Infogation Corp v. Hyundai Motor Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Infogation Corporation (Texas)
  • Defendant: Hyundai Motor Company (Republic of Korea) and Kia Corporation (Republic of Korea)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-01019, E.D. Tex., 12/10/2024
• Venue Allegations: Venue is asserted on the basis that Defendants are not residents of the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendants’ in-vehicle navigation systems infringe four patents related to map display technology and distributed route calculation.
• Technical Context: The lawsuit concerns in-vehicle GPS navigation systems, a standard feature in the modern automotive market, focusing on how maps are rendered and how route data is processed between a vehicle and a remote server.
• Key Procedural History: The complaint alleges that the patents-in-suit have been cited in over 200 other patents issued to industry leaders. The provided Ex Parte Reexamination Certificate for U.S. Patent 8,406,994, one of the patents-in-suit, indicates that all of its claims (1-18) were cancelled as of March 28, 2025.

Case Timeline

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

U.S. Patent No. 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, particularly for leisure activities like visiting a zoo, as "boring" and ineffective because they fail to display points of interest clearly until a user is very close, making navigation difficult (’628 Patent, col. 1:40-54).
• The Patented Solution: The invention proposes using a non-linearly scaled "artistic map" where objects like landmarks are exaggerated for easy viewing and selection. The system works by allowing a user to select an exaggerated object on the artistic map, transforming the coordinates of that selection into a real-world geographic point (latitude/longitude), and then calculating and displaying a navigation path to that point on the user-friendly artistic map (’628 Patent, col. 2:29-39; Fig. 3).
• Technical Importance: This approach aimed to improve the user experience by prioritizing visual simplicity and recognizability over strict geographic accuracy, making navigation in complex, attraction-dense environments more intuitive (’628 Patent, col. 1:60-65).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶18).
• Essential elements of claim 1, a method, include:
  • Downloading an "artistic map" that is "non-linearly scaled" and has "exaggeratedly shown" objects.
  • Receiving a user's selection of one of the objects.
  • Determining the coordinates of a point on the selected object.
  • Transforming those coordinates into a "physical point" (latitude and longitude) on a standard 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 displayed artistic map.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,292,743 - "Mobile Navigation System"

Issued Sep. 18, 2001

The Invention Explained

• Problem Addressed: Stand-alone in-vehicle navigation systems of the time were limited by local storage capacity and lacked access to real-time data like traffic. Early connected systems were proprietary, requiring the client device and server to use identical, specially-designed mapping databases, making them inflexible and expensive to update (’743 Patent, col. 1:10-52).
• The Patented Solution: The invention describes a distributed navigation system. A client device (the in-vehicle unit) sends a route request to a remote server. The server, which can access real-time data, calculates the optimal route and transmits it back to the client formatted as a "non-proprietary, natural language description." This generic description allows the client to reconstruct the route using its own, potentially different, local mapping database, thus decoupling the server's calculation from the client's specific software (’743 Patent, col. 3:21-49; Abstract).
• Technical Importance: This architecture aimed to create a more universal and flexible client-server navigation system, reducing the need for frequent, costly, and proprietary software updates on the client device while enabling the use of powerful, centralized route calculation with real-time data (’743 Patent, col. 3:1-10).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶34).
• Essential elements of claim 15, a system, include:
  • A navigation computer.
  • A wireless transceiver for connecting to a navigation server that calculates optimal routes based on real-time information and formats them using a "non-proprietary, natural language description."
  • A mapping database for reconstructing the optimal route from the natural language description.
  • A display screen for displaying the reconstructed route.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,898,003 - "GPS Map Resembling Ambient Environment"

Issued Nov. 25, 2014

• Technology Synopsis: This patent describes a navigation device that displays a digital map designed to resemble the "ambient environment" with a "certain level of realism." The invention focuses on altering the map or objects on the map (e.g., changing colors or tones) to correspond with external conditions, such as the time of day or the weather, to enhance realism (’003 Patent, Abstract).
• Asserted Claims: The complaint asserts infringement of Claim 1 (Compl. ¶50).
• Accused Features: The complaint accuses the Hyundai Navigation System of infringing by providing realistic map displays that are responsive to ambient conditions (Compl. ¶12, ¶50).

U.S. Patent No. 8,406,994 - "Electronically Generated Realistic-Like Map"

Issued Mar. 26, 2013

• Technology Synopsis: This patent, a parent to the ’003 patent, also describes a navigation device that presents a "realistic-like" digital map. Its core concept involves superimposing images of objects onto the map and changing those images with different color effects based on an input related to the location's conditions, such as time or weather, to create a more realistic display (’994 Patent, Abstract). As noted, the Ex Parte Reexamination Certificate No. 90/019,433 states that all claims of this patent were cancelled.
• Asserted Claims: The complaint asserts infringement of Claim 1 (Compl. ¶66).
• Accused Features: The complaint accuses the Hyundai Navigation System of infringing by generating realistic maps whose features change based on environmental conditions (Compl. ¶12, ¶66).

