DCT
2:24-cv-01022
Infogation Corp v. TomTom Intl BV
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-01022, E.D. Tex., 04/15/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is not a resident of 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 three patents related to GPS navigation, map display interfaces, and client-server route calculation.
- Technical Context: The technology at issue involves methods for enhancing the user experience and technical architecture of in-vehicle GPS navigation systems, a now-standard feature in the automotive industry.
- Key Procedural History: This First Amended Complaint follows an original complaint. For U.S. Patent 6,292,743, the complaint alleges pre-suit knowledge based on Defendant’s partnership with TomTom, which had previously cited the patent in its own patent application. U.S. Patent 6,292,743 expired in January 2019, limiting potential damages to a past period.
Case Timeline
| Date | Event |
|---|---|
| 1999-01-06 | U.S. Patent 6,292,743 – Priority Date |
| 2001-09-18 | U.S. Patent 6,292,743 – Issue Date |
| 2007-08-11 | U.S. Patent 10,107,628 – Priority Date |
| 2008-11-07 | U.S. Patent 8,898,003 – Priority Date |
| 2011-01-01 | Alleged TomTom awareness of ’743 Patent |
| 2014-11-25 | U.S. Patent 8,898,003 – Issue Date |
| 2018-10-23 | U.S. Patent 10,107,628 – Issue Date |
| 2019-01-06 | U.S. Patent 6,292,743 – Expiration Date |
| 2019-03-01 | Alleged partnership between Nissan and TomTom |
| 2025-04-15 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,107,628 - "METHOD AND APPARATUS FOR NAVIGATING ON ARTISTIC MAPS"
- Issued: October 23, 2018.
The Invention Explained
- Problem Addressed: The patent’s background section describes conventional GPS displays as unengaging, particularly in leisure settings like zoos or parks, where points of interest may not appear on the map until a user is very close, making navigation difficult (’628 Patent, col. 1:38-54; Compl. ¶7).
- The Patented Solution: The invention proposes a system for navigating using a visually stylized "artistic map" that is "non-linearly scaled" to exaggerate points of interest. A user selects an object on this artistic map; the system translates the selection’s coordinates into a real-world physical point (latitude and longitude) on a separate, underlying geographical map and then calculates and displays a route to that point on the artistic map (’628 Patent, Abstract; col. 2:26-40).
- Technical Importance: This approach enabled the use of user-friendly, illustrative maps for navigation in specific environments where a traditional, to-scale road map would be less practical or informative (’628 Patent, col. 1:61-67).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶22, ¶27).
- Key elements of Claim 1 include:
- downloading an "artistic map" that is "non-linearly scaled" with "exaggeratedly shown" objects;
- using the artistic map for display while using a separate, non-displayed "geographical map" for navigation guidance;
- receiving a user's selection of an object on the artistic map;
- transforming the coordinates of the selected object into a "physical point" (latitude and longitude) on the geographical map;
- determining a navigational direction from the user's current location to that physical point; and
- showing the resulting navigational direction on the displayed artistic map.
- The complaint reserves the right to assert additional claims (Compl. ¶22).
U.S. Patent No. 6,292,743 - "MOBILE NAVIGATION SYSTEM"
- Issued: September 18, 2001.
The Invention Explained
- Problem Addressed: The patent describes the limitations of early stand-alone navigation systems that relied on local media like CDs. These systems had limited data storage, required frequent and costly manual updates, lacked access to real-time information (e.g., traffic), and used proprietary data formats that prevented interoperability between different navigation clients and servers (’743 Patent, col. 1:33-40, col. 2:1-9; Compl. ¶11).
- The Patented Solution: The patent discloses a distributed navigation system where a client device wirelessly connects to a remote server that performs the computationally intensive task of route calculation using real-time data. The server then transmits the route to the client using a "non-proprietary, natural language description." This allows the client to "reconstruct" and display the route using its own, potentially minimal, local mapping database, thereby decoupling the server's data sources from the client's specific map software (’743 Patent, Abstract; col. 3:9-26).
- Technical Importance: This client-server architecture shifted route calculation to a powerful, connected server, enabling the integration of live data and alleviating the need for users to constantly update local map databases (’743 Patent, col. 2:45-53).
