DCT
1:25-cv-03357
Artax LLC v. Verizon Connect Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Artax LLC (Texas)
- Defendant: Verizon Connect, Inc. (Delaware)
- Plaintiff’s Counsel: Insight, PLC; Key Kesan Dallmann PLLC
- Case Identification: 1:25-cv-03357, N.D. Ga., 06/16/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Georgia because Defendant has committed acts of infringement and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s fleet management solutions infringe three patents related to networked vehicle navigation, route planning with spatial and non-spatial data, and the sharing of relative position information.
- Technical Context: The lawsuit concerns fleet management and telematics technology, a field focused on using GPS, network connectivity, and software to optimize vehicle routing, asset tracking, and logistics for commercial enterprises.
- Key Procedural History: The complaint notes that U.S. Patent No. 8,509,412 is part of a family of patents that includes an earlier issued patent. This shared prosecution history may be relevant for purposes of claim construction.
Case Timeline
| Date | Event |
|---|---|
| 2001-07-17 | Earliest Priority Date for '581 and '412 Patents |
| 2003-02-14 | Earliest Priority Date for '343 Patent |
| 2011-09-13 | '581 Patent Issued |
| 2012-05-01 | '343 Patent Issued |
| 2013-08-13 | '412 Patent Issued |
| 2025-06-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,019,581 - "System and Method for Providing Routing, Mapping, and Relative Position Information to Users of a Communication Network"
- Patent Identification: U.S. Patent No. 8,019,581, "System and Method for Providing Routing, Mapping, and Relative Position Information to Users of a Communication Network," issued September 13, 2011.
The Invention Explained
- Problem Addressed: The patent describes prior art navigation systems as reliant on local, static data storage, such as CD-ROM or DVD discs, which were cumbersome, required periodic replacement to stay current, and were often inaccurate, particularly for data like telephone numbers that change frequently ('581 Patent, col. 1:37-2:16).
- The Patented Solution: The invention proposes a networked system where a mobile communication device (e.g., a cell phone) works in concert with a complementary in-vehicle device. The mobile device requests and receives up-to-date navigational and position information from an online server, which is then passed to the in-vehicle device for display, overcoming the limitations of static, locally stored maps ('581 Patent, Abstract; col. 2:44-56).
- Technical Importance: This technology represents a shift from self-contained, offline navigation units to dynamic, network-connected systems capable of providing real-time, reliable routing information (Compl. ¶15).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶35).
- Key elements of claim 1 include:
- Receiving location information from a GPS receiver on a wireless communication device.
- Receiving destination information.
- Sending a request for navigational information from the wireless device to a server.
- The server querying a remote party for permission to grant the position request.
- The wireless device receiving the navigational information back from the server.
- Sending the received navigational information from the wireless device to a separate in-vehicle navigational device.
- Displaying driving directions on the in-vehicle device.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,169,343 - "Method and System for Saving and Retrieving Spatial Related Information"
- Patent Identification: U.S. Patent No. 8,169,343, "Method and System for Saving and Retrieving Spatial Related Information," issued May 1, 2012.
The Invention Explained
- Problem Addressed: The patent identifies a need for a system that can store, link, and graphically display both spatial data (i.e., location) and non-spatial "Meta data" (e.g., images, forms, messages, waypoints) in an integrated manner ('343 Patent, col. 1:49-55).
- The Patented Solution: The invention describes a method and system for associating spatial and non-spatial data and displaying it in a temporal or indexed format, such as a Calendar or Gantt view. This allows users of GPS-enabled devices to utilize various forms of data within a single graphical application ('343 Patent, col. 1:55-62).
- Technical Importance: This approach enabled the creation of richer, context-aware applications by combining location information with other relevant data, moving beyond simple map displays (Compl. ¶23).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶47).
- Key elements of claim 1 (a machine-readable medium claim) include steps for:
- Receiving "presence information" including a start time, end time, origin point, and destination point.
- Determining at least one stop point with an expected duration.
- Adding the stop point(s) to the route.
- Determining a route that includes the stop point(s).
- Providing directions for the route.
- Estimating a travel time for the route.
- Comparing the travel time with the duration of the presence information.
- Updating the presence information in response to the comparison.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,509,412 - "System and Method for Providing Routing, Mapping, and Relative Position Information to Users of a Communication Network"
- Patent Identification: U.S. Patent No. 8,509,412, "System and Method for Providing Routing, Mapping, and Relative Position Information to Users of a Communication Network," issued August 13, 2013.
