DCT

2:24-cv-00302

Infogation Corp v. Denso Ten Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:24-cv-00302, E.D. Tex., 05/01/2024
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is a foreign entity that maintains a regular and established business presence in the United States, invoking the “alien venue rule.”
  • Core Dispute: Plaintiff alleges that Defendant’s in-vehicle navigation systems infringe two patents related to map display technology and distributed route calculation.
  • Technical Context: The lawsuit concerns the architecture of automotive navigation systems, specifically how they process and display map data and interact with remote servers to provide routing information.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the ’743 Patent because a Denso Corporation patent application cited the ’743 Patent as prior art in 2004, a fact which may be material to the willfulness allegation for that patent.

Case Timeline

Date Event
1999-01-06 U.S. Patent 6,292,743 Priority Date
2001-09-18 U.S. Patent 6,292,743 Issued
2004-08-05 Denso Corp. patent application citing the '743 Patent Published
2007-08-11 U.S. Patent 10,107,628 Priority Date
2018-10-23 U.S. Patent 10,107,628 Issued
2024-05-01 Complaint Filed

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

U.S. Patent No. 10,107,628 - “Method and Apparatus for Navigating on Artistic Maps”

  • The Invention Explained:
    • Problem Addressed: The patent describes conventional GPS navigation maps as potentially "boring" and failing to effectively show a user their location relative to points of interest, especially in leisure settings like a zoo or park where landmarks may not be displayed until a user is very close (’628 Patent, col. 1:40-54).
    • The Patented Solution: The invention proposes using a non-linearly scaled, "artistic map" where objects or points of interest are shown in an exaggerated manner. A user's selection on the artistic map is transformed into a physical point with real-world latitude and longitude coordinates. A navigation route is then calculated to this physical point, and the resulting directions are synchronized with and displayed on the artistic map, rather than a standard geographical map (’628 Patent, col. 2:26-39; Fig. 3).
    • Technical Importance: This approach aimed to create a more intuitive and "pleasant" user experience for navigation in specific, bounded areas like theme parks, where stylized maps are common and geographic accuracy is less critical than landmark identification (’628 Patent, col. 1:60-65).
  • 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 includes "various objects being exaggeratedly shown".
      • Receiving a user's selection of one of the objects.
      • Determining a pair of coordinates for a point on the selected object.
      • Transforming the coordinates to a "physical point" represented by latitude and longitude in a "geographical map" that is not being displayed.
      • Detecting a current location of the computing device.
      • Determining a "navigational direction" from the current location to the selected object according to the geographical map.
      • Showing the navigational direction on the artistic map.
    • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,292,743 - “Mobile Navigation System”

  • The Invention Explained:
    • Problem Addressed: The patent identifies shortcomings of stand-alone navigation systems of the time, including reliance on local, often outdated, mapping databases with limited storage capacity. Such systems lacked access to real-time data (e.g., traffic) and required that the client system use a specific, proprietary mapping database that matched the server's, making updates and interoperability difficult and costly (’743 Patent, col. 1:24-42, col. 2:1-13).
    • The Patented Solution: The invention describes a distributed client-server system. A mobile client in a vehicle sends route start and end points to a remote server. The server, with access to extensive, real-time data, calculates an optimal route. The server then formats this route into a "non-proprietary, natural language description" (e.g., text-based turn-by-turn directions) and downloads it to the client. The client interprets this generic description and uses its own, potentially different, local mapping database to reconstruct and display the route (’743 Patent, col. 3:10-55).
    • Technical Importance: This architecture aimed to decouple the client from the server, allowing a "thin" client with any mapping software to leverage a powerful, centralized server for complex, real-time route calculations, thereby reducing the hardware and software burden on the in-vehicle unit (’743 Patent, col. 2:52-62).
  • 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.
      • 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.
      • Displaying the route on the client's display system.
    • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused products as "DENSO TEN's car navigation systems worldwide, including under the ECLIPSE brand" (Compl. ¶20).
  • Functionality and Market Context:
    • The complaint alleges these are in-vehicle systems that provide navigation and information services (Compl. ¶5).
    • A screenshot from Defendant’s website describes the systems as using "connective technologies" and "ICT, such as cloud services," to deliver "customized" information and "make driving more enjoyable and active" (Compl., p. 3). This screenshot depicts an in-dash navigation unit displaying a map (Compl., p. 3).
    • The complaint asserts that Defendant manufactures, sells, and generates substantial revenue from these systems, which are provided in vehicles from manufacturers including Toyota (Compl. ¶5, ¶24).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not filed with the public complaint (Compl. ¶25, ¶41). Accordingly, the infringement allegations are summarized below in prose based on the complaint's narrative.

