DCT
2:24-cv-00363
Infogation Corp v. Daimler AG
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Daimler AG (Germany) and Mercedes-Benz USA, LLC
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-00363, E.D. Tex., 05/14/2024
- Venue Allegations: Venue is based on Defendant Daimler AG being a foreign entity, invoking the "alien venue rule." The complaint alleges Defendant conducts substantial business and makes infringing products available to consumers in the district.
- Core Dispute: Plaintiff alleges that Defendant’s MBUX and COMAND® in-vehicle infotainment and navigation systems infringe four U.S. patents related to map display, distributed route calculation, and realistic map rendering.
- Technical Context: The lawsuit concerns the technology of in-vehicle navigation systems, a critical feature in the modern automotive market that integrates GPS, real-time data, and advanced graphical user interfaces.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of one of the asserted patents, U.S. Patent 6,292,743, through its partnership with GPS manufacturer TomTom, which had previously cited the patent in one of its own European patent applications. No other prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 1999-01-06 | Priority Date for ’743 Patent |
| 2001-09-18 | Issue Date for U.S. Patent 6,292,743 |
| 2007-08-11 | Priority Date for ’628 Patent |
| 2008-11-07 | Priority Date for ’003 and ’994 Patents |
| 2013-01-01 | Approx. date of Mercedes partnership with TomTom |
| 2013-03-26 | Issue Date for U.S. Patent 8,406,994 |
| 2014-11-25 | Issue Date for U.S. Patent 8,898,003 |
| 2018-10-23 | Issue Date for U.S. Patent 10,107,628 |
| 2019-01-01 | Approx. launch date for MBUX Navigation System |
| 2024-05-14 | Complaint Filing Date |
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 identifies a limitation in conventional GPS systems where maps used for leisure activities (e.g., touring a zoo or park) are often boring or fail to clearly display points of interest until the user is very close, diminishing the user experience (’628 Patent, col. 1:38-54).
- The Patented Solution: The invention proposes a two-map system. A user interacts with a visually rich "artistic map," which is non-linearly scaled and shows exaggerated objects to highlight points of interest. When a user selects a destination on this artistic map, the system translates that selection into precise latitude and longitude coordinates on a hidden, standard "geographical map" used for calculating the navigation route. The resulting directions are then displayed back on the user-friendly artistic map (’628 Patent, col. 2:26-42; Fig. 3).
- Technical Importance: This approach allows for a more engaging and intuitive user interface for navigation in specific venues without sacrificing the mathematical precision of traditional GPS routing (’628 Patent, col. 1:55-65).
Key Claims at a Glance
- The complaint asserts independent method claim 1 (Compl. ¶18).
- Key elements of Claim 1 include:
- Downloading an "artistic map" that is "non-linearly scaled" with "exaggeratedly shown" objects, while a "geographical map is not being displayed."
- Receiving a user's selection of an object on the artistic map.
- Determining coordinates for a point on the selected object.
- "Transforming" those coordinates into a "physical point represented by a pair of latitude and longitude in the geographical map."
- Detecting the device's current location and determining a navigational direction to the physical point using the geographical map.
- Showing the final navigational direction on the artistic map.
- The complaint does not explicitly reserve the right to assert dependent claims for the '628 Patent.
U.S. Patent 6,292,743, “Mobile Navigation System,” Issued Sep. 18, 2001
The Invention Explained
- Problem Addressed: The patent describes stand-alone vehicle navigation systems of the time as being limited by their on-board data storage and inability to access real-time information like traffic or road conditions. Furthermore, keeping client software and server software synchronized created a burden for manufacturers and customers (’743 Patent, col. 1:24-44, col. 2:21-36).
- The Patented Solution: The invention claims a distributed navigation system where a client device in a vehicle connects wirelessly to a remote server. The server, with access to real-time data, performs the complex route calculation. It then sends the optimal route to the client formatted as a "non-proprietary, natural language description." This allows the client, using any local mapping database, to interpret these universal instructions and reconstruct the route for display, decoupling the client from specific server software or proprietary map formats (’743 Patent, col. 3:21-51; Fig. 3).
- Technical Importance: This architecture aimed to make navigation systems more powerful by leveraging server-side processing and real-time data, while simultaneously making them more flexible and less costly by avoiding proprietary data formats (’743 Patent, col. 2:45-53).
Key Claims at a Glance
- The complaint asserts independent system claim 15 (Compl. ¶34).
- Key elements of Claim 15 include:
- A navigation computer.
- A wireless transceiver for connecting with a navigation server.
- The navigation server calculates optimal routes based on real-time information.
