was not available for analysis (Compl. ¶¶16-17). The complaint asserts in a conclusory manner that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶16). Without access to the claim charts or a description of the accused products, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the language of the patent and the general nature of the dispute, several points of contention may arise during litigation.
    • Scope Questions: A central question may be whether the claimed "computer module... programmed with information" covers systems that receive clearance and location data dynamically from a remote server, as is common in modern navigation apps, versus a system with a static, self-contained database as described in the patent’s embodiments (’205 Patent, col. 4:41-46).
    • Technical Questions: The infringement analysis may turn on how the accused products implement the warning trigger. Specifically, discovery may be required to determine if the accused products use a "predetermined distance" to trigger an alert, as required by Claim 1, or if they employ a more dynamic calculation based on factors like vehicle speed, traffic, and road conditions.

V. Key Claim Terms for Construction

  • The Term: "computer module"

  • Context and Importance: This term defines the core processing component of the claimed invention. Its construction will be critical in determining whether the claim reads on a dedicated hardware device, a general-purpose device like a smartphone running an application, or a distributed, cloud-based system.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent describes the computer module in functional terms, stating it is "adapted to be programmed with information" and "adapted to process information," which could support an interpretation covering any processing unit capable of performing these functions (’205 Patent, col. 5:19-23; col. 6:45-53).
    • Evidence for a Narrower Interpretation: The specification consistently depicts the computer module as being located within the "hollow interior volume" of a singular "main body," along with the GPS module and power source. This physical co-location could support an argument that the term requires a self-contained, dedicated hardware device (’205 Patent, col. 4:41-44; Fig. 1).

  • The Term: "predetermined distance"

  • Context and Importance: This term defines the condition that triggers the system's warning. The outcome of the infringement analysis may depend on whether an accused product that calculates a warning distance dynamically (e.g., based on real-time speed) can be said to use a "predetermined" distance.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term itself is not explicitly defined, which may allow for an interpretation where the distance is "determined" by an algorithm "pre"-loaded onto the device, even if the output value changes based on variables.
    • Evidence for a Narrower Interpretation: The detailed description uses the phrase "at a preset distance from the structure," which may suggest a fixed, pre-configured, or static value, potentially narrowing the scope to exclude dynamically calculated warning zones (’205 Patent, col. 4:30-31).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end-users how to use the accused products in a manner that infringes the ’205 Patent (Compl. ¶14).
  • Willful Infringement: The complaint bases its allegation of knowledge of infringement on the service of the complaint itself (Compl. ¶13). This suggests the allegations are directed at post-suit, rather than pre-suit, willful infringement.

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

  • A primary issue will be one of evidentiary support: The complaint's infringement allegations rely entirely on an unattached exhibit. A key early question will be whether the factual basis for infringement, once revealed, is sufficient to demonstrate that the accused products meet every limitation of the asserted claims.
  • A central technical question will concern claim scope in a modern context: Can the patent’s disclosure of a self-contained device with a pre-programmed database (’205 Patent, col. 4:41-46) be construed to cover modern smartphone applications or in-vehicle systems that may rely on cloud-based processing and real-time, dynamic data feeds? The construction of "computer module" will be pivotal to this inquiry.
  • The case may also turn on a functional distinction: Does the accused product’s warning logic operate based on a "predetermined distance" as claimed, or does it use a fundamentally different, dynamic algorithm (e.g., based on time-to-hazard) that could place it outside the literal scope of the claims?