Infogation Corp v. American Honda Motor Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Infogation Corporation (Texas)
  • Defendant: American Honda Motor Co., Inc. (California)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-00346, E.D. Tex., 05/08/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a "regular and established business presence" in the district through its network of authorized dealers ("Customer Agents"), over which Defendant allegedly exercises control and holds out to the public as its own locations.
• Core Dispute: Plaintiff alleges that Defendant’s Honda and Acura in-vehicle GPS navigation systems infringe four U.S. patents related to displaying artistic or realistic maps and utilizing server-based route calculation.
• Technical Context: The technologies at issue concern methods for making GPS navigation more intuitive and visually engaging, moving beyond simple two-dimensional line drawings to incorporate non-literal maps, realistic environmental effects, and real-time, server-side data.
• Key Procedural History: The complaint alleges that Defendant’s parent company, Honda Motor Co., cited the ’743 patent in its own patent applications as early as 2005, which may be used to support allegations of pre-suit knowledge. Notably, U.S. Patent 8,406,994, one of the patents-in-suit, was the subject of an ex parte reexamination, which concluded with a certificate issued on March 28, 2025, cancelling all claims (1-18) of the patent.

Case Timeline

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

U.S. Patent 10,107,628 - Method and Apparatus for Navigating on Artistic Maps (Issued Oct. 23, 2018)

The Invention Explained

• Problem Addressed: The patent’s background describes conventional GPS maps used in leisure settings (e.g., parks, zoos) as potentially "boring" and ineffective at displaying points of interest unless a user is already very close. ( ’628 Patent, col. 1:40-54).
• The Patented Solution: The invention proposes using a non-linearly scaled "artistic map" where points of interest are shown in an exaggerated or stylized manner. The system allows a user to select a point on one of these exaggerated objects; it then transforms the display coordinates of that selection into real-world geographic coordinates (latitude and longitude) to calculate and display a navigational route. (’628 Patent, Abstract; col. 2:26-38). This enables functional navigation on a map that prioritizes visual appeal over strict geographic accuracy.
• Technical Importance: This technology allows navigation systems to utilize visually rich, thematic maps (e.g., theme park guides) for turn-by-turn directions, aiming to create a more pleasant and intuitive user experience in recreational environments. (’628 Patent, col. 1:61-65).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶31).
• 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 on one of the objects.
  • Determining a pair of coordinates for a point on the selected object.
  • Transforming that pair of coordinates into a "physical point represented by a pair of latitude and longitude in the geographical map."
  • Detecting the device's current location.
  • Determining a navigational direction from the current location to the physical point.
  • Showing the navigational direction on the artistic map.
• The complaint reserves the right to assert additional claims. (Compl. ¶26).

U.S. Patent 8,898,003 - GPS Map Resembling Ambient Environment (Issued Nov. 25, 2014)

The Invention Explained

• Problem Addressed: The patent identifies conventional GPS maps as "boring" because their visual style remains static regardless of the time of day or ambient conditions. (’003 Patent, col. 1:40-44).
• The Patented Solution: The invention describes a navigation system that displays a map with a "certain level of realism." It achieves this by superimposing images of objects (e.g., landmarks, buildings) onto the map and dynamically "changing the images with different color effects" based on input from a source that reflects the "conditions of the location," such as time of day or weather. (’003 Patent, Abstract; col. 2:5-14). One specific feature claimed is an on-screen vehicle icon that shows its headlights on when the physical vehicle's headlights are active. (’003 Patent, cl. 1).
• Technical Importance: This approach moves navigation displays beyond static representations toward a more immersive, context-aware interface that visually reflects the user's real-world environment. (’003 Patent, col. 4:50-54).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶47).
• Essential elements of claim 1 include:
  • Displaying a map with a route.
  • Superimposing images of objects to create a "3D impression" where the perspective changes as the user moves.
  • Changing the images with "different color effects" in reference to an input from a source about the "conditions of the location."
  • Making the map resemble an electronic map with a "certain level of realism."
  • An "icon of a vehicle in the map shows that headlights are on when the vehicle is supposed to turn on its headlights."
• The complaint reserves the right to assert additional claims. (Compl. ¶26).

U.S. Patent 8,406,994 - Electronically Generated Realistic-Like Map (Issued Mar. 26, 2013)

• Technology Synopsis: This patent addresses the issue of static 2D GPS maps by describing a system that generates a more realistic map. (’994 Patent, col. 1:39-41). The solution involves superimposing images of objects onto the map and altering them with color effects based on external inputs (e.g., time of day, weather from a sensor), thereby creating a more dynamic visual experience that reflects the ambient environment. (’994 Patent, Abstract).
• Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶63).
• Accused Features: The accused features are the functionalities within the Honda/Acura GPS Navigation systems that display maps with realistic or simulated 3D objects and change the map's appearance based on ambient conditions, such as a day/night mode. (Compl. ¶25).

U.S. Patent 6,292,743 - Mobile Navigation System (Issued Sep. 18, 2001)

• Technology Synopsis: This patent addresses the problem of stand-alone navigation devices that rely on limited, often outdated, local map data. (’743 Patent, col. 1:24-34). The invention proposes a distributed system where a mobile client wirelessly connects to a server; the server calculates an optimal route using real-time data and sends it to the client using a generic, "natural language" description, which the client then reconstructs and displays on its own mapping system. (’743 Patent, Abstract).
• Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶79).
• Accused Features: The accused features are the functionalities within the Honda/Acura GPS Navigation systems that rely on a connection to a remote server to calculate routes, particularly those using real-time traffic or other dynamic data. (Compl. ¶25).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Instrumentalities" as the "Honda/Acura GPS Navigation system" included in a wide range of Honda and Acura vehicle models, such as the Honda Accord, Civic, CR-V, Pilot, and Acura MDX, RDX, and TLX. (Compl. ¶25).

