DCT
6:20-cv-01271
Celeritasworks LLC v. Thumb Cellular LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Celeritasworks, LLC (Kansas)
- Defendant: Thumb Cellular LLC (Michigan)
- Plaintiff’s Counsel: Hovey Williams LLP
- Case Identification: 6:20-cv-01271, D. Kan., 10/05/2020
- Venue Allegations: Venue is based on Defendant allegedly conducting regular business in the district, providing cellular coverage to customers located within the district, and operating a website with an allegedly infringing tool that is accessible to residents of the district.
- Core Dispute: Plaintiff alleges that Defendant’s website-based cellular coverage map tool infringes a patent related to a geographic network management system.
- Technical Context: The technology concerns systems that receive location-based search queries over a web server, retrieve telecommunications network data and geographic data, and generate an integrated map for a user.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated December 23, 2019, nearly ten months prior to the filing of the lawsuit; this allegation forms the basis for the willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 1999-12-22 | ’290 Patent Priority Date |
| 2002-01-29 | ’290 Patent Issue Date |
| 2019-12-23 | Alleged notice of infringement sent to Defendant |
| 2020-10-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,343,290 - "Geographic Network Management System" (issued Jan. 29, 2002)
The Invention Explained
- Problem Addressed: The patent’s background section identifies the increasing difficulty of managing telecommunications networks, noting that service providers need a system to effectively "view, configure, and manage wireline and wireless networks" and provide useful data to users in a geographic context (’290 Patent, col. 1:11-28).
- The Patented Solution: The invention proposes a client-server system, typically comprising a web server, a database server, and a map server, that allows a user to input a location-based search query through a web browser. The system then "geocodes" the query (e.g., converts an address to latitude/longitude), retrieves relevant network data (e.g., cell site status) and geospatial data (e.g., streets) from a database, and generates a map displaying the network elements overlaid on the geographic data (’290 Patent, Abstract; Fig. 4).
- Technical Importance: The technology provided a way to organize and present complex telecommunications network data visually, allowing users to "view, monitor, configure, and manage" the network through a graphical interface rather than text-based reports (’290 Patent, col. 3:13-17).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a system claim) and 86 (a method claim) (Compl. ¶8).
- Independent Claim 1 (System): The key elements include:
- A database server configured to retrieve and transmit network and geospatial data.
- A web server configured to receive search criteria and transmit a map.
- A map server configured to receive the search criteria from the web server, geocode the search criteria, retrieve data from the database server corresponding to the geocode, and generate the map.
- Independent Claim 86 (Method): The key steps include:
- Receiving a search criteria.
- Determining a geocode for the search criteria.
- Obtaining network data and geospatial data within a search range of the geocode.
- Transmitting the network data and the geospatial data for display with a map.
- The prayer for relief seeks judgment for infringement of "one or more claims" of the ’290 Patent (Compl. p. 5, ¶A).
III. The Accused Instrumentality
Product Identification
- The "coverage map tool" available on Defendant's website, https://www.thumbcellular.com/ (Compl. ¶8).
Functionality and Market Context
- The complaint alleges that the accused tool allows a user to input a search criterion, such as a zip code or address, into a web-based interface (Compl. ¶8). The system then allegedly processes this query to generate and display a map illustrating cellular network coverage overlaid on geographic data (Compl. p. 3). A screenshot in the complaint depicts the tool generating a color-coded coverage map for "Kansas City, Missouri" after receiving the zip code "64108" as input (Compl. p. 3). The tool’s function is to provide information about the availability of cellular service to current or potential customers.
