DCT
2:24-cv-01021
Infogation Corp v. Nissan Motor Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Nissan Motor Co., Ltd. (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:24-cv-01021, E.D. Tex., 12/10/2024
- Venue Allegations: Venue is asserted on the basis that Defendant is a foreign corporation not resident in the United States and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s NissanConnect in-vehicle infotainment systems infringe four patents related to navigation technology, including methods for displaying maps, client-server route calculation, and creating realistic map visuals.
- Technical Context: The patents address foundational technologies in automotive navigation systems, a critical and highly competitive feature set within the modern vehicle market.
- Key Procedural History: The complaint states the asserted patents have been cited in over 200 later patents issued to industry leaders. Provided documentation also includes an Ex Parte Reexamination Certificate for U.S. Patent 8,406,994, requested in February 2024 (prior to this complaint's filing), which cancels all claims of that patent. The certificate's issue date is noted as March 28, 2025.
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 ’003 and ’994 Patents |
| 2013-03-26 | Issue Date for ’994 Patent |
| 2014-11-25 | Issue Date for ’003 Patent |
| 2018-10-23 | Issue Date for ’628 Patent |
| 2024-02-27 | Reexamination of ’994 Patent Requested |
| 2024-12-10 | Complaint Filing Date |
| 2025-03-28 | Issue Date for ’994 Patent Reexamination Certificate (cancelling all claims) |
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 at showing a user's location relative to points of interest, particularly for leisure activities where stylized maps (e.g., for a zoo or park) are more intuitive than geographically precise road maps (’628 Patent, col. 1:41-54).
- The Patented Solution: The invention proposes a system that separates the user-facing map from the underlying navigation data. It uses a non-linearly scaled "artistic map" with exaggerated objects for display. When a user selects an object on this artistic map, the system transforms the screen coordinates into real-world geographic coordinates (latitude/longitude), calculates a route using a standard geographic map, and then projects the resulting navigational directions back onto the artistic map for the user to follow (’628 Patent, Abstract; col. 2:26-39; Fig. 3).
- Technical Importance: This technique allows for more user-friendly and visually engaging navigation interfaces by decoupling the aesthetic map representation from the rigid, to-scale data required for routing calculations (’628 Patent, col. 1:55-65).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶18).
- Essential elements of independent method claim 1 include:
- Downloading a non-linearly scaled "artistic map" with "exaggeratedly shown" objects to a portable computing device.
- The artistic map is not used directly for navigation, and an underlying "geographical map" is not displayed.
- Receiving a user's selection of an object on the artistic map.
- Determining screen coordinates for a point on the selected object.
- Transforming those screen coordinates into a physical point (latitude and longitude) on the non-displayed geographical map.
- Detecting the device's current location and determining a navigational direction using the geographical map.
- Showing the determined navigational direction on the displayed artistic map.
U.S. Patent 6,292,743 - Mobile Navigation System (issued Sep. 18, 2001)
The Invention Explained
- Problem Addressed: The patent identifies the limitations of early stand-alone navigation systems, which had limited local data storage, required frequent and costly map updates, and could not access real-time information such as traffic conditions (’743 Patent, col. 1:10-41).
- The Patented Solution: The invention discloses a distributed, client-server navigation system. A client device in a vehicle connects wirelessly to a remote server that performs the computationally intensive task of calculating an optimal route using real-time data. The server formats this route as a "non-proprietary, natural language description" (e.g., text-based turn instructions) and sends it to the client. The client then uses its own, potentially simpler, local mapping database to interpret these instructions and reconstruct the route for display (’743 Patent, Abstract; col. 3:21-52; Fig. 3).
- Technical Importance: This architecture offloads complex processing to a server, reducing the hardware and data storage requirements of the in-vehicle unit and enabling the use of dynamic, real-time data for routing (’743 Patent, col. 2:52-64).
Key Claims at a Glance
- The complaint asserts independent claim 15 and reserves the right to assert others (Compl. ¶34).
