DCT
2:24-cv-00362
Infogation Corp v. Subaru Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Subaru Corporation (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-00362, E.D. Tex., 07/16/2024
- Venue Allegations: Plaintiff alleges venue is proper under the "alien venue rule," asserting that Defendant is a foreign entity with a regular and established business presence in the United States.
- Core Dispute: Plaintiff alleges that Defendant’s Subaru STARLINK® Multimedia Navigation systems infringe four patents related to GPS navigation, including methods for displaying non-linearly scaled maps, server-based route calculation using non-proprietary language, and generating realistic map displays.
- Technical Context: The technology at issue involves in-vehicle navigation and infotainment systems, a mature and competitive market where user interface design, map realism, and real-time data integration are significant differentiating features.
- Key Procedural History: The complaint is a First Amended Complaint. For U.S. Patent 6,292,743, Plaintiff alleges pre-suit knowledge and willfulness based on Defendant’s navigation partner, TomTom, having cited the patent in a 2011 application, with knowledge imputed to Subaru as of their partnership around 2013. A Reexamination Certificate for the ’994 patent, provided with the case materials and dated March 28, 2025, indicates that all claims (1-18) were cancelled following a reexamination request filed on February 27, 2024.
Case Timeline
| Date | Event |
|---|---|
| 1999-01-06 | Earliest Priority Date for ’743 Patent |
| 2001-09-18 | Issue Date for ’743 Patent |
| 2007-08-11 | Earliest Priority Date for ’628 Patent |
| 2008-11-07 | Earliest Priority Date for ’994 and ’003 Patents |
| 2011-01-01 | Alleged earliest date TomTom was aware of ’743 Patent (approximate) |
| 2013-01-01 | Alleged date Subaru partnered with TomTom (approximate) |
| 2013-03-26 | Issue Date for ’994 Patent |
| 2014-11-25 | Issue Date for ’003 Patent |
| 2018-10-23 | Issue Date for ’628 Patent |
| 2019-01-06 | Expiration Date for ’743 Patent |
| 2024-02-27 | Reexamination requested for ’994 Patent |
| 2024-07-16 | First Amended Complaint Filing Date |
| 2025-03-28 | Issue Date of '994 Patent Reexamination Certificate (as provided) |
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 addresses the issue that conventional GPS maps used in leisure settings like zoos or theme parks can be visually uninteresting and fail to clearly show points of interest (POIs) until the user is very close, as the display is bound by geographic accuracy. (’628 Patent, col. 1:38-54).
- The Patented Solution: The invention proposes using a non-linearly scaled "artistic map" where POIs are displayed as exaggerated, stylized images. When a user selects a location on one of these exaggerated objects, the system translates the screen coordinates into a single, precise latitude/longitude point on an underlying (and undisplayed) geographical map. It then calculates a route to that point and displays the navigational guidance on the user-friendly artistic map, bridging the gap between aesthetic presentation and functional navigation. (’628 Patent, Abstract; col. 4:51-64; Fig. 3).
- Technical Importance: This method allows navigation systems to provide a more engaging and intuitive user experience in specific environments by separating the visual map interface from the underlying geographic data used for routing. (’628 Patent, col. 1:60-65).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶18).
- Key elements of claim 1 include:
- Downloading an "artistic map" that is "non-linearly scaled" and has "exaggeratedly shown" objects.
- The artistic map itself is not used directly for navigation, and an underlying geographical map is not displayed.
- Receiving a user's selection of one of the exaggerated objects.
- Transforming the coordinates of the user's selection to a single "physical point" (latitude/longitude) on the geographical map, such that all points on the exaggerated object correspond to that same physical point.
- Determining a navigational direction to that physical point and displaying it on the artistic map.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent 6,292,743: Mobile Navigation System (Issued Sep. 18, 2001)
The Invention Explained
- Problem Addressed: At the time of the invention, in-vehicle navigation systems were typically stand-alone devices reliant on local media (e.g., CDs) for map data. This data was static, quickly outdated, and could not incorporate real-time information. Early connected systems required proprietary data formats, tying the client device to a specific, and often expensive, map provider. (’743 Patent, col. 1:10-27; col. 2:35-44).
- The Patented Solution: The patent describes a distributed navigation architecture. A client device (e.g., an in-car system) with its own mapping database establishes a wireless connection to a server. The server calculates an optimal route, potentially using real-time data, and transmits it back to the client not as proprietary map data, but as a "non-proprietary, natural language description" (e.g., a list of turns and street names). The client then uses this generic description to reconstruct and display the route on its own local mapping database, which can be from any vendor. (’743 Patent, Abstract; col. 3:21-49).
- Technical Importance: This approach decouples the server-side routing intelligence from the client-side map display, enabling more flexible, lower-bandwidth systems that can leverage real-time information without requiring constant, proprietary updates to the client's local database. (’743 Patent, col. 2:45-51).
Key Claims at a Glance
- The complaint asserts independent claim 15. (Compl. ¶34).
