DCT
1:22-cv-02274
Route Guidance Systems LLC v. Here Global BV
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Route Guidance Systems LLC (Delaware)
- Defendant: HERE Global B.V. (Netherlands)
- Plaintiff’s Counsel: Devlin Law Firm LLC
- Case Identification: Route Guidance Systems LLC v. HERE Global B.V., 1:22-cv-02274, N.D. Ill., 05/02/2022
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendant HERE maintains an established place of business in Chicago.
- Core Dispute: Plaintiff alleges that Defendant’s HERE WeGo mobile application and associated backend server infrastructure infringe a patent related to methods for efficiently delivering route guidance data to vehicles.
- Technical Context: The technology addresses the challenge of providing centralized, server-based vehicle navigation by using intermittent, short-burst data transmissions to conserve network bandwidth, a significant concern for early-generation wireless networks.
- Key Procedural History: The complaint does not allege any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2001-05-04 | ’876 Patent Priority Date |
| 2005-07-12 | ’876 Patent Issue Date |
| 2022-05-02 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,917,876 - “Route Guidance for Vehicles,” issued July 12, 2005
The Invention Explained
- Problem Addressed: The patent's background section describes prior art route guidance systems as requiring a continuous, open transmission channel between a central computer and a vehicle. This approach was inefficient, incurred high running costs, and limited the number of vehicles a system could support, particularly given the low data rates of wireless networks at the time (Compl. ¶¶ 13-14; ’876 Patent, col. 2:21-23).
- The Patented Solution: The invention proposes a system where a central computer calculates a route and transmits the guidance data to an in-vehicle device over a communication channel that is opened only for a "short burst" and is "then closed." The channel remains closed until a further transmission is needed, for example, if traffic conditions change or the driver deviates from the route. This intermittent communication method is designed to increase system scalability and reduce operational costs (Compl. ¶ 11; ’876 Patent, col. 1:64-2:2). The method of operation describes this as transmitting a compressed data message with all route points for the entire journey in a single transmission, after which the channel is closed (’876 Patent, col. 4:5-20).
- Technical Importance: This approach aimed to make centralized, real-time route guidance practical and scalable for a large number of vehicles over the capacity-constrained 2G wireless networks prevalent around the year 2000 (Compl. ¶ 13).
Key Claims at a Glance
- The complaint asserts independent claims 1 (system) and 26 (method) (’Compl. ¶ 33).
- Independent Claim 1 recites the following essential elements for a route guidance system:
- a central computer adapted to calculate route guidance data providing a route for the vehicle to the desired destination;
- means for supplying the vehicle with the route guidance data calculated by the central computer, providing a channel of communication which is opened to transmit said route guidance data to the vehicle in a short burst and is then closed, so that transmission to the vehicle via said channel ceases, unless and until a need for further transmission...arises;
- means for receiving the route guidance data calculated by the central computer; and
- means for presenting respective instructions to the vehicle as to the route to be taken to the desired destination.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The complaint identifies the accused instrumentalities as the "HERE WeGo App, along with associated hardware and/or software, including but not limited to HERE's back-end servers and related computer systems operated by HERE" (Compl. ¶ 33).
Functionality and Market Context
The complaint alleges that these components form a system for providing route guidance. HERE's backend servers are alleged to perform route calculation, while the HERE WeGo App, running on a user's device, receives and presents the route guidance (Compl. ¶ 33). The complaint frames this functionality as an improvement over older systems by using packet data networks for communication, which it equates to the "short burst" communication taught by the patent, thereby allowing the system to support a large number of users simultaneously (Compl. ¶¶ 19-20). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’876 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a central computer adapted to calculate route guidance data providing a route for the vehicle to the desired destination; | HERE's "back-end servers and related computer systems" are alleged to calculate routes for users of the HERE WeGo App. | ¶33 | col. 4:5-8 |
| means for supplying the vehicle with the route guidance data..., providing a channel of communication which is opened to transmit said route guidance data to the vehicle in a short burst and is then closed... | The complaint alleges that the accused system's use of packet data networks for communication constitutes transmission in "short bursts," contrasting it with older, continuously open circuit-switched connections. | ¶¶18, 20-21 | col. 1:64-2:2 |
| means for receiving the route guidance data calculated by the central computer; | The HERE WeGo App on a user's device is alleged to be the means for receiving route guidance data from HERE's servers. | ¶33 | col. 1:60-63 |
| means for presenting respective instructions to the vehicle as to the route to be taken to the desired destination. | The HERE WeGo App is alleged to present driving instructions to the user, including through "text-to-speech" technology. | ¶¶25, 33 | col. 1:20-24 |
Identified Points of Contention
- Scope Questions: The core of the dispute may turn on whether a modern, "always-on" packet-switched data connection (e.g., 4G/5G/Wi-Fi) used by a mobile app can be considered a "channel of communication which is... closed" when data is not actively being transmitted. The court will have to determine if this claim language, drafted in the era of dial-up and circuit-switched data, reads on the fundamentally different architecture of modern mobile data networks.
- Technical Questions: Claim 1 is written in means-plus-function format under 35 U.S.C. § 112(f). This raises the question of what specific structure disclosed in the '876 patent corresponds to the claimed "means for supplying." The infringement analysis will require a comparison of that disclosed structure to the architecture of the accused HERE backend servers and network infrastructure.
V. Key Claim Terms for Construction
The Term: "a channel of communication which is opened to transmit said route guidance data to the vehicle in a short burst and is then closed"
Context and Importance: This term is central to the patent's asserted novelty over prior art that allegedly required a continuously open channel. The viability of the infringement claim depends on whether the operation of the accused HERE WeGo app and its underlying packet-switched data connection falls within the scope of this "open... and then closed" limitation. Practitioners may focus on this term because its construction will likely be dispositive of infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent repeatedly contrasts the invention with systems where the channel is "kept permanently open" (’876 Patent, col. 2:21-23). Plaintiff may argue that any communication method that does not transmit data continuously for the entire duration of a trip, such as the intermittent data packets used by mobile apps, embodies the inventive concept of a non-permanent channel, and thus the channel is effectively "closed" between packets.
- Evidence for a Narrower Interpretation: The specification describes an affirmative sequence of events: a channel is "opened to transmit," and "is then closed, so that transmission... ceases" (’876 Patent, col. 1:64-2:2). This language, along with the description of a single compressed data message being downloaded at the start of a journey, could support a narrower interpretation requiring a discrete termination of the communication session, rather than the mere absence of data flow over a persistently available packet-switched connection.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that HERE encourages infringement by its "partners, drivers, clients, customers/subscribers, and end users" through actions such as "advertising and distributing the Accused Instrumentalities" (Compl. ¶¶ 35-36).
- Willful Infringement: The willfulness allegation is based on knowledge of the '876 patent acquired "since at least the time of receiving this Complaint," indicating a claim for post-suit willfulness (Compl. ¶ 38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the phrase "a channel of communication which is... opened... and is then closed," which was conceived to distinguish from continuously open circuit-switched data calls, be construed to cover the persistent, "always-on" nature of modern packet-switched mobile data connections where data is transmitted intermittently?
- A second key issue will be one of structural correspondence under § 112(f): because Claim 1 is drafted in means-plus-function format, the analysis will require the court to first identify the specific structures disclosed in the '876 patent specification that perform the claimed functions (e.g., "means for supplying") and then determine whether the accused HERE server and network architecture is the same as or equivalent to those disclosed structures.