Location Based Services LLC v. RM Acquisition LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Location Based Services, LLC (Texas)
  • Defendant: RM Acquisition, LLC d/b/a Rand McNally (Delaware)
  • Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 2:17-cv-00135, E.D. Tex., 02/16/2017
• Venue Allegations: Venue is asserted based on Defendant having allegedly transacted business in the district and committed acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s navigation devices and software infringe patents related to map display systems that determine and show the status of locations based on a set of interaction rules.
• Technical Context: The technology relates to dynamic, context-aware map displays for navigation systems, a core feature in the consumer and commercial GPS market.
• Key Procedural History: The complaint notes that U.S. Patent 8,768,610 is part of a patent family that claims priority back to the application that issued as U.S. Patent 7,522,996, indicating a shared technical disclosure. No other procedural events are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 8,768,610 - "Map Display System and Method," issued July 1, 2014

The Invention Explained

• Problem Addressed: The patent addresses the need for map display systems to provide more than static geographic information by dynamically managing and displaying location-specific data based on predefined rules. (’610 Patent, col. 2:31-41).
• The Patented Solution: The invention is a computer system equipped with a processor, memory, and a receiver (e.g., GPS). The core of the system is a "map display module" containing a "data store" for "interaction rules" and a "status module." This status module determines the status of a location on the map as a function of the stored interaction rules, allowing for a dynamic and rule-based display. (’610 Patent, col. 17:46-64, Claim 1).
• Technical Importance: This system architecture enables context-aware navigation that can be tailored to specific users or changing conditions, moving beyond generic, one-size-fits-all map displays. (’610 Patent, col. 15:24-41).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2 and 6 (Compl. ¶15).
• Independent Claim 1 recites a computer system comprising:
  • a processor; a memory coupled to the processor; a receiver coupled to the processor; and
  • a map display module coupled to the receiver and the memory, the map display module including
  • a data store configurable to hold data related to one or more interaction rules associated with one or more locations in a predefined area and one or more identifiers; and
  • a status module configurable to determine a status associated with at least one of the one or more locations on the map, the status being a function of one or more location interaction rules associated with the at least one of the locations.

U.S. Patent No. 7,522,996 - "Map Display System and Method," issued April 21, 2009

The Invention Explained

• Problem Addressed: The patent describes a need for map displays that can convey the "status" of a location, such as whether access is permitted, based on rules that go beyond simple cartography. (’996 Patent, col. 1:7-16).
• The Patented Solution: The patent claims a method where a system receives a request for a map, determines a location's status as a function of "location interaction rules," and then generates a signal to visually indicate that status, specifically regarding a "permitted traverse or visit." (’996 Patent, Abstract; col. 17:15-28). The detailed description provides an example of a theme park map where a user's ticket acts as an identifier that interacts with rules to grant or deny access to certain rides or locations. (’996 Patent, col. 6:55-65).
• Technical Importance: This method provides a framework for enabling rule-based access control, guidance, and even gamification within a navigation or mapping application. (’996 Patent, col. 10:43-55).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2, 16, and 17 (Compl. ¶22).
• Independent Claim 1 recites a method for providing map-related data, comprising:
  • receiving a request for a map display illustrating information relative to one or more locations in a predetermined area;
  • determining a status associated with at least one of the locations on the map display, the status being a function of one or more location interaction rules associated with at least one of the locations on the map display; and
  • generating a signal to indicating on the map display the status regarding a permitted traverse or visit that is allowed under an applicable location interaction rule associated with the at least one of the locations on the map display.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are a series of Rand McNally navigation devices and associated software, including the Road Explorer 70, Road Explorer 60, Road Explorer 50, RV Tablet 80, RVND 7730 LM, TND Tablet 80, IntelliRoute TND 730 LM, and IntelliRoute TND 530 LM (Compl. ¶15).

Functionality and Market Context

• The complaint alleges these products are navigation systems that provide mapping and routing functions (Compl. ¶¶14, 21). Their relevant functionality includes determining routes and traffic conditions based on factors such as road type (e.g., toll vs. freeway), speed limits, and user preferences (e.g., avoid tolls) (Compl. ¶¶16, 23). The devices are alleged to provide visual feedback to the user, such as highlighting a route to be traveled or displaying overlays indicating traffic conditions (Compl. ¶¶18, 26). The complaint does not provide sufficient detail for analysis of the products' specific market positioning.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

’610 Patent Infringement Allegations

’996 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central issue may be whether the term "interaction rules" can be construed to cover general, conventional navigation parameters like traffic flow, road type, and speed limits, as alleged in the complaint (Compl. ¶¶16, 23). The patents provide more novel examples, such as user-specific permissions in a theme park or time limits for visits, which may suggest a narrower scope than what is alleged (’996 Patent, col. 7:46-67).
  • Technical Questions: For the ’996 Patent, a question arises as to whether routing a user based on traffic data or an "avoid tolls" preference performs the claimed function of indicating a "permitted traverse or visit." The court may need to determine if this standard routing functionality is technically equivalent to the more explicit permission-based systems (e.g., ticket-based access) described in the patent's specification (’996 Patent, col. 6:55-65).

V. Key Claim Terms for Construction

• The Term: "interaction rules"
• Context and Importance: This term appears in both asserted independent claims and is foundational to the Plaintiff's infringement theory. The viability of the case may depend on whether this term is construed broadly enough to read on the conventional navigation parameters (e.g., traffic, road type) alleged to be used by the Defendant's products. Practitioners may focus on this term because its construction will likely define the boundary between the patented invention and the prior art of standard GPS navigation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims themselves use broad, functional language, referring to rules "associated with one or more locations" without express limitation to specific types of rules (’610 Patent, col. 17:54-57). The summary section is similarly general, describing a status that is a "function of one or more location interaction rules." (’996 Patent, col. 1:11-13).
  • Evidence for a Narrower Interpretation: The specification provides specific, and arguably narrowing, examples of what "interaction rules" can be. These include rules for a user with specific needs (a "deaf child"), rules based on payment ("amount a user has paid to visit a park"), and rules limiting the time or number of visits to a location (’996 Patent, col. 8:1-6; col. 6:55-65). A party could argue these examples limit the term to user-specific permissions rather than general, objective data like traffic conditions.

VI. Other Allegations

• Indirect Infringement: The complaint makes passing references to infringement "through intermediaries" and the prayer for relief seeks to enjoin inducement of infringement (Compl. ¶14; p. 7, ¶2). However, the complaint does not plead specific facts to support the knowledge and intent elements required for a claim of indirect infringement, such as allegations related to user manuals or advertising that instruct users to perform the claimed methods.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement.

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

• A core issue will be one of definitional scope: can the term "interaction rules," which the patents illustrate with novel examples of user-specific permissions and visit limitations, be construed to cover the long-standing, conventional parameters of digital navigation such as traffic conditions, road types, and speed limits as alleged in the complaint?
• A key question of technical operation will be whether the accused products' function of calculating an optimal route based on traffic and user preferences (e.g., "avoid tolls") is the same as, or equivalent to, the claimed method of indicating the status of a "permitted traverse or visit," which the patent specification links to more explicit, location-specific access rights.