2:10-cv-10578
Visteon Global Tech Inc v. Garmin Intl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Visteon Global Technologies, Inc. (Michigan) and Visteon Technologies, LLC (Delaware)
- Defendant: Garmin International, Inc. (Kansas)
- Plaintiff’s Counsel: Alston & Bird LLP; Wolfson Bolton PLLC
- Case Identification: 2:10-cv-10578, E.D. Mich., 01/04/2011
- Venue Allegations: Venue is based on allegations that Garmin conducts business, has significant contacts, and has offered for sale, sold, and shipped infringing products into the Eastern District of Michigan.
- Core Dispute: Plaintiff alleges that Defendant’s vehicle navigation systems, including the nüvi, zūmo, and Street Pilot series, infringe five U.S. patents related to route previewing, turn-by-turn display graphics, destination selection, and data management.
- Technical Context: The technology at issue concerns the user interface and functional logic of in-vehicle and portable GPS navigation systems, a highly competitive and mature consumer electronics market.
- Key Procedural History: The complaint notes that the Visteon plaintiffs are debtors in a Chapter 11 bankruptcy proceeding. It also states that for all five patents-in-suit, Garmin was put on notice of its alleged infringement in a letter dated May 6, 2009, nearly 20 months prior to the filing of the amended complaint. Reexamination proceedings for U.S. Patent No. 5,832,408 resulted in the cancellation of asserted claims 1, 2, 3, and 6, leaving only claims 4 and 5 confirmed as patentable.
Case Timeline
| Date | Event |
|---|---|
| 1991-10-16 | Priority Date for U.S. Patent No. 5,544,060 |
| 1991-10-18 | Priority Date for U.S. Patent No. 5,654,892 |
| 1996-02-14 | Priority Date for U.S. Patent Nos. 5,832,408 and 5,987,375 |
| 1996-08-06 | Issue Date for U.S. Patent No. 5,544,060 |
| 1997-08-05 | Issue Date for U.S. Patent No. 5,654,892 |
| 1998-04-20 | Priority Date for U.S. Patent No. 6,097,316 |
| 1998-11-03 | Issue Date for U.S. Patent No. 5,832,408 |
| 1999-11-16 | Issue Date for U.S. Patent No. 5,987,375 |
| 2000-08-01 | Issue Date for U.S. Patent No. 6,097,316 |
| 2009-05-06 | Plaintiff allegedly put Defendant on notice of infringement |
| 2011-01-04 | Third Amended Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 5,544,060 - “Vehicle Mounted Navigation System with Preview Function,” issued August 6, 1996
The Invention Explained
- Problem Addressed: The patent describes conventional navigation systems as problematic because they only display path information sequentially as a vehicle is driven, preventing the driver from knowing the overall optimal path beforehand, which may compromise driving safety (’060) Patent, col. 1:21-38).
- The Patented Solution: The invention provides a "preview function" that allows a user to manually step through and sequentially view the instructions for a calculated optimal route before beginning to drive. This is enabled by an "instruction signal output means," such as a preview switch, which signals the system to display the next step in the route instructions (’060 Patent, Abstract; col. 2:7-20; col. 4:1-10). The system also includes a function to cancel a portion of the displayed path and request the calculation of an alternate route (’060 Patent, col. 4:11-18).
- Technical Importance: This technology aimed to improve user confidence and safety by allowing drivers to familiarize themselves with a complex route prior to departure, rather than reacting to instructions in real-time.
Key Claims at a Glance
- The complaint asserts infringement of claims 3, 4, and 6, with claim 4 being the sole asserted independent claim (’060 Patent, col. 6:45-60; Compl. ¶12).
- Essential elements of independent claim 4 include:
- A microcomputer for calculating an optimal path and computing instructions for following that path.
- Sensors for determining the vehicle's present position.
- Means for displaying the plurality of instructions sequentially.
- Means for enabling an operator to preview the optimal path.
- Input means for permitting an operator to request an alternate optimal path on demand.
- The complaint reserves the right to assert other claims, including dependent claims 3 and 6 (Compl. ¶12).
