Infogation Corp v. General Motors LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Infogation Corporation (Texas)
  • Defendant: General Motors LLC (Delaware)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-1015, E.D. Tex., 12/10/2024
• Venue Allegations: Venue is alleged to be proper because Defendant GM maintains a "regular and established place of business" within the district and has purportedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s in-vehicle "Maps+ Navigation system" infringes two patents related to methods for displaying stylized maps and for using a client-server architecture to calculate and display navigation routes.
• Technical Context: The technology at issue concerns in-vehicle GPS navigation systems, a highly competitive and technologically significant feature in the modern automotive industry.
• Key Procedural History: The complaint alleges that U.S. Patent 6,292,743 was cited in patent applications by Honda Motor Co.—which the complaint alleges to be Defendant's parent company—as early as 2005, a fact Plaintiff may use to support its claim of willful infringement. The complaint also notes that the '743 patent expired on January 6, 2019, limiting any potential damages for that patent to the pre-expiration period.

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 describes conventional GPS maps as potentially "boring" and ineffective for leisure activities like touring a park or zoo, where key points of interest may not be displayed unless a user is very close, thus losing broader context (’628 Patent, col. 1:40-53).
• The Patented Solution: The invention proposes a method using a "non-linearly scaled" or "artistic map" where objects are "exaggeratedly shown" for user-friendliness. When a user selects a point on this artistic display, the system transforms the selection's coordinates into a physical point (latitude and longitude) on a standard geographical map, determines a route, and then synchronizes and displays this navigational direction back onto the artistic map for the user to follow (’628 Patent, Abstract; col. 2:42-52). This bridges the gap between a stylized, intuitive display and precise, real-world routing.
• Technical Importance: This approach allows for the creation of more engaging and informative navigation experiences, particularly in environments like theme parks, by combining a visually rich interface with the underlying accuracy of GPS technology (’628 Patent, col. 1:61-66).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶19).
• The essential elements of independent claim 1 include:
  • Downloading an "artistic map" that is "non-linearly scaled" and has "exaggeratedly shown" objects to a computing device.
  • Receiving a user's selection of one of the objects.
  • Determining coordinates for a point on the selected object.
  • Transforming those coordinates into a physical point (latitude/longitude) in a geographical map.
  • Detecting the device's current location.
  • Determining a navigational direction using the geographical map.
  • Showing the navigational direction on the displayed artistic map.
• The complaint reserves the right to assert additional claims (Compl. ¶19).

U.S. Patent 6,292,743 - MOBILE NAVIGATION SYSTEM (Issued Sep. 18, 2001)

The Invention Explained

• Problem Addressed: In-vehicle navigation systems at the time of the invention were typically stand-alone devices reliant on local data storage (e.g., CDs). This limited the level of detail, required frequent and costly user updates, and prevented the use of real-time information like traffic conditions (’743 Patent, col. 1:10-38).
• The Patented Solution: The patent discloses a distributed navigation system where a "client" device in a vehicle wirelessly connects to a remote "server." The server calculates an optimal route using real-time data and formats the route into a "non-proprietary, natural language description." This description is sent to the client, which then interprets it and uses its own local mapping database to "reconstruct" and display the route for the user (’743 Patent, Abstract).
• Technical Importance: This client-server architecture offloads complex route computation, enables the integration of real-time data, and decouples the server from the client's specific mapping software, creating a more flexible and powerful navigation system than was typical for the era (’743 Patent, col. 2:45-3:10).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶19).
• The essential elements of independent 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.
  • The server 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.
  • Displaying the route on the client's display system.
• The complaint reserves the right to assert additional claims (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

The "Maps+ Navigation system" and associated methods provided in vehicles from GM brands including Chevrolet, Buick, GMC, and Cadillac (Compl. ¶18).

Functionality and Market Context

The complaint alleges that the Maps+ system is an in-vehicle navigation platform that provides route guidance to users (Compl. ¶18). A screenshot provided in the complaint depicts the Maps+ user interface, showing a graphical map with a highlighted route, distance to the next turn, and a "4G LTE" connectivity status icon (Compl. p. 6). Plaintiff alleges that GM manufactures, sells, and controls the operation of these systems, generating substantial revenue from them (Compl. ¶23, ¶39).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Ex. 1 and Ex. 4) detailing its infringement theories (Compl. ¶24, ¶40). The narrative infringement allegations are summarized below.

’628 Patent Infringement Allegations: The complaint alleges that the Maps+ system directly infringes at least Claim 1 of the ’628 Patent by making, using, and selling the system (Compl. ¶19, ¶24). The core theory is that the Maps+ system’s map display constitutes an infringing "artistic map" as claimed. A screenshot from a GM website showing the Maps+ interface with a highlighted route is provided as exemplary evidence of the accused system (Compl. p. 6, "GMC LIFE"). This screenshot shows the Maps+ system displaying a route on a graphical map with turn-by-turn information (Compl. p. 6).