- Essential elements of independent system claim 15 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 coupled to the navigation computer for reconstructing the optimal route from the non-proprietary description.
- A display screen for displaying the reconstructed route using the mapping database.
U.S. Patent 8,898,003 - GPS Map Resembling Ambient Environment (issued Nov. 25, 2014)
- Technology Synopsis: This patent describes a method to make digital maps more realistic by creating a display that resembles the "ambient environment." The system superimposes images representing objects like landmarks onto the map and alters their appearance based on external inputs, such as the time of day or weather, to provide a more dynamic and context-aware visual experience (’003 Patent, Abstract; col. 2:4-13).
- Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶50).
- Accused Features: The complaint makes a general allegation that the Accused Instrumentalities perform the steps of claim 1, referencing a marketing video without identifying specific features (Compl. ¶50).
U.S. Patent 8,406,994 - Electronically Generated Realistic-like Map (issued Mar. 26, 2013)
- Technology Synopsis: This patent, related to the ’003 patent, discloses a method for creating a "realistic-like" map. The technique involves displaying a map, superimposing images of objects (e.g., signs, buildings) onto it, and changing the color effects of those images in response to conditions like weather to make the map display more closely resemble the real-world environment (’994 Patent, Abstract; col. 2:1-14).
- Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶66).
- Accused Features: The complaint alleges infringement of claim 1 by the Accused Instrumentalities, again citing a marketing video without further detail (Compl. ¶66).
III. The Accused Instrumentality
- Product Identification: The "NissanConnect infotainment system and platform" and the various Nissan vehicle models in which it is installed (Compl. ¶12-13).
- Functionality and Market Context: The complaint alleges the NissanConnect system is a navigation-equipped platform with a GPS built into the vehicle dashboard that provides visual and voice commands (Compl. ¶13). A screenshot provided in the complaint shows a user interface for finding destinations via a "Places Directory" and an in-vehicle view of the system's map display (Compl. p. 6). The complaint alleges the system provides the functionality described in the asserted patents, such as downloading maps, calculating routes based on real-time information, and displaying navigation guidance (Compl. ¶18, ¶34). The extensive list of vehicle models suggests broad commercial deployment of the accused system (Compl. ¶12).
IV. Analysis of Infringement Allegations
’628 Patent 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... | Defendant's system downloads an "artistic map" that is non-linearly scaled with exaggerated objects to facilitate user selection. | ¶18(i) | col. 4:9-11 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The system receives a user's selection of one of the objects on the map. | ¶18(ii) | col. 2:31-33 |
| determining by the computing device a pair of coordinates for one of the points on the selected object | The system determines a pair of coordinates for a point on the selected object. | ¶18(iii) | col. 2:33 |
| 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 system transforms the coordinates to a latitude/longitude pair in a geographical map that is not shown on the display. | ¶18(iv) | col. 2:33-36 |
| detecting a current location of the computing device in the geographical map | The system detects the device's current location within the geographical map. | ¶18(v) | col. 2:36-37 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected | The system determines a navigational direction from the current location to the selected object using the geographical map. | ¶18(vi) | col. 2:36-37 |
| showing the navigational direction on the artistic map being displayed | The system shows the calculated navigational direction on the artistic map. | ¶18(vii) | col. 4:5-8 |
- Identified Points of Contention: The infringement analysis for the ’628 Patent raises the question of whether a standard automotive navigation map, as depicted in the complaint's screenshot (Compl. p. 6), qualifies as an "artistic map" that is "non-linearly scaled" and contains "exaggeratedly shown" objects within the meaning of the patent. A further technical question is whether the accused system actually uses a separate, non-displayed "geographical map" for routing, or if its display and routing functions operate on a single, integrated map dataset.
