DCT
1:24-cv-13059
Social Positioning Input Systems LLC v. PetPace LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Social Positioning Input Systems, LLC (Wyoming)
- Defendant: PetPace LLC (Delaware)
- Plaintiff’s Counsel: Lambert Shortell & Connaughton
- Case Identification: 1:24-cv-13059, D. Mass., 12/11/2024
- Venue Allegations: Plaintiff alleges venue is proper in the District of Massachusetts because Defendant maintains a regular and established place of business in the District.
- Core Dispute: Plaintiff alleges that Defendant’s pet tracking collars and associated mobile application infringe a patent related to remotely programming positional information devices like GPS units.
- Technical Context: The technology concerns systems and methods for remotely entering location data into a navigation device, bypassing direct manual entry.
- Key Procedural History: The complaint notes that the patent-in-suit is anticipated to expire on April 28, 2026, and explicitly seeks damages for past infringement, citing case law that affirms the value of an expired patent for such actions. The complaint also asserts the patent is "pioneering" based on citations in subsequent patent applications by other technology companies.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | Priority Date for U.S. Patent No. 9,261,365 |
| 2016-02-16 | U.S. Patent No. 9,261,365 Issued |
| 2024-12-11 | Complaint Filed |
| 2026-04-28 | Anticipated Expiration of U.S. Patent No. 9,261,365 |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 9,261,365, "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued February 16, 2016.
The Invention Explained
- Problem Addressed: The patent describes the difficulty and potential danger of manually programming destination addresses into GPS devices ('365 Patent, col. 1:54-2:6). Problems cited include inconsistent address formatting across different devices, the inefficiency of programming the same address into multiple devices (e.g., for a user with multiple vehicles), and the safety risk of attempting to enter an address while driving ('365 Patent, col. 2:7-25).
- The Patented Solution: The invention provides a system where a user of a "positional information device" can request location information by communicating with a remote server, often through a live operator or an automated system ('365 Patent, Abstract; col. 2:45-54). This remote server resolves the requested location into geographic coordinates and transmits them directly to the user's device, which can then display route guidance without requiring manual entry by the user ('365 Patent, col. 2:54-60). The system is also described as enabling the sharing of addresses between different GPS devices associated with the same user ('365 Patent, col. 11:1-6).
- Technical Importance: This approach sought to improve the safety and convenience of in-vehicle navigation by offloading the task of address entry and formatting from the user to a remote, automated system ('365 Patent, col. 2:39-44).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 (Compl. ¶27).
- Independent Claim 1 requires:
- Sending a request from a "requesting positional information device" to a server for an address stored in a "sending positional information device."
- The request includes a "first identifier" of the requesting device.
- Receiving, at the requesting device, a retrieved address from the server.
- The server performs the intermediate steps of:
- Determining a "second identifier" for the sending device based on the received first identifier.
- Retrieving the requested address stored in the identified sending device.
- The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims" (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
- Defendant’s "PetPace AI smart collars" when paired with the "PetPace Health 2.0 application" installed on a mobile device (Compl. ¶27).
Functionality and Market Context
- The complaint alleges the accused system involves a smart collar that tracks a pet's location and an application on the owner's mobile device (Compl. ¶27). The application allows the owner to access the pet's location information, which is derived from the collar (Compl. ¶27). The complaint does not provide further detail on the technical operation or market positioning of the accused products. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Instrumentalities perform the method of Claim 1, but it incorporates by reference a claim chart (Exhibit B) that was not attached to the publicly filed document (Compl. ¶27, ¶33). The following table summarizes the infringement theory based on the narrative allegations in the complaint.