U.S. Patent No. 5,654,892 - “Navigation System Displaying Forthcoming Turns,” issued August 5, 1997
The Invention Explained
- Problem Addressed: Prior art navigation displays showed only the single next required action (e.g., "turn right"). If two turning points were close together, the patent suggests an "unalerted driver may pass the second turning point without sufficient advance warning," creating a safety hazard (’892) Patent, col. 1:35-43).
- The Patented Solution: The invention creates and displays a single, composite icon that represents a plurality of upcoming directions of advance. For example, instead of showing a right turn arrow followed later by a left turn arrow, the system can generate a single icon that visually depicts a right turn followed by a left turn (’892 Patent, Abstract; col. 3:40-54). The patent describes creating these icons either "on the fly" based on map data or by selecting them from a pre-stored library of complex turn shapes (’892 Patent, Fig. 4B).
- Technical Importance: This approach sought to increase information density on small navigation screens, giving drivers a more holistic and intuitive preview of complex, multi-part maneuvers.
Key Claims at a Glance
- The complaint asserts infringement of claims 1, 8, and 10, with claims 1, 10, and others being independent (’892 Patent, col. 6:43-57; Compl. ¶20).
- Essential elements of independent claim 1 include:
- Means for continuously computing a plurality of directions of advance immediately following an upcoming turning point.
- Means for creating an icon representing the current direction of advance and said plurality of directions of advance.
- Means for displaying said icon before the vehicle reaches the upcoming turning point.
- The complaint reserves the right to assert other claims, including method claims 8 and 10 (Compl. ¶20).
U.S. Patent No. 5,832,408 - “Method and Apparatus for Selecting a Destination in a Vehicle Navigation System,” issued November 3, 1998
Technology Synopsis
This invention addresses methods for destination entry. It discloses a system that provides two distinct modes for finding a destination: first, by browsing through predefined categories (e.g., cities, points of interest), and second, by activating a "global search" function that allows a user to enter an alphanumeric string to search for a destination across all available categories simultaneously (’408) Patent, Abstract; col. 2:20-30). This provides flexibility for a user who knows the name of a destination but not its specific category.
Asserted Claims
The complaint asserts claims 1-6 (Compl. ¶28). However, reexamination has resulted in the cancellation of claims 1-3 and 6, leaving only claims 4 and 5 patentable.
Accused Features
The complaint alleges that Garmin devices provide a user interface for selecting a destination by either browsing a category or by entering an alphanumeric input to search across a plurality of categories (Compl. ¶26-27).
U.S. Patent No. 5,987,375 - “Method and Apparatus for Selecting a Destination in a Vehicle Navigation System,” issued November 16, 1999
Technology Synopsis
This patent describes a method for managing a destination history to protect user privacy. The system automatically determines if a selected destination belongs to a "specific category" (e.g., a public "point of interest"). It includes the destination in a history list "only where the first destination belongs to the specific category," thereby preventing sensitive destinations (e.g., private residences) from being saved and viewed by subsequent users (’375) Patent, Abstract; col. 6:5-12).
Asserted Claims
Claims 1, 8, and 9 are asserted (Compl. ¶37). Independent claims include 1 (method), 7 (apparatus), and 9 (system).
Accused Features
Garmin devices are alleged to include a destination history function that, without user intervention, automatically includes a selected destination in the history only when that destination belongs to a specific category (Compl. ¶34-35).
U.S. Patent No. 6,097,316 - “Communication Protocol for a Vehicle Navigation System,” issued August 1, 2000
Technology Synopsis
This invention relates to data communication in a vehicle where a navigation computer is a separate component from a central vehicle controller that manages the user interface. The system selects a specific transmission protocol from a plurality of available protocols based on the type of data being requested (e.g., a text-based list versus a complex graphical screen) (’316) Patent, Abstract). This allows the system to transmit data more efficiently, for example by sending a list in small chunks as the user scrolls, but sending a full graphics screen all at once (’316 Patent, col. 6:11-47).
