DCT
2:24-cv-00303
Infogation Corp v. Panasonic Automotive Systems Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Panasonic Automotive Systems Co., Ltd. (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-00303, E.D. Tex., 07/10/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation that conducts substantial business in the State of Texas and the Eastern District, and under the "alien venue rule."
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle navigation and infotainment systems infringe two patents related to displaying routes on artistic maps and client-server route calculation.
- Technical Context: The patents address technologies for vehicle navigation systems, one focusing on user experience with non-literal maps and the other on the architecture of early cloud-based navigation.
- Key Procedural History: The complaint alleges that U.S. Patent 6,292,743 expired in 2019, limiting any potential damages for that patent to a past infringement period. A key allegation for willfulness regarding this patent is that a 2004 patent application assigned to Panasonic cited the patent-in-suit, suggesting potential pre-suit knowledge.
Case Timeline
| Date | Event |
|---|---|
| 1999-01-06 | Earliest Priority Date for ’743 Patent |
| 2001-09-18 | ’743 Patent Issue Date |
| 2004-11-04 | Publication of Panasonic-assigned patent application citing ’743 Patent |
| 2007-08-11 | Earliest Priority Date for ’628 Patent |
| 2018-10-23 | ’628 Patent Issue Date |
| 2019-01-06 | ’743 Patent Expiration Date |
| 2024-07-10 | 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 October 23, 2018
The Invention Explained
- Problem Addressed: The patent’s background describes conventional GPS navigation maps as potentially "boring" and ineffective for leisure activities, such as visiting a zoo or park, because they fail to clearly display points of interest until a user is very close (’628 Patent, col. 1:37-54).
- The Patented Solution: The invention proposes a system for navigating using an "artistic map," which is non-linearly scaled and may show "exaggeratedly" objects or points of interest (’628 Patent, col. 2:13-16). The system works by capturing a user's selection on the artistic map, transforming the coordinates of that selection into a physical point (latitude and longitude) on a corresponding geographic map, calculating a navigational direction, and then synchronizing or mapping that direction back onto the artistic map for display (’628 Patent, col. 2:30-39; FIG. 3).
- Technical Importance: This approach aims to provide a more engaging and intuitive user experience for navigation in environments like theme parks or tourist areas, where stylized maps are common and geographic accuracy is less critical than highlighting key attractions (’628 Patent, col. 1:55-65).
Key Claims at a Glance
- The complaint does not identify specific claims it intends to assert but reserves the right to do so. Independent claims 1 (a method) and 11 (a portable device) appear to cover the core invention.
- The essential elements of independent claim 1 include:
- Downloading a non-linearly scaled "artistic map" with exaggerated objects.
- Receiving a user's selection of an object on the map.
- Transforming the coordinates of a point on the selected object to a physical point (latitude/longitude) in a geographical map.
- Detecting a current location and determining a navigational direction to the selected object.
- Showing the determined navigational direction on the artistic map.
U.S. Patent No. 6,292,743 - "Mobile Navigation System," issued September 18, 2001
The Invention Explained
- Problem Addressed: The patent identifies shortcomings in both stand-alone and early networked navigation systems. Stand-alone systems lack real-time data (e.g., traffic), while early networked systems required a proprietary, tightly-coupled relationship between the server and the specific mapping database on the client device, making updates and interoperability difficult (’743 Patent, col. 1:10-2:43).
- The Patented Solution: The invention describes a distributed navigation system where a central server performs the complex task of calculating an optimal route using real-time data. The server then formats this route into a "non-proprietary, natural language description" and downloads it to a client device. This description is independent of the client's local map data. The client device then interprets this generic description and uses its own local mapping database to "reconstruct" and display the route, thereby decoupling the server's advanced capabilities from the client's specific hardware and software (’743 Patent, col. 3:10-48, FIG. 3).
