Social Positioning Input Systems LLC v. Valve Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Social Positioning Input Systems, LLC (Wyoming)
  • Defendant: Valve Corporation (Washington), Gearbox Software, L.L.C. (Texas)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:23-cv-00422, E.D. Tex., 09/18/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Gearbox Software has its principal place of business in the District. Venue over Defendant Valve Corporation is alleged based on its continuous business contacts in Texas, appointment of an agent for service of process, sales of products through retailers in the District, and prior consent to venue in the District in unrelated litigation.
• Core Dispute: Plaintiff alleges that Defendants infringe a patent related to remotely programming positional information devices, such as GPS units, by making, using, or selling certain real-time location systems.
• Technical Context: The technology concerns systems that allow users to remotely send location information (e.g., a destination address) to a device for automatic programming, bypassing the need for manual data entry on the device itself.
• Key Procedural History: The patent-in-suit is a continuation of prior applications and is noted to be enforceable for past damages even after its expiration, which is anticipated to occur in 2026. The complaint also cites prior cases in which Defendant Valve Corporation allegedly consented to venue in the Eastern District of Texas.

Case Timeline

Date	Event
2006-04-28	Earliest Priority Date for U.S. Patent No. 9,261,365
2016-02-16	U.S. Patent No. 9,261,365 Issued
2023-09-18	Complaint Filed

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

U.S. Patent No. 9,261,365, "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," Issued Feb. 16, 2016

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty and inefficiency of manually programming destination addresses into Global Positioning System (GPS) devices at the time of the invention (c. 2006). Problems included inconsistencies in how different devices recognized addresses, the need to enter the same address into multiple devices individually, and the safety risks of programming a device while driving (’365 Patent, col. 1:54-2:25).
• The Patented Solution: The invention proposes a system where a user can communicate a desired location to a remote server, either through a live operator or an automated interface (’365 Patent, col. 9:26-32). This server resolves the location into geographic coordinates and transmits them directly to the user's positional information device, which is then automatically programmed with the destination (’365 Patent, Abstract; Fig. 4). This process is intended to be easier, safer, and allows for addresses to be shared or pre-loaded onto one or more devices (’365 Patent, col. 4:3-12).
• Technical Importance: The described solution aimed to streamline the user experience for navigation systems by centralizing the task of address resolution and data entry, moving it from the end-user device to a remote service.

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 (’365 Patent, col. 14:55-15:2).
• Independent Claim 1 is a method claim with the following essential elements:
  • Sending a request from a "requesting positional information device" to a server for an "address" stored in a separate "sending positional information device."
  • The request includes a "first identifier" of the requesting device.
  • Receiving the retrieved "address" at the requesting device from the server.
  • The method specifies that the server performs intermediate steps: determining a "second identifier" for the sending device based on the first identifier, and then using that to retrieve the requested address from the sending device.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Accused Instrumentalities" as "Kinexon's Real Time Location System ('RTLS') for tracking and management method of indoor industrial environments for monitoring real-time locations(i.e., location information) of goods, vehicles, and employees through Kinexon RTLS Hardware (e.g., ePaper Tag, X-Tag and SafeTag) on positional information devices (e.g., desktop or mobile devices)" (Compl. ¶28).

Functionality and Market Context

• The complaint describes the accused RTLS technology as enabling "scalability for factories and warehouses" (Compl. ¶28).
• The complaint also contains factual allegations and visual evidence related to Defendants' other products, such as Valve's Steam platform, "HTC Vive headsets," and Gearbox's "Borderlands 2 VR" game (Compl. ¶¶ 2, 5). Figure 1 in the complaint is a screenshot announcing that "Borderlands 2 VR" is available on Valve's Steam platform (Compl. p. 2). Figure 3 shows a "Valve Corporation USB receiver for a Valve Game Controller" (Compl. p. 3). However, the complaint does not allege in Count I that these specific products infringe or how they relate to the accused Kinexon RTLS.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" to detail its infringement allegations but does not attach the exhibit (Compl. ¶¶ 28, 33-34). In lieu of a claim chart summary, the narrative infringement theory is presented.