Asserted Claims
Claims 1 and 10 are asserted (Compl. ¶44). Independent claims include 1 (system) and 10 (method).
Accused Features
The complaint specifically accuses the "Cirrus Perspective" avionics product, alleging it contains a CPU that selects from multiple transmission protocols to transmit interface data between the navigation unit and a vehicle controller, using different data busses (Compl. ¶43).
III. The Accused Instrumentality
Product Identification
The complaint names a wide array of Garmin's portable and in-vehicle navigation systems, including dozens of models from the nüvi, zūmo, Street Pilot, GVN, and Quest product lines (Compl. ¶¶10, 18, 26, 36). For the '316 Patent, the complaint specifically identifies the "Cirrus Perspective" system, which is an integrated avionics suite for aircraft that includes navigation functions (Compl. ¶43).
Functionality and Market Context
The accused products are described as GPS-based navigation systems that perform functions corresponding to the asserted patents. These functions include calculating an optimal path, allowing a user to preview that path before travel, displaying icons for upcoming turns, and providing interfaces for searching for destinations by category or text input (Compl. ¶¶10, 18, 26). The complaint alleges these devices are designed to perform the patented methods and that their user manuals instruct users on how to operate these features (Compl. ¶10). The extensive list of accused products suggests an allegation of infringement across a substantial portion of Garmin's consumer and aviation navigation product portfolio.
IV. Analysis of Infringement Allegations
'060 Patent Infringement Allegations
| Claim Element (from Independent Claim 4) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a microcomputer adapted for calculating, on a map available to said microcomputer, an optimal path between a starting point and a destination | The accused devices are alleged to include a microcomputer and to be "designed to perform a method that includes steps of calculating, on an electronically-stored map, an optimal path between a starting point and a destination." | ¶10, ¶11 | col. 2:42-56 |
| sensors for determining, in cooperation with said microcomputer, a present position of said vehicle | The devices are GPS-enabled navigation systems, and the complaint alleges they calculate on said map a present position of a vehicle. | ¶1, ¶10, ¶11 | col. 2:57-65 |
| said microcomputer being further adapted for computing a plurality of instructions for following said optimal path... | The devices are alleged to compute and transmit "a plurality of instructions for following said optimal path." | ¶10, ¶11 | col. 5:48-51 |
| means for displaying said plurality of instructions sequentially | The devices are alleged to be capable of "displaying said plurality of instructions sequentially." | ¶10, ¶11 | col. 5:44-47 |
| means for enabling an operator of said vehicle to preview said optimal path | The devices are alleged to transmit the instructions "responsive to a request by an operator for performing said transmitting prior to traveling on said optimal path." | ¶10, ¶11 | col. 5:51-53 |
| input means for permitting said operator of said vehicle to request an alternate optimal path on demand | The devices are alleged to be capable of "calculating and selecting an alternate optimal path responsive to a request from said operator of said vehicle." | ¶10, ¶11 | col. 5:57-59 |
'892 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| means for continuously computing a plurality of directions of advance... immediately following an upcoming turning point from a current direction of advance | The devices are alleged to be "designed to perform a method that includes steps of continuously computing a plurality of successive directions of advance." | ¶18, ¶19 | col. 3:40-48 |
| means for creating an icon representing said current direction of advance and said plurality of directions of advance | The devices are alleged to create "an arrow icon that represents said current direction of advance and at least a first and a second direction of advance of said vehicle." | ¶18, ¶19 | col. 4:5-10 |
| means for displaying said icon before said vehicle reaches said upcoming turning point | The devices are alleged to perform the step of "displaying said arrow icon before said vehicle reaches said upcoming turning point." | ¶18, ¶19 | col. 4:6-10 |
Identified Points of Contention
- Scope Questions: Both the ’060 and ’892 patents use "means-plus-function" claim language (e.g., "means for enabling... to preview", "means for creating an icon"). The scope of these terms is limited by law to the specific structures disclosed in the patent specifications and their equivalents. A central question for the court will be whether the accused user interfaces in Garmin's products are structurally equivalent to the "preview switch" described in the ’060 patent or the icon-creation logic (either computed or table-based) described in the ’892 patent.
