DCT
2:25-cv-00492
Modena Navigation LLC v. Toyota Motor Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modena Navigation LLC (Texas)
- Defendant: Toyota Motor Corporation (Japan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:25-cv-00492, E.D. Tex., 05/06/2025
- Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation not resident in the United States, and thus may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle infotainment and navigation systems infringe four patents related to user interface and experience, including automatic display mode switching, dynamic map adjustment, destination arrival displays, and the display of location-based activity information.
- Technical Context: The technology at issue involves in-vehicle navigation and infotainment systems, which are integral components of the modern automotive market.
- Key Procedural History: The complaint notes that the technologies described in the patents-in-suit were developed at MiTAC International Corp. No other procedural history, such as prior litigation or administrative proceedings involving these patents, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-18 | ’881 Patent Priority Date |
| 2006-10-13 | ’124 Patent Priority Date |
| 2008-04-14 | ’461 Patent Priority Date |
| 2008-06-10 | ’881 Patent Issue Date |
| 2009-10-16 | ’286 Patent Priority Date |
| 2011-06-21 | ’124 Patent Issue Date |
| 2012-03-06 | ’461 Patent Issue Date |
| 2013-04-16 | ’286 Patent Issue Date |
| 2025-01-01 | Exemplary Accused Product Year (2025 Toyota RAV4) |
| 2025-05-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,385,881 - "Display Mode Control Method for an Electronic Device", issued June 10, 2008
The Invention Explained
- Problem Addressed: The patent’s background section describes the inconvenience and potential distraction for a vehicle driver caused by manually switching a device’s display between daytime and nighttime modes ('881 Patent, col. 1:33-38). A bright background at night can be a "source of distraction and discomfort to the viewer's eye" ('881 Patent, col. 1:28-30).
- The Patented Solution: The invention is a method for an electronic device to automatically switch its display mode based on the time of day. A microprocessor, using a clock circuit, determines the time and operates the display in a "nighttime display mode" (e.g., light text on a dark background) during a predetermined nighttime period and a "daytime display mode" (e.g., dark text on a light background) otherwise ('881 Patent, Abstract; col. 2:17-30).
- Technical Importance: Automating the display mode transition based on time aimed to improve driver safety and convenience by reducing screen glare and manual interactions with the device during nighttime driving ('881 Patent, col. 2:39-42).
Key Claims at a Glance
- The complaint asserts independent method Claim 1 (Compl. ¶20).
- Essential elements of Claim 1 include:
- enabling the electronic device to determine the time of day;
- enabling the device to operate in a nighttime display mode when the time of day corresponds to nighttime, and a daytime display mode otherwise;
- wherein navigational map information is shown in a light shade against a dark background in nighttime mode, and a dark shade against a light background in daytime mode.
- The complaint reserves the right to assert additional claims (Compl. ¶19).
U.S. Patent No. 7,966,124 - "Navigation Device and its Navigation Method for Displaying Navigation Information According to Travelling Direction", issued June 21, 2011
The Invention Explained
- Problem Addressed: Conventional navigation systems often center the vehicle's current position on the display. This results in up to half the screen being used to show the route already traveled, which is "not required in navigation" and limits the view of the route ahead, potentially compromising driver safety ('124 Patent, col. 2:20-39).
- The Patented Solution: The invention describes a navigation device that dynamically adjusts the display of the map based on the vehicle’s direction of travel. It adjusts a "first displaying parameter" (the icon's position on the screen) and a "second displaying parameter" (the displayed map section and scale) to bias the view in the direction of travel, thereby showing more of the upcoming route ('124 Patent, Abstract; col. 6:45-51). For example, when traveling north, the current position icon is moved toward the bottom of the display frame ('124 Patent, Fig. 4A).
- Technical Importance: This approach seeks to maximize the presentation of relevant, forward-looking route information within the limited screen real estate of a navigation device, improving the driver's situational awareness ('124 Patent, col. 2:45-50).
Key Claims at a Glance
- The complaint asserts independent device Claim 7 (Compl. ¶34).
- Essential elements of Claim 7 include:
- a memory for storing a navigation map;
- a signal receiving unit;
- a central processing unit that retrieves the current position and dynamically adjusts a first displaying parameter (for the current position) and a second displaying parameter (for the navigation map) when a direction parameter changes;
- a displaying unit to show the map and position according to these parameters.
- The complaint reserves the right to assert additional claims (Compl. ¶33).
U.S. Patent No. 8,131,461 - "Navigation Methods and Systems", issued March 6, 2012
- Technology Synopsis: The patent addresses situations where a navigation system terminates its process upon arrival, leaving the user near their destination but potentially unable to recognize the exact location, particularly in areas with uniform streets ('461 Patent, col. 1:26-34). The invention proposes that when a specific "navigation condition" occurs (e.g., termination of the navigation process), the system displays a "position schematic diagram" showing the destination, the user's current position, and nearby landmarks to assist with final recognition ('461 Patent, Abstract).
