DCT
2:23-cv-00513
Infogation Corp v. Honda Motor Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Honda Motor Co. Ltd. (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:23-cv-00513, E.D. Tex., 05/13/2024
- Venue Allegations: Venue is alleged to be proper under the "alien venue rule," based on Defendant being a foreign corporation that maintains a regular and established business presence in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle GPS navigation systems infringe four U.S. patents related to non-linear map displays, client-server route calculation, and realistic map generation.
- Technical Context: The lawsuit concerns the technology behind modern automotive navigation systems, focusing on the methods used to display maps, render realistic environmental features, and efficiently calculate routes using remote servers.
- Key Procedural History: The complaint alleges that Defendant Honda Motor Co. cited the ’743 Patent eight times in its own patent applications, a fact Plaintiff uses to support its claim of pre-suit knowledge and willful infringement. It also notes that the Patents-in-Suit have been cited in over 200 other patents. U.S. Patent 8,406,994, one of the asserted patents, had all claims (1-18) canceled in an ex parte reexamination certificate issued on March 28, 2025, a fact not mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 1999-01-06 | Earliest Priority Date for U.S. Patent 6,292,743 |
| 2001-09-18 | U.S. Patent 6,292,743 Issues |
| 2005-06-23 | Earliest alleged citation of ’743 Patent by Honda in a patent application |
| 2007-08-11 | Earliest Priority Date for U.S. Patent 10,107,628 |
| 2008-11-07 | Earliest Priority Date for U.S. Patents 8,898,003 and 8,406,994 |
| 2013-03-26 | U.S. Patent 8,406,994 Issues |
| 2014-11-25 | U.S. Patent 8,898,003 Issues |
| 2018-10-23 | U.S. Patent 10,107,628 Issues |
| 2019-01-06 | U.S. Patent 6,292,743 Expires |
| 2024-05-13 | First Amended Complaint Filed |
| 2025-03-28 | Ex Parte Reexamination Certificate issues canceling all claims of U.S. Patent 8,406,994 |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,107,628 - “Method and Apparatus for Navigating on Artistic Maps” (Oct. 23, 2018)
The Invention Explained
- Problem Addressed: The patent’s background describes conventional GPS map displays as potentially "boring" and ineffective for leisure activities, such as touring a zoo or park, because they may not display points of interest until a user is very close and they lack the user-friendly, stylized nature of an artistic map (e.g., a theme park guide) (’628 Patent, col. 1:36-54).
- The Patented Solution: The invention proposes a system for navigating using a "non-linearly scaled" or "artistic map" where objects like landmarks are "exaggeratedly shown" for clarity (’628 Patent, col. 2:27-31). When a user selects a point on one of these exaggerated objects, the system translates the screen coordinates to a single, precise real-world geographic point (latitude and longitude). It then calculates a route to that physical point and displays the navigational direction on the user-friendly artistic map, effectively bridging the gap between a stylized display and precise GPS functionality (’628 Patent, Abstract; FIG. 3).
- Technical Importance: This technology aims to enhance the user experience by allowing navigation systems to use more intuitive, visually rich, and context-appropriate maps rather than being limited to conventional, strictly scaled road maps (’628 Patent, col. 1:61-66).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶29).
- Essential elements of claim 1 include:
- Downloading an "artistic map" that is "non-linearly scaled" and has "various objects being exaggeratedly shown."
- Receiving a user's selection of one of the objects.
- Transforming coordinates from the selected point on the map to a "physical point" (latitude/longitude) on a non-displayed geographical map.
- A specific condition where different points selected within the exaggerated object all correspond "substantially to the physical point."
- Determining a "navigational direction" from the user's current location to the selected object.
- Displaying that navigational direction on the artistic map.
- The complaint reserves the right to assert additional claims (Compl. ¶23).
U.S. Patent No. 6,292,743 - “Mobile Navigation System” (Sep. 18, 2001)
The Invention Explained
- Problem Addressed: The patent identifies shortcomings in prior art navigation systems. Stand-alone units relied on limited, quickly outdated local map data, while early server-connected systems required proprietary, high-bandwidth data formats and client-specific software, leading to vendor lock-in and high operational costs (’743 Patent, col. 1:26-38; col. 2:1-14).
- The Patented Solution: The invention describes a distributed navigation system where a client device (in a vehicle) sends a simple route request (e.g., start and end addresses) to a remote server (’743 Patent, col. 3:25-32). The server calculates the optimal route using real-time data (e.g., traffic) and sends it back to the client formatted as a "non-proprietary, natural language description"—essentially a simple, text-based list of maneuvers. The client device then interprets this generic description and uses its own local mapping database, regardless of its vendor or version, to reconstruct and display the route (’743 Patent, Abstract; col. 3:40-47).