Functionality and Market Context

The complaint alleges these systems provide integrated GPS navigation that performs the methods claimed by the patents-in-suit, including the display of maps with various features and the calculation of routes. (Compl. ¶25). The complaint asserts that Defendant "generates substantial financial revenues and benefits" from manufacturing and selling vehicles containing these systems. (Compl. ¶30).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentalities infringe at least claim 1 of each of the four patents-in-suit but relies on exhibits not attached to the pleading for detailed infringement contentions. (Compl. ¶26). The analysis below is based on the general allegations in the complaint.

’628 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A primary dispute will likely concern whether the standard road maps used in the Accused Instrumentalities can be properly characterized as "artistic," "non-linearly scaled," and featuring "exaggeratedly shown" objects, as required by the claim.
  • Technical Questions: The analysis may question whether the accused system's method for selecting a point of interest constitutes "transforming" coordinates from an artistic map to a geographical map, or if it functions by a different mechanism, such as selecting a pre-defined entity from a database.

’003 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A key question is whether a simple day/night color scheme change, based on a system clock, meets the claim limitation of "changing the images with different color effects in reference to an input from at least a source about conditions of the location."
  • Technical Questions: An evidentiary focus will be on the "headlights" limitation. The case may require proof that the on-screen icon's headlights are functionally linked to the actual vehicle's headlights, a highly specific technical requirement that may not be present in a standard navigation system.

V. Key Claim Terms for Construction

Term 1 (’628 Patent): "artistic map"

• Context and Importance: The definition of this term is fundamental to the ’628 Patent. The infringement case hinges on whether the maps in Defendant's navigation systems fall within this definition. Practitioners may focus on this term because it appears to be the primary point of differentiation from conventional mapping patents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the purpose as making navigation a "pleasant experience" and showing "exaggeratedly points of interest," which could be argued to encompass any map that uses stylized icons or graphical elements beyond basic lines. (’628 Patent, col. 1:55-65).
  • Evidence for a Narrower Interpretation: The patent’s title, abstract, and figures (e.g., FIG. 1, a zoo map) consistently frame the invention in the context of recreational or thematic environments, not standard road navigation. This suggests the term could be limited to highly stylized, non-literal, illustrative maps like those for a theme park or zoo. (’628 Patent, FIG. 1; col. 4:3-6).

Term 2 (’003 Patent): "an input from at least a source about conditions of the location"

• Context and Importance: This term's construction is critical for determining if features like an automatic day/night mode constitute infringement. The dispute will likely center on what qualifies as a "source" and what constitutes "conditions of the location."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is general and does not explicitly limit the "source" or "conditions." An internal system clock providing the time of day could plausibly be argued to be a "source" providing information about a "condition" (i.e., whether it is nighttime) at the vehicle's location. (’003 Patent, cl. 1).
  • Evidence for a Narrower Interpretation: The specification discusses making the map resemble the "ambient environment" and mentions weather. (’003 Patent, Abstract). This could support a narrower construction requiring the "source" to be a sensor that measures actual ambient conditions, such as a light sensor or a connection to a weather data service, rather than just an internal clock. (’003 Patent, col. 4:42-45).

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement of all asserted patents by providing the Accused Instrumentalities and encouraging infringing use through "advertising an infringing use" and, presumably, user manuals and other instructional materials. (Compl. ¶¶39, 55, 71, 88).
• Willful Infringement: For all four patents, willfulness is alleged based on post-suit knowledge derived from the service of the complaint itself. (Compl. ¶¶35, 51, 67, 83). The complaint further alleges willful blindness based on a purported "practice of not performing a review of the patent rights of others." (Compl. ¶40). For the ’743 patent, the allegation is strengthened by a claim of pre-suit knowledge, asserting that Defendant's parent, Honda Motor Co., has cited the ’743 patent in its own patent applications since 2005. The complaint provides a screenshot of a patent search result to support this claim. This visual shows a list of U.S. patent applications assigned to "Honda Motor Co., Ltd." that cite the ’743 Patent, with publication dates beginning in 2005. (Compl. ¶83, p. 19).

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

This case presents several critical questions for the court, blending issues of claim scope, factual evidence, and patent validity.

• A core issue will be one of definitional scope: can terms rooted in specialized contexts, such as an "artistic map" from leisure settings (’628 Patent) and a map that changes based on "conditions of the location" (’003 Patent), be construed broadly enough to cover the common features of a mass-market automotive navigation system, like its use of stylized icons and an automatic day/night mode?
• A key evidentiary question will be one of functional specificity: does the accused system's software perform the highly specific functions required by certain claims? For instance, does the on-screen vehicle icon in Honda’s system display illuminated headlights that are functionally tied to the operation of the car's physical headlights, as recited in claim 1 of the ’003 patent?
• A dispositive threshold question will be the enforceability of the ’994 Patent: given that a reexamination certificate has cancelled all claims of the ’994 patent, the court will first need to address whether the infringement count based on this patent has any legal basis to proceed.