’743 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a navigation computer | The accused system includes a navigation computer. | ¶34(i) | col. 5:50-51 |
| a wireless transceiver coupled to said navigation computer for connecting with a navigation server, 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 uses a wireless transceiver to connect to a server that calculates optimal routes using real-time data and formats them in a "non-proprietary, natural language description." | ¶34(ii) | col. 3:21-43 |
| a mapping database coupled to said navigation computer for reconstructing said optimal route from said non-proprietary, natural language description | The system uses a local mapping database to reconstruct the route received from the server. | ¶34(iii) | col. 3:43-48 |
| a display screen coupled to said navigation computer for displaying said optimal route using said mapping database | The system uses a display screen to show the reconstructed route. | ¶34(iv) | col. 3:49-52 |
- Identified Points of Contention: The core of the infringement dispute for the ’743 Patent may focus on the nature of the data transmitted from the server to the accused NissanConnect system. The key question is whether this data constitutes a "non-proprietary, natural language description," as required by the claim, or if it is transmitted in a proprietary, compressed format that is dependent on the specific local mapping database.
V. Key Claim Terms for Construction
For the ’628 Patent:
- The Term: "artistic map"
- Context and Importance: This term is central to the invention's novelty. The infringement case depends on whether the accused NissanConnect map display can be characterized as "artistic." Practitioners may focus on this term because its scope will determine whether the patent covers conventional navigation maps or is limited to more stylized, non-traditional displays.
- 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).
- Evidence for a Narrower Interpretation: The patent’s background and embodiments repeatedly reference use in "leisure activities, such as touring a city, a park or a zoo" and show a stylized zoo map as a primary example, suggesting the term applies to non-standard, illustrative maps with "exaggeratedly" shown objects, not conventional road maps (’628 Patent, col. 1:46-48, 60-62; Fig. 1).
For the ’743 Patent:
- The Term: "non-proprietary, natural language description"
- Context and Importance: This term defines the critical interface between the server and the client, which is the core of the patented system. Whether Nissan's system infringes will depend heavily on the court's construction of this phrase. Practitioners may focus on this term to determine if it is limited to human-readable text or if it can encompass other generic, database-independent data formats.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's objective is to make the server "hardware and software independent from the client" (’743 Patent, col. 3:7-9). This purpose could support a construction that includes any data format that achieves this independence, even if not strictly "natural language."
- Evidence for a Narrower Interpretation: The specification explicitly describes the format as a "plain text description for each link in the route using pre-defined generic terms" and provides an example with text such as "Interstate 8 90 Deg. 1.4 Miles," suggesting a specific, human-readable or text-based structure is required (’743 Patent, col. 3:39-43; Fig. 5).
VI. Other Allegations
- Indirect Infringement: For all asserted patents, the complaint alleges induced infringement, stating that Defendant advertises the accused systems and provides user manuals and instructions that encourage customers to use the systems in an infringing manner (Compl. ¶24, ¶26, ¶40, ¶56).
- Willful Infringement: The complaint alleges willfulness based on Defendant's knowledge of the patents following the filing and service of the complaint (Compl. ¶22, ¶54, ¶70). It further alleges "willful blindness," asserting that Defendant has a policy of not reviewing third-party patent rights before launching its products (Compl. ¶27, ¶38, ¶43, ¶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 roots in the context of stylized, non-linearly scaled leisure maps (e.g., zoo maps), be construed broadly enough to read on the conventional, to-scale road map interface of the accused NissanConnect system?
- A key evidentiary question will be one of technical implementation: for the ’743 Patent, does the accused system's server communicate route guidance using a "non-proprietary, natural language description" as claimed, or does it rely on a proprietary data format that is intrinsically tied to the client's specific mapping database, potentially avoiding infringement?
- A threshold procedural and substantive question will be the enforceability of the ’994 Patent: given the provided documentation of an Ex Parte Reexamination Certificate cancelling all claims of the ’994 Patent, the court will need to address whether the continued assertion of this patent is permissible and what, if any, impact this has on the remainder of the case.