- The optimal routes are formatted using a "non-proprietary, natural language description."
- A local mapping database on the client for "reconstructing said optimal route from said non-proprietary, natural language description."
- A display screen for showing the reconstructed route.
- The complaint does not explicitly reserve the right to assert dependent claims for the '743 Patent.
Multi-Patent Capsule: U.S. Patent 8,898,003 & U.S. Patent 8,406,994
- Patent Identification:
- U.S. Patent 8,898,003, “GPS Map Resembling Ambient Environment,” Issued Nov. 25, 2014.
- U.S. Patent 8,406,994, “Electronically Generated Realistic-Like Map,” Issued Mar. 26, 2013.
- Technology Synopsis: These related patents describe a navigation system that enhances realism by displaying a digital map that reflects the ambient environment. The system superimposes images of objects (e.g., buildings, signs, sky) onto the map and alters their appearance—such as color, tone, or lighting—based on external conditions like the time of day or weather, which can be detected by onboard sensors or a clock (’994 Patent, Abstract; ’003 Patent, Abstract).
- Asserted Claims: Claim 1 of the ’003 Patent and Claim 1 of the ’994 Patent are asserted (Compl. p.16, ¶5; p.20, ¶21).
- Accused Features: The complaint accuses the MBUX and COMAND® systems, particularly their augmented reality and 3D map views that display realistic graphical overlays which change in appearance to reflect the driving environment (Compl. p.6, ¶13).
III. The Accused Instrumentality
Product Identification
The Mercedes-Benz Navigation System, as implemented in the MBUX (Mercedes-Benz User Experience) and COMAND® infotainment platforms in Defendant's vehicles (Compl. ¶12).
Functionality and Market Context
The complaint alleges these systems provide advanced navigation features. The screenshot of the MBUX system in the complaint describes an "optional augmented video for navigation feature" that uses a front-mounted camera to display a live view of the road ahead, overlaid with graphical navigation instructions and information like street names and addresses (Compl. p.6, ¶13). The COMAND® system is described as offering features like real-time traffic updates and configurable 3D map views (Compl. p.6, ¶13). The complaint positions MBUX as a feature that "revolutionized in-vehicle infotainment" and is standard on recent vehicle models, suggesting significant commercial importance (Compl. p.6, ¶13).
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... the geographical map is not being displayed on the display | The MBUX/COMAND systems download map data and display it in a manner that allegedly includes exaggerated or artistically rendered features, such as 3D buildings or augmented reality overlays, for user interaction. | ¶18(i) | col. 2:29-38 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The system receives user input, such as tapping a point of interest on the displayed map to select it as a destination. | ¶18(ii) | col. 5:12-14 |
| 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 on the artistic display. | ¶18(iii) | col. 2:59-62 |
| 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 allegedly converts the screen coordinates of the selected object into real-world latitude and longitude coordinates for route calculation, a process that occurs in the background. | ¶18(iv) | col. 5:19-24 |
| detecting a current location of the computing device in the geographical map | The system uses its GPS receiver to determine the vehicle's current real-world location. | ¶18(v) | col. 1:29-37 |
| 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 calculates a route to the selected destination and displays it to the user via graphical instructions overlaid on the augmented reality view or 3D map. A visual in the complaint shows such an overlay. | ¶18(vi); p.6, ¶13 | col. 2:38-42 |
- Identified Points of Contention:
- Scope Questions: A central dispute may be whether the MBUX system's augmented reality view or 3D maps qualify as an "artistic map" that is "non-linearly scaled" and shows "exaggeratedly shown" objects, as those terms are used in the patent. The defense may argue that features like 3D buildings are realistic representations, not exaggerated artistic ones.
- Technical Questions: The case may turn on how the accused system internally handles coordinates. A key question is whether the system performs the claimed two-step "transforming" process: first capturing display coordinates from an "artistic map" and then converting them to a separate "geographical map" for calculation, or whether it uses a more integrated single-map model where display objects are already tied to geographic coordinates.