- Technical Importance: This architecture aimed to create a more flexible and universal system for networked navigation, reducing complexity on the client side and allowing systems from different vendors to potentially work with a common server infrastructure (’743 Patent, col. 3:5-9).
Key Claims at a Glance
- The complaint does not identify specific claims it intends to assert. Independent claims 1, 15, 21, and 22 appear representative of the invention.
- The essential elements of independent claim 1 include:
- Establishing a wireless connection between a client and a server.
- Transmitting route designations from the client to the server.
- The server accessing real-time information and calculating an optimal route.
- Formatting the route into a "non-proprietary, natural language description."
- Downloading the description to the client.
- The client reconstructing the route using a local mapping database and displaying it.
III. The Accused Instrumentality
- Product Identification: The complaint identifies the accused products as Defendant's (1) Car Navigation systems, (2) Navigation Receivers (e.g., Pioneer AVIC-W8600NEX), and (3) In-Vehicle Infotainment (IVI) systems (Compl. ¶21).
- Functionality and Market Context: The complaint alleges these systems provide "door-to-door directions and traffic reports" and feature "sophisticated touchscreens to cloud-navigation systems to hands-free communication systems" (Compl. ¶21, p. 9). Plaintiff asserts that Panasonic is a "pioneer and market leader" in these technologies and works with OEMs to develop customized solutions (Compl. ¶21, p. 9). A screenshot from a Panasonic webpage shows various "Next-generation cockpit systems, IVI cockpit systems, Car Navigation systems" as part of its business initiatives (Compl. p. 8).
IV. Analysis of Infringement Allegations
The complaint does not contain claim charts or detailed infringement theories. The following summary is based on mapping the general allegations to the elements of the lead independent claims.
’628 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| downloading... an artistic map, the artistic map being non-linearly scaled and including various objects being exaggeratedly shown | The Accused Instrumentalities are "Car Navigation systems" that display maps on a screen. A provided image shows a map with graphical icons and route overlays. | ¶21, p. 8 | col. 7:26-34 |
| receiving... a selection on the one of the objects | The accused systems feature "sophisticated touchscreens" for user interaction. | ¶21, p. 9 | col. 6:12-14 |
| transforming... the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 8:41-50 |
| determining... a navigational direction from the current location to the one of the objects being selected | The accused systems are alleged to provide "great door-to-door directions and traffic reports." | p. 9 | col. 8:51-56 |
| showing the navigational direction on the artistic map being displayed | The complaint includes a visual example of an accused product displaying a navigation route on its screen. This image shows a map with a highlighted route to "Safeco Field, CenturyLink Field." | p. 8 | col. 8:57-59 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the maps used by the Accused Instrumentalities qualify as "artistic" and "non-linearly scaled" under the patent's definition, or if they are standard, linearly-scaled geographic maps that merely include point-of-interest icons.
- Technical Questions: What evidence does the complaint provide that the accused systems perform the critical step of transforming coordinates from a non-literal "artistic" map space to a real-world geographic coordinate space as required by the claim? The complaint appears silent on this key technical function.
’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 Instrumentalities are described as "cloud-navigation systems." | ¶21, p. 9 | col. 15:58-62 |
| calculating the optimal route by the server, based on the real-time information | This functionality is inherent in the allegation of "cloud-navigation systems" that provide "traffic reports." | ¶21, p. 9 | col. 15:63-67 |
| formatting the optimal route into a non-proprietary, natural language description | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 16:1-3 |
| reconstructing the optimal route by the client using a local mapping database | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 16:4-6 |
- Identified Points of Contention:
- Scope Questions: Does the data protocol used between Panasonic's servers and its in-vehicle units constitute a "non-proprietary, natural language description"? The court may need to determine if this term covers modern, standardized but likely binary data formats, or if it is limited to the plain-text-like examples in the patent.
