DCT
2:19-cv-02453
Geographic Location Innovations LLC v. Natural Organics
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: Natural Organics, Inc. (New York)
- Plaintiff’s Counsel: The Law Office of Gerard F. Dunne; Kizzia Johnson, PLLC
- Case Identification: 2:19-cv-02453, E.D.N.Y., 04/26/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed a resident of the district and because acts of infringement are occurring in the district where Defendant has a regular and established place of business.
- Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to remotely programming a positional information device with location data.
- Technical Context: The technology concerns systems that allow users to find and send address information from a remote source (like a server) to a location-aware device (like a GPS unit or smartphone) to avoid manual data entry.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the asserted patent.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | '285 Patent Priority Date |
| 2011-03-29 | '285 Patent Issue Date |
| 2019-04-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,917,285 - "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device"
- Patent Identification: U.S. Patent No. 7,917,285, "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued March 29, 2011.
The Invention Explained
- Problem Addressed: The patent's background section describes the difficulty and potential danger of manually programming addresses into GPS devices, particularly while driving. It also notes that different devices have inconsistent user interfaces and that users with multiple devices must tediously enter the same addresses on each one. (’285 Patent, col. 1:43-2:14).
- The Patented Solution: The invention provides a system where a user can send a request for a location to a remote server. The server determines the coordinates for that location and transmits them back to the user's "positional information device" (e.g., a GPS unit), which can then calculate and display a route, bypassing the need for manual entry on the device itself. (’285 Patent, col. 2:32-48; Fig. 3).
- Technical Importance: The technology aimed to improve the safety and user experience of then-prevalent dedicated GPS navigation systems by offloading the cumbersome task of address entry to a remote, network-connected system. (’285 Patent, col. 2:6-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 13. (Compl. ¶13).
- The essential elements of independent claim 13 include:
- A server that receives a location request, determines an address, and transmits it.
- A "positional information device" with modules for determining its own location (locational), receiving the address from the server (communication), determining route guidance (processing), and displaying the route (display).
- A communications network coupling the server and the device.
- A requirement that the server receives, transmits, and the device displays a time and date associated with the requested location.
- The complaint does not explicitly reserve the right to assert dependent claims, but refers to infringement of "one or more claims." (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant's "store locator service" (the "System"), which is described as a "mobile website with associated hardware and software" available at naturesplus.com/storelocator. (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the System allows for the "remote entry of location information" by automatically loading nearby store locations onto a user's device (e.g., a smartphone or tablet) based on that device's current location. (Compl. ¶14). The system then provides a map-based interface to display store locations and provide route guidance to a selected store. (Compl. ¶19). A screenshot provided in the complaint shows the system prompting a user to allow the website to access the device's location. (Compl. p. 7).
IV. Analysis of Infringement Allegations
’285 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a server configured to receive a request for an address of at least one location not already stored in the positional information device, to determine the address of the least one location and to transmit the determined address to the positional information device; | The System includes one or more servers that receive a request for a store location, determine the address of the store, and transmit it to the user's device. A provided screenshot depicts a list of stores with addresses and a map with corresponding location pins. | ¶15, ¶16 | col. 13:38-42 |
| the positional information device including a locational information module for determining location information of the positional information device; | The user's device (e.g., smartphone) includes a "locational information module (e.g., GPS hardware)" that determines the device's location to find nearby stores. | ¶17 | col. 13:49-51 |
| a communication module for receiving the determined address of the at least one location from the server; | The user's device includes a "communications module (e.g., cellular or WiFi components)" that receives the determined store addresses from the server. | ¶18 | col. 13:52-54 |
| a processing module configured to receive the determined address from the communication module and determine route guidance based on the location of the positional information device and the determined address; | The System includes a "processing module (e.g., mapping software and the mobile website)" that receives the store address and "determines route guidance." A screenshot shows a calculated route displayed on a map. | ¶19 | col. 13:55-60 |
| and a display module for displaying the route guidance; | The user's device includes a "display module (e.g., screen...)" for displaying the determined route guidance. | ¶20 | col. 13:61-62 |
| and a communications network for coupling the positional information device to the server, | The System includes a "communications network (e.g., cellular network)" that couples the user's device to the server. | ¶21 | col. 13:63-65 |
| wherein the server receives a time and date...and transmits the associated time and date with the determined address...and the positional information device displays the determined address at the associated time and date. | The complaint alleges that the server must receive the time and date of the request to determine traffic conditions, and that this information is transmitted to and displayed by the user's device. | ¶22 | col. 14:23-30 |
- Identified Points of Contention:
- Scope Questions: The patent specification repeatedly refers to a "GPS device" and depicts a dedicated navigation unit. (’285 Patent, Fig. 1; col. 1:13). The infringement analysis may raise the question of whether a general-purpose computing device like a smartphone or tablet running a web browser falls within the scope of the claimed "positional information device."
- Technical Questions: The final "wherein" clause of claim 13 requires the server to receive and transmit a "time and date" and the device to display it. The complaint alleges this is necessary for determining traffic conditions. (Compl. ¶22). A key factual question will be what evidence supports the allegation that the accused System actually performs this specific time-and-date-based data exchange and display, as the provided screenshots do not explicitly show this functionality. For instance, the screenshot on page 8 shows a route with a "Light traffic" indicator, which may support Plaintiff's theory that time-of-day data is used. (Compl. p. 8).
V. Key Claim Terms for Construction
- The Term: "positional information device"
- Context and Importance: This term is central to the dispute as it defines the primary component of the claimed system from the user's perspective. The construction will determine whether the patent's claims, drafted in an era of dedicated GPS units, can read on modern multi-function devices like smartphones and tablets accessing a website.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself defines the device by its functional modules (locational, communication, processing, display). Plaintiff may argue that any device containing these modules, such as a smartphone, meets the claim's requirements, regardless of its form factor or other capabilities. (col. 13:49-62).
- Evidence for a Narrower Interpretation: The specification's consistent references to a "global positioning system (GPS) device," the depiction of a dedicated unit in Figure 1, and the description of the problem solved in the context of vehicle-mounted or handheld navigation units may support an interpretation limited to devices whose primary purpose is navigation. (’285 Patent, Abstract; Fig. 1; col. 4:1-8).
VI. Other Allegations
- Indirect Infringement: The complaint alleges both contributory and inducement infringement. (Compl. ¶13). The inducement theory appears to be based on Defendant making its store locator System available and its operation implicitly instructing users to perform the allegedly infringing steps. (Compl. ¶13-14). The complaint also alleges direct infringement by Defendant, at least through testing by its employees. (Compl. ¶13).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may turn on two central questions:
- A core issue will be one of definitional scope: Can the term "positional information device", which is described in the patent in the context of dedicated GPS units, be construed to cover a modern, general-purpose smartphone or tablet that is merely accessing the accused website?
- A key evidentiary question will be one of factual sufficiency: Does the accused store locator actually perform all the steps recited in claim 13, particularly the specific requirement that the server receives, transmits, and the end-user device displays an associated "time and date" with the location address, or is there a functional mismatch between the claim and the accused system's operation?