IV. Analysis of Infringement Allegations
U.S. Patent No. 6,343,290 Infringement Allegations (Claim 1 - System)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a database server configured to retrieve and to transmit network data and geospatial data | The complaint alleges the accused tool retrieves network and geospatial data, implying the existence and function of a backend database server architecture. | ¶8 | col. 7:31-33 |
| a web server configured to receive a search criteria...and to transmit the map | The accused tool is allegedly part of a website that operates via a web server to receive search criteria (e.g., a zip code) from a user and transmit the resulting coverage map for display. | ¶8 | col. 7:48-52 |
| a map server configured to receive the search criteria from the web server, to geocode the search criteria, to retrieve network data and geospatial data from the database server...and to generate the map | The accused system allegedly contains a component that receives the user's search, "geocodes" it, retrieves the corresponding coverage (network) and map (geospatial) data, and generates the final map image. | ¶8 | col. 8:50-58 |
U.S. Patent No. 6,343,290 Infringement Allegations (Claim 86 - Method)
| Claim Element (from Independent Claim 86) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving a search criteria | The accused tool receives a search criterion, such as a zip code or address, entered by a user into a search box on the website. | ¶8; p. 3 | col. 5:19-24 |
| determining a geocode for the search criteria | The complaint alleges the system "geocoded the search criteria" to process the user's location-based input. | ¶8 | col. 8:59-62 |
| obtaining network data and geospatial data within a search range of the geocode | The system allegedly retrieves "color-coded network data" (cellular coverage) and "geospatial data" (a geographic map) corresponding to the input location. | ¶8; p. 3 | col. 6:61-65 |
| transmitting the network data and the geospatial data for display with a map | The system transmits the resulting map, which combines the network and geospatial data, for display on the user's browser. | ¶8; p. 3 | col. 7:1-4 |
Identified Points of Contention
- Architectural Questions: A central question may be whether the accused system possesses the specific three-part architecture of a "web server", "database server", and "map server" as recited in Claim 1. The defense may argue its system does not use this particular structure, while the plaintiff may argue that the recited servers are logical components whose functions are performed by the accused system, even if not implemented as physically separate machines (’290 Patent, col. 7:42-47).
- Technical Questions: The infringement allegation for the "geocoding" step appears to be a key technical point. The complaint asserts that this function is performed (Compl. ¶8), but the provided evidence is the input of a zip code and the output of a map. The court will likely require further evidence demonstrating that the accused system performs a technical translation of the search criteria into specific geographic coordinates (e.g., latitude and longitude), as described in the patent (’290 Patent, col. 8:59-62), rather than a more generic database lookup.
V. Key Claim Terms for Construction
The Term: "map server"
- Context and Importance: The "map server" is a distinct and critical component of the system claimed in Claim 1. Its definition will be central to determining whether the architecture of the accused tool infringes, as the dispute may focus on whether the defendant's system contains a component that meets the structural and functional requirements of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the term "server" means "software and/or hardware that may be implemented as one or more components" and that the recited servers "represent logical components that are scalable" and can be implemented "individually, as a single component, or as multiple components" (’290 Patent, col. 7:39-47). This may support a construction where the "map server" is a logical function that can be co-located on the same physical hardware as the "web server".
- Evidence for a Narrower Interpretation: The patent’s abstract and detailed description consistently describe a specific set of interactions: the "map server" is configured to "receive the search criteria from the web server" and "obtains network data and geospatial data from the database server" (’290 Patent, Abstract). Figure 4 also depicts the "map server" (410) as a discrete block separate from the "web server" (402) and "database server" (404), which may support a narrower construction requiring a logically distinct entity with these specific inputs and outputs.
The Term: "geocode"
- Context and Importance: This term describes a key action in both the system and method claims. Proving that the accused tool performs "geocoding" is essential to the plaintiff's infringement case. The construction will determine the technical threshold for what constitutes this step.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined in a standalone glossary. A party could argue for a plain and ordinary meaning, such as simply associating a search term like a zip code with a general geographic area.
- Evidence for a Narrower Interpretation: The specification provides specific examples, stating the "geocode generator" (412) "identifies and generates a geocode, such as a latitude and a longitude, based on a search criteria" and can use coordinate systems like "North American data (NAD) 27, NAD 83" (’290 Patent, col. 8:59-65). This language suggests a technical process of converting an address or place name into specific numerical coordinates, which is more specific than a simple lookup.
VI. Other Allegations
Willful Infringement
- The complaint alleges that Defendant has willfully infringed the ’290 Patent (Compl. ¶14). This allegation is based on purported pre-suit knowledge, arising from a notice letter Plaintiff allegedly sent to Defendant on December 23, 2019, which informed Defendant of the patent and the alleged infringement (Compl. ¶11).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: Does the defendant's web-based mapping tool, as implemented, contain the distinct "web server", "database server", and "map server" components as required by the system claims, or can the plaintiff prove these logically separate functions are performed even if integrated into a monolithic architecture?
- A key evidentiary question will be one of functional proof: What evidence will be presented to demonstrate that the accused tool performs the specific step of "geocoding" a search criterion into geographic coordinates (e.g., latitude/longitude), as required by the claims, versus a more generic location lookup?
- A third question will relate to damages and willfulness: Given the patent expired before the suit was filed, damages will be limited to past infringement. The allegation of pre-suit notice from December 2019, if proven, will be central to the plaintiff's attempt to establish willfulness and seek enhanced damages for the post-notice period.