Infogation Corp v. Mapbox

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Infogation Corporation (Texas)
  • Defendant: Mapbox, Inc. (Delaware)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: Infogation Corporation v. Mapbox, Inc., 2:24-cv-01027, E.D. Tex., 12/11/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a regular and established place of business in the district, evidenced by the presence of employees in Frisco, the operation of mobile mapping vehicles, the use of third-party cloud servers located in Tyler, and business conducted with customers in the district.
• Core Dispute: Plaintiff alleges that Defendant’s digital mapping and navigation platforms, including its Software Development Kits (SDKs), infringe three patents related to displaying non-standard maps, server-based route calculation, and rendering realistic map features.
• Technical Context: The technology concerns digital navigation systems used in mobile and in-vehicle applications, focusing on the methods for generating, displaying, and interacting with map data.
• Key Procedural History: The complaint notes that the patents-in-suit have been cited in numerous other patents, including one issued to Defendant Mapbox. A publicly available ex parte reexamination certificate for the ’994 Patent, issued after the filing of this complaint, indicates that all claims of that patent, including the asserted Claim 1, have been canceled. The complaint asserts damages for the ’743 Patent may be limited due to its expiration in 2019.

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: October 23, 2018

The Invention Explained

• Problem Addressed: The patent describes conventional GPS maps as potentially boring or unhelpful for leisure activities, such as touring a zoo, because they may not display points of interest clearly or engagingly until a user is very close (’628 Patent, col. 1:45-54).
• The Patented Solution: The invention proposes a method using a two-map system. A user interacts with a visually engaging, “non-linearly scaled” or “artistic” map where landmarks are “exaggeratedly shown” (’628 Patent, col. 2:29-31, FIG. 3). When the user selects an object on this artistic map, the system translates the on-screen coordinates to a corresponding physical point (latitude and longitude) on a hidden, standard geographical map. It then calculates a navigation route using the geographical map and displays the resulting directional guidance back on the user-facing artistic map (’628 Patent, Abstract; col. 2:32-38).
• Technical Importance: This approach decouples the user-facing visual presentation from the underlying navigational logic, allowing for more creative and user-friendly map displays without sacrificing the accuracy of GPS routing (’628 Patent, col. 1:55-65).

Key Claims at a Glance

• Independent claim 1 is asserted (Compl. ¶45).
• 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.
  • Determining coordinates for a point on the selected object.
  • “Transforming” those coordinates to a physical point (latitude/longitude) in a geographical map that is not being displayed.
  • Detecting the device’s current location in the geographical map.
  • Determining a navigational direction from the current location to the selected object’s physical point using the geographical map.
  • Showing the resulting navigational direction on the artistic map.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

• Issued: September 18, 2001

The Invention Explained

• Problem Addressed: The patent identifies shortcomings in early navigation systems, which either relied on limited, quickly outdated onboard map data or required a client device and a server to use identical, proprietary mapping software, creating inflexibility and high costs (’743 Patent, col. 1:10-38; col. 2:1-8).
• The Patented Solution: The invention describes a distributed system where a client device wirelessly connects to a remote server (’743 Patent, col. 3:26-28). The server performs the complex, real-time route calculation and sends the result to the client formatted as a “non-proprietary, natural language description.” The client then uses its own local mapping database, whatever it may be, to interpret this simple description and “reconstruct” the route for display (’743 Patent, Abstract; col. 3:35-48).
• Technical Importance: This architecture separates the powerful server-side route calculation from the client’s specific software, enabling interoperability between different systems and reducing the complexity and data requirements on the client device (’743 Patent, col. 3:1-12).

Key Claims at a Glance

• Independent claim 15 is asserted (Compl. ¶61).
• Essential elements of claim 15 include:
  • A navigation computer.
  • A wireless transceiver for connecting with a navigation server that calculates optimal routes formatted using a “non-proprietary, natural language description.”
  • A mapping database for “reconstructing” the optimal route from that description.
  • A display screen for showing the reconstructed route.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

• Issued: March 26, 2013

Technology Synopsis

• This patent addresses the perceived “boring” nature of conventional 2D maps by proposing a system to make them more realistic (’994 Patent, col. 1:40-44). The invention involves superimposing images of objects, such as buildings or signs, onto a map and dynamically altering their appearance (e.g., color effects) to reflect ambient conditions like the time of day or weather, thereby creating a more immersive visual experience (’994 Patent, Abstract).

Asserted Claims & Accused Features

• Asserted Claims: Independent claim 1 is asserted (Compl. ¶77).
• Accused Features: The complaint alleges that Defendant’s systems, including its weather features, infringe the ’994 Patent (Compl. ¶77).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities include the Mapbox Navigation SDK for in-vehicle and mobile applications, Mapbox MapGPT AI Assistant, Mapbox Autopilot Map system, Mapbox for EV solution, and Mapbox Matrix API systems and platforms (Compl. ¶39).

