Geographic Locations Innovations LLC v. True Value Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: True Value Company (Delaware)
  • Plaintiff’s Counsel: RABICOFF LAW LLC
• Case Identification: 1:19-cv-00822, N.D. Ill., 02/08/2019
• Venue Allegations: Venue is alleged to be proper based on Defendant's headquarters and principal place of business being located in the district, as well as the occurrence of alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to remotely sending location data to a user's positional information device for navigation.
• Technical Context: The technology at issue addresses methods for automatically programming navigation devices with destination addresses, bypassing the need for manual user entry, a common feature in modern web and mobile applications.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit. The patent’s term was extended by 1,307 days pursuant to 35 U.S.C. § 154(b).

Case Timeline

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 the difficulty and potential safety issues of manually programming addresses into GPS devices, especially when a user is driving or owns multiple devices with different interfaces (’285 Patent, col. 1:42-50; col. 2:5-13). Manual entry can be a "laborious and timely procedure" and different devices may not recognize the same address format (’285 Patent, col. 1:53-61).
• The Patented Solution: The invention proposes a system where a user can request an address from a remote server, which then resolves the location into 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, Abstract). This architecture, depicted in Figure 3, uses a communications network to link the user's device (100) with a remote server (304), eliminating the need for manual data entry by the user (’285 Patent, Fig. 3; col. 3:9-25).
• Technical Importance: The described technical approach sought to create a safer and more efficient method for users to input destination information into navigation systems, particularly for in-transit requests or for users managing multiple devices (’285 Patent, col. 2:26-30).

Key Claims at a Glance

• The complaint asserts "at least Claim 13" of the ’285 Patent (Compl. ¶13).
• The essential elements of independent claim 13 are:
  • A server configured to receive a request for an address not already stored on a positional information device, determine the address, and transmit it to the device.
  • A positional information device comprising a locational information module, a communication module, a processing module, and a display module.
  • A communications network coupling the device to the server.
  • The server receives a time and date associated with the request and transmits this time and date with the determined address to the device.
  • The positional information device displays the determined address at the associated time and date.
• The complaint’s phrasing suggests it may reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's mobile website (https://www.truevalue.com) and its associated store locator service, referred to in the complaint as "the System" (Compl. ¶13).

Functionality and Market Context

The System allows a user of a device like a smartphone or tablet to find nearby True Value store locations (Compl. ¶14). The complaint alleges the System includes servers that receive a user's request, determine the addresses of relevant stores, and transmit this information back to the user's device (Compl. ¶15-16). The user's device then displays the store locations on a map and can provide route guidance (Compl. ¶19-20). The complaint includes a screenshot of the store locator map interface displaying multiple store locations. (Compl. p. 4). The complaint does not provide detail for analysis of the product's market positioning.

IV. Analysis of Infringement Allegations

’285 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: The complaint alleges on "information and belief" that the system transmits and displays a "time and date" with the address, reasoning that this is necessary to determine traffic conditions (Compl. ¶22). A central question will be what factual evidence supports this assertion. The visual evidence provided in the complaint does not appear to show an explicit time and date being displayed with the address as required by the claim language.
• Scope Questions: The case will likely involve the question of whether the final limitation of claim 13—"displays the determined address at the associated time and date"—is met by the accused system's functionality. The interpretation of this phrase will be critical.

V. Key Claim Terms for Construction

The Term: "displays the determined address at the associated time and date"

Context and Importance

This limitation appears at the end of independent claim 13 and recites a highly specific function. Practitioners may focus on this term because the complaint’s supporting allegations are inferential rather than demonstrative (Compl. ¶22), making it a potential focal point for a non-infringement defense.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification describes a scenario where "When the date and time changes, the GPS device will then display the next specified and stored address on the date and time that corresponds to that address" (’285 Patent, col. 10:59-62). This could be argued to mean the system displays an address that is relevant for a given time (e.g., the next stop in an itinerary), rather than requiring a literal display of a timestamp.
• Evidence for a Narrower Interpretation: The plain language of the claim requires the device to "display" the address "at" the associated time and date. This could be construed to require that the timestamp itself be visibly displayed alongside the address, or that the address is only displayed at that specific moment. The patent also discusses displaying a "planned stop" at a "suggested time and/or date" (’285 Patent, col. 12:59-62), language which may support a more specific temporal display requirement.

The Term: "positional information device"

Context and Importance

This term defines the user-end component of the claimed system. While the complaint identifies this as a smartphone or tablet (Compl. ¶14), its precise scope as defined in the patent is crucial for the infringement analysis.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification states the invention can be "applied to any type of navigation or positional information device" and gives examples including vehicle-mounted units and devices coupled to laptops (’285 Patent, col. 4:5-8). It further describes its applicability to mobile computing applications running on operating systems like SymbianOS, Windows Mobile, and Palm OS, which were precursors to modern smartphone OSs (’285 Patent, col. 4:56-62).
• Evidence for a Narrower Interpretation: The primary embodiment shown is a dedicated, handheld "GPS device 100" with specific hardware components illustrated in Figure 1, such as an input module with physical buttons (108) (’285 Patent, Fig. 1; col. 4:1-4). A party could argue that a general-purpose smartphone executing a web browser is distinct from the dedicated hardware device that is the focus of the patent's detailed description.

VI. Other Allegations

Indirect Infringement

The complaint makes a passing allegation of "contributory infringement or inducement" but does not plead specific facts to support the requisite elements of knowledge and intent, such as referencing user manuals or advertising that would encourage infringing use (Compl. ¶13).

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 evidentiary proof: Can the Plaintiff produce evidence that the accused store locator system performs the specific function recited in the "time and date" limitation of Claim 13? The complaint's theory for this element relies on an inference about traffic calculation, which is not directly substantiated by the provided screenshots or other factual allegations.
• A related and potentially dispositive question will be one of claim construction: What is the scope of the phrase "displays the determined address at the associated time and date"? Whether this requires a literal, visible timestamp or has a broader functional meaning will be a central point of legal argument that could determine the outcome of the infringement analysis.