DCT

8:25-cv-02703

WirelessWerx IP LLC v. Hapn Holdings LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-02703, M.D. Fla., 10/06/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Florida and has committed or induced acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s GPS tracking products and associated software platform infringe a patent related to methods for remotely controlling movable entities using pre-configured geographical zones.
  • Technical Context: The technology at issue involves GPS-based asset tracking and geofencing, a widely used capability for fleet management, logistics, and personal vehicle monitoring.
  • Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and that it and its predecessors-in-interest have previously entered into settlement licenses with other entities, which may become relevant to issues of damages and patent marking.

Case Timeline

Date Event
2004-11-05 ’982 Patent Priority Date
2008-01-29 U.S. Patent No. 7,323,982 Issued
2025-10-06 Complaint Filed

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

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

The patent-in-suit is U.S. Patent No. 7,323,982, issued January 29, 2008 (’982 Patent).

The Invention Explained

  • Problem Addressed: The patent describes prior art GPS tracking systems as being limited to relaying location information to a control center for plotting on a map, lacking more advanced, automated control functionalities based on an entity's location ( ’982 Patent, col. 1:48-52).
  • The Patented Solution: The invention discloses a method where a transponder attached to a movable entity is loaded with coordinates that define a "geographical zone." A microprocessor within the transponder is programmed to detect the occurrence of an event—such as the entity entering or leaving the defined zone—and then automatically execute a "configurable operation," like sending an alert, locking a door, or turning off an engine. This shifts intelligence from a central server to the remote device itself, enabling automated, location-aware control ('982 Patent, Abstract; col. 2:1-4).
  • Technical Importance: This approach enables automated, real-time responses to location-based events without requiring constant communication with a central server, a significant step beyond simple asset tracking ( ’982 Patent, col. 1:53-61).

Key Claims at a Glance

  • The complaint asserts infringement of claims 1-61, with a focus on independent claim 1 (Compl. ¶18).
  • The essential elements of independent claim 1 include:
    • loading from a computing device to a transponder's memory a plurality of coordinates;
    • programming a microprocessor of the transponder to define a geographical zone by creating an enclosed area on a pixilated image using said plurality of coordinates;
    • programming the microprocessor to determine the occurrence of an event associated with a status of the entity in relation to the geographical zone; and
    • configuring the microprocessor to execute a configurable operation if the event occurs.
  • The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶18).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant’s GPS tracking products and the associated HAPN application, which are accessible via Defendant's website (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). This system is marketed for tracking vehicles and other assets, providing users with location data and alerts based on the asset's movement, which aligns with the functionality described in the ’982 Patent (Compl. ¶17-18). The complaint does not provide further technical detail on the operation of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in an "Exhibit B" that was not provided with the filed document (Compl. ¶19). Accordingly, the infringement theory is summarized from the complaint's narrative allegations.

Plaintiff alleges that Defendant directly infringes by operating a system that practices the claimed methods for controlling a movable entity (Compl. ¶18). The system allegedly includes a transponder (the Spytec GPS device) and a user interface (the HAPN application) that together perform the steps of defining geographical zones, monitoring a transponder's location relative to those zones, and executing operations based on events, such as a zone breach (Compl. ¶18, ¶20). The complaint contends that "but for Defendant's actions, the claimed embodiments involving Defendant's products and services would never have been put into service" (Compl. ¶18).

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused system's method of defining a geofence (e.g., drawing a shape on a digital map within an application) constitutes "creating an enclosed area on a pixilated image using said plurality of coordinates" as recited in claim 1. The specific implementation of this limitation in the patent (e.g., an 80x80 pixel map) may create a dispute over the claim's scope relative to modern geofencing technology ('982 Patent, col. 16:35-38).
  • Technical Questions: The analysis may turn on where the key processing occurs. A key question is whether the accused transponder itself is "programmed" to "determine the occurrence of an event," or if this logic is primarily executed on Defendant’s servers, with the transponder merely reporting its coordinates. The complaint's direct infringement theory against Defendant appears to depend on Defendant's role in "operating" the system that performs these steps (Compl. ¶18).

V. Key Claim Terms for Construction

"creating an enclosed area on a pixilated image using said plurality of coordinates"

  • Context and Importance: This term is at the heart of the patented geofencing mechanism. Its construction will be critical to determining whether modern digital mapping and zone-definition technologies, as likely used in the accused system, fall within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that the term should not be limited to the specific embodiments, pointing to the overall concept of defining a zone using coordinates on any digital representation, which inherently involves pixels ('982 Patent, col. 15:21-30).
    • Evidence for a Narrower Interpretation: Defendant may argue the claim is limited by the specification's detailed description of a specific implementation, such as creating a "bounding' square or box" and generating an "80/80-pixel map" ('982 Patent, col. 15:23-24; col. 16:35-38).

"programming a microprocessor of a transponder"

  • Context and Importance: The identity of the infringing actor may depend on the meaning of this term. Practitioners may focus on this term because it raises the question of whether infringement occurs when Defendant provides a pre-configured system, or when an end-user defines a specific geofence and alert.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Plaintiff may argue that sending configuration data, such as the coordinates of a geofence, from a server or application to the transponder constitutes "programming" it to perform the claimed monitoring function ('982 Patent, col. 2:62-65).
    • Evidence for a Narrower Interpretation: Defendant could contend that "programming" implies writing or altering firmware or executable code, not merely supplying user-defined parameters to a device with pre-existing capabilities ('982 Patent, col. 12:4-14).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement and contributory infringement, asserting that Defendant actively encourages and instructs its customers on how to use the accused products in an infringing manner through its website and product manuals (Compl. ¶20-21).
  • Willful Infringement: The complaint alleges Defendant has known of the ’982 Patent "from at least the filing date of the lawsuit," establishing a basis for post-suit willfulness (Compl. ¶20). The prayer for relief seeks a finding of willfulness if discovery reveals pre-suit knowledge (Compl. p. 11, ¶e).

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

  • A core issue will be one of definitional scope: can the claim term "creating an enclosed area on a pixilated image," which is described in the patent with reference to a specific pixel-grid implementation, be construed broadly enough to cover the methods used by modern, web-based geofencing systems?
  • A second key question will be the locus of infringement: who performs the claimed act of "programming" the microprocessor? The case may turn on whether providing a system that allows a user to configure a geofence constitutes direct infringement by the system operator, or whether the allegedly infringing acts are performed by the end-user.
  • An evidentiary question will be the division of labor between the accused device and Defendant's servers. The infringement analysis will likely depend on whether the critical logic for determining a geofence breach and triggering an operation resides on the transponder itself, as contemplated by the patent, or on a centralized server.