- Technical Questions: The complaint lacks any factual allegations about the specific architecture or data formats used in Panasonic's "cloud-navigation." A key evidentiary issue will be whether discovery reveals a system that is merely a proprietary, thin-client model or one that truly uses a map-agnostic data description as claimed.
V. Key Claim Terms for Construction
Term: "artistic map" (from the ’628 Patent)
- Context and Importance: The definition of this term is fundamental. If the accused maps are not "artistic," a core premise of the infringement allegation may fail. Practitioners may focus on this term because the patent's examples depict highly stylized, non-literal maps (like for a zoo), which may differ significantly from the road maps used in modern car navigation.
- Intrinsic Evidence for a Broader Interpretation: The specification states the map "may show exaggeratedly objects" and is "non-linearly scaled," which could be argued to cover any map that deviates from strict geographic scale to emphasize certain features, not just illustrative drawings (’628 Patent, col. 2:13-16).
- Intrinsic Evidence for a Narrower Interpretation: The problem statement and figures (e.g., FIG. 1, a zoo map) ground the invention in the context of leisure navigation with illustrative, cartoon-like maps where animals are "exaggeratedly shown," suggesting a narrower scope than typical road maps (’628 Patent, col. 1:61-63, FIG. 1).
Term: "non-proprietary, natural language description" (from the ’743 Patent)
- Context and Importance: This term defines the novel decoupling between the client and server. The case may turn on whether Panasonic's data format falls within this definition.
- Intrinsic Evidence for a Broader Interpretation: The patent emphasizes that the description is "independent from the local mapping database software," which could support an interpretation that any standardized, interoperable data format (even if binary) that is not tied to a single vendor's map data meets the "non-proprietary" element (’743 Patent, col. 3:23-27).
- Intrinsic Evidence for a Narrower Interpretation: The patent provides an exemplary embodiment of a "plain text description for each link" using terms like road names, turn angles, and distances (e.g., "INTERSTATE 8 90 DEG. 1.4 MILES") (’743 Patent, FIG. 5, col. 3:37-39). This may support a narrower construction requiring a human-readable or text-based format, as opposed to a complex, compressed binary data stream.
VI. Other Allegations
- Indirect Infringement: For both patents, the complaint alleges inducement based on Defendant's advertising and provision of user instructions for the Accused Instrumentalities, which allegedly encourage infringing use by customers (Compl. ¶31, ¶47).
- Willful Infringement:
- For the ’628 Patent, willfulness is alleged based on post-suit knowledge acquired through the filing and service of the complaint (Compl. ¶30).
- For the ’743 Patent, willfulness is alleged based on pre-suit knowledge dating back to 2004. The complaint asserts that a patent application filed by a Panasonic employee and assigned to Panasonic Holdings Corp. cited the ’743 patent, and that Defendant would have discovered the patent through its own due diligence (Compl. ¶46). The complaint provides a screenshot of a patent search result as evidence for this allegation (Compl. p. 14).
VII. Analyst’s Conclusion: Key Questions for the Case
- Evidentiary Sufficiency: A primary issue for the court will be one of evidentiary support. The complaint makes broad allegations but lacks specific facts on the core technical operations of the accused systems. The case may hinge on whether discovery uncovers evidence of the ’628 patent's claimed coordinate-transformation process and the ’743 patent's claimed "non-proprietary, natural language" data protocol.
- Claim Scope and Technological Age: The dispute will likely focus on definitional scope. Can the term "artistic map," conceived for stylized leisure maps, be construed to cover modern, data-rich automotive navigation displays? Similarly, can the ’743 patent's concept of a "natural language description," rooted in early 2000s architecture, be read to encompass the sophisticated, high-bandwidth data streams of today's "cloud-navigation" systems?
- Willfulness and Damages: For the expired ’743 patent, a critical question will be one of imputed knowledge. Can a patent citation in a 20-year-old patent application from a corporate affiliate be sufficient to prove that the Defendant acted willfully, particularly when seeking enhanced damages for a historical infringement period?