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; DNL Zito
• Case Identification: 1:24-cv-13059, D. Mass., 01/23/2026
• Venue Allegations: Venue is asserted based on Defendant maintaining a regular and established business presence in the District of Massachusetts.
• Core Dispute: Plaintiff alleges that Defendant’s PetPace AI smart collars and associated mobile application infringe a patent related to systems for remotely entering, storing, and sharing location data for positional information devices.
• Technical Context: The technology addresses methods for simplifying the programming of GPS navigation devices by using a remote server to process location requests and transmit coordinates directly to the device, thereby avoiding manual entry by the user.
• Key Procedural History: The complaint notes that the patent-in-suit was examined by the U.S. Patent and Trademark Office, which considered numerous prior art references before allowing the claims. It also alleges the patent is "pioneering" and has been cited as relevant prior art in patent applications by major technology companies.

Case Timeline

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

U.S. Patent No. 9,261,365 - Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty and safety risks associated with manually programming destination addresses into GPS devices, particularly while driving (Compl. ¶13; ’365 Patent, col. 2:9-25). It notes that different devices have inconsistent user interfaces and address formats, and users with multiple vehicles must program each device individually, which is inefficient (’365 Patent, col. 1:54-2:8).
• The Patented Solution: The invention provides a system where a user can communicate a desired location to a remote service, such as a live operator at a customer service center or an automated server, via a communications link (’365 Patent, col. 9:7-13, 9:26-34). This remote service resolves the location into geographic coordinates and transmits them directly to the user's GPS device, which then stores the location and can provide route guidance (’365 Patent, col. 10:46-59; Fig. 4). The system also facilitates sharing stored addresses between a user's different GPS devices via the remote server (’365 Patent, col. 11:7-13).
• Technical Importance: This method aimed to improve the safety and convenience of in-vehicle navigation by offloading the task of address entry from the driver to a remote, centralized service, a concept central to early automotive telematics systems (Compl. ¶13; ’365 Patent, col. 2:26-36).

Key Claims at a Glance

• The complaint asserts at least independent claim 1 (Compl. ¶27).
• Claim 1 (Method):
  • 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 for the requesting device.
  • Receiving the retrieved address at the requesting device.
  • The server performs the intermediate steps of determining a second identifier for the sending device based on the first identifier and using it to retrieve the requested address stored in that sending device.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The "PetPace AI smart collars (including at least versions 2.0 and 3.0)" and the associated "PetPace Health application (including at least versions 2.0 and 3.0)" installed on an owner's mobile device (Compl. ¶27).

Functionality and Market Context

• The accused instrumentality is a system for tracking the location of pets (Compl. ¶27). The collar, worn by the pet, is paired with a mobile application on the owner's device. This application allows the owner to access the pet's location information (Compl. ¶27). The complaint does not provide further detail on the specific technical architecture or operational methods of the accused system.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in its Exhibit B, which was not provided with the filed complaint (Compl. ¶27, ¶33). The narrative infringement theory presented is therefore summarized below.

The complaint alleges that the Accused Instrumentalities—the PetPace smart collar and its associated mobile application—perform the method of Claim 1 of the ’365 Patent (Compl. ¶27). The theory suggests that when a pet owner uses the mobile application (the "requesting positional information device") to find their pet, a request is sent that ultimately causes the location of the collar (the "sending positional information device") to be retrieved and displayed. The complaint alleges that the steps of the claim are performed by hardware designed and programmed by the Defendant (Compl. ¶28). It further alleges direct infringement by Defendant's employees who test the products (Compl. ¶29) and indirect infringement through Defendant's sale of the products and distribution of instructional materials to end-users (Compl. ¶31).

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the patent's claims, which are described in the context of programming destination addresses for vehicle navigation, can be read to cover a real-time pet tracking system. The dispute may center on whether a pet collar transmitting its current coordinates qualifies as a "sending positional information device" containing a "stored address" as contemplated by the patent.
  • Technical Questions: The complaint does not specify the architecture of the accused system. A key question will be whether the system operates according to the specific steps of Claim 1—where the requesting device queries a server for information stored on a separate sending device—or whether it uses a different architecture, such as the collar independently reporting its location to a server, which the user's application then queries. The complaint does not provide sufficient detail for analysis of this element.

V. Key Claim Terms for Construction

• The Term: "at least one address stored in at least one sending positional information device"

  • Context and Importance: The infringement theory appears to depend on construing the pet collar as the "sending positional information device" and its real-time location data as the "stored address." Practitioners may focus on this term because the viability of the infringement case may turn on whether the current GPS coordinates of a pet collar can be considered an "address stored in" that device in the manner described by the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define "address" and uses terms like "address points" and "waypoints" throughout the specification, which could be argued to encompass raw coordinate data (’365 Patent, col. 1:31, 1:50).
    • Evidence for a Narrower Interpretation: The patent's background and summary are heavily focused on solving the problem of manually entering human-readable destination addresses (e.g., street, city, state) into vehicle navigation systems (’365 Patent, col. 1:54-2:25). This context may support an interpretation that "address" requires more than just transient GPS coordinates and implies a pre-programmed destination for route guidance.

• The Term: "sending positional information device"

  • Context and Importance: The claim requires two distinct devices, one "sending" and one "requesting." The defense may argue that a pet collar, which primarily transmits its own location and may lack a user interface or the ability to store a list of destination waypoints, is not a "positional information device" of the type disclosed in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers generally to a "global positioning system (GPS) device" and notes the invention can be applied to hand-held devices and various vehicles, not just automobiles (’365 Patent, col. 3:13-22).
    • Evidence for a Narrower Interpretation: The patent's detailed description of an exemplary device includes components like a display module, input buttons for user interaction, a microphone, and a speaker for providing route guidance (’365 Patent, Fig. 1; col. 3:30-4:48). A simple tracking collar lacks these features, which may suggest it falls outside the intended scope of the term.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end-users to operate the products in a manner that infringes the ’365 Patent (Compl. ¶31). It also makes a conclusory allegation of contributory infringement (Compl. ¶27).
• Willful Infringement: The basis for willfulness appears to be post-suit knowledge. The complaint alleges that Defendant has knowledge of its infringement "at least as of the service of the present complaint" and has "actively, knowingly, and intentionally continued to induce infringement" after being served (Compl. ¶25, ¶32).

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

The resolution of this case may depend on the court's determination of several key, open questions:

• A core issue will be one of definitional scope: can claim terms like "address stored in" a "positional information device," which are rooted in the patent's context of sharing pre-programmed navigation destinations between vehicles, be construed broadly enough to cover the real-time GPS coordinates transmitted by a pet tracking collar?
• A central evidentiary question will be one of technical operation: does the accused PetPace system function according to the specific multi-device request-and-retrieval method recited in Claim 1, or does it utilize a more conventional tracking architecture where the collar reports its position to a server that is then independently accessed by the user's application? The complaint's lack of technical detail leaves this as a fundamental point of contention.