Geographic Location Innovations LLC v. Discount Tire Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: Discount Tire Co. d/b/a Discount Tire d/b/a America's Tire (Arizona)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Identification: 2:16-cv-01327, E.D. Tex., 11/30/2016
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed to reside in the district and has committed acts of infringement within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s mobile website and associated server infrastructure, which allows users to find store locations, infringes a patent related to remotely providing location information to a user's device.
• Technical Context: The technology concerns client-server systems for providing location-based services, a common feature for businesses seeking to direct customers to physical retail locations via mobile devices.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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 describes the difficulty and potential safety issues of manually programming addresses into GPS devices, particularly while driving. It also notes that different devices may recognize addresses in different formats, creating a laborious and frustrating user experience. (’285 Patent, col. 1:42-5:14).
• The Patented Solution: The invention proposes a system where a user can request location information from a remote server, either through a telematics service with a live operator or a computer network. The server resolves the address into coordinates and transmits them directly to the user's "positional information device," which can then provide route guidance without requiring manual entry by the user. (’285 Patent, Abstract; col. 2:32-48; Fig. 3).
• Technical Importance: This client-server approach aimed to simplify and improve the safety of interacting with navigation systems, a key usability concern as such devices became ubiquitous. (’285 Patent, col. 2:8-14).

Key Claims at a Glance

• The complaint asserts "one or more claims, including at least Claim 13." (Compl. ¶13).
• Independent Claim 13 is a system claim comprising the following essential elements:
  • A server configured to receive a request for an address not already stored in the positional information device, determine the address, and transmit it to the device.
  • A positional information device that includes: a locational module, a communication module to receive the address from the server, a processing module to determine route guidance, and a display module.
  • A communications network coupling the device to the server.
  • The server receives a time and date associated with the requested location and transmits that time and date with the determined address.
  • The positional information device displays the determined address at the associated time and date.

III. The Accused Instrumentality

Product Identification

• Defendant's "mobile website with associated hardware and software (the 'System')" is the accused instrumentality. (Compl. ¶13).

Functionality and Market Context

• The complaint alleges the accused System provides for remote entry of store locations into a user's "positional information device," such as a smartphone. (Compl. ¶14). The user’s device communicates with one or more servers, which receive a request for a nearby store, determine the store's address, and transmit it back to the device to be displayed on a map. (Compl. ¶¶15-16). The system is also alleged to determine and display route guidance to the selected store location. (Compl. ¶19). A screenshot provided in the complaint shows a "Find a Store" feature that displays multiple nearby store locations on a map based on a user-entered location. (Compl. p. 4).

IV. Analysis of Infringement Allegations

'285 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a modern smartphone operating a mobile website constitutes a "positional information device" as contemplated by the patent. The patent's specification frequently refers to dedicated "GPS devices" and telematics systems common in the mid-2000s, raising the question of whether the claim scope extends to general-purpose computing devices running web applications.
  • Technical Questions: Claim 13 requires the server to receive and transmit a "time and date" and for the device to display the address "at the associated time and date." The complaint alleges this functionality exists to determine traffic conditions (Compl. ¶22), but provides no specific evidence, such as screenshots or technical documents, demonstrating that the accused system actually performs this time-sensitive display function. The court may need to determine if the accused system's operation meets this specific limitation or if the allegation is conclusory.

V. Key Claim Terms for Construction

• The Term: "positional information device"

• Context and Importance: This term's definition is critical, as the accused instrumentality is a modern smartphone running a mobile website, whereas the patent was drafted in an era dominated by dedicated GPS navigation units. The outcome of the infringement analysis may depend on whether a smartphone falls within the scope of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that the principles "may be applied to any type of navigation or positional information device including but not limited to a vehicle-mounted device, a GPS receiver coupled to a desktop computer or laptop, etc." (’285 Patent, col. 4:5-9). It also contemplates software running on operating systems developed for mobile computing, such as SymbianOS, Windows Mobile, Palm OS, and Linux. (’285 Patent, col. 4:57-62).
  • Evidence for a Narrower Interpretation: The patent’s abstract and primary embodiment (Fig. 1) describe and illustrate a dedicated hand-held GPS unit. (’285 Patent, Abstract; col. 4:1-4). The background section focuses on problems specific to programming such dedicated devices. (’285 Patent, col. 1:15-21). This context could support an interpretation more narrowly focused on devices whose primary purpose is navigation.

• The Term: "displays the determined address at the associated time and date"

• Context and Importance: This limitation appears to require a specific, time-dependent function. Infringement hinges on whether the accused system performs this function as claimed. Practitioners may focus on this term because it appears to be a specific functional requirement that may not be present in a standard store locator feature.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue the language simply means the address is displayed on the device screen at the same time and date that the server transmitted it, without requiring a specialized scheduling or time-gating function.
  • Evidence for a Narrower Interpretation: The patent specification describes an embodiment where "When the date and time changes, the GPS device will then display the next specified and stored address on the date and time that corresponds to that address." (’285 Patent, col. 10:59-62). This suggests a more complex function, such as displaying trip itinerary stops or appointments only on the relevant day, which may impose a narrower meaning on the claim language.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of contributory and inducement infringement. (Compl. ¶13). It does not, however, plead specific facts to support the requisite elements of knowledge and intent, such as referencing user manuals or marketing materials that allegedly instruct users to perform infringing acts.

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 context of dedicated GPS units from the mid-2000s, be construed to cover a modern smartphone running a standard mobile website?
• A key evidentiary question will be one of functional performance: does the complaint provide sufficient factual support that the accused store locator performs the specific, time-sensitive function of receiving, transmitting, and displaying an address "at the associated time and date," as expressly required by Claim 13, or is there a mismatch in technical operation?