- Technology Synopsis: The patent addresses the shortcomings of prior art systems that were "incapable of obtaining position information over dynamically-configured connections" and required static registration of device addresses (Compl. ¶32; ’412 Patent, col. 2:17-21). The invention provides a system for obtaining and sharing real-time position information between wireless devices using an online database and networked authentication, providing benefits of real-time information sharing between parties (Compl. ¶¶33, p. 12).
- Asserted Claims: Independent Claim 1 (Compl. ¶60).
- Accused Features: The complaint alleges that the Accused Products, by enabling near real-time tracking and location sharing between devices (e.g., a driver's device and a manager's device) over a network, infringe the ’412 Patent (Compl. ¶¶61-65). Figure 3-2 describes the vehicle tracking functionality, where a GPS receiver transmits information via GPRS to web servers (Compl. p. 43).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are identified as Verizon's fleet management solutions, delivered as a software-as-a-service, including the "Verizon Connect platform," which utilizes hardware like GPS tracking devices in conjunction with software applications such as "Fleet Tracking" and "Route Cloud" (Compl. ¶5).
Functionality and Market Context
- The Accused Products constitute a telematics system that uses in-vehicle hardware and networked software to provide near real-time monitoring and management of a vehicle fleet (Compl. ¶5, Fig. 2). The system's functionality includes collecting GPS and other telematics data from vehicles, transmitting it to Verizon's servers, and using that data for route planning, turn-by-turn navigation, and displaying vehicle locations on a live map for fleet managers (Compl. ¶3, Fig 1-6, Fig 1-16). Figure 1-11 explains that the Verizon Connect system uses the "RouteCloud application programming interface (API)" for route planning (Compl. p. 19).
IV. Analysis of Infringement Allegations
'581 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [1a] receiving location information of said wireless communication device using said GPS receiver... | The Accused Products utilize in-vehicle GPS hardware to receive location information for a vehicle, which contains a wireless communication device (Compl. ¶37). | ¶37 | col. 6:15-19 |
| [1b] receiving destination information... | The system receives destination information from a user for the purpose of planning a route (Compl. ¶38). | ¶38 | col. 6:20-22 |
| [1c] sending, from said wireless communication device, a request for navigational information...to a server... | The wireless device sends a request with job data and other variables to the RouteCloud API (server) to determine a route (Compl. ¶39). | ¶39 | col. 6:23-29 |
| [1d] wherein the server queries a remote party of position request for permission on whether the position request can be granted based on criteria | The complaint alleges this is met by the application requesting user permission for location access during setup (Compl. ¶40, Fig 1-17). Figure 1-17 depicts an Android application permissions screen for "Navigation by Verizon Connect" (Compl. p. 22). | ¶40 | col. 5:20-29 |
| [1e] receiving, by said wireless communication device from said server...said navigational information | The driver's wireless device receives optimized route information back from the Verizon Connect server (Compl. ¶41). | ¶41 | col. 6:34-37 |
| [1f] sending, from said wireless communication device to an in-vehicle navigational device... | The system provides the generated route information to the driver's in-vehicle display device (Compl. ¶42). | ¶42 | col. 6:38-41 |
| [1g] displaying, at a display device of said in-vehicle navigational device, driving directions... | The in-vehicle device displays turn-by-turn navigation for the received route (Compl. ¶43). | ¶43 | col. 6:42-48 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the interpretation of "the server queries a remote party...for permission." The complaint proffers a one-time application permission grant as satisfying this element. This raises the question of whether this claim language requires a dynamic, request-specific query for authorization, as opposed to a static, one-time permission setting.
- Technical Questions: The claim recites sending information from a "wireless communication device" to an "in-vehicle navigational device." A question may arise as to whether these are functionally distinct components in the accused system, or if a single device (e.g., a tablet) performs both roles, and whether such an architecture would meet the claim limitations.
