Geographic Location Innovations LLC v. CVS Pharmacy Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: Boston Market Corporation (Delaware)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Identification: 2:19-cv-00192, E.D. Tex., 08/01/2019
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, specifically citing a store location in Plano, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s website-based store locator service infringes a patent related to remotely providing location information and route guidance to a user's device.
• Technical Context: The technology concerns the integration of remote servers with personal navigation devices to simplify the process of finding and navigating to a point of interest.
• Key Procedural History: The operative pleading is a First Amended Complaint, filed in response to a motion to dismiss the original complaint.

Case Timeline

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

• 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 identifies several problems with early GPS navigation devices: they were difficult to program, especially while driving; different models had inconsistent interfaces and address formats; and sharing an address among multiple devices required redundant manual entry (’285 Patent, col. 1:43-2:13).
  • The Patented Solution: The invention describes a system where a user's "positional information device" (e.g., a GPS unit) communicates with a remote server over a network (’285 Patent, FIG. 3). The user requests a location from the server (e.g., via a live operator or a web interface), and the server determines the location's coordinates and transmits them back to the user's device, which then calculates and displays route guidance (’285 Patent, col. 2:40-46; col. 8:10-24). This offloads the task of address entry and lookup from the user to a remote system, aiming for a safer and more convenient experience.
  • Technical Importance: This approach presaged the now-common functionality of modern mapping applications, where a centralized service provides point-of-interest data to a distributed network of user devices, overcoming the limitations of standalone, offline navigation units (’285 Patent, col. 2:25-30).
• Key Claims at a Glance:
  • The complaint asserts at least independent claim 13 (’285 Patent, col. 14:13-52; Compl. ¶19).
  • Claim 13 recites a system comprising:
    • A server configured to receive a request for an address, determine the address, and transmit it.
    • A "positional information device" that itself includes:
      • a locational information module (to find its own position).
      • a communication module (to receive the address from the server).
      • a processing module (to determine route guidance).
      • a display module (to show the route guidance).
    • A communications network coupling the server and the device.
    • A specific requirement that the server receives, transmits, and the device displays the address associated with a specific time and date.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's "store locator service" accessible via its website, which the complaint refers to as the "System" (Compl. ¶19).

Functionality and Market Context

The System is described as a mobile website with associated hardware (e.g., servers) that allows a user to find nearby Boston Market store locations (Compl. ¶20-21). A user can input a location (e.g., zip code) or allow the website to use the device's current location to display a map of nearby stores (Compl. ¶23). The complaint alleges the System provides for "remote entry of location information" and determines route guidance to a selected store (Compl. ¶20, ¶25). A screenshot provided in the complaint shows the website prompting the user to allow location access, a common feature of location-aware web applications (Compl. p. 8).

IV. Analysis of Infringement Allegations

'285 Patent Infringement Allegations

Identified Points of Contention:

• Scope Questions: A central question may be whether a general-purpose smartphone executing a web browser constitutes the claimed "positional information device" with its specified "modules." The defense could argue the patent describes a more integrated, special-purpose navigation device, whereas the accused system involves a standard client-server web architecture where the "modules" are not discrete components of the device itself but rather functions of the browser and remote server.
• Technical Questions: The complaint alleges the "processing module" is the "mapping software and the mobile website" on the user's device (Compl. ¶25). A point of dispute may be whether the route guidance is actually "determined" on the device, as the claim requires, or if it is determined by the remote server and merely rendered for display by the browser on the device.
• Technical Questions: Claim 13 includes a detailed limitation requiring the server to receive a time/date, transmit that same time/date back to the device with the address, and for the device to then display the address at that associated time/date. The complaint alleges the server receives the time/date to calculate traffic (Compl. ¶28), but it does not explicitly allege the full sequence of transmission and time-contingent display required by the claim language. This may represent a gap between the allegations and the claim requirements.

V. Key Claim Terms for Construction

• The Term: "processing module"
• Context and Importance: This term's construction is critical because Claim 13 requires the "positional information device" to include a "processing module" that performs the function of determining route guidance. The complaint alleges this is the "mobile website" (Compl. ¶25). The location of this function—whether on the client device or the remote server—will be a key issue. Practitioners may focus on whether transient web-based code can constitute a "module" of the device itself.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification is described in functional terms, stating the "computer processing module 120 will use computer software instructions" to organize traffic flow between other modules, and that the disclosure can be implemented in "various forms of hardware, software, firmware, special purpose processors, or a combination thereof" (’285 Patent, col. 4:39-46). This could support an argument that software loaded from a website qualifies.
  • Evidence for a Narrower Interpretation: Figure 2 of the patent depicts the "COMPUTER PROCESSING MODULE" (120) as a distinct, co-equal block alongside other hardware-centric modules like "LOCATIONAL INFORMATION MODULE" (122) and "COMMUNICATION MODULE" (112), all connected by a system bus (’285 Patent, FIG. 2). This architectural diagram suggests a more integrated, persistent component of the device, rather than code temporarily executed within a general-purpose web browser.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of inducement in violation of 35 U.S.C. § 271 but does not plead specific facts to support the requisite knowledge or intent, such as referencing user manuals or specific instructions provided by Defendant (Compl. ¶19).
• Willful Infringement: The complaint does not use the word "willful" but does request damages "in accordance with 35 U.S.C. § 284" (Compl. p. 12, ¶(c)), which is the statutory basis for enhanced damages. The complaint does not allege any pre-suit knowledge of the patent by the Defendant.

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

The dispute will likely center on whether a modern, web-based store locator fits within the specific system architecture claimed in the '285 patent. The key questions for the court appear to be:

1. A core issue will be one of definitional scope: can the term "positional information device", with its enumerated "locational", "communication", and "processing" modules, be construed to read on a standard smartphone running a web browser, or does the patent’s specification and figures limit the term to a more integrated, special-purpose navigation unit?

2. A key evidentiary question will be one of locus of function: does the accused system's "processing module"—identified as the mobile website—actually "determine route guidance" on the user's device as required by Claim 13, or is that determination performed by a remote server, with the user's device merely displaying the results?

3. A third question will be one of strict compliance with claim language: does the complaint adequately allege that the accused system performs the full, multi-step process recited in the final "wherein" clause of Claim 13, which requires the server to not only receive a time/date but also transmit it back to the device for a time-specific display of the address?