- Technical Importance: This client-server architecture decouples the complex, real-time route calculation (performed on the server) from the map display (performed on the client), enabling lower-cost client hardware and the use of diverse, non-matching map databases while reducing bandwidth needs (’743 Patent, col. 3:1-9).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶46).
- Essential elements of claim 1 include:
- Establishing a wireless connection between a client and a server.
- Transmitting start and end route designations from the client to the server.
- The server accessing "real-time information" to calculate an optimal route.
- Formatting the route into a "non-proprietary, natural language description."
- Downloading this description to the client.
- The client "reconstructing the optimal route" using its "local mapping database."
- Displaying the reconstructed route.
- The complaint reserves the right to assert additional claims (Compl. ¶23).
U.S. Patent No. 8,898,003 - “GPS Map Resembling Ambient Environment” (Nov. 25, 2014)
- Technology Synopsis: This patent describes methods for enhancing the realism of a GPS map display. The system superimposes images representing objects like landmarks or 3D road signs onto the map and dynamically alters their appearance (e.g., color, lighting) to reflect ambient conditions such as the time of day or weather, creating a more immersive user experience (’003 Patent, Abstract; col. 2:5-18).
- Asserted Claims: At least Claim 1 (Compl. ¶23).
- Accused Features: The complaint alleges that the Honda/Acura navigation systems incorporate these features to provide realistic map views that change based on the vehicle's environment (Compl. ¶17, ¶22).
U.S. Patent No. 8,406,994 - “Electronically Generated Realistic-Like Map” (Mar. 26, 2013)
- Technology Synopsis: As a parent to the ’003 Patent, this patent covers similar technology for creating realistic map displays. It focuses on superimposing images onto a map and changing their color effects based on inputs about the location's current conditions (e.g., weather, time), thereby making the map "resembling an electronically generated map with a certain level of realism" (’994 Patent, Abstract; col. 2:9-14).
- Asserted Claims: At least Claim 1 (Compl. ¶23).
- Accused Features: The Honda/Acura navigation systems are accused of using these methods to generate dynamic, realistic map displays (Compl. ¶17, ¶22).
III. The Accused Instrumentality
Product Identification
- The "Honda/Acura GPS Navigation system" and "Honda/Acura Satellite-Linked Navigation System™ with Honda RealTime Traffic systems" (Compl. ¶5, ¶22). These systems are alleged to be included in numerous Honda and Acura vehicle models, such as the Honda Accord, Civic, and CR-V, and the Acura MDX, RDX, and TLX (Compl. ¶22).
Functionality and Market Context
- The Accused Instrumentalities are in-vehicle infotainment systems that provide drivers with map-based turn-by-turn navigation. The complaint alleges these systems incorporate functionality that infringes the patents-in-suit, including the display of non-linearly scaled maps with exaggerated points of interest, the use of a client-server architecture to obtain route guidance based on real-time traffic data, and the generation of realistic map displays that adapt to ambient conditions (Compl. ¶5, ¶16, ¶17, ¶18). The complaint alleges these systems are featured across a wide array of high-volume vehicle models sold in the U.S. (Compl. ¶22). The complaint provides a screenshot from a Honda owner's manual showing a map display with options to find a destination by exploring the map or searching for a point of interest (Compl. ¶30, p. 9).
IV. Analysis of Infringement Allegations
10,107,628 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| downloading from a network into a computing device an artistic map, the artistic map being non-linearly scaled and including various objects being exaggeratedly shown... | The system displays a "non-linearly scaled map" which "shows exaggeratedly points of interest, in this case, gas stations." | ¶30 | col. 2:27-31 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The system allows a user to set a destination by selecting a POI icon directly on the map, as described under the "EXPLORE" function. | ¶30 (p. 9) | col. 5:12-14 |
| transforming in the computing device the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map not being shown on the display | This internal processing step is alleged to occur on information and belief as a necessary function for the system to translate a map selection into a navigable route. | ¶23, ¶29 | col. 2:32-37 |
| the points representing the selected object having different pairs of coordinates, but all of the different pairs of coordinates... corresponding substantially to the physical point... | This is alleged to occur when a user selects an "exaggeratedly" shown object, where any point within that object maps to a single real-world location. | ¶23, ¶29 | col. 8:47-52 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected | The system provides route guidance from the user's current position to the selected destination. | ¶30 (p. 9) | col. 2:48-51 |
Identified Points of Contention
- Scope Questions: A primary issue may be whether the map display in the Accused Instrumentalities qualifies as an "artistic map" that is "non-linearly scaled" in the manner contemplated by the patent. The defense may argue that the accused map is a conventional road map with icons, distinct from the highly stylized zoo and park maps emphasized as embodiments in the ’628 Patent’s specification (e.g., ’628 Patent, FIG. 1).