The complaint alleges that Defendants have infringed and continue to infringe at least Claim 1 of the ’365 Patent "by manufacturing, using, importing, selling, offering for sale, and/or providing" the accused Kinexon RTLS (Compl. ¶28). The complaint further alleges that "the Accused Instrumentalities practice the technology claimed by the '365 Patent" and "satisfy all elements of exemplary claim 1" (Compl. ¶33). The complaint does not, however, provide specific factual allegations detailing how the accused industrial RTLS meets each limitation of the asserted method claim.

Identified Points of Contention

• Factual Link to Defendants: A primary question for the court will be the factual basis for attributing infringement via the Kinexon RTLS to Defendants Valve and Gearbox. The complaint does not allege that Defendants manufacture, sell, or are otherwise responsible for the Kinexon system named in the infringement count (Compl. ¶28).
• Technical Mismatch: The infringement analysis may focus on whether the functionality of an "indoor industrial" RTLS for tracking "goods, vehicles, and employees" aligns with the method steps of Claim 1. Claim 1 requires sending a request for an "address" stored on one device to be used by another, a process the patent describes in the context of consumer travel navigation (’365 Patent, col. 11:13-18, col. 13:3-16).
• Scope Questions: A potential dispute concerns whether the components of the accused Kinexon system (e.g., "ePaper Tag, X-Tag and SafeTag") constitute a "positional information device" as that term is used in the patent, which provides examples such as in-vehicle GPS units (’365 Patent, col. 4:13-18).

V. Key Claim Terms for Construction

Term: "positional information device"

• Context and Importance: This term appears throughout Claim 1 and defines the core devices that perform the claimed method. Its construction is critical because the patent's specification focuses on consumer navigation devices (e.g., vehicle GPS), while the accused instrumentality is described as an industrial tracking system. The scope of this term will determine whether the claim can read on the accused technology.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is general and not explicitly limited in the claim language. The specification states the principles "may be applied to any type of navigation or positional information device" (’365 Patent, col. 4:18-19).
  • Evidence for a Narrower Interpretation: The specification's consistent examples relate to "a global positioning system (GPS) device," often in the context of automobiles, boats, and other vehicles (’365 Patent, Abstract; col. 2:26-31; col. 4:21-22). An argument could be made that the term's meaning is informed by this specific context.

Term: "address"

• Context and Importance: Claim 1 requires requesting and receiving at least one "address." The viability of the infringement allegation depends on whether the location data managed by the accused industrial RTLS constitutes an "address" as claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is not explicitly defined. It could be argued to encompass any data that identifies a location, including a set of coordinates, a zone ID in a warehouse, or a tag identifier.
  • Evidence for a Narrower Interpretation: The patent's background and detailed description repeatedly use "address" to mean a conventional street address for route guidance (e.g., "19333 Collins Avenue, Sunny Isles, Fla.") (’365 Patent, col. 1:61-62). The problem solved by the patent is the difficulty of entering such human-readable addresses into a device, suggesting a narrower meaning than raw location coordinates (’365 Patent, col. 1:54-2:8).

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induce infringement by distributing "product literature and website materials" that instruct end users on infringing uses (Compl. ¶31). It also alleges contributory infringement (Compl. ¶28). However, the complaint refers to the unattached Exhibit B for specific details, providing no concrete factual examples of such inducement or contribution in the pleading itself.
• Willful Infringement: The willfulness allegation appears to be based on post-suit knowledge. The complaint alleges Defendants have "knowledge of its infringement of the '365 Patent, at least as of the service of the present complaint" (Compl. ¶26), and that continued infringement despite this knowledge constitutes inducement (Compl. ¶32).

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

The complaint as filed presents several fundamental questions that will likely define the early stages of this litigation.

• A central issue will be evidentiary and factual: What connection, if any, will Plaintiff establish between Defendants Valve and Gearbox—entities known for video games and digital distribution—and the "Kinexon...RTLS" for "factories and warehouses" that is the sole instrumentality identified in the infringement count? The complaint does not plead facts to bridge this gap.
• A second core issue will be one of definitional scope and technical applicability: Assuming a factual link is demonstrated, can the claim terms "positional information device" and "address", which are described in the patent's specification in the context of consumer vehicle navigation, be construed to cover the hardware tags and location data of an indoor industrial tracking system?
• A third question relates to the infringement theory itself: As Claim 1 is a method claim detailing a multi-step interaction between two end-user devices and a server, a key evidentiary question will be whether Plaintiff can show that Defendants or their customers perform all steps of this specific information-sharing method using the accused industrial RTLS.