- Technical Questions: A key evidentiary question will be whether the accused products’ functions meet the specific requirements of the claims. For the ’060 Patent, does a static route overview map or a non-interactive list of turns in a Garmin device perform the function of the claimed interactive, step-by-step "preview"? For the ’892 Patent, does a standard turn arrow in a Garmin device constitute an "icon representing... a plurality of directions of advance," or does the claim require a composite graphic that explicitly depicts two or more distinct, sequential turns?
- No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
For the ’060 Patent:
- The Term: "preview said optimal path" (from claim 4)
- Context and Importance: This term is the central feature of the patent. Its construction will determine whether infringement requires an interactive, step-by-step review of turns, or whether a more passive display of the entire route (e.g., a map overview or a complete turn list) is sufficient. Practitioners may focus on this term because the difference between an interactive "preview" and a static "overview" is a potentially dispositive distinction.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract describes a "preview function" that "allows the operator to sequentially view the calculated optimal path," which could be argued to cover any sequential presentation, including a simple list (’060 Patent, Abstract).
- Evidence for a Narrower Interpretation: The detailed description repeatedly links the preview function to the manual operation of a "preview switch 70" to advance the display one step at a time, as detailed in the flowchart of Figure 3. This suggests a narrower meaning requiring an interactive, user-driven, step-by-step process (’060 Patent, col. 4:1-10, Fig. 3).
For the ’892 Patent:
- The Term: "icon representing said current direction of advance and said plurality of directions of advance" (from claim 1)
- Context and Importance: This term defines the invention's novel visual element. The core of the infringement question for this patent will be what kind of graphic satisfies this limitation. The patent's contribution is displaying multiple future turns in one icon, so the definition of "representing... a plurality" is critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not explicitly require the icon to be a composite of multiple arrowheads. An argument could be made that any arrow showing a turn implies a continuing path afterward, thus representing a "plurality" of directions.
- Evidence for a Narrower Interpretation: The specification explicitly aims to solve the problem of two turns in close succession (’892 Patent, col. 1:35-43). Figure 4B provides numerous examples of composite icons that visually combine two distinct turns (e.g., a right turn followed by another right turn). The abstract also states the icon represents "at least two successive turning points," suggesting the icon must convey information about more than one maneuver (’892 Patent, col. 2:21-22).
VI. Other Allegations
Indirect Infringement
For all five patents, the complaint alleges both contributory and induced infringement. The basis for inducement is the allegation that Garmin’s "user manuals associated with these devices provide instructions that allow the user to cause the devices to perform such a method" (Compl. ¶¶10, 18, 26, 34).
Willful Infringement
The complaint alleges willful and deliberate infringement for all five patents. The primary basis for this allegation is a notice letter dated May 6, 2009, after which Garmin allegedly "continued its activities despite an objectively high likelihood that its actions constitute infringement" (Compl. ¶¶13, 21, 29, 38, 45). This frames the willfulness claim as being based on post-notice conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope for means-plus-function limitations: The asserted claims in the lead ’060 and ’892 patents depend heavily on "means for" language. The case may turn on whether the court construes these claims narrowly, limiting them to the specific "preview switch" and "composite icon matrix" embodiments described in the patents, or more broadly, finding Garmin's modern graphical user interface to be a legal "equivalent."
- A second central question is one of factual and evidentiary proof: For the patents to be infringed, Garmin's devices must perform the specific functions claimed. The litigation will require a detailed technical comparison between, for example, the ’060 patent's step-by-step "preview" and Garmin's route overview feature, and between the ’892 patent's "composite icon" and Garmin's actual turn-by-turn graphics. The complaint's conclusory allegations on these points raise significant evidentiary questions.
- Finally, a key legal challenge for the plaintiff will be the viability of its infringement claims for the '408 patent. The complaint asserts infringement of claims 1-6, but post-issuance reexaminations have invalidated claims 1-3 and 6. This raises the question of whether the infringement theory can be sustained based solely on the surviving dependent claims 4 and 5.