Navog LLC v. Garmin Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Navog LLC (NM)
  • Defendant: Garmin International, Inc. (KS)
  • Plaintiff’s Counsel: Beusse Sanks; Rabicoff Law LLC
• Case Identification: 0:25-cv-60328, S.D. Fla., 02/19/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business in the district and committing alleged acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s GPS products infringe a patent related to a system for warning drivers of large vehicles about upcoming low-clearance structures.
• Technical Context: The technology at issue involves using GPS data and a database of structure-clearance heights to provide advance warnings and rerouting options for vehicles like trucks and RVs, a critical safety function in the commercial and recreational vehicle navigation market.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or specific licensing history related to the patent-in-suit.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent identifies the problem of drivers of high-profile vehicles (e.g., commercial trucks, buses, RVs) colliding with low-clearance structures like bridges, tunnels, and underpasses because they lack adequate advance warning to stop or find an alternate route (U.S. Patent No. 10,593,205, col. 1:56-69).
• The Patented Solution: The invention is a vehicle-mounted system that uses a GPS module to track the vehicle's location and a computer module programmed with a database of structure locations and their clearance heights. When the system determines the vehicle is approaching a low-clearance obstacle within a "predetermined distance," it activates a "warning mechanism" (e.g., audible alarm and flashing light) and can display alternate routes on a screen to avoid the hazard (’205 Patent, col. 2:31-48, col. 4:26-35).
• Technical Importance: The described solution aims to provide a dedicated, reliable, and automated warning system to prevent costly and dangerous collisions, 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, but incorporates claim charts by reference that presumably identify them (Compl. ¶11, ¶16). Assuming Claim 1 is representative as the first independent claim:
• Independent Claim 1:
  • A GPS and warning system for an automobile comprising:
  • (a) a main body with a hollow interior volume;
  • (b) a computer module within the volume, programmed with information about roads, bridges, viaducts, and underpasses;
  • (c) a GPS module within the volume to provide location information;
  • (d) at least one warning mechanism connected to the computer module to provide a loud audible sound to warn of impending danger;
  • (e) a display screen on an outer surface, connected to the computer module, to provide visual information including the height of an approaching structure and alternate routes;
  • wherein the computer module processes location information to determine when to send a signal to the warning mechanism and is adapted to initiate the warning when the device is within a predetermined distance from a dangerous structure.
• The complaint reserves the right to assert additional claims, potentially including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify specific accused products by name. It refers to them generally as "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that the accused products are GPS devices made, used, sold, or imported by Garmin (Compl. ¶11). The infringement theory implies these products contain functionality for vehicle navigation that includes warnings for road hazards, which would align with Garmin's navigation products targeted at the trucking and RV markets. The complaint does not provide specific details on the operation of the accused products, instead incorporating by reference unattached claim charts from Exhibit 2 (Compl. ¶16-17).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe the '205 patent literally or under the doctrine of equivalents (Compl. ¶11). It states that detailed infringement comparisons are provided in claim charts in Exhibit 2; however, Exhibit 2 was not filed with the public version of the complaint (Compl. ¶16-17). The narrative alleges that the accused products "practice the technology claimed by the '205 Patent" and "satisfy all elements of the Exemplary '205 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Lacking specific infringement contentions, the analysis will likely focus on the following questions:
  • Scope Questions: Do Garmin's integrated navigation systems, which may be software-based features within a multi-function device, constitute a "system" with a "main body," "computer module," and "GPS module" as distinct structural elements required by the claim?
  • Technical Questions: Does the warning functionality in the accused Garmin products operate based on a "predetermined distance" from a hazard, as claimed, or does it use a different logic, such as time-to-arrival or route-based proximity? Further, what evidence demonstrates that the accused products' warnings constitute a "loud audible sound" specifically for impending danger, as opposed to general navigation alerts?

V. Key Claim Terms for Construction

• The Term: "computer module"

• Context and Importance: This term appears in independent claim 1 and is central to the invention's logic. Its construction will determine whether the accused functionality must be performed by a single, dedicated hardware component or if it can be met by software running on a general-purpose processor within a larger device. Practitioners may focus on this term because Garmin’s products likely integrate this functionality via software on a multi-purpose CPU.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the computer module by its function: it is "adapted to be programmed with information" and "adapted to process information and location" (’205 Patent, col. 4:41-46, col. 4:55-56). This functional description could support an interpretation covering software implementations.
  • Evidence for a Narrower Interpretation: The claims and figures repeatedly depict the "computer module 120" as a discrete component located within the "hollow interior volume 114" of the "main body 110" (’205 Patent, col. 4:41-43; Claim 1). This could support a narrower construction requiring a distinct physical module.

• The Term: "warning mechanism"

• Context and Importance: The nature of the "warning" is a core element of the claimed solution. The definition will be critical to determine if standard navigational alerts in the accused products meet this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is general. The specification states it is "adapted to provide a loud audible sound and flashing light to warn a driver of impending danger" (’205 Patent, col. 4:50-53), but the independent claim only requires the "loud audible sound" (’205 Patent, col. 6:27-32). This could suggest any loud audio alert for danger infringes.
  • Evidence for a Narrower Interpretation: The patent repeatedly ties the warning to "impending danger" caused by a low-clearance structure (’205 Patent, col. 4:53-54). An argument could be made that this requires a specific type of alarm distinct from routine navigation pings or general traffic alerts.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’205 patent (Compl. ¶14-15). The allegations are tied to knowledge obtained at least as of the service of the complaint (Compl. ¶15).
• Willful Infringement: The complaint alleges willful infringement based on Defendant's continuation of allegedly infringing activities despite having "actual knowledge" of the '205 patent, with such knowledge established by the service of the complaint and its attached claim charts (Compl. ¶13-14). This frames the willfulness claim as being based on post-suit conduct.

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

1. A central issue will be one of structural interpretation: Do the asserted claims, which describe a system with distinct physical components like a "main body" and an internal "computer module," read on Garmin's integrated navigation devices where processing functions may be performed by software on a general-purpose processor rather than a dedicated, separate module?
2. A key evidentiary question will be one of operational correspondence: Since the complaint lacks specific factual allegations mapping product features to claim elements, the case will depend on evidence demonstrating that the accused Garmin products, in operation, initiate a specific "warning mechanism" based on a "predetermined distance" from a hazard, as opposed to using a more complex, route-aware algorithm for generating alerts.
3. Given the reliance on post-suit notice for willfulness and inducement allegations, a pivotal question will be the adequacy of pre-suit notice or knowledge. The complaint does not allege any pre-suit notification, which may limit the scope of damages and the viability of enhanced damages or pre-suit indirect infringement claims.