Identified Points of Contention:

• Scope Questions: A central question will be whether the Maps+ system's display, which appears to be a conventional navigation map, meets the claim requirement of a "non-linearly scaled" and "artistic map" with "objects being exaggeratedly shown." The patent's specification repeatedly references illustrative theme park and zoo maps as examples (’628 Patent, Fig. 1; col. 4:34-37).
• Technical Questions: The complaint does not detail how the accused system allegedly performs the claimed two-step process of transforming user selections on an "artistic map" to a physical point for routing and then synchronizing the resulting directions back to that artistic map.

’743 Patent Infringement Allegations: The complaint alleges that the Maps+ system infringes at least Claim 1 of the ’743 Patent by operating as a distributed, client-server system (Compl. ¶19, ¶40). The asserted theory is that the in-vehicle system (client) wirelessly communicates with a remote GM server that calculates routes using real-time data and sends them back to the vehicle for reconstruction and display. The allegation of a wireless connection is potentially supported by the "4G LTE" icon visible in the complaint's screenshot of the accused system (Compl. p. 6).

Identified Points of Contention:

• Scope Questions: Does the data format used between GM's server and the Maps+ client meet the claim limitation of a "non-proprietary, natural language description"? The definition of this term will be a critical issue for claim construction.
• Technical Questions: What is the technical architecture of the Maps+ system? The complaint does not provide evidence to distinguish between two possibilities: (1) the client receives a high-level "description" and performs the claimed "reconstructing" of the route using its local map data, or (2) the server sends fully rendered map tiles or detailed vector data that the client simply displays, which may not meet the claim elements.

V. Key Claim Terms for Construction

Term from ’628 Patent: "artistic map"

Context and Importance: This term is foundational to the infringement allegation for the ’628 Patent. The viability of the claim may depend on whether a modern, commercial in-vehicle map display can be construed as an "artistic map."

Intrinsic Evidence for a Broader Interpretation: The specification suggests a goal of making navigation "a pleasant experience" but does not provide a precise definition, which may support a broader interpretation beyond literal art (’628 Patent, col. 2:65-66).

Intrinsic Evidence for a Narrower Interpretation: The specification's examples consistently refer to maps for "leisure activities, such as touring a city, a park and a zoo," and figures depict stylized, non-proportional maps with "exaggeratedly shown" objects, such as animals (’628 Patent, col. 1:61-64; Fig. 1). This context suggests the term may be limited to such illustrative, non-standard maps.

Term from ’743 Patent: "non-proprietary, natural language description"

Context and Importance: This term defines the specific nature of the data transmitted from the server to the client and is key to the patent's goal of decoupling the two. The infringement analysis for the ’743 Patent will likely hinge on the construction of this phrase.

Intrinsic Evidence for a Broader Interpretation: The abstract refers to a "plain text description," which could be argued to encompass any human-readable data format, as distinct from compiled binary code (’743 Patent, Abstract).

Intrinsic Evidence for a Narrower Interpretation: The patent provides examples of the description as a sequence of road names, headings, and distances (e.g., "INTERSTATE 8 90 DEG. 1.4 MILES") (’743 Patent, Fig. 5). This suggests a structured, text-based format for turn-by-turn instructions, which may not read on modern, complex data formats like XML or JSON used for transmitting rich geographic data.

VI. Other Allegations

Indirect Infringement: The complaint alleges that GM induces infringement by advertising the Maps+ system and providing it to customers, thereby encouraging them to use the system in an infringing manner (Compl. ¶29, ¶46, ¶49).

Willful Infringement: For the ’628 Patent, willfulness is alleged based on notice provided by the filing of the complaint (Compl. ¶28). For the ’743 Patent, the complaint alleges pre-suit knowledge and willfulness, asserting "upon information and belief" that GM's "parent, Honda Motor Co." cited the ’743 patent in its own patent applications as early as 2005 (Compl. ¶44). The complaint includes a screenshot of patent citation data to support this allegation (Compl. p. 11). It further alleges a policy of "willful blindness" to the patent rights of others (Compl. ¶50).

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

1. Definitional Scope: A core issue will be one of claim construction: can the term "artistic map", which the ’628 Patent describes in the context of exaggerated theme park-style illustrations, be interpreted to cover the conventional-appearing graphical display of the accused Maps+ commercial navigation system?

2. Technical Operation: A key evidentiary question will concern the architecture of the accused system. Does the GM server transmit a high-level, "non-proprietary, natural language description" for client-side route "reconstruction," as required by the ’743 Patent, or does it use a modern, proprietary data stream to send fully processed map information, suggesting a fundamental mismatch in technical operation?

3. Willfulness and Imputed Knowledge: The willfulness claim for the ’743 Patent will depend on whether Plaintiff can substantiate its allegation of a parent-subsidiary relationship between Honda and GM, and legally impute knowledge to GM based on patent citations made by Honda nearly two decades prior to the suit.