DCT
1:19-cv-00823
Geographic Location Innovations LLC v. Echo Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: ECHO Incorporated (Illinois)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 1:19-cv-00823, N.D. Ill., 02/08/2019
- Venue Allegations: Venue is alleged to be proper because Defendant is headquartered and incorporated in the Northern District of Illinois, and alternatively, because Defendant has a regular and established place of business in the district where acts of infringement allegedly occur.
- Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to remotely programming a positional information device with address data.
- Technical Context: The technology concerns systems that allow a user to request location information from a remote server, which then transmits the address to the user's device for navigation, bypassing manual data entry.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | ’285 Patent Priority Date |
| 2011-03-29 | ’285 Patent Issue Date |
| 2019-02-08 | 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 the difficulty and potential danger of manually programming addresses into then-current GPS devices, particularly while driving (’285 Patent, col. 2:5-13). It also notes that different devices often have incompatible address formats and user interfaces, creating a laborious and frustrating user experience (’285 Patent, col. 2:42-56).
- The Patented Solution: The invention proposes a client-server system where a user transmits a request for a location to a remote server, for example through a telematics service with a live operator or a website (’285 Patent, col. 8:11-37). The server determines the coordinates for the requested location and transmits the address data directly to the user’s "positional information device," which then uses the data for route guidance without requiring manual entry (’285 Patent, Abstract; Fig. 4).
- Technical Importance: This approach aimed to improve the safety and convenience of in-vehicle navigation systems by automating the process of address entry, a significant usability challenge for early consumer GPS technology (’285 Patent, col. 2:26-31).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 13 (Compl. ¶13).
- Essential elements of independent claim 13 include:
- A server configured to receive a request for an address not already stored in a positional information device, determine the address, and transmit it to the device.
- A positional information device comprising a locational module, a communications module, a processing module to determine route guidance, and a display module.
- A communications network coupling the server and the device.
- A requirement that the server receives a time and date associated with the request and transmits this time and date with the determined address to the device, which then displays the address at the associated time and date.
- 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 service,” which the complaint identifies as a "mobile website with associated hardware and software" available at "https://www.echo-usa.com" (Compl. ¶13).
Functionality and Market Context
- The service allows a user to find nearby ECHO store locations (Compl. ¶14). The complaint alleges the system involves the user's device (e.g., a smartphone or tablet) sending a request to ECHO’s server(s), which determine the addresses of nearby stores and transmit them back to the user's device (Compl. ¶15-16). The device then displays the store locations on a map and can provide route guidance (Compl. ¶19). A screenshot in the complaint shows a user's device being prompted to allow the website to use its location, indicating the interactive nature of the service (Compl. 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... and to transmit the determined address to the positional information device | Defendant's server(s) receive a request for a nearby branch location, determine the address(es) of the branch(es), and transmit them to the user's device. | ¶15-16 | col. 8:11-19 |
| the positional information device including a locational information module for determining location information of the positional information device | The user's device (e.g., smartphone) includes a locational information module like GPS hardware to determine its own location. | ¶17 | col. 5:4-14 |
| a communication module for receiving the determined address of the at least one location from the server | The user's device includes a communications module (e.g., cellular or Wi-Fi components) that receives the determined store address(es) from the server(s). | ¶18 | col. 6:40-48 |
| a processing module configured to receive the determined address... and determine route guidance based on the location of the positional information device and the determined address | The user's device uses mapping software and the mobile website to determine route guidance. A screenshot shows turn-by-turn directions generated by the system. | ¶19, p. 6 | col. 8:1-5, col. 4:5-9 |
| a display module for displaying the route guidance | The screen of the user's device displays the route guidance. A screenshot shows a map with a plotted route. | ¶20, p. 7 | col. 5:32-43 |
| a communications network for coupling the positional information device to the server | A communications network, such as a cellular network, is used to couple the user's device to the server(s). | ¶21 | col. 8:15-28 |
| 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 complaint alleges that the time and date must be sent to the server to determine traffic conditions for varying routes. | ¶22 | col. 10:51-61 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a modern smartphone or tablet running a web browser constitutes a "positional information device" as contemplated by the patent, which focuses its background discussion on dedicated in-vehicle GPS units.
- Technical Questions: The complaint's allegation for the "time and date" limitation appears to be based on an inference that the system must transmit this data to provide features like traffic-aware routing (Compl. ¶22). A key factual question will be whether the accused system actually transmits and uses discrete "time and date" data in the manner required by the claim, or if this functionality is achieved through other means. The complaint provides no direct evidence, such as data packet captures, to support this specific allegation.
V. Key Claim Terms for Construction
- The Term: "positional information device"
- Context and Importance: The definition of this term is critical. Defendant may argue that the term is limited to the dedicated, vehicle-integrated or portable GPS units described in the patent's background, which would not read on the accused instrumentality of a general-purpose smartphone or computer accessing a website. Plaintiff will likely argue for a broader construction.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the invention "may be applied to any type of navigation or positional information device including but not limited to a vehicle-mounted device, a GPS receiver coupled to a desktop computer or laptop, etc." (’285 Patent, col. 8:5-9). This language may support a construction that includes modern multi-function devices.
- Evidence for a Narrower Interpretation: The "Background of the Invention" section exclusively discusses problems associated with "GPS (Global Positioning System) devices" that are "particularly useful in automobiles and other vehicles" (’285 Patent, col. 2:14-24). An argument could be made that the term's meaning is informed and limited by this context.
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of contributory infringement and inducement (Compl. ¶13). It does not, however, plead specific facts to support the knowledge and intent elements, such as detailing how Defendant's instructions or manuals direct users to perform the infringing steps.
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to center on the application of a 2006-era patent to modern web-based mapping technology. The outcome will likely depend on the court's resolution of two primary questions:
A core issue will be one of definitional scope: Can the term "positional information device", which is rooted in the patent's description of dedicated GPS units, be construed broadly enough to encompass a modern smartphone or computer rendering a standard website?
A key evidentiary question will be one of technical proof: Can the Plaintiff provide evidence that ECHO's store locator system performs the specific function of receiving and transmitting a "time and date" associated with a location request, as strictly required by the final limitation of asserted claim 13, or is the complaint's allegation on this point merely inferential?