Route Guidance Systems LLC v. Salesforcecom

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Route Guidance Systems LLC (Delaware)
  • Defendant: Salesforce.com, Inc. (Delaware)
  • Plaintiff’s Counsel: Devlin Law Firm LLC
• Case Identification: 1:22-cv-02279, N.D. Ill., 05/02/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Salesforce maintains an established place of business in the district, specifically an office in Chicago.
• Core Dispute: Plaintiff alleges that Defendant’s Salesforce Maps App and associated back-end systems infringe a patent related to efficiently providing vehicle route guidance over a communications network.
• Technical Context: The technology concerns server-based vehicle navigation systems that manage network resources by transmitting route data intermittently rather than through a continuously open connection.
• 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

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

U.S. Patent No. 6,917,876 - "Route Guidance for Vehicles"

• Patent Identification: U.S. Patent No. 6,917,876, "Route Guidance for Vehicles", issued July 12, 2005.

The Invention Explained

• Problem Addressed: The patent describes a problem with prior art route guidance systems that required a transmission channel between a central computer and a vehicle to be kept "permanently open" ('876 Patent, col. 2:21-23). This approach was inefficient, costly, and limited the number of vehicles a system could support, particularly given the low-bandwidth wireless networks available at the time of the invention (Compl. ¶13-14).
• The Patented Solution: The invention proposes a system that conserves network resources by opening a communication channel only to transmit route guidance data in a "short burst," and then closing the channel until a further transmission is needed ('876 Patent, col. 1:64-2:2). The detailed description explains that an in-vehicle device receives a compressed data message with "route points" for the entire journey in a "single transmission," after which the communication channel is closed unless the user requests a new route or traffic conditions change ('876 Patent, col. 4:5-20).
• Technical Importance: This on-demand, burst-based communication method was designed to increase system scalability and reduce operational costs compared to systems requiring persistent connections ('876 Patent, col. 4:53-60).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 26 (Compl. ¶33).
• Independent Claim 1:
  • A route guidance system comprising a central computer adapted to calculate route guidance data.
  • Means for supplying the vehicle with the calculated route guidance data.
  • This supply means provides 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 channel ceases transmission "unless and until a need for further transmission...arises."
  • Means for receiving the route guidance data at the vehicle.
  • Means for presenting instructions to the vehicle's driver.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "Salesforce Maps App, along with associated hardware and/or software, including but not limited to Salesforce's back-end servers and related computer systems" are collectively identified as the "Accused Instrumentalities" (Compl. ¶33).

Functionality and Market Context

• The complaint alleges that the Accused Instrumentalities provide route guidance to users (Compl. ¶33). The complaint frames these functionalities in the context of modern app-based platforms, noting that centralized route guidance for vehicles is "more commonplace than ever" and that the patented inventions could improve the scalability and ease of use of platforms like Salesforce's (Compl. ¶16). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that detailed infringement allegations are contained in an "attached preliminary and exemplary claim charts provided in Exhibit 2" (Compl. ¶33). However, Exhibit 2 was not filed with the complaint. The following summary is based on the narrative allegations.

’876 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: The complaint’s central allegation hinges on the claim that the Salesforce Maps system transmits data in a "short burst" and then "closes" the communication channel. A primary factual question will be whether the accused system's architecture, which likely operates on modern packet-switched networks (e.g., TCP/IP over cellular), actually performs this specific open-transmit-close sequence. The complaint does not provide specific factual allegations detailing this operational behavior, instead referring to an unfiled exhibit.
• Scope Questions: Claim 1 recites several elements in means-plus-function format (e.g., "means for supplying"). Litigation will require identifying the corresponding structure in the '876 patent's specification (e.g., the off-board computer 6 and mobile telephone network, '876 Patent, col. 2:42-50; Fig. 1) and then determining whether the accused Salesforce servers and modern cellular/Wi-Fi networks perform the identical function in a way that is structurally the same or equivalent.

V. Key Claim Terms for Construction

• The Term: "a channel of communication which is opened to transmit... in a short burst and is then closed"
• Context and Importance: This phrase captures the core of the purported invention. The definition of what constitutes a "short burst" and a "closed" channel will be dispositive for infringement. The defense may argue that modern, "always-on" mobile applications do not operate in this manner, while the plaintiff may argue the terms should be interpreted more broadly to cover any non-continuous data transfer.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent repeatedly contrasts its method with systems where the channel is "kept permanently open" ('876 Patent, col. 2:22-23), suggesting "closed" could mean any state that is not permanent and continuous. The objective is to free up "bandwidth for use by any driver who requires route guidance" (Compl. ¶20), an objective arguably met by any efficient, intermittent data transmission protocol.
  • Evidence for a Narrower Interpretation: The specification describes the process as a "single transmission" of a "compressed data message" for the entire route, after which communication "ceases" ('876 Patent, col. 4:5-16). This could support a narrow construction where the entire route is sent in one discrete package, after which the logical connection is fully terminated, a process potentially different from how modern applications stream or update data.

VI. Other Allegations

• Indirect Infringement: The complaint alleges Salesforce induces infringement by providing the Accused Instrumentalities along with materials and services to its partners, customers, and end users, with the specific intent that their use will constitute direct infringement (Compl. ¶35-36). Contributory infringement is also alleged, stating the Accused Instrumentalities are material components especially adapted for infringing use and not a staple article of commerce (Compl. ¶37).
• Willful Infringement: Willfulness is alleged based on Salesforce's knowledge of the '876 patent "since at least the time of receiving this Complaint" (Compl. ¶38). This establishes a basis for potential post-filing willfulness.

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

1. A central question will be one of claim construction and technological evolution: How should the terms "short burst" and "closed" channel, conceived in the context of early 2000s mobile networks, be interpreted in relation to the architecture of modern, IP-based mobile applications? The court's construction of these terms will likely determine the scope of the patent.
2. A key evidentiary question will be one of technical operation: What factual evidence can be produced to show that the Salesforce Maps platform actually functions by opening a communications channel, transmitting data in a discrete "burst," and then definitively "closing" that channel, as required by the claims? The outcome will depend on whether the plaintiff can demonstrate this specific sequence of operations in the accused system's software and network protocols.