- Key elements of claim 15 include:
- A navigation computer.
- A wireless transceiver for connecting to a navigation server.
- The server calculates optimal routes based on real-time information.
- The routes are formatted using a "non-proprietary, natural language description."
- A local mapping database is used to reconstruct the route from that description.
- A display screen shows the reconstructed route.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent 8,406,994: Electronically Generated Realistic-like Map (Issued Mar. 26, 2013)
- Technology Synopsis: This patent aims to make electronic maps more visually appealing and realistic. It describes a system that superimposes images representing real-world objects (e.g., buildings, signs, landmarks) onto a map. The appearance of these objects and the map background can be altered to reflect ambient conditions, such as the time of day (e.g., a sunset sky) or weather, creating a more immersive 3D-like experience. (’994 Patent, Abstract; col. 2:4-14).
- Asserted Claims: The complaint asserts Claim 1. (Compl. ¶51).
- Accused Features: The complaint alleges that the Subaru STARLINK navigation systems infringe by providing realistic-like map displays, but does not specify which particular features meet the claim limitations beyond citing a general marketing video. (Compl. ¶51).
U.S. Patent 8,898,003: GPS Map Resembling Ambient Environment (Issued Nov. 25, 2014)
- Technology Synopsis: As a continuation of the application leading to the ’994 patent, this patent covers similar technology. It discloses a navigation device that presents a digital map resembling the ambient environment by superimposing images of structures and signs. The system alters the appearance of these map objects based on factors like time or weather to enhance realism. (’003 Patent, Abstract; col. 1:13-22).
- Asserted Claims: The complaint identifies the ’003 patent as a "Patent-in-Suit" but does not specify which, if any, claims are asserted. (Compl. ¶[Patents-in-Suit]1, ¶56).
- Accused Features: No specific infringement allegations are made for the ’003 patent; it is grouped generally with the other patents asserted against the STARLINK systems. (Compl. ¶56).
III. The Accused Instrumentality
Product Identification
The Subaru STARLINK® Multimedia Navigation systems included in or adapted for various Subaru vehicle models, such as the Outback, Ascent, Forester, and others. (Compl. ¶12).
Functionality and Market Context
The STARLINK system is an in-dash infotainment platform that provides navigation, multimedia, and smartphone connectivity via a touchscreen interface. (Compl. ¶13). The complaint notes that the navigation functionality is provided by industry leader TomTom. (Compl. p.8 visual). A screenshot from Subaru's website, included in the complaint, describes the navigation system's "intuitive interface and high resolution" display. (Compl. p.8). The system is marketed as a core technology suite that makes "every drive more entertaining, confident, and enjoyable." (Compl. ¶13, p.7 visual).
IV. Analysis of Infringement Allegations
10,107,628 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... wherein the computing device is portable, equipped with navigation capability and provides a traveling guidance based on a geographical map, the artistic map is not used directly by the computing device for navigation... and the geographical map is not being displayed on the display | The STARLINK system allegedly downloads and displays a non-linearly scaled "artistic map" with exaggerated objects to facilitate user selection for navigation, where the system is portable (in a vehicle) and provides guidance, while not using the artistic map itself for raw navigation calculations. (Compl. ¶18(i)). | ¶18(i) | col. 2:26-39 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The system allegedly receives a user's selection of one of the objects on the map display. (Compl. ¶18(ii)). | ¶18(ii) | col. 2:31-33 |
| 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 points representing the selected object having different pairs of coordinates, but all of the different pairs of coordinates for the selected object corresponding substantially to the physical point when said transforming is performed | The system allegedly transforms the coordinates of the selected object on the artistic map into a single physical point (latitude and longitude) on the underlying geographical map, with all points on the artistic representation mapping to that same physical point. A screenshot from the complaint shows the TomTom navigation system on the STARLINK display. (Compl. p.8). | ¶18(iv) | col. 4:55-64 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected; and showing the navigational direction on the artistic map being displayed | The system allegedly determines a navigational route from the current location to the selected object's physical point and displays this route on the artistic map. (Compl. ¶18(vi), last bullet). | ¶18(vi) | col. 2:36-39 |
- Identified Points of Contention:
- Scope Questions: A central question is whether the STARLINK display constitutes an "artistic map" that is "non-linearly scaled" as required by the claim. The defense may argue the system uses a standard, proportionally-scaled 2D or 3D map, and that POI icons are not the same as "exaggeratedly shown" objects that are "not used directly... for navigation."
- Technical Questions: The complaint alleges that a user can select any point on an exaggerated object and have it map to a single physical location. It will be a key factual question whether the accused system actually performs this specific "plurality of points to one" transformation, or if it uses a more conventional method where only a single, predefined icon anchor point is selectable.
