Infogation Corp v. Stellantis NV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Infogation Corporation (Texas)
  • Defendant: Stellantis N.V. (Netherlands)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-1026, E.D. Tex., 12/11/2024
• Venue Allegations: Venue is alleged to be proper on the basis that the 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 UConnect in-vehicle navigation systems infringe two patents related to methods for displaying non-linearly scaled maps and for using a client-server architecture to calculate and display routes.
• Technical Context: The lawsuit concerns in-vehicle GPS navigation technology, a common feature in the contemporary automotive market for providing driving directions and point-of-interest information.
• Key Procedural History: The complaint notes that the patents-in-suit have collectively been cited by over 200 other patents. It also states that U.S. Patent 6,292,743 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 No. 10,107,628 - "Method and Apparatus for Navigating on Artistic Maps" (issued Oct. 23, 2018)

The Invention Explained

• Problem Addressed: The patent’s background describes conventional GPS navigation maps as potentially "boring" and failing to clearly display points of interest, particularly in "leisure activities, such as touring a city, a park and a zoo" (’628 Patent, col. 1:40-49).
• The Patented Solution: The invention proposes a system that uses a visually engaging, non-linearly scaled "artistic map" (e.g., a theme park map with exaggerated landmarks) for user interaction. A user selects a destination on this artistic map. The system then translates the selected point into its corresponding real-world latitude and longitude on a hidden, underlying "geographical map," calculates a route using this geographical data, and then displays the resulting navigational guidance on the user-facing artistic map (’628 Patent, col. 2:29-39; FIG. 3). The key is the separation: the artistic map is for display, while the geographical map is for calculation (’628 Patent, col. 7:35-37).
• Technical Importance: This approach allows for the use of customized, user-friendly maps that are more intuitive in specific environments than standard road maps, enhancing the navigation experience in venues like parks or campuses (’628 Patent, col. 1:61-65).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶17).
• Essential elements of claim 1 include:
  • Downloading an "artistic map" that is "non-linearly scaled" with "exaggeratedly shown" objects.
  • Receiving a user's selection of an object on the artistic map.
  • Transforming the coordinates of the selection into a "physical point" (latitude and longitude) on a "geographical map" that is not displayed.
  • Determining a navigational direction to the physical point using the geographical map.
  • Showing the resulting navigational direction on the displayed artistic map.
• The complaint does not explicitly reserve the right to assert dependent claims, though this remains a possibility.

U.S. Patent No. 6,292,743 - "Mobile Navigation System" (issued Sep. 18, 2001)

The Invention Explained

• Problem Addressed: The patent identifies limitations of early stand-alone navigation systems, including their reliance on local storage (e.g., CDs) with limited capacity, the need for frequent and costly map updates, and the inability to access real-time data like traffic conditions (’743 Patent, col. 1:24-44).
• The Patented Solution: The invention describes a distributed navigation system. A "client" device in a vehicle establishes a wireless connection to a remote "server" (’743 Patent, col. 3:26-28). The server, with access to extensive, real-time data, performs the complex route calculation. It then formats the route into a "non-proprietary, natural language description" and sends this simplified data to the client (’743 Patent, col. 3:33-36). The client, using its local mapping database, interprets this simple description to "reconstruct" and display the route, decoupling the client's capabilities from the server's (’743 Patent, col. 3:40-43).
• Technical Importance: This client-server architecture offloads heavy computational tasks to a central server, enabling in-vehicle systems to leverage real-time information and extensive map data without requiring powerful onboard processors or large, frequently updated storage (’743 Patent, col. 2:53-62).

Key Claims at a Glance

• The complaint asserts independent claim 15 (Compl. ¶33).
• Essential elements of claim 15 (an apparatus claim) include:
  • A navigation computer.
  • A wireless transceiver for connecting with a navigation server that calculates optimal routes based on real-time information.
  • The server formats these routes using a "non-proprietary, natural language description."
  • A local mapping database 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.

III. The Accused Instrumentality

Product Identification

• The "UConnect Navigation system and platform" and its variations, which are included in a wide range of vehicles sold under Stellantis brands such as Chrysler, Dodge, Jeep, Ram, Fiat, and Alfa Romeo (Compl. ¶11).

Functionality and Market Context

• The UConnect system is an in-vehicle infotainment platform that provides GPS navigation. The complaint alleges, through a screenshot from a Chrysler website, that the system features "stunning 3D graphics and detailed views of landmarks, cities and terrains" (Compl. p. 6). This screenshot from the Chrysler website shows the UConnect Navigation system's interface, which Plaintiff highlights for its "stunning 3D graphics and detailed views of landmarks, cities and terrains" (Compl. p. 6). The complaint further alleges that the system downloads map information, calculates routes based on real-time data, and provides navigational guidance, thereby embodying the technologies of both patents-in-suit (Compl. ¶17, ¶33).