  • ’628 Patent Infringement Allegations
    The complaint alleges that Defendant’s systems directly infringe at least claim 1 of the ’628 Patent by making, using, selling, and offering for sale the Accused Instrumentalities (Compl. ¶25). The narrative theory suggests that the DENSO TEN navigation systems perform the steps of the claimed method by displaying a map, allowing a user to select a destination on that map, and providing navigation guidance to that destination. A screenshot from Defendant's website shows one of its navigation systems displaying a map interface, which Plaintiff may argue constitutes the claimed "artistic map" (Compl., p. 7).

  • ’743 Patent Infringement Allegations
    The complaint alleges that Defendant’s systems directly infringe at least claim 1 of the ’743 Patent (Compl. ¶41). The infringement theory is based on the client-server architecture of the accused systems. The complaint points to Defendant's marketing, which references "connective technologies" and "cloud services," as evidence that the in-vehicle units (clients) connect to a remote system (server) to obtain navigation information (Compl., p. 3). This aligns with the claimed method of a client requesting a route from a server that performs the calculation and downloads the result.

  • Identified Points of Contention:

    • Scope Questions (’628 Patent): A central question will be whether the maps used in the DENSO TEN systems qualify as "artistic maps" that are "non-linearly scaled" and feature "exaggeratedly shown" objects, as required by claim 1. The court may need to determine if this language covers conventional navigation maps with emphasized icons, or if it is limited to the highly stylized, non-geographically precise maps shown as examples in the patent (e.g., a zoo map).
    • Technical Questions (’743 Patent): A key evidentiary issue will be the format of data transmitted from Defendant's "cloud services" to the in-vehicle units. Infringement of claim 1 hinges on whether this data is a "non-proprietary, natural language description." The court will need to examine whether the accused systems use a generic, text-based format as claimed, or if they use a proprietary, binary data format for communication between the server and the client.

V. Key Claim Terms for Construction

  • Term 1: "artistic map" (’628 Patent, Claim 1)

    • Context and Importance: This term is foundational to the infringement analysis for the ’628 Patent. If the accused DENSO TEN maps are not "artistic," infringement cannot be found. Practitioners may focus on this term as its scope will likely be a primary point of dispute.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the map simply as "non-linearly scaled" and showing "exaggeratedly... points of interest" (’628 Patent, col. 1:55-57). This could be argued to encompass any map that deviates from a strict linear scale to emphasize certain features.
      • Evidence for a Narrower Interpretation: The patent’s title, abstract, and detailed examples focus on navigating leisure venues like zoos using stylized, cartoon-like maps (e.g., ’628 Patent, Fig. 1-2). This context could support a narrower construction limited to non-traditional, illustrative maps rather than standard road navigation maps.

  • Term 2: "non-proprietary, natural language description" (’743 Patent, Claim 1)

    • Context and Importance: The definition of this term is critical, as it embodies the core inventive concept of decoupling the server's route calculation from the client's specific mapping software. The dispute may turn on whether the accused system's data protocol meets this definition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states that one goal is to use "low bandwidth communication channels," and that the natural language descriptions can be "highly compressed" (’743 Patent, col. 3:15-21). This might support a view that any human-readable, text-based instruction set, as opposed to raw graphical or coordinate data, falls within the claim's scope.
      • Evidence for a Narrower Interpretation: The abstract specifies a "plain text description for each link using pre-defined generic terms," and Figure 5 provides examples like "INTERSTATE 8 90 DEG. 1.4 MILES" (’743 Patent, Abstract; Fig. 5). This could be interpreted to require a specific, structured, link-by-link text format, excluding other forms of route communication.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for both patents. The allegations are based on Defendant making, selling, and advertising the Accused Instrumentalities for an infringing use by end-users (Compl. ¶30, ¶33, ¶46, ¶49).
  • Willful Infringement:
    • For the ’628 Patent, the willfulness allegation is based on post-suit notice via the filing and service of the complaint (Compl. ¶29).
    • For the ’743 Patent, the complaint alleges pre-suit willfulness, stating that Defendant has been on notice "since 2004 when Defendant cited it in its application for its own" patent (Compl. ¶45). The complaint includes a screenshot of a patent search result allegedly showing a patent application from "Denso Corporation" that cites the ’743 patent, submitted as evidence of this knowledge (Compl., p. 12).

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

  1. A central issue will be one of definitional scope: Does the term "artistic map" from the ’628 patent, which is exemplified in the specification with stylized zoo maps, read on the potentially more conventional road maps used in DENSO TEN’s commercial navigation systems?

  2. A key evidentiary question will be one of technical implementation: Do the accused systems, which are described as using "cloud services," transmit route data from server to client using a "non-proprietary, natural language description" as required by the ’743 patent, or do they rely on a proprietary data format that falls outside the claim scope?

  3. A critical question for damages will be pre-suit knowledge and willfulness, particularly for the ’743 patent. The plaintiff's allegation that a Denso entity cited the ’743 patent in its own patent application in 2004 raises a significant factual question for the court regarding whether the infringement, if any, was willful.