Functionality and Market Context

• The complaint alleges these products provide a suite of tools and services for developers to build navigation and mapping applications. A screenshot from the Defendant's website, included in the complaint, describes the "Mapbox rendering engine" as powering "stunning 3D map graphics that enhance the navigation experience with detailed landmarks, dynamic lighting, and lane-level road visuals" (Compl. ¶40). This functionality is central to the allegations of infringement, particularly regarding the patents on artistic and realistic maps.

IV. Analysis of Infringement Allegations

'628 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central issue will be the definition of an “artistic map.” The patent primarily describes stylized, non-realistic maps (e.g., a zoo map in FIG. 1) that are “non-linearly scaled” and feature “exaggeratedly shown” objects. The infringement analysis raises the question of whether Defendant’s “Immersive 3D” maps, which are marketed for their realism and dynamic lighting, fall within the scope of this term.
  • Technical Questions: The complaint alleges the accused products perform the claimed two-step process of translating coordinates from an artistic map to a separate geographical map for routing. A key technical question for the court will be whether Defendant’s system operates in this manner, or if it uses a single set of geographical data to render a 3D view directly, which may present a mismatch with the claimed method.

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'743 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The case may turn on the construction of “non-proprietary, natural language description.” The patent provides examples of simple text strings (e.g., “Interstate 8 90 Deg. 1.4 Miles”). Modern systems like Defendant’s typically use structured data formats such as JSON or Protocol Buffers for API communications. The court will need to determine if these structured, machine-readable formats fall within the scope of the claimed term.
  • Technical Questions: The complaint alleges a system architecture where the client reconstructs a route from a simple server description. It raises the question of whether Defendant’s SDKs and APIs function in this manner, or if the client and server engage in a more complex, continuous data exchange that differs from the specific client-reconstruction model claimed in the patent.

V. Key Claim Terms for Construction

• Term: "artistic map" (’628 Patent, Claim 1)

  • Context and Importance: This term is foundational to the ’628 patent. The infringement case depends on whether Defendant's "Immersive 3D" maps are properly classified as "artistic maps." Practitioners may focus on this term because its scope will determine whether the patent applies to modern, realistic 3D renderings or is limited to the stylized, cartoon-like examples shown in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states a purpose is to make navigation a "pleasant experience" and refers to maps that are "artistically made" (’628 Patent, col. 1:64-65). This could support an interpretation covering any visually enhanced, non-standard map.
    • Evidence for a Narrower Interpretation: The patent consistently defines an "artistic map" as being "non-linearly scaled" with "objects being exaggeratedly shown" (’628 Patent, Abstract, col. 2:29-31). The primary embodiment shown is a highly stylized zoo map (FIG. 1), which may support a narrower construction limited to non-photorealistic or distorted-scale maps.

• Term: "non-proprietary, natural language description" (’743 Patent, Claim 15)

  • Context and Importance: This term defines the data format for server-client communication, which is central to the patent's claim of being independent of the client's mapping software. The definition will be critical in determining whether modern API data structures infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue "non-proprietary" means any format not tied to a single vendor's specific database, and "natural language" could refer to the human-readable text labels (e.g., "Main Street") contained within a structured data file like JSON.
    • Evidence for a Narrower Interpretation: The patent’s only specific example is a simple plain-text string, such as "Interstate 8 90 Deg. 1.4 Miles" (’743 Patent, FIG. 5). This could support a narrow construction limited to unstructured, human-readable text, potentially excluding modern, heavily structured API formats.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for all patents. The allegations are based on Defendant providing its SDKs and platforms with instructions and advertisements that allegedly encourage and guide developers and end-users to use the accused products in an infringing manner (Compl. ¶¶51-53, 67-69, 83-85).
• Willful Infringement: The complaint alleges willful infringement for all patents based on Defendant’s alleged knowledge of the patents from the date of service of the complaint (Compl. ¶¶49, 58, 81). It further alleges willful blindness, stating on information and belief that Defendant has a practice of not reviewing the patent rights of others prior to launching products (Compl. ¶¶54, 70, 86).

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

• A core issue will be one of definitional scope: can the term "artistic map" from the ’628 patent, exemplified by a stylized zoo map with “exaggeratedly shown” objects, be construed to cover the photorealistic, dynamically lit “Immersive 3D” renderings of the accused products?
• A second key issue will be one of technical interpretation: do the structured data formats (e.g., JSON) used by modern APIs, such as those in the accused systems, constitute the “non-proprietary, natural language description” claimed in the ’743 patent, which is described in the specification as simple text strings?
• A threshold question for the third count of the complaint will be one of patent viability: what is the legal effect of asserting infringement of Claim 1 of the ’994 Patent when a reexamination certificate, issued after the complaint was filed, confirms that this claim has been canceled?