DCT
1:20-cv-24469
Geographic Location Innovations LLC v. Elemis USA Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: Elemis USA, Inc. (Florida)
- Plaintiff’s Counsel: Rodriguez-Albizu Law, P.A.
- Case Identification: 1:20-cv-24469, S.D. Fla., 12/04/2020
- Venue Allegations: Venue is alleged to be proper as Defendant is a resident of the district, acts of infringement are occurring in the district, and Defendant has a regular and established place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s website "store locator" feature infringes a patent related to remotely providing location information and route guidance to a positional device.
- Technical Context: The technology concerns server-client systems for location-based services, a foundational component of modern mobile e-commerce and navigation applications.
- Key Procedural History: The operative pleading is a First Amended Complaint, indicating a prior version was filed and subsequently modified. No other significant procedural events are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | ’285 Patent Priority Date |
| 2011-03-29 | ’285 Patent Issue Date |
| 2020-12-04 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,917,285 - "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued March 29, 2011.
The Invention Explained
- Problem Addressed: The patent describes challenges with early GPS devices, including the difficulty of manually inputting addresses, especially while driving; inconsistent address formats between different devices; and the inconvenience of programming the same destination into multiple devices for users traveling to the same location (’285 Patent, col. 1:43-2:13).
- The Patented Solution: The invention proposes a system where a user can request an address from a remote server, which then determines the address coordinates and transmits them directly to the user's "positional information device" (e.g., a GPS unit) for automatic programming and route guidance (’285 Patent, col. 2:33-46). This architecture, depicted in system diagrams like Figure 3, offloads the task of address lookup and entry from the end-user device to a central server, intended to simplify and improve the safety of obtaining directions (’285 Patent, col. 2:26-31).
- Technical Importance: The technology aimed to streamline the user experience for navigation systems by centralizing address resolution and leveraging network connectivity, a departure from the standalone, manually-programmed GPS units that were common at the time.
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 13 (Compl. ¶19).
- The essential elements of independent claim 13 are:
- A system comprising a server and a positional information device.
- The server is configured to:
- receive a request for an address of at least one location.
- determine the address.
- transmit the determined address to the positional information device.
- receive a time and date associated with the request.
- transmit the associated time and date with the determined address.
- The positional information device includes:
- a locational information module for determining the device's location.
- a communication module for receiving the address from the server.
- a processing module for determining route guidance based on the device's location and the received address.
- a display module for displaying the route guidance.
- displays the determined address at the associated time and date.
- A communications network coupling the device and server.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant’s "store locator system and mobile application" available on its website, referred to as "the System" (Compl. ¶19).
Functionality and Market Context
The complaint alleges the System is a "route planner mobile application" that allows a user to find store locations and receive directions on a positional device like a smartphone (Compl. ¶20). A user can enter an address or allow the system to use the device's current location to find nearby stores (Compl. ¶¶20, 23). The system then displays store locations and provides route guidance on a map (Compl. ¶¶21, 25). The complaint includes a screenshot of the "Store Locator" interface, showing an input field for an address or zip code and a "LOCATE NEARBY" button (Compl. ¶20, p. 5).
IV. Analysis of Infringement Allegations
’285 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a server configured to receive a request for an address of at least one location not already stored in the positional information device, to determine the address of the least one location and to transmit the determined address to the positional information device | The System includes one or more servers that receive a request for a store address, determine the address of the destination, and transmit it to the user's smartphone (Compl. ¶21). | ¶¶21-22 | col. 13:38-42 |
| the positional information device including a locational information module for determining location information of the positional information device | The user's smartphone, on which the system is installed, utilizes its GPS to determine its location (Compl. ¶23). A screenshot shows a browser permission pop-up stating "us.elemis.com wants to Know your location" (Compl. p. 8). | ¶23 | col. 13:48-50 |
| a communication module for receiving the determined address of the at least one location from the server | The user's smartphone uses its cellular network communication transceiver to receive the destination address from the server (Compl. ¶24). | ¶24 | col. 13:51-53 |
| a processing module configured to receive the determined address from the communication module and determine route guidance based on the location of the positional information device and the determined address | The System includes mapping software and a mobile website on the smartphone that function as a processing module, determining route guidance based on the phone's location and the received address (Compl. ¶25). | ¶25 | col. 13:54-59 |
| a display module for displaying the route guidance | The screen on the smartphone functions as a display module to show the route guidance (Compl. ¶26). A screenshot displays a map with a blue line representing the calculated route between two points (Compl. p. 11). | ¶26 | col. 13:60-61 |
| a communications network for coupling the positional information device to the server | A cellular network and/or the Internet serve as the communications network coupling the smartphone to the server (Compl. ¶27). | ¶27 | col. 13:62-64 |
| wherein the server receives a time and date associated with the requested at least one location and transmits the associated time and date with the determined address to the positional information device and the positional information device displays the determined address at the associated time and date | The server receives a time and date of the request and transmits it with the destination address to the smartphone, which then displays the address at the associated time and date (Compl. ¶28). The complaint provides a screenshot of inspected webpage code showing a gtm.start event with a new Date().getTime() value (Compl. p. 13). |
¶28 | col. 14:47-54 |
Identified Points of Contention
- Scope Questions: A central question may be whether a general-purpose smartphone executing code within a web browser constitutes the claimed "positional information device" with its enumerated "modules." The defense may argue that the patent's disclosure, which references specific hardware modules (e.g., Fig. 2), envisions a more dedicated, self-contained navigation device rather than a distributed, software-defined system running on a standard smartphone.