6,292,743 Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a navigation computer | The MBUX/COMAND systems are based on an in-vehicle computer. | ¶34(i) | col. 5:49-54 |
| a wireless transceiver coupled to said navigation computer for connecting with a navigation server | The systems include wireless connectivity (e.g., cellular) to communicate with remote servers for services like real-time traffic. | ¶34(ii) | col. 5:8-13 |
| 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 complaint alleges that Mercedes servers calculate routes using real-time data and transmit them to the vehicle using what it contends is a non-proprietary, natural language description. | ¶34(ii) | col. 3:11-19 |
| a mapping database coupled to said navigation computer for reconstructing said optimal route from said non-proprietary, natural language description | The MBUX/COMAND system allegedly uses its local on-board map data to interpret the server's route instructions and draw the route on the screen. | ¶34(iii) | col. 3:40-48 |
| a display screen coupled to said navigation computer for displaying said optimal route using said mapping database | The system's central infotainment screen displays the final calculated route. A screenshot in the complaint shows this display. | ¶34(iv); p.6, ¶13 | col. 6:3-7 |
- Identified Points of Contention:
- Scope Questions: The dispute will likely focus on the meaning of "non-proprietary, natural language description." The defense may argue that the data format used between its servers and vehicles, while perhaps text-based, is a proprietary or structured format (like JSON or XML with specific schemas) that does not meet the patent's description of a generic, "natural language" format independent of any specific database.
- Technical Questions: Evidence will be needed on the actual data format transmitted from Mercedes' servers to its vehicles. The analysis will question whether the client truly "reconstructs" the route from generic instructions or simply displays pre-packaged, map-specific vector data sent by the server.
V. Key Claim Terms for Construction
For the ’628 Patent:
- The Term: "artistic map"
- Context and Importance: This term is at the heart of the invention and the infringement allegation. The definition will determine whether the accused MBUX augmented reality view and 3D maps, which aim for realism, can be considered "artistic." Practitioners may focus on this term because its scope is not explicitly defined and appears to be subjective.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the artistic map as one where "points of interests are exaggeratedly displayed to assist a visitor to locate what is desired to be seen" (’628 Patent, col. 4:4-6). This could be argued to cover any non-literal, stylized, or enhanced representation, including 3D models or augmented reality overlays that emphasize certain features over others.
- Evidence for a Narrower Interpretation: The primary examples provided are for specific venues like a zoo, where objects like animal exhibits are graphically represented (’628 Patent, Fig. 1). A defendant could argue the term is limited to such non-photorealistic, illustrative maps of contained areas, not real-world road navigation.
For the ’743 Patent:
- The Term: "non-proprietary, natural language description"
- Context and Importance: This term is the central limitation distinguishing the claimed invention from prior art systems that used proprietary data formats. The infringement case for the '743 patent hinges on whether the data transmitted by Mercedes' servers meets this definition. Practitioners will recognize this as the likely dispositive claim construction issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the goal is to be "completely independent from the local mapping database software" (’743 Patent, col. 3:25-28) and uses an example with plain text like "Interstate 8 90 Deg. 1.4 Miles" (’743 Patent, Fig. 5). A plaintiff could argue this covers any human-readable, text-based format that does not rely on proprietary binary codes or indices specific to one map vendor.
- Evidence for a Narrower Interpretation: The specification contrasts its "natural language" with proprietary formats that include "data points, indices and the like that are specific to the particular mapping database" (’743 Patent, col. 2:65-68). A defendant could argue that any structured data format (e.g., XML, JSON) with defined tags and schemas is not "natural language" but is instead a specific, albeit text-based, protocol that falls outside the claim scope.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by advertising the accused systems and providing user manuals and instructions that encourage customers to use the navigation features in an infringing manner (Compl. ¶26, ¶43).
- Willful Infringement: For all patents, the complaint alleges willfulness based on knowledge acquired upon service of the complaint (Compl. ¶22, ¶38, p.17 ¶9, p.21 ¶25). For the ’743 Patent specifically, the complaint alleges pre-suit knowledge and willful blindness. The basis is Defendant's partnership with TomTom, which had cited the ’743 Patent in a European patent application, and an allegation that Defendant has a policy of not investigating third-party patent rights (Compl. ¶38-39). The complaint includes a screenshot of a patent search result as evidence of TomTom's citation (Compl. p.14).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "artistic map" from the ’628 patent, described in the context of stylized venue maps, be construed to cover the photorealistic augmented reality overlays and 3D models used in the accused MBUX system? Similarly, can the critical term "non-proprietary, natural language description" from the ’743 patent encompass the likely structured, server-to-client data protocols used in a modern connected car platform?
- A second central question will be one of evidentiary proof for willfulness: Can the plaintiff demonstrate that knowledge of the ’743 patent by a third-party partner, TomTom, can be imputed to the Defendant to support a claim of pre-suit willful infringement? The court's view on this nexus will be critical, especially in light of the complaint's additional allegation of a general policy of willful blindness.
- A key technical question will be one of operational mapping: Does discovery show that the accused systems function as claimed, particularly with respect to the ’628 patent’s two-map "transforming" process and the ’743 patent’s client-side "reconstruction" from generic instructions, or will it reveal a more integrated architecture that presents a fundamental mismatch with the claimed methods and systems?