Key Claims at a Glance
- The complaint asserts independent Claim 15 (Compl. ¶43).
- Key elements of Claim 15 include:
- a navigation computer;
- a wireless transceiver for connecting with a navigation server that calculates optimal routes based on real-time information;
- the server formatting the optimal routes using a "non-proprietary, natural language description";
- a local mapping database for "reconstructing" the optimal route from the non-proprietary description; and
- a display screen for displaying the reconstructed route.
U.S. Patent No. 8,898,003 - "GPS MAP RESEMBLING AMBIENT ENVIRONMENT"
- Issued: November 25, 2014.
- Technology Synopsis: The patent addresses the problem of static and "boring" 2D electronic maps by disclosing a system that creates a more realistic and dynamic display (’003 Patent, col. 1:35-46). The solution involves superimposing images representing objects like buildings and landmarks onto the map to create a 3D impression and altering the images with different color effects based on external inputs, such as the time of day or weather conditions, to make the map resemble the ambient environment (’003 Patent, col. 2:1-14; Compl. ¶9).
- Asserted Claims: The complaint asserts infringement of Claim 1 (Compl. Count III, ¶5).
- Accused Features: The complaint alleges that the NissanConnect systems infringe by displaying maps that superimpose images to create a 3D effect and that change appearance to reflect environmental conditions such as the time of day (Compl. ¶5, ¶9).
III. The Accused Instrumentality
Product Identification
- The "NissanConnect infotainment system and platform" and its variations, which are incorporated into a wide array of Nissan vehicle models (Compl. ¶20).
Functionality and Market Context
- The accused instrumentality is an in-dashboard GPS navigation system that provides users with map displays and route guidance (Compl. p. 14). The complaint alleges that these systems download map data, display it with 3D and artistic elements, and connect to network services for route calculation (Compl. ¶27, ¶43). The screenshot from Nissan's website shows a navigation system integrated into the vehicle's dashboard, providing visual and voice commands (Compl. p. 14). The extensive list of vehicle models suggests this is a core technology for the defendant's products (Compl. ¶20).
IV. Analysis of Infringement Allegations
U.S. Patent 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 system allegedly downloads an artistic map that includes non-linearly scaled and exaggerated objects to facilitate user navigation. | ¶27(i) | col. 2:26-30 |
| 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 system allegedly uses the artistic map for display only, while relying on a separate, non-displayed geographical map for actual navigation calculations. | ¶27(i) | col. 8:31-39 |
| 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 a point of interest on the displayed map. | ¶27(ii) | col. 2:30-33 |
| 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 converts the coordinates of the user's selection on the artistic map into real-world latitude and longitude coordinates. | ¶27(iv) | col. 2:33-37 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected; | The system calculates a route from the user's current location to the selected physical point using the geographical map. | ¶27(vi) | col. 2:37-39 |
| showing the navigational direction on the artistic map being displayed. | The calculated route is displayed to the user on the artistic map. | ¶27 | col. 2:39-40 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the maps in the NissanConnect system, which feature 3D renderings of buildings, meet the claim definition of an "artistic map" that is "non-linearly scaled" with "exaggeratedly shown" objects. The interpretation of these terms will be critical.
- Technical Questions: The complaint alleges a specific technical architecture where an "artistic map" is used for display and a separate "geographical map" is used for calculation (Compl. ¶27(i)). A key question will be whether the accused system actually operates this way, or if it uses a single set of map data that is merely rendered with artistic attributes for display.
U.S. Patent 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, said navigation server for calculating optimal routes based on real-time information... | The system allegedly uses a wireless transceiver to connect to a remote server that calculates routes using real-time data. | ¶43(ii) | col. 3:26-34 |
| ...said optimal routes being formatted using a non-proprietary, natural language description; | The route data sent from the server to the client is allegedly formatted in a non-proprietary, natural language description. | ¶43(ii) | col. 3:15-25 |
| a mapping database coupled to said navigation computer for reconstructing said optimal route from said non-proprietary, natural language description; | The in-vehicle system allegedly uses its local mapping database to reconstruct the route from the generic description provided by the server. | ¶43(iii) | col. 3:40-44 |
| a display screen coupled to said navigation computer for displaying said optimal route using said mapping database. | The system includes a display screen to show the reconstructed route to the user. | ¶43(iv) | col. 6:3-14 |
- Identified Points of Contention:
- Scope Questions: The definition of "non-proprietary, natural language description" will likely be a significant point of dispute. The defense may argue that the data format used between Nissan's system and its data provider (e.g., TomTom) is a proprietary, compressed binary format, not the "plain text description" contemplated by the patent's specification (’743 Patent, col. 3:37-40).
