DCT

2:24-cv-00301

Infogation Corp v. Aisin Corp Pursuant To Court Order Docket In Lead Case As Directed

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00301, E.D. Tex., 05/01/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation with a regular and established business presence in the United States, invoking the "alien venue rule."
  • Core Dispute: Plaintiff alleges that Defendant’s in-vehicle connected navigation systems infringe two patents related to displaying routes on stylized maps and a client-server architecture for route calculation.
  • Technical Context: The technology at issue involves in-vehicle GPS navigation systems, specifically those that connect to remote servers for updated map data and real-time route optimization.
  • Key Procedural History: The complaint alleges that Defendant Aisin has been on notice of one of the patents-in-suit (the ’743 Patent) since 2010, when Aisin cited it in its own patent application, a fact Plaintiff supports with a screenshot and which forms the basis for a pre-suit willfulness allegation.

Case Timeline

Date Event
1999-01-06 Priority Date for U.S. Patent 6,292,743
2001-09-18 Issue Date for U.S. Patent 6,292,743
2007-08-11 Priority Date for U.S. Patent 10,107,628
2010-06-03 Publication date of Aisin patent application citing the ’743 Patent
2018-10-23 Issue Date for U.S. Patent 10,107,628
2024-05-01 Complaint Filing Date

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

U.S. Patent No. 10,107,628 - METHOD AND APPARATUS FOR NAVIGATING ON ARTISTIC MAPS (Issued Oct. 23, 2018)

The Invention Explained

  • Problem Addressed: The patent describes that conventional GPS navigation maps can be visually uninteresting and may fail to adequately display specific points of interest, such as in a leisure area like a park or zoo, until the user is very close to the destination (’628 Patent, col. 1:45-54).
  • The Patented Solution: The invention proposes a method for navigating using a non-linearly scaled or "artistic map" where objects and points of interest are shown in an exaggerated or stylized manner. When a user selects a point on this artistic map, the system transforms the selection’s coordinates into a physical geographic point (latitude and longitude), determines a route from the user's current location to that physical point, and then synchronizes and displays the navigational guidance on the artistic map (’628 Patent, Abstract; Fig. 3).
  • Technical Importance: This technology allows for the creation of more intuitive and visually engaging navigation experiences in specific environments (e.g., theme parks, campuses) where highlighting key attractions is more important than strict geographic scale (’628 Patent, col. 1:61-65).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶25).
  • The 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 on the map.
    • Determining coordinates for a point on the selected object.
    • Transforming those coordinates into a "physical point" (latitude and longitude) in a geographical map.
    • Detecting the device's current location.
    • Determining a "navigational direction" to the physical point using the geographical map.
    • Showing the determined navigational direction on the displayed artistic map.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,292,743 - MOBILE NAVIGATION SYSTEM (Issued Sep. 18, 2001)

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of early in-vehicle navigation systems, which relied on static, locally stored map data (e.g., on CDs) that was capacity-limited and quickly outdated. Such systems could not incorporate real-time information like traffic, and early connected systems often required proprietary client-side software that was tightly coupled to the server, creating incompatibility and update burdens (’743 Patent, col. 1:11-34; col. 2:1-8).
  • The Patented Solution: The invention discloses a distributed navigation system where a client device in a vehicle establishes a wireless connection to a remote server. The client sends start and end points for a desired route. The server accesses real-time data, calculates the optimal route, and formats it as a "non-proprietary, natural language description." This generic description is sent to the client, which then interprets it and uses its own local mapping database to reconstruct and display the route (’743 Patent, Abstract; col. 3:20-47).
  • Technical Importance: This client-server architecture offloads heavy computational tasks to the server, enables the use of real-time data for routing, and decouples the server's functionality from the client's specific mapping software, allowing for greater hardware and software independence (’743 Patent, col. 3:5-9).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶41).
  • The 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."
    • The server calculating an optimal route based on the real-time information and route designations.
    • The server formatting the route into a "non-proprietary, natural language description."
    • Downloading this description to the client.
    • The client reconstructing the optimal route using a local mapping database.
    • The client displaying the optimal route on a display system.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "Aisin's Toyota Lexus Genuine Navigation systems," described as "connected navigation" platforms (Compl. ¶5, ¶20).

