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: 1:25-cv-20787, 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 acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s GPS products infringe a patent related to a vehicle warning system that alerts drivers of large vehicles to low-clearance obstacles.
• Technical Context: The technology addresses collision avoidance for large vehicles like trucks and RVs, a critical safety issue in the logistics and transportation industries.
• 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

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.

The Invention Explained

• Problem Addressed: The patent identifies the problem of commercial truck, bus, and RV drivers who must safely navigate their high-profile vehicles under structures like bridges, tunnels, and underpasses. A driver’s failure to know their vehicle’s height relative to an upcoming obstacle can lead to collisions, and rerouting after discovering an impassable structure wastes time and resources (’205 Patent, col. 1:56- col. 2:2).
• The Patented Solution: The invention proposes a dedicated in-vehicle GPS system that stores the vehicle's height and a database of low-clearance structures with their GPS coordinates and clearance measurements (’205 Patent, col. 2:31-44). When the system detects the vehicle is approaching a structure with insufficient clearance, it provides a "loud audible sound and flashing light" to warn the driver and can display alternate routes (’205 Patent, col. 2:41-44, col. 2:55-59). Figure 4 illustrates the system (100) in a truck (172) approaching a low-clearance overpass (176), triggering a warning.
• Technical Importance: The system aims to provide a reliable, automated safety mechanism to prevent costly and dangerous collisions that rely on driver memory or roadside warnings alone (’205 Patent, col. 2:13-18).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary claims" without specifying claim numbers, but incorporates claim charts by reference (’205 Patent, Compl. ¶11). Independent claim 1 is the broadest system claim.
• Essential elements of Independent Claim 1 include:
  • a main body with a hollow interior volume
  • a computer module located within the body, programmed with information about roads, bridges, viaducts, and underpasses
  • a GPS module located within the body to provide location information
  • at least one warning mechanism electrically connected to the computer module to provide a loud audible sound
  • a display screen on an outer surface to provide visual information, including the height of an approaching bridge or underpass
  • the computer module processes location information and determines when to send a signal to the warning mechanism
  • the computer module initiates the warning when the device is within a predetermined distance of a dangerous structure
• The complaint reserves the right to assert other claims, including dependent claims (’205 Patent, Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Exemplary Defendant Products" which are detailed in external charts referenced as Exhibit 2, but does not name any specific Garmin products in the body of the complaint (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint broadly alleges that Defendant makes, uses, sells, and imports infringing products (Compl. ¶11). It alleges these products are used by Defendant’s employees and sold to customers for end-user applications that infringe the '205 patent (Compl. ¶12, ¶15). The complaint does not provide specific details on the technical functionality or market position of the accused products, instead incorporating these details by reference to an unprovided exhibit (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" satisfy all elements of the "Exemplary '205 Patent Claims" either literally or under the doctrine of equivalents (Compl. ¶16). However, the specific factual basis for this allegation is contained in charts in "Exhibit 2," which is incorporated by reference but not attached to the pleading provided (Compl. ¶17). The complaint therefore does not provide sufficient detail for a claim-element-by-element analysis of the infringement allegations.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether standard consumer or commercial GPS devices, such as those sold by Garmin, meet the specific combination of elements required by the claims. For example, Claim 4 requires that the "computer module is further adapted to prevent the automobile from being operated until the GPS and warning device is turned on and activated" (’205 Patent, col. 6:64-67). It is a point of contention whether a standalone GPS device, not integrated with a vehicle's ignition or engine control systems, can perform this function.
• Technical Questions: The complaint's infringement theory relies on charts that are not provided (Compl. ¶17). A key technical question will be what evidence Plaintiff presents to demonstrate that the accused Garmin products contain a "computer module... programmed with information pertaining to... underpass clearance measurements" and a "warning mechanism" that provides a "loud audible sound" specifically for this purpose, as opposed to a general-purpose navigation and alert functionality (’205 Patent, col. 6:15-30).

V. Key Claim Terms for Construction

The Term

"computer module is further adapted to prevent the automobile from being operated" (from dependent claim 4).

Context and Importance

This term is critical because it appears to describe a system with a hard-wired interlock function that disables the vehicle, a feature not typically found in aftermarket GPS units. Proving that a standard Garmin product is "adapted to" perform this function may be a significant hurdle for the plaintiff and a key non-infringement argument for the defendant. Practitioners may focus on whether "adapted to" requires specific structural design for this purpose or could be met by software that, for example, simply refuses to provide navigation until activated.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent does not specify the mechanism for preventing operation. A plaintiff could argue that "prevent... from being operated" does not strictly require an engine kill-switch, but could be interpreted more broadly to mean preventing the driver from using the vehicle for its intended purpose (e.g., by withholding navigation guidance until the safety system is active).
• Evidence for a Narrower Interpretation: The specification describes the invention as a single, integrated "GPS and warning system" located within a "main body" (’205 Patent, col. 4:39-41). The detailed description repeatedly discusses the system being "turned on and activated" as a prerequisite for vehicle operation, which suggests a direct, physical or electronic link to the vehicle's operational systems, not merely a software feature on a standalone device (’205 Patent, col. 3:20-22, col. 4:65-67).

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 products in a manner that infringes the '205 patent (Compl. ¶14).

Willful Infringement

The complaint alleges Defendant has actual knowledge of infringement at least from the service of the complaint and its attached claim charts (Compl. ¶13). It alleges that despite this knowledge, Defendant continues its infringing activities (Compl. ¶14).

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

1. A core issue will be one of technical capability and claim scope: Can a standalone, aftermarket GPS device be considered "adapted to prevent the automobile from being operated," as required by dependent claim 4? The case may turn on whether this limitation requires a physical vehicle interlock system, which the accused products may lack.
2. A key evidentiary question will be one of infringement evidence: As the complaint's specific infringement contentions are located in an unprovided exhibit, the case will depend on the evidence Plaintiff ultimately produces to show that the accused Garmin products perform each specific function of the claimed system, as opposed to providing general navigation alerts that a user could interpret as a warning.
3. A third question relates to inducement: Assuming the accused products do not directly infringe out of the box, what specific instructions in Defendant's "product literature and website materials" actively encourage users to combine the product with other components or use it in a specific way that satisfies all limitations of a claim?