DCT
2:19-cv-00085
Geographic Location Innovations LLC v. Talbots Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: The Talbots, Inc. (Delaware)
- Plaintiff’s Counsel: Kizzia Johnson, PLLC
- Case Identification: 2:19-cv-00085, E.D. Tex., 03/14/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant conducts business and has a regular and established place of business in the Eastern District of Texas, citing a retail store location in Plano, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s mobile website store locator service infringes a patent related to systems and methods for remotely providing a user's device with location information for navigation.
- Technical Context: The technology concerns networked location-based services, where a central server processes a location request and sends data to a mobile device, a foundational architecture for modern e-commerce and mapping applications.
- 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. The patent lists Reagan Inventions, LLC as the original assignee, and the complaint notes that Plaintiff is the current owner by assignment.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | Earliest Priority Date for U.S. Patent No. 7,917,285 |
| 2011-03-29 | U.S. Patent No. 7,917,285 Issued |
| 2019-03-14 | Complaint Filed |
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. (Compl. ¶11; ’285 Patent, p. 1).
The Invention Explained
- Problem Addressed: The patent describes challenges with early-generation GPS devices, including the difficulty and potential danger of manually inputting addresses while driving, inconsistencies in how different devices recognize addresses, and the need to re-enter the same addresses on multiple devices owned by one user. (’285 Patent, col. 1:42-2:13).
- The Patented Solution: The invention discloses a client-server system to solve these problems. A user requests location information from a remote server, either through a telematics service or a separate computer. The server looks up and resolves the address, determines its geographic coordinates, and transmits this data directly to the user's "positional information device" (e.g., a car's GPS unit or a handheld device). The device then uses this server-provided data to calculate and display a route, obviating the need for manual entry on the device itself. (’285 Patent, Abstract; col. 2:33-55; Fig. 3).
- Technical Importance: This architecture represents a shift from device-centric data entry to a network-based model where a remote server performs the complex task of address resolution, thereby simplifying the user interaction on the mobile device. (’285 Patent, col. 2:26-30).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 13. (Compl. ¶13).
- Claim 13 recites a system comprising three main parts:
- A "server" that receives a location request, determines an address, and transmits it.
- A "positional information device" that includes a "locational information module" (to find itself), 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 server and the device.
- The claim further requires that the server receives and transmits a "time and date" associated with the request, which the device then uses when displaying the address. (’285 Patent, col. 13:26-14:5).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is identified as "the System," which consists of Defendant’s "mobile website with associated hardware and software embodied, for example, in its store locator service." (Compl. ¶13).
Functionality and Market Context
- The complaint alleges that the accused "System" enables users of mobile devices, such as smartphones, to find nearby Talbots retail stores. (Compl. ¶14).
- The functionality involves the mobile website detecting the user's location and displaying nearby stores on a map. (Compl. ¶14). The user can then select a store to receive route guidance. (Compl. ¶19).
- A screenshot in the complaint shows the website prompting the user for permission to access the device's location, which supports the allegation that the system uses the device's own positioning capabilities. (Compl. p. 6).
- The complaint alleges the system involves servers that receive requests, determine store addresses, and transmit them to the user's device for display. (Compl. ¶¶15-16). A screenshot shows a map with Talbots locations plotted around a given zip code. (Compl. p. 4).
