DCT

1:22-cv-02275

Route Guidance Systems LLC v. American Honda Motor Co Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-02275, N.D. Ill., 05/02/2022
  • Venue Allegations: Venue is based on Defendants maintaining an established place of business in the district, specifically a training center in Hoffman Estates, Illinois.
  • Core Dispute: Plaintiff alleges that Defendant’s Honda Satellite-Linked Navigation System infringes a patent related to methods for providing vehicle route guidance from a central computer using intermittent, short-burst data transmissions.
  • Technical Context: The technology addresses the problem of network inefficiency in early-generation centralized vehicle navigation systems by minimizing the time a communication channel remains open between a vehicle and a server.
  • Key Procedural History: The complaint makes no mention of prior litigation, IPR proceedings, or licensing history. It does, however, include substantial pre-emptive arguments that the patented invention represents a specific, communication-related technological improvement and is not merely an abstract idea, suggesting an anticipation of a patent-eligibility defense under 35 U.S.C. § 101.

Case Timeline

Date Event
2001-05-04 U.S. Patent No. 6,917,876 Priority Date
2005-07-12 U.S. Patent No. 6,917,876 Issued
2022-05-02 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

  • Patent Identification: U.S. Patent No. 6,917,876, "Route Guidance for Vehicles," issued July 12, 2005. (Compl. ¶9, ¶32).

The Invention Explained

  • Problem Addressed: The patent describes prior art vehicle navigation systems as requiring a transmission channel between a central computer and a vehicle to remain permanently open during guidance (Compl. ¶11, ¶18). This approach was described as inefficient, increasing running costs, and limiting the number of vehicles a system could support, particularly on the low-bandwidth wireless networks available at the time of the invention (Compl. ¶14; ’876 Patent, col. 4:53-60).
  • The Patented Solution: The invention proposes a system where a central computer calculates a route and transmits the guidance data to the vehicle in a "short burst," after which the communication channel is "closed" (Compl. ¶12; ’876 Patent, Abstract). This method of intermittent communication is intended to cease transmission "unless and until a need for further transmission via said channel to said vehicle arises," thereby conserving network resources and enabling greater system scalability (’876 Patent, col. 1:64-2:2).
  • Technical Importance: This approach aimed to make centralized, real-time vehicle navigation more scalable and cost-effective on the limited-capacity second-generation (2G) wireless networks of the early 2000s (Compl. ¶14, ¶21).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (a system claim) and 26 (a method claim) (’876 Patent, col. 5:1-12, col. 7:26-40; Compl. ¶34).
  • Independent Claim 1 (System): The key elements include:
    • a central computer adapted to calculate route guidance data;
    • means for supplying the vehicle with the calculated 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, so that transmission to the vehicle via said channel ceases";
    • means for receiving the data in the vehicle; and
    • means for presenting instructions to the driver.
  • Independent Claim 26 (Method): The key steps include:
    • supplying route guidance data from a central computer to a vehicle by "opening a channel of communication to transmit the route guidance data to the vehicle in a short burst";
    • "then closing said channel of communication so that transmission to that vehicle via said channel ceases, unless and until a need for further transmission...arises"; and
    • presenting instructions to the driver.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are the "Honda Satellite-Linked Navigation System, along with associated hardware and/or software, including but not limited to Honda's back-end servers and related computer systems" (Compl. ¶34).

Functionality and Market Context

  • The complaint alleges that the accused system provides centralized route guidance and navigation to users (Compl. ¶21). It further alleges that these systems work in conjunction with back-end servers operated by Honda (Compl. ¶34). The complaint does not provide specific technical details on the operation of the accused system, instead referencing "preliminary and exemplary claim charts provided in Exhibit 2" (Compl. ¶34). This exhibit was not included with the complaint document.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided, and therefore a summary table cannot be constructed. The narrative infringement theory alleges that the accused Honda navigation system, including its in-vehicle components and back-end servers, practices the patented method (Compl. ¶34). The core of the allegation is that Honda’s back-end servers function as the claimed "central computer," calculating routes and transmitting them to vehicles. This transmission is alleged to occur over a communication channel that is opened for a "short burst" and then closed, mirroring the central limitations of asserted claims 1 and 26.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern the interpretation of the phrase "a channel of communication which is opened...and is then closed." The question is whether this language, drafted when circuit-switched data calls were a common paradigm, can be read to cover intermittent data transmission over modern, "always-on" packet-switched networks.
    • Technical Questions: A key factual question is how the accused Honda system's communication protocol actually functions. Does the system establish and terminate a distinct communication session for each route data transfer, or does it maintain a persistent underlying connection over which data packets are sent intermittently? The complaint does not provide sufficient detail for analysis of the accused system's specific protocol.

V. Key Claim Terms for Construction

  • The Term: "a channel of communication which is opened to transmit...and is then closed" (Claim 1)

    • Context and Importance: This limitation is central to the patent's purported novelty over prior art that allegedly kept channels "permanently open" (Compl. ¶11; ’876 Patent, col. 2:21-23). The construction of this term will be critical in determining whether the operation of a modern navigation system on a packet-switched network falls within the scope of the claims.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s emphasis on solving the problem of a "permanently open" channel and reducing "running costs" could support an interpretation where any intermittent data transmission, regardless of the underlying network layer's state, meets the limitation (’876 Patent, col. 2:21-23, col. 4:57-60).
      • Evidence for a Narrower Interpretation: The specification's description of the system using a "single mobile telephone connection" could be argued to invoke a model more akin to a circuit-switched call that is formally established and terminated, rather than just the transmission of packets over a persistent IP connection (’876 Patent, col. 4:56-60).

  • The Term: "short burst" (Claim 1)

    • Context and Importance: This term defines the nature of the data transmission. Its construction is linked to the "open...and is then closed" limitation and is necessary to distinguish the claimed invention from a continuous data stream.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's stated goal of freeing up bandwidth for other users suggests "short burst" could be construed broadly to mean any non-continuous, packetized transmission of data (Compl. ¶23).
      • Evidence for a Narrower Interpretation: The specification describes downloading a "compressed data message including all route points in respect of the entire best route" in a "single transmission," which could support a narrower definition tied to the transfer of a complete set of route data at one time (’876 Patent, col. 4:4-15).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement, asserting that Honda advertises, distributes, and provides materials for the accused systems with the specific intent to cause infringement by end users and partners (Compl. ¶36-37). It also alleges contributory infringement, claiming the accused products are material components especially adapted for infringing use and are not staple articles of commerce (Compl. ¶38).
  • Willful Infringement: Willfulness is alleged based on knowledge of the patent "since at least the time of receiving this Complaint" (Compl. ¶39). No allegations of pre-suit knowledge are made (Compl. ¶35).

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

  • A core issue will be one of technological translation: Can the claim term "a channel of communication which is opened...and is then closed," which was written to distinguish from the "permanently open" channels of the early 2000s, be construed to cover the inherently "bursty" but persistent connections of modern packet-switched mobile networks? The resolution of this question will likely determine the outcome of the infringement analysis.
  • A key evidentiary question will be one of technical operation: Discovery will need to establish the specific communication protocols used by the Honda Satellite-Linked Navigation System. The case may turn on factual findings as to whether the system establishes and terminates discrete communication sessions for route data updates or simply transmits packets over an "always-on" underlying network connection.