’365 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method for receiving location information at a positional information device, the method comprising: sending a request from a requesting positional information device to a server for at least one address stored in at least one sending positional information device... | The PetPace Health 2.0 application on an owner's mobile device (the "requesting device") sends a request to PetPace's servers to access the location of the pet. | ¶27 | col. 14:53-61 |
| ...the request including a first identifier of the requesting positional information device; | The request from the mobile application presumably includes an identifier (e.g., user account, device ID) that associates it with the owner. | ¶27 | col. 14:59-61 |
| receiving at the requesting positional information device, from the server, a retrieved at least one address to the requesting positional information device... | The mobile application receives the pet's location information from the PetPace servers and displays it to the owner. | ¶27 | col. 14:62-64 |
| ...wherein the server determines a second identifier for identifying the at least one sending positional information device based on the received first identifier... | PetPace's servers use the owner's account information ("first identifier") to determine the unique identifier of the associated PetPace smart collar (the "sending device"). | ¶27 | col. 14:64-15:2 |
| ...and retrieves the requested at least one address stored in the identified at least one sending positional information device. | PetPace's servers retrieve the location data, which is alleged to be "stored in" the PetPace smart collar. | ¶27 | col. 15:1-2 |
- Identified Points of Contention:
- Scope Questions: The patent specification is heavily focused on in-vehicle GPS navigation systems ('365 Patent, col. 2:7-25). A central dispute may be whether the claim term "positional information device" can be construed to read on a pet tracking collar (the alleged "sending device") and a mobile phone application (the alleged "requesting device").
- Technical Questions: Claim 1 requires the server to "retrieve" the address "stored in" the sending device. The complaint does not specify whether the PetPace server actively queries the collar for its location upon a user's request (a "pull" or "retrieve" action) or if the collar periodically transmits its location to the server, which the server then stores and provides to the user (a "push" action). A determination that the system operates on a "push" basis could raise questions about whether it performs the claimed "retrieves" step.
V. Key Claim Terms for Construction
The Term: "requesting positional information device" / "sending positional information device"
Context and Importance: These terms define the two key endpoints of the claimed system. The viability of the infringement case depends on whether a mobile software application can be considered a "requesting positional information device" and a pet collar a "sending positional information device" within the meaning of the patent. Practitioners may focus on these terms because the patent's examples are exclusively drawn from the vehicle navigation context.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not limit the devices to vehicles. The specification contemplates a "hand-held device" (col. 4:15-16), a "personal computer" (col. 4:41), and application to "various types of vehicles such as an automobile, a boat, a bicycle, etc." (col. 4:21-22), which may support a broader construction not limited to cars.
- Evidence for a Narrower Interpretation: The patent's "Background" and "Summary" sections repeatedly frame the invention as a solution for programming "a vehicle's GPS device" ('365 Patent, col. 2:41-42). The problem statement is tied to drivers and vehicles, which could support a narrower construction tied to navigation-focused devices.
The Term: "retrieves"
Context and Importance: This term defines the action the server takes with respect to the "sending device." The infringement analysis may turn on the precise technical mechanism by which the server obtains location data from the collar. Practitioners may focus on this term to determine if there is a mismatch between the claim language, which suggests a "pull" action, and the actual operation of the accused system, which might use a "push" architecture.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a server "retriev[ing] any entered address" from a database that is periodically updated by polling registered devices ('365 Patent, col. 11:1-3). This could be argued to cover a system where the server accesses data that was previously pushed to it by the device.
- Evidence for a Narrower Interpretation: The primary embodiment describes the server using a communication channel to "contact the device and retrieve the stored address information" directly from it ('365 Patent, col. 11:47-52). This language suggests a direct, on-demand query-and-response action, which may not read on a system where the server simply accesses a database of previously-pushed location updates.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶31). Contributory infringement is also alleged (Compl. ¶27).
- Willful Infringement: Willfulness is alleged based on Defendant's continued infringement after receiving notice of the lawsuit via service of the complaint and its attached (but unfiled) claim chart (Compl. ¶30, ¶32). This appears to be a claim for post-suit willfulness only, as no pre-suit knowledge is alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "positional information device", which is described in the patent almost exclusively in the context of vehicle navigation, be construed broadly enough to encompass the mobile application and pet tracking collar of the accused system?
- A key evidentiary question will be one of technical mechanism: does the accused PetPace system operate by having its server actively "retrieve" location data from the collar on-demand, as required by Claim 1, or does the collar proactively "push" its location data to the server, potentially creating a mismatch with the literal claim language?
- A central question of system architecture will be whether the plaintiff can prove that the accused system practices the specific three-party method of Claim 1, wherein an identifier from the requesting device (the app) is used by the server to identify and then retrieve data from a distinct sending device (the collar).