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 ... and to transmit the determined address... | The System includes server(s) that allegedly receive a request for a store location, determine the store's address, and transmit it to the user's device (e.g., a smartphone). | ¶¶15-16 | col. 13:28-36 |
| 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) is alleged to have a locational information module, such as GPS hardware, to determine its own location. | ¶17 | col. 13:38-40 |
| a communication module for receiving the determined address... | The device is alleged to include a communication module (e.g., cellular, Wi-Fi) that receives the store address from the server. | ¶18 | col. 13:41-43 |
| a processing module configured to... determine route guidance based on the location of the positional information device and the determined address; | The System is alleged to include a processing module (e.g., mapping software and the mobile website) that determines route guidance. A screenshot shows turn-by-turn directions and a map. | ¶19; p. 7 | col. 13:44-49 |
| and a display module for displaying the route guidance; | The device's screen is alleged to be the display module that displays the calculated route guidance. | ¶20 | col. 13:50-51 |
| and a communications network for coupling the positional information device to the server, | A cellular network is alleged to serve as the communications network coupling the user's device to the server(s). | ¶21 | col. 13:52-54 |
| wherein the server receives a time and date associated with the requested... location and transmits the associated time and date with the determined address... | The complaint alleges on information and belief that the server receives a time and date with the request to determine traffic conditions and transmits this data back to the device. | ¶22 | col. 13:56-61 |
| ...and the positional information device displays the determined address at the associated time and date. | The device is alleged to display the address and route conditions corresponding to the transmitted time and date. | ¶22 | col. 13:61-64 |
Identified Points of Contention
- Scope Questions: Claim 13 is a system claim requiring both a server (controlled by Defendant) and a "positional information device" (controlled by the end-user). This raises the question of whether Defendant can be held liable for infringing the entire system under a theory of divided infringement, which would require Plaintiff to show Defendant directs or controls the actions of its users in a manner that satisfies the standard set by the Federal Circuit in Akamai.
- Technical Questions: A key technical question is where the "determine route guidance" step occurs. The claim requires this to be performed by a "processing module" on the "positional information device". The complaint alleges the "mobile website" acts as this module. (Compl. ¶19). It is a point for factual discovery whether the browser on the user's device performs the substantive route calculation or if it merely displays route information that was fully calculated on Defendant's remote server. The screenshot showing route guidance also contains attribution to MapQuest, TomTom, and Mapbox, suggesting the use of third-party, server-based routing engines. (Compl. p. 7).
V. Key Claim Terms for Construction
The Term: "positional information device"
- Context and Importance: The claim requires this "device" to contain the processing module that determines route guidance. The infringement theory depends on the user's smartphone qualifying as this device. Practitioners may focus on this term because its construction is central to the divided infringement analysis—if key functions are performed by the server rather than the "device," the claim may not be infringed as written.
- Intrinsic Evidence for a Broader Interpretation: The specification states the invention can be "applied to any type of navigation or positional information device," including a "GPS receiver coupled to a desktop computer or laptop." (’285 Patent, col. 4:6-9). This language may support an interpretation that includes a general-purpose device like a smartphone running specific software.
- Intrinsic Evidence for a Narrower Interpretation: The patent’s primary embodiment is a self-contained, dedicated GPS unit (Fig. 1). The specification repeatedly refers to a "GPS device." (’285 Patent, col. 3:59-65). This could support an argument that the claimed "device" must be a more integrated piece of hardware, where the processing module is not a transient web application.
The Term: "determine route guidance"
- Context and Importance: This term defines the function of the "processing module" located on the user's device. Whether the accused system meets this limitation will depend on the technical specifics of how route information is generated and delivered.
- Intrinsic Evidence for a Broader Interpretation: An argument could be made that receiving routing data from a server and rendering it into a set of directions and a visual map on the device's display constitutes "determining" the guidance in the context of the device's function, even if the core pathfinding algorithm runs on the server.
- Intrinsic Evidence for a Narrower Interpretation: The claim's structure separates the server (which "transmits the determined address") from the device's processing module (which "determine[s] route guidance"). This structure suggests two distinct "determination" steps. A narrow reading may require the device itself to perform the computational work of calculating the route based on map data, rather than just displaying a pre-calculated result.
VI. Other Allegations
- Indirect Infringement: The complaint includes a conclusory allegation of contributory and induced infringement without pleading specific supporting facts, such as identifying instructions or advertising that would encourage users to perform the infringing acts. (Compl. ¶13).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of divided infringement: As Defendant controls the server and its customers control the end-user devices, the case will depend on whether Plaintiff can prove Defendant exercises sufficient direction or control over its users to be held liable for infringement of the entire claimed system.
- The outcome may also turn on a question of functional locus: Does the accused system's "processing module"—the mobile website running in a browser on a smartphone—actually "determine route guidance" on the device as required by the claim's architecture, or does it merely display a route fully calculated by a remote server, potentially creating a mismatch with the claim language?
- A key evidentiary question will be one of factual proof: Can Plaintiff substantiate its allegation that the accused system transmits a "time and date" from the server back to the device for the purpose of displaying time-sensitive route conditions, or will discovery show this claim limitation is not met by the accused system's operation?