Functionality and Market Context

  • The complaint alleges these systems operate via "communication with the center" to provide positional and other useful information (Compl. ¶8). A screenshot from Aisin's website, included in the complaint, states that the system "Automatically downloads up-to-date maps," including updates for new roads, and can perform operations via an "interactive voice agent" (Compl. ¶8, Fig. at 3). This description suggests a client-server architecture where the in-vehicle unit receives data from a remote source to provide navigation services. The complaint further alleges these systems generate substantial revenue for Aisin (Compl. ¶24, ¶40).

IV. Analysis of Infringement Allegations

’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 on the computing device... The accused systems allegedly download maps from a central server that meet the "artistic" and "exaggeratedly shown" limitations. The website description notes the system "Automatically downloads up-to-date maps" (Compl. ¶8). ¶25, ¶8 col. 2:26-30
receiving in the computing device a selection on the one of the objects from the user as a selected object; A user selects a destination on the navigation system's display screen. This is a standard function of the accused navigation systems. ¶25, ¶20 col. 2:30-32
determining by the computing device a pair of coordinates for one of the points on the selected object; The system captures the screen coordinates of the user's selection. ¶25 col. 2:32-34
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... The system converts the screen selection into real-world latitude and longitude coordinates for routing. ¶25 col. 2:34-39
detecting a current location of the computing device in the geographical map; The system uses GPS to determine its current position, which is described as providing "positional information" (Compl. ¶8). ¶25, ¶8 col. 2:39-41
determining according to the geographical map a navigational direction from the current location to the one of the objects being selected; and The system calculates a route from its current position to the selected destination via "communication with the center" (Compl. ¶8). ¶25, ¶8 col. 2:41-44
showing the navigational direction on the artistic map being displayed. The system displays the calculated route on the vehicle's navigation screen. ¶25, ¶20 col. 2:45-47
  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether the maps used in the accused "Toyota Lexus Genuine Navigation systems" can be properly characterized as "artistic" and "non-linearly scaled" with "exaggeratedly shown" objects. The patent's examples depict highly stylized theme park maps (’628 Patent, Figs. 1-2), raising the question of whether standard automotive navigation maps, even those with 3D renderings or other graphical enhancements, fall within the claimed scope.
    • Technical Questions: What evidence does the complaint provide that the accused systems’ maps are "non-linearly scaled"? The complaint relies on general product descriptions without offering specific technical details on the map rendering technology.

’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 accused system is a "connected navigation" platform that operates via "communication with the center," implying a wireless link (Compl. ¶8). ¶41, ¶8 col. 15:58-60
transmitting start and end route designations from the client to the server; A user inputs a destination, and the system communicates with the server to obtain route information. ¶41, ¶20 col. 15:60-62
accessing real-time information by the server; The server-side component of the accused system allegedly accesses data for updated maps and roads, which Plaintiff characterizes as "real-time information" (Compl. ¶8). ¶41, ¶8 col. 15:63
calculating the optimal route by the server...; The complaint alleges route calculation is performed by the remote "center" (Compl. ¶8). ¶41, ¶8 col. 15:64-67
formatting the optimal route into a non-proprietary, natural language description; The complaint alleges that the route data sent from the server to the client meets this limitation, but provides no specific details on the data format used. ¶41 col. 16:1-3
downloading said...description to the client; The system "downloads up-to-date maps" and route guidance from the server (Compl. ¶8). ¶41, ¶8 col. 16:3-5
reconstructing the optimal route by the client using a local mapping database; and The in-vehicle client device processes the downloaded server data to generate a displayable route on its local map. ¶41 col. 16:5-7
displaying said optimal route on a display system coupled to the client. The client device displays the final reconstructed route on its navigation screen. ¶41, ¶20 col. 16:8-10
  • Identified Points of Contention:
    • Technical Questions: The primary unresolved question is the nature of the data transmitted from Aisin's servers to the in-vehicle clients. The complaint offers no evidence that this data is a "non-proprietary, natural language description". Discovery will be required to determine if the data format is text-based and "natural language" (like the patent's example, "INTERSTATE 8 90 DEG. 1.4 MILES" ('743 Patent, Fig. 5)) or if it is a proprietary binary or otherwise structured format that falls outside the claim's scope.