6,292,743 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a wireless transceiver coupled to said navigation computer for connecting with a navigation server | The STARLINK system allegedly includes a wireless transceiver that connects to a navigation server. (Compl. ¶34(ii)). | ¶34(ii) | col. 3:26-31 |
| said navigation server for calculating optimal routes based on real-time information, said optimal routes being formatted using a non-proprietary, natural language description | The system allegedly connects to a server that calculates optimal routes using real-time information and formats this route data as a "non-proprietary, natural language description." The complaint provides a screenshot of a Google Patents search result showing that TomTom, Subaru's navigation partner, had previously cited the ’743 patent in its own patent application. (Compl. p.15). | ¶34(ii) | col. 3:32-41 |
| a mapping database coupled to said navigation computer for reconstructing said optimal route from said non-proprietary, natural language description | The STARLINK system allegedly uses its local mapping database to reconstruct the route received from the server. (Compl. ¶34(iii)). | ¶34(iii) | col. 3:41-49 |
| a display screen coupled to said navigation computer for displaying said optimal route using said mapping database | The system's display screen is allegedly used to show the reconstructed optimal route. (Compl. ¶34(iv)). | ¶34(iv) | col. 3:49-53 |
- Identified Points of Contention:
- Scope Questions: The case will likely turn on the construction of "non-proprietary, natural language description." Does this term read on the likely compressed, proprietary data stream used between a modern navigation server (TomTom) and its integrated client (Subaru STARLINK), or is it limited to the plain-text, human-readable format exemplified in the patent?
- Technical Questions: A key factual dispute will be determining the actual data format used to transmit route information from the server to the accused STARLINK systems. The complaint provides no direct evidence on this point, relying instead on a conclusory allegation that mirrors the claim language.
V. Key Claim Terms for Construction
For the ’628 Patent:
- The Term: "artistic map"
- Context and Importance: This term is foundational to claim 1. The infringement analysis depends entirely on whether the accused STARLINK display can be classified as an "artistic map." Practitioners may focus on this term because modern 3D-perspective maps often include stylized elements, and the boundary between a "geographical map" and an "artistic map" is not clearly defined.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term relates to user experience, stating a map "may be artisticly made to make the navigation as a pleasant experience." (’628 Patent, col. 1:64-65). This could support an argument that any map with aesthetic, non-utilitarian elements qualifies.
- Evidence for a Narrower Interpretation: The patent repeatedly defines the "artistic map" by its specific technical characteristics: it is "non-linearly scaled," includes "exaggeratedly shown" objects, and is explicitly contrasted with the underlying "geographical map" used for calculations. (’628 Patent, Abstract; col. 2:29-31). This may support a narrower construction requiring significant, non-proportional visual distortion.
For the ’743 Patent:
- The Term: "non-proprietary, natural language description"
- Context and Importance: This term is the central point of dispute for infringement of the ’743 patent. If the data format used by Subaru is deemed proprietary, the infringement claim fails. Practitioners may focus on this term because the patent's goal was to create interoperability, and the definition of "non-proprietary" is key to achieving that objective.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent emphasizes that the description is "completely independent from the local mapping database software," suggesting that any data format achieving this independence could be considered "non-proprietary" in context. (’743 Patent, col. 3:23-26).
- Evidence for a Narrower Interpretation: The Abstract specifies a "plain text description for each link using pre-defined generic terms," and Figure 5 provides an example of a route table with text-based street names, headings, and distances. (’743 Patent, Abstract; Fig. 5). This suggests the term requires a human-readable or simple text-based format, not a complex or compressed binary data stream.
VI. Other Allegations
- Indirect Infringement: For all asserted patents, the complaint alleges that Subaru induces infringement by advertising and selling the STARLINK systems with instructions and encouragement for customers to use the accused navigational features. (Compl. ¶24, ¶41, ¶57).
- Willful Infringement: The complaint alleges two different grounds for willfulness.
- For the ’628 and ’994 patents, willfulness is alleged to have begun upon the filing and service of the complaint, establishing post-suit knowledge. (Compl. ¶22, ¶55).
- For the ’743 patent, the complaint alleges pre-suit willfulness. It asserts that Subaru’s navigation partner, TomTom, cited the ’743 patent in a 2011 patent application and that Subaru "would have discovered" the patent during its due diligence when partnering with TomTom around 2013. (Compl. ¶38). A screenshot of the purported citation is included as evidence. (Compl. p.15).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: For the ’743 patent, can the term "non-proprietary, natural language description," which the patent illustrates with plain-text examples, be construed to cover the likely optimized and proprietary data format used between a modern navigation provider and an integrated in-vehicle system?
- A second core issue is one of technical operation: For the ’628 patent, does the accused STARLINK system’s map interface function as a "non-linearly scaled" "artistic map" where selecting any point on an "exaggeratedly shown" object maps to a single physical coordinate, or is this a mischaracterization of a standard map with conventional POI icons?
- A critical threshold question concerns the viability of the ’994 patent: Given the provided reexamination certificate indicating that all claims of the ’994 patent have been cancelled, a primary issue for the court will be to determine the final, official status of these claims and whether Plaintiff can maintain its infringement count based on this patent.