- Technical Questions: The complaint alleges, but does not provide direct evidence for, the internal transformation process. A key question for discovery will be whether the accused system functions such that multiple, distinct coordinates within an "exaggerated" POI icon on the screen are all resolved to a single "physical point" (latitude/longitude), as the claim requires.
6,292,743 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| establishing a wireless connection between the client and the server | The system connects to a server to obtain real-time data for routing, which necessitates a wireless connection from the vehicle. | ¶5, ¶18 | col. 3:25-28 |
| transmitting start and end route designations from the client to the server | Users input destination information, which is allegedly transmitted to the server to request a route calculation. | ¶46, ¶50 | col. 3:28-30 |
| accessing real-time information by the server | The accused products include "Honda RealTime Traffic systems," which allegedly provide the server with real-time data for use in route calculation. | ¶5, ¶18 | col. 3:30-34 |
| formatting the optimal route into a non-proprietary, natural language description | The complaint alleges on information and belief that the server formats and transmits the route in a manner consistent with this limitation. | ¶18, ¶46 | col. 3:35-40 |
| reconstructing the optimal route by the client using a local mapping database | The client device allegedly receives the server's route description and reconstructs it for display on its own local map. | ¶18, ¶46 | col. 3:42-45 |
Identified Points of Contention
- Technical Questions: The infringement analysis will likely center on the exact format of the data transmitted from Honda's servers to the vehicle. The complaint does not provide evidence showing that this data is a "non-proprietary, natural language description." Discovery will be needed to determine if Honda uses such a format or a proprietary, map-database-specific format that would fall outside the claim scope.
- Scope Questions: The definition of "non-proprietary, natural language description" will be critical. The parties may dispute whether this term is limited to simple, plain-text instructions as shown in the patent’s examples, or if it can encompass more complex but standardized data structures.
V. Key Claim Terms for Construction
For the ’628 Patent
- The Term: "artistic map"
- Context and Importance: This term defines the type of map to which the claimed method applies. Its construction is critical because if the accused Honda maps are not deemed "artistic," a core premise of the infringement allegation may fail. Practitioners may focus on this term because the patent’s examples are highly stylized (e.g., a zoo map), whereas the accused product appears to be a more conventional navigation map.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that a map "may be artisticly made to make the navigation as a pleasant experience," which could suggest that being "artistic" is an optional or qualitative characteristic rather than a strict structural requirement (’628 Patent, col. 1:65-66).
- Evidence for a Narrower Interpretation: The detailed description repeatedly refers to examples such as a "touring map provided by a zoo" (col. 4:35-36) and shows a highly illustrated zoo map in FIG. 1, potentially linking the term to non-standard, illustrative maps rather than typical road maps.
For the ’743 Patent
- The Term: "non-proprietary, natural language description"
- Context and Importance: This term is the linchpin of the claimed invention, distinguishing it from prior art that used proprietary, complex data formats. The infringement case for the ’743 patent depends entirely on whether the data downloaded by the accused Honda systems meets this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the goal as creating a system where the server is "hardware and software independent from the client" (’743 Patent, col. 3:6-9). This purpose could support a broader reading where any data format not tied to a specific client map version qualifies as "non-proprietary."
- Evidence for a Narrower Interpretation: The abstract specifies that the description "includes a plain text description for each link using pre-defined generic terms" (’743 Patent, Abstract). A defendant could argue this limits the claim to simple, human-readable text strings, not structured data formats like XML or JSON, even if they are standardized.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Honda induces infringement by advertising the accused systems and providing user manuals and instructions that encourage customers to use the products in an infringing manner (Compl. ¶35-¶38, ¶53-¶56).
- Willful Infringement: The willfulness allegation for the ’628 Patent is based on notice provided by the filing of the complaint (post-suit knowledge) and a general allegation of willful blindness (Compl. ¶34, ¶39). For the ’743 Patent, the allegation is notably stronger, based on pre-suit knowledge stemming from Honda Motor Co.’s own citation to the ’743 Patent in at least eight of its own patent applications since 2005 (Compl. ¶51). The complaint includes a screenshot from a patent search database as evidence for this allegation (Compl. ¶52, p. 14).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "artistic map," which the ’628 Patent illustrates with highly stylized zoo maps, be construed to cover the more conventional, icon-based road maps allegedly used in Honda's navigation systems?
- A key evidentiary question will be one of technical implementation: what is the precise data format transmitted between Honda's servers and its vehicles? The viability of the infringement claim for the ’743 Patent will depend on whether this format constitutes a "non-proprietary, natural language description" or a proprietary data stream that falls outside the patent's claims.
- The dispute over willfulness regarding the ’743 Patent will likely focus on pre-suit knowledge: will Honda's repeated citation of the ’743 Patent in its own patent prosecution be sufficient for a fact-finder to conclude that Honda knew of the patent and the risks of infringement before the lawsuit was filed?