- Technical Questions: A factual question is whether the accused system truly "reconstructs" a route from a generic, map-agnostic description, as claimed. An alternative possibility is that the server sends route information already tailored to the specific version of the map database installed in the client device, which may not align with the patent's claimed method of decoupling the client and server.
V. Key Claim Terms for Construction
Term (’628 Patent): "artistic map"
- Context and Importance: This term is fundamental to the scope of the ’628 Patent. The case will depend on whether this term can be construed to cover modern 3D-rendered navigation maps or if it is limited to more stylized, illustrative maps like those for theme parks.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the goal is to make navigation "a pleasant experience" and that the map may be "artisticly made," language that could encompass aesthetically enhanced but still geographically-based maps (’628 Patent, col. 1:66-67).
- Evidence for a Narrower Interpretation: The patent's figures and description repeatedly use a zoo map as the primary example, where animals and exhibits are "exaggeratedly shown," suggesting the term may be limited to maps that prioritize illustration over precise geographic scale (’628 Patent, col. 1:63-65, FIG. 1).
Term (’743 Patent): "non-proprietary, natural language description"
- Context and Importance: This term defines the data format that enables the patent's core inventive concept: decoupling the client's map software from the server's route calculation engine. The infringement analysis for the ’743 patent hinges on whether the accused system's data protocol fits this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the description is "completely independent from the local mapping database software used on the clients, and can therefore be used in conjunction with any type of mapping database software," which could support interpreting the term functionally to include any format that achieves this independence (’743 Patent, col. 3:23-26).
- Evidence for a Narrower Interpretation: The specification provides a specific example of the format as a "plain text description for each link in the route using pre-defined generic terms such as road names and turning directions," which could support a narrower construction limited to human-readable text rather than more complex data structures (’743 Patent, col. 3:37-40).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Nissan induces infringement by manufacturing, advertising, and selling the Accused Instrumentalities for use by its customers in an infringing manner (Compl. ¶32, ¶49, Count III ¶10).
- Willful Infringement: For the ’628 and ’003 patents, willfulness is alleged to commence upon the filing and service of the complaint (Compl. ¶31; Count III, ¶9). For the ’743 patent, the complaint alleges pre-suit willfulness dating to March 2019, based on Nissan’s partnership with TomTom. The complaint includes a screenshot of a patent search result allegedly showing that a TomTom patent application cited the ’743 patent as early as 2011, which Plaintiff asserts supports an inference of knowledge (Compl. ¶47, p. 21). Willful blindness is also alleged based on a purported practice of not conducting patent clearance reviews (Compl. ¶48).
VII. Analyst’s Conclusion: Key Questions for the Case
- Definitional Scope: A core issue for the ’628 and ’003 patents will be one of definitional scope: can terms like "artistic map" and a "map resembling an ambient environment," which were drafted in the context of earlier navigation technology, be construed to cover the sophisticated, 3D-rendered maps standard in modern infotainment systems?
- Architectural Equivalence: For the ’743 patent, the case will likely turn on a question of technical architecture: does the accused NissanConnect system, which integrates technology from partners like TomTom, utilize the specific decoupled architecture of the patent, where a "non-proprietary, natural language description" is sent for local "reconstruction," or does it employ a more conventional, integrated data format that falls outside the claim scope?
- Imputed Knowledge: A key evidentiary question for willfulness on the ’743 patent will be whether a patent citation by a technology partner (TomTom) years before its partnership with the defendant can be used to establish that the defendant knew or should have known of the patent, thereby supporting a claim for enhanced damages.