V. Key Claim Terms for Construction

For the ’628 Patent:

  • The Term: "artistic map"
  • Context and Importance: This term is foundational to Claim 1 of the ’628 Patent. The outcome of the infringement analysis for this patent may depend entirely on whether the maps in Aisin's navigation systems are construed as "artistic." Practitioners may focus on this term because it appears to describe a specific type of stylized, non-scaled map rather than a conventional road map.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the purpose is to "help a user of a GPS receiver locate what is desired to see" (’628 Patent, col. 1:63-65). This purpose-driven language could support an argument that any map graphically enhanced for user convenience (e.g., with 3D landmarks) is "artistic."
    • Evidence for a Narrower Interpretation: The patent’s specific embodiments are a zoo map (Fig. 1) and a botanical garden map (Fig. 2), both of which are highly stylized and geographically distorted. The abstract describes "various objects being exaggeratedly shown," suggesting a departure from conventional cartography that may be required to meet the definition.

For the ’743 Patent:

  • The Term: "non-proprietary, natural language description"
  • Context and Importance: This term defines the core technical distinction of the claimed invention—decoupling the server from the client's specific map database. Proving that Aisin's system uses such a format is critical to Plaintiff's infringement case.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent provides an example of the description: "INTERSTATE 5 0 DEG. 127.3 MILES" (’743 Patent, Fig. 5, element 515). This suggests that a structured, text-based format containing human-readable elements like road names and turn directions could qualify as a "natural language description."
    • Evidence for a Narrower Interpretation: A party could argue the term requires the format to be "non-proprietary," meaning it is not specific to the manufacturer's ecosystem. Further, the emphasis on being "completely independent from the local mapping database software" (’743 Patent, col. 3:23-25) could be used to argue that any format requiring a specific client-side interpreter is, by definition, proprietary.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for both patents. The theory is that Aisin provides the accused navigation systems and instructs end-users (drivers) on how to use them for navigation, which constitutes the directly infringing acts (Compl. ¶31-33, ¶47-49).
  • Willful Infringement:
    • For the ’628 Patent, the willfulness allegation is based on post-suit knowledge acquired through the filing of the complaint (Compl. ¶29).
    • For the ’743 Patent, the complaint makes a more significant allegation of pre-suit willfulness, claiming Aisin has known of the patent since at least 2010 when it allegedly cited the ’743 patent in its own patent application (U.S. Pub. No. 2010/0138434). The complaint includes a screenshot from a patent search to support this allegation (Compl. ¶45). Plaintiff also alleges willful blindness (Compl. ¶50).

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

  1. A core issue will be one of definitional scope: Can the term "artistic map," which the ’628 Patent illustrates with stylized, non-scaled theme park maps, be construed to cover the graphical road maps used in the accused commercial navigation systems?
  2. A key evidentiary question will be one of data architecture: Does discovery show that the data transmitted between Aisin's servers and its in-vehicle navigation clients constitutes a "non-proprietary, natural language description" as required by the ’743 Patent, or is it a proprietary format that falls outside the claim scope?
  3. A third central question relates to knowledge and intent: Given the allegation that Aisin cited the ’743 Patent in a 2010 patent application, what was the extent of Aisin’s awareness of the patent’s technology, and does this evidence support a finding of willful infringement from that date?