Traxcell Tech II LLC v. Maplebear Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Traxcell Technologies II, LLC (Texas)
  • Defendant: Maplebear Inc. (Delaware)
  • Plaintiff’s Counsel: David J. Hoffman
• Case Identification: 1:25-cv-04614, S.D.N.Y., 06/02/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and derives substantial revenue from services provided there.
• Core Dispute: Plaintiff alleges that Defendant’s systems and services for online and off-line navigation infringe a patent related to providing geographic navigation information on mobile devices.
• Technical Context: The technology concerns methods for providing mobile devices with location-based data and routing information, dynamically accounting for network connectivity and external factors like traffic.
• Key Procedural History: Plaintiff states it is a non-practicing entity. The complaint discloses that Plaintiff and its predecessors have entered into settlement licenses with other entities, but asserts these were to end litigation and did not involve an admission of infringement or an agreement to produce a patented article.

Case Timeline

Date	Event
2002-01-29	Earliest Priority Date for ’388 Patent
2017-01-17	’388 Patent Issued
2025-06-02	Complaint Filed

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

U.S. Patent No. 9,549,388 - Mobile wireless device providing off-line and on-line geographic navigation information

• Patent Identification: U.S. Patent No. 9,549,388, issued January 17, 2017.

The Invention Explained

• Problem Addressed: The patent describes challenges in providing reliable location and navigation data to mobile wireless devices, particularly in areas with poor signal reception like dense urban "canyons" or rural areas, which can lead to inaccuracies (’388 Patent, col. 1:60-2:1). It also notes the lack of a "universal standard" for formatting and decoding location data from various network sources, which hinders the development of portable navigation applications (’388 Patent, col. 5:42-49).
• The Patented Solution: The invention proposes a system and method centered on a "user location database manager" (ULDM) that can provide a mobile device with navigation information for both "on-line (connected)" and "off-line (not connected)" operation (’388 Patent, Abstract; col. 5:53-65). The system can use pre-stored mapping data when a network connection is unavailable and can also access a network to obtain real-time information, such as traffic data, to determine an "optimum route" (’388 Patent, Abstract). The ULDM acts as a standardized interface, processing location data from the network and providing it in a usable format for various applications (’388 Patent, col. 17:55-18:6).
• Technical Importance: The technology aimed to provide more robust and flexible mobile navigation by enabling functionality regardless of consistent network connectivity and by creating a standardized layer for location data management.

Key Claims at a Glance

• The complaint asserts claims 1-30 (Compl. ¶9). Independent claims appear to be 1, 11, 21, and 28.
• Independent Claim 1 (a wireless communications system) includes these essential elements:
  • A first radio-frequency transceiver on a mobile device coupled to a first processor.
  • The first processor is programmed to receive a location of the mobile device and generate an indication of that location on a display.
  • A second processor at a remote location, coupled to at least one second radio-frequency transceiver.
  • The second processor selectively determines the mobile device's location depending on "the setting of preference flags."
  • The second processor determines if the mapping information stored on the mobile device is sufficient.
  • If not sufficient, the second processor requests additional mapping information from the network.
  • The second processor receives traffic congestion information and updates the navigation information for the mobile device.
• The complaint reserves the right to assert all claims, including dependent claims (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the "systems, products, and services" offered by Defendant Maplebear Inc. (dba Instacart) that "use online and/or off-line navigation" (Compl. ¶9).

Functionality and Market Context

• The complaint alleges that Defendant maintains, operates, and administers systems related to "wireless communication devices, wireless networks, [and] wireless-network components" (Compl. ¶9). It does not provide specific details on the technical operation of the Instacart platform. The complaint alleges these services are sold and offered throughout New York (Compl. ¶3). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" which was not attached to the filed document (Compl. ¶10). Therefore, the infringement theory is based on the narrative allegations in the complaint. The core allegation is that Instacart's service, which necessarily involves providing location and routing information to its shoppers' mobile devices, constitutes a "system... that use[s] online and/or off-line navigation" that infringes the ’388 patent (Compl. ¶9). The complaint does not map specific features of the Instacart service to the elements of any asserted claim.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "navigation information," as described in the patent in the context of user-driven vehicle routing (’388 Patent, Abstract), can be construed to cover the type of logistical and task-based routing information provided to a worker in a gig-economy platform. It also raises the question of whether Instacart's application-layer software constitutes the "wireless communications system" described in the claims, which includes network-level components like radio-frequency transceivers.
  • Technical Questions: The complaint does not provide evidence that the accused Instacart service performs specific functions required by the claims. For example, a key technical question will be whether the Instacart system uses "preference flags" to "selectively" determine a user's location, or whether it determines if locally stored "mapping information is not sufficient" before requesting new data from a network, as required by Claim 1.

V. Key Claim Terms for Construction

• The Term: "navigation information" (Claim 1)

• Context and Importance: The scope of this term appears central to the dispute. The Plaintiff may argue for a broad definition covering any location or routing data, while the Defendant may argue it is limited to the specific context of personal travel and turn-by-turn directions described in the patent.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes displaying the location of a device with respect to "geographic features" (col. 128:64-65) and providing location data for a plurality of devices (col. 37:58-60), which could support a more general meaning beyond a single user's trip.
  • Evidence for a Narrower Interpretation: The abstract frames the invention around selecting an "optimum route" based on "expected trip duration" (’388 Patent, Abstract). The specification repeatedly discusses using the system for "traffic monitoring and routing" to help a vehicle "avoid congested traffic" (’388 Patent, col. 21:65-22:5), suggesting a primary focus on vehicle travel.

• The Term: "preference flags" (Claim 1)

• Context and Importance: This term appears to be a specific mechanism for controlling the system's behavior. Practitioners may focus on this term because its construction could determine whether a generic user setting in the accused product meets this limitation, or if a more specific type of flag is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the nature of the "preference flags," which may support an argument that any user-settable parameter that affects location determination qualifies.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of such flags, including a "full privacy flag" that prevents location sharing and an "anonymous privacy flag" that allows location sharing without identifying information (’388 Patent, col. 20:11-20). A defendant could argue these examples limit the term's scope to privacy-related controls.

VI. Other Allegations

• Indirect Infringement: The complaint does not include counts for indirect or induced infringement. The allegations are limited to direct infringement (Compl. ¶11).
• Willful Infringement: The complaint includes a prayer for a finding of willful infringement and treble damages (Compl. p. 6, ¶e). However, the body of the complaint does not plead specific facts to support this claim, such as allegations of pre-suit knowledge of the ’388 patent or egregious conduct.

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

• A core issue will be one of "definitional scope": Can the claims, which describe a "wireless communications system" providing "navigation information" in a context that appears focused on personal vehicle travel and network-level location management, be construed to cover the application-level software of a commercial delivery and logistics platform like Instacart? The construction of "navigation information" and "preference flags" will likely be dispositive.
• A key evidentiary question will be one of "factual proof": As the complaint lacks specific infringement contentions, the case may turn on whether the Plaintiff can, through discovery, produce evidence demonstrating that the accused Instacart platform performs the specific, multi-step processes recited in the asserted claims, such as checking the sufficiency of local map data before requesting updates and selectively determining location based on user-set flags.