IV. Analysis of Infringement Allegations

'628 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: A primary issue may be whether the "3D graphics and detailed views of landmarks" in a general-purpose automotive navigation system (Compl. p. 6) fall within the scope of an "artistic map," a term the ’628 Patent primarily illustrates in the context of leisure venues like zoos and parks (’628 Patent, FIG. 1; col. 1:61-65).
  • Technical Question: What evidence will demonstrate that the UConnect system employs the specific two-map architecture required by the claim, where an "artistic map" is used purely for display and is explicitly "not used directly by the computing device for navigation," while a separate, non-displayed "geographical map" is used for all route calculations (’628 Patent, col. 7:35-37)?

'743 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: The viability of this claim may depend heavily on the construction of "non-proprietary, natural language description." The patent provides an example of simple plain text, such as "Interstate 8 90 Deg. 1.4 miles" (’743 Patent, FIG. 5; col. 3:37-38). A key question is whether the likely complex and proprietary data format transmitted between Stellantis's server and its vehicles can be interpreted as meeting this claim limitation.
  • Technical Question: Does the UConnect client device actually perform a "reconstruction" of the route based on a high-level description, as claimed, or does the server transmit a fully detailed, proprietary route data package that the client device simply renders on its screen? Proving the former technical process will be critical.

V. Key Claim Terms for Construction

From the ’628 Patent:

• The Term: "artistic map"
• Context and Importance: The infringement argument hinges on whether the 3D city and terrain views in the accused UConnect system qualify as an "artistic map." Practitioners may focus on this term because the patent’s examples differ significantly from the accused product's context.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the map as "non-linearly scaled, where points of interests are exaggeratedly displayed" (’628 Patent, col. 4:4-5), language which could arguably be applied to 3D models of landmarks in a city view.
  • Evidence for a Narrower Interpretation: The patent's background and detailed description repeatedly ground the invention in "leisure activities, such as touring a city, a park or a zoo" (’628 Patent, col. 1:61-62). Figure 1, a central illustration, depicts a zoo map. This context may support an interpretation limited to stylized, non-photorealistic maps for specific venues.

From the ’743 Patent:

• The Term: "non-proprietary, natural language description"
• Context and Importance: This term defines the core data exchange mechanism that distinguishes the invention from prior art systems that allegedly used proprietary data formats. The infringement case against the modern, sophisticated UConnect system will likely turn on whether its data protocol fits this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide a formal definition, potentially leaving room to argue that any structured, human-intelligible data format, even if not plain English, could qualify.
  • Evidence for a Narrower Interpretation: The specification states the format includes a "plain text description for each link in the route using pre-defined generic terms" (’743 Patent, col. 3:37-40). The only visual example provided is a list of simple text strings like "INTERSTATE 8 90 DEG. 1.4 MILES" (’743 Patent, FIG. 5), suggesting the term requires a simple, text-based format rather than a compressed, binary data stream.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Stellantis induces infringement by providing its UConnect systems and advertising their infringing use (Compl. ¶25, ¶41). For the ’743 patent, it specifically alleges that Stellantis maintains a "policy or practice against investigating third party patent rights," which it claims constitutes willful blindness (Compl. ¶37).
• Willful Infringement: Willfulness is alleged for the ’628 patent based on notice provided by the complaint itself (post-suit knowledge) (Compl. ¶21). For both patents, willfulness is also alleged on the basis of willful blindness, with the complaint asserting that Stellantis has a practice of not performing patent clearance reviews before launching products (Compl. ¶26, ¶42).

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

• A core issue will be one of definitional scope: can the term "artistic map," which is rooted in the patent’s examples of zoo and park maps for leisure, be construed to cover the 3D terrain and landmark graphics used in a general-purpose automotive navigation system?
• A second central question will be both technical and definitional: does the data format transmitted between Stellantis's servers and its UConnect vehicles meet the definition of a "non-proprietary, natural language description" as taught in the ’743 patent, and does the client device perform the claimed step of "reconstructing" the route, or does it operate in a fundamentally different manner?
• A key evidentiary challenge for the plaintiff will be to prove, with technical evidence, that the accused UConnect software operates according to the specific multi-step architectures claimed in the patents, rather than merely achieving a similar navigational result through a different technical implementation.