'343 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [1a] receiving presence information including a start time, an end time, an origin point, and a destination point | The RouteCloud system receives inputs including start/end times and origin/destination locations to plan a route (Compl. ¶49). | ¶49 | col. 5:48-52 |
| [1b] determining at least one stop point associated with the presence information, each of the at least one stop point associated with a duration... | The system allows for the inclusion of stop points, such as jobs, which have an associated "time_on_site" or duration (Compl. ¶50). | ¶50 | col. 5:53-57 |
| [1c] adding each of the at least one stop point to the route, each of the at least one stop point between the starting point and the destination point | The system's multi-stop route planning functionality adds the determined stop points into the sequence between the origin and destination (Compl. ¶51). | ¶51 | col. 5:58-61 |
| [1d] determining a route between the origin point and the destination point, the route including each of the at least one stop point | The system determines an optimized route that incorporates the specified origin, destination, and all intermediate stop points (Compl. ¶52). Figure 2-15 displays a map with annotations identifying the 'Route Start Point,' 'Stops Along the route,' and 'Route END POINT' (Compl. p. 35). | ¶52 | col. 5:62-64 |
| [1e] providing direction in response to the route | The system provides turn-by-turn directions and other guidance for the determined route (Compl. ¶53). | ¶53 | col. 5:65-66 |
| [1f] estimating a travel time for the route in response to the duration associated with each of the at least one stop | The system calculates and displays an estimated duration and travel time for the entire route, which accounts for the duration of stops (Compl. ¶54). | ¶54 | col. 5:67-6:2 |
| [1g] comparing the travel time with a duration between the start time and the end time of the presence information | The complaint alleges this is met by the system's ability to create a route overview with estimated time durations, which it implicitly compares to the overall work period (Compl. ¶55). | ¶55 | col. 6:3-6 |
| [1h] updating the presence information in response to the comparison | The complaint alleges this step is performed through features that allow for managing routes and adapting to last-minute changes (Compl. ¶56). | ¶56 | col. 6:7-9 |
- Identified Points of Contention:
- Scope Questions: The definition of "presence information" will be critical. The patent specification describes it broadly as a user's status (e.g., "Available," "En Route"), while the claim recites it "including a start time, an end time, an origin point, and a destination point." The proper construction of this term will impact the viability of the infringement theories for the final claim elements.
- Technical Questions: A key technical question is whether the Accused Products perform the specific logical sequence recited in elements [1g] and [1h]. The complaint does not provide direct evidence that the system explicitly compares the total route time to the overall "presence information" duration and then updates that presence information as a direct result of the comparison. A defense may suggest that route optimization is a different function than the specific comparison-and-update sequence claimed.
V. Key Claim Terms for Construction
'581 Patent
- The Term: "queries a remote party of position request for permission" (from claim 1)
- Context and Importance: This term is central to the infringement analysis for the ’581 Patent. The Plaintiff's case may depend on this phrase being construed broadly enough to cover a one-time application permission grant. Practitioners may focus on this term because the complaint's supporting evidence (an app permissions screen) may not align with a plain reading of a dynamic "query."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses the use of "authentication and authorization protocols" generally, which a party could argue is a broad category that includes initial, one-time permission settings to enable the service ('581 Patent, col. 2:53-56).
- Evidence for a Narrower Interpretation: The claim's use of the active verb "queries" in the context of a "position request" suggests a specific, event-driven action rather than a static, pre-existing state. The specification also describes privacy settings that can be configured to "allow position information to be received while calls are received" or "for a given period of time," suggesting a more granular control than a one-time app installation permission ('581 Patent, col. 10:1-10).
'343 Patent
- The Term: "presence information" (from claim 1)
- Context and Importance: The definition of this term is critical for the final two steps of claim 1, which require comparing the route's travel time to the duration of the "presence information." If "presence information" is construed narrowly as only the route inputs, the comparison step becomes difficult to map. If construed broadly to mean a driver's entire work shift, the plaintiff's theory may be more plausible.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification explicitly defines "presence" in broad terms: "a presence field associated with a user signifies the status of a user for a specified period of time, such as Available, Busy, Away, En Route, On the Phone, At Home, At Lunch, or the like" ('343 Patent, col. 1:28-32). This supports a meaning beyond simple route start and end points.
- Evidence for a Narrower Interpretation: The claim itself states "receiving presence information including a start time, an end time, an origin point, and a destination point." A party could argue that for the purposes of this specific claim, the term is defined by these enumerated elements, limiting its scope to the primary inputs for a route plan.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of induced and contributory infringement in its introductory paragraph (Compl. ¶1). However, the specific counts for relief (Counts I, II, and III) are pleaded exclusively as direct infringement under 35 U.S.C. § 271(a), and the complaint does not plead specific facts to support the knowledge and intent elements required for indirect infringement.
- Willful Infringement: The complaint does not allege willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the act of a user granting one-time, upfront application permissions for location access be construed to meet the '581 patent's requirement that a server "queries a remote party...for permission" in response to a position request, or does the claim mandate a dynamic, per-request authorization?
- A key evidentiary question will be one of functional operation: does Verizon's RouteCloud software perform the specific, two-part logical function required by the '343 patent—first comparing an optimized route's travel time against the total duration of a broader "presence information" (like a work shift), and then updating that presence information based on the comparison—or is this an attempt to map claim language onto a more conventional route optimization algorithm that operates differently?