- Technical Questions: The infringement allegation for the "time and date" limitation relies on a screenshot of code referencing "gtm.start" (Google Tag Manager) and
new Date().getTime()(Compl. ¶28, p. 13). The court will need to determine if this timestamp, which may be primarily for web analytics, is in fact "transmitted... with the determined address" and "display[ed]" by the device as part of the claimed navigational function, or if its function is entirely separate from the route guidance presented to the user. The complaint alleges display, but the visual evidence for this specific element appears to be limited to the code snippet itself.
V. Key Claim Terms for Construction
The Term: "positional information device"
Context and Importance: The definition of this term is critical because the accused product is a modern smartphone running a website, whereas the patent was filed in 2006 when dedicated GPS units were more common. The outcome of the case may depend on whether a smartphone running a browser is considered equivalent to the "device" described in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the principles may apply to various devices, stating it is not limited to a "hand-held device" and can include a "GPS receiver coupled to a desktop computer or laptop, etc." (’285 Patent, col. 4:6-9). The claims themselves do not limit the device to a specific form factor.
- Evidence for a Narrower Interpretation: The detailed description and Figure 2 illustrate the device with distinct, discrete components like a "computer processing module," "storage module," and "locational information module," connected by a "system bus" (’285 Patent, Fig. 2; col. 4:38-51). This could support an argument that the term requires a device with a more integrated, hardware-like architecture than a standard smartphone running third-party web software.
The Term: "processing module"
Context and Importance: Practitioners may focus on this term because the complaint alleges that "mapping software and the mobile website" constitute the module (Compl. ¶25). This conflates software (some of which may execute on the server) with the device's local processing capability. The dispute will likely center on whether this combination of web elements and local execution meets the claim's requirement for a "module... configured to... determine route guidance."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the "various processes and functions described herein may either be part of the micro instruction code or part of an application program" executed by an operating system, suggesting a software-based interpretation is contemplated (’285 Patent, col. 4:52-57).
- Evidence for a Narrower Interpretation: Figure 2 depicts the "Computer Processing Module (120)" as a distinct block, separate from the "Communication Module (112)" that receives data from the server (’285 Patent, Fig. 2). This could support an argument that the "processing" to determine the route must be a self-contained function of the device itself, rather than a process heavily reliant on a "mobile website" delivered from the server.
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of inducement and contributory infringement (Compl. ¶19). However, it does not plead specific facts to support the requisite knowledge and intent, such as referencing user manuals, advertisements, or other materials that would allegedly instruct users to perform the infringing actions.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technological scope: can the claim language for a "system" comprising a "positional information device" with distinct "modules", drafted in the context of 2006-era navigation technology, be construed to read on a modern, distributed web application running on a general-purpose smartphone? The case may turn on whether the accused browser-based functionality maps onto the more hardware-centric architecture described in the patent.
- A key evidentiary question will be one of functional proof: does the "gtm.start" timestamp cited by the plaintiff (Compl. ¶28) fulfill the claim requirement that a "time and date" be transmitted with the address and displayed by the device? The court will likely need to analyze whether this timestamp is integral to the claimed routing function or an incidental artifact of web analytics, a distinction that could be dispositive for infringement of claim 13.