III. The Accused Instrumentality

Product Identification

The "Accused Instrumentalities" are identified as the "Hyundai Navigation System" included in a wide range of Hyundai, Kia, and Genesis brand vehicles (Compl. ¶12-13).

Functionality and Market Context

The complaint alleges these are in-vehicle systems that provide map-based navigation functionalities (Compl. ¶12). Visual evidence from a Hyundai manual shows an "Operating Navigation Screen" with a 2D/3D map view, route information, and various on-screen controls (Compl. p. 6). A separate image from a Genesis website highlights a "Split-Screen Navigation" feature on a 14.5" widescreen HD screen, showing its capability to display navigation maps alongside other information (Compl. p. 7). The complaint asserts these systems are a key feature in a large number of vehicle models sold by Defendants, suggesting significant commercial presence.

IV. Analysis of Infringement Allegations

'628 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the map displayed by the Hyundai Navigation System, which appears to be a conventional 2D/3D navigation map (Compl. p. 6), qualifies as an "artistic map" that is "non-linearly scaled" with "exaggeratedly shown" objects as contemplated by the patent. The patent's specification and figures emphasize highly stylized maps, such as for a zoo, which may differ significantly from the accused functionality (’628 Patent, Fig. 1).
  • Technical Questions: The complaint alleges a transformation from "artistic map" coordinates to geographical coordinates. A question for discovery will be whether the accused systems perform such a two-step transformation, or if the displayed map objects are already directly tied to their underlying geographic coordinates.

'743 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The primary technical question will be the format of the data transmitted from the server to the vehicle. The complaint alleges it meets the "non-proprietary, natural language description" limitation. Modern connected car systems often use highly structured and compressed data formats (e.g., XML, JSON, or proprietary binary formats) for efficiency, which may not align with the patent's teaching of a plain-text, human-readable description (e.g., "Interstate 8 90 Deg. 1.4 miles") (’743 Patent, Fig. 5).

V. Key Claim Terms for Construction

• For the '628 Patent:

  • The Term: "artistic map"
  • Context and Importance: This term is the cornerstone of the asserted claim. Its construction will determine whether the patent is limited to highly stylized, non-literal maps or can be read more broadly to cover modern 3D-perspective navigation displays. The infringement analysis hinges entirely on this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the map may show "exaggeratedly objects (or points of interest) to help a user locate where he/she is" (’628 Patent, col. 2:14-16). Plaintiff may argue that any map that distorts scale or perspective for user convenience, such as a 3D view, is "artistic."
    • Evidence for a Narrower Interpretation: The specification repeatedly uses examples like a zoo map (Fig. 1) and a theme park map, which are explicitly described as "artistic and non-linearly scaled" (’628 Patent, col. 4:3-5). Defendant may argue the term is limited to such manually illustrated, non-photorealistic, and topical maps.

• For the '743 Patent:

  • The Term: "non-proprietary, natural language description"
  • Context and Importance: This term defines the nature of the communication between the server and the client, which is the core of the invention's claimed departure from prior art. Whether the accused system's data protocol meets this definition will likely be a dispositive issue for infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the invention's use of a "natural language to describe optimal routing information that can be interpreted by a variety of clients with minimal software additions" (’743 Patent, col. 3:11-14). Plaintiff may argue this means any format that uses human-readable terms, even if embedded in a structured file, meets the "natural language" requirement.
    • Evidence for a Narrower Interpretation: The patent provides a specific example of the description: a list of text strings such as "INTERSTATE 8 90 DEG. 1.4 MILES" (’743 Patent, Fig. 5, 514). Defendant may argue this limits the claim to a simple, plain-text format that is fundamentally different from structured data languages like XML or JSON used in modern APIs.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induce infringement by advertising the navigation systems and providing them to end-users with instructions on how to use them in an infringing manner (Compl. ¶23, ¶26, ¶39, ¶55).
• Willful Infringement: Willfulness is alleged based on Defendants' knowledge of the patents following the filing of the complaint (Compl. ¶22, ¶54, ¶70). The complaint also makes a general allegation that Defendants have a "practice of not performing a review of the patent rights of others," constituting willful blindness (Compl. ¶27, ¶43, ¶59, ¶75).

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

• A core issue will be one of definitional scope: can the term "artistic map," which the ’628 patent illustrates with a stylized zoo map, be construed broadly enough to read on the 2D/3D graphical user interfaces of modern in-vehicle navigation systems?
• A central evidentiary question will be one of technical implementation: does the route data transmitted to the accused navigation systems conform to the ’743 patent's requirement of a "non-proprietary, natural language description," or does it use a more conventional, structured, and proprietary data format that falls outside the claim's scope?
• A key procedural question will be the viability of the infringement claim for the ’994 patent: given that a reexamination certificate indicates all claims of the ’994 patent have been cancelled, the court will need to determine if the fourth count of the complaint, which is predicated on this patent, can proceed.