- Asserted Claims: The complaint asserts at least independent system Claim 7 (Compl. ¶47).
- Accused Features: The accused functionality is the infotainment system's behavior upon reaching a set destination, where it allegedly "indicates on the infotainment display that the destination has been reached and the navigation is terminated," which Plaintiff contends is a "navigation condition" that triggers an infringing display (Compl. ¶48).
U.S. Patent No. 8,423,286 - "Method for Displaying Activity Information on a Navigation device and Related Navigation Device", issued April 16, 2013
- Technology Synopsis: The patent seeks to improve upon conventional methods of finding points of interest, where users must browse text-based lists that are not intuitive ('286 Patent, col. 1:44-53). The invention is a method and device that receives "activity information" with location data and displays corresponding "activity icons" directly on the navigation map at their geographic locations, potentially filtered by a user's preferences ('286 Patent, Abstract).
- Asserted Claims: The complaint asserts at least independent device Claim 13 (Compl. ¶59).
- Accused Features: The complaint accuses Toyota's systems, such as the bZ4X in conjunction with the Toyota App, of infringing by providing "real-time information about certain locations, such as charging stations," and displaying them on the navigation map (Compl. ¶¶60-61). A screenshot from the Toyota App shows a list of nearby charging stations (Compl. p. 22).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as Defendant’s "Toyota Entune and Toyota Audio Multimedia, and Defendant's navigation systems," as well as the "Toyota App," included in a wide range of Toyota and Lexus vehicles (Compl. ¶¶12, 15). The Toyota RAV4 and Toyota bZ4X are used as exemplary products for the infringement allegations (Compl. ¶¶19, 58).
Functionality and Market Context
- The accused instrumentalities are in-vehicle infotainment systems that provide navigation, media, and connectivity functions. The complaint alleges these systems incorporate features such as automatic display brightness adjustment, turn-by-turn navigation, destination arrival notifications, and the ability to display points of interest (POIs) like charging stations on a map (Compl. ¶¶21, 36, 48, 61). The complaint provides a screenshot from a 2025 Toyota RAV4 showing a "Display" settings menu with an "Automatic" mode for brightness and contrast (Compl. p. 7). Another visual shows various configurable "Notification settings" for navigation, such as "Turn by turn" voice guidance (Compl. p. 13).
IV. Analysis of Infringement Allegations
’881 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) enabling the electronic device to determine the time of day | The Toyota RAV4 performs the step of enabling the electronic device to determine the time of day. | ¶21 | col. 3:5-6 |
| b) enabling the electronic device to operate the display panel in a nighttime display mode when the time of day corresponds to nighttime, and in a daytime display mode when the time of day is otherwise | The Toyota RAV4 performs the step of enabling the electronic device to operate the display panel in a nighttime display mode when the time of day corresponds to nighttime, and in a daytime display mode when the time of day is otherwise. | ¶21 | col. 3:19-21 |
| wherein the navigational map information is shown on the display panel in a light shade against a dark background when the display panel is operated in the nighttime display mode... | ...wherein the navigational map information is shown on the display panel in a light shade against a dark background when the display panel is operated in the nighttime display mode, and in a dark shade against a light background when the display panel is operated in the daytime display mode. | ¶21 | col. 2:30-42 |
Identified Points of Contention
- Technical Question: Claim 1 recites a method based on determining the "time of day." The complaint includes a screenshot of the accused system's display settings, where the "Automatic" mode is described as being "Based on time and ambient light" (Compl. p. 7). This raises a factual question for the court: does a system that considers an additional input (ambient light) infringe a claim that recites only a time-based condition? The resolution may depend on whether the time-based trigger is independent or can be overridden by the ambient light sensor.
’124 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a memory for storing a navigation map | The Toyota RAV4 comprises a memory for storing a navigation map (e.g., internal flash memory, SSD in the infotainment head unit, and/or SD card or other removeable media). | ¶35 | col. 4:13-15 |
| a signal receiving unit for receiving at least one positioning signals from a position system via an antenna | The Toyota RAV4 comprises a signal receiving unit for receiving at least one positioning signals from a position system via an antenna (e.g., GPS antenna). | ¶35 | col. 4:16-20 |
| a central processing unit... wherein the central processing unit dynamically adjusts a first displaying parameter of the current position and a second displaying parameter of the navigation map... when a direction parameter of the current position is changed | ...wherein the central processing unit dynamically adjusts a first displaying parameter of the current position and a second displaying parameter of the navigation map, and fetches a corresponding displayed section of the traveling direction of navigation map... when a direction parameter of the current position is changed. | ¶35 | col. 5:15-20 |
| a displaying unit for displaying the current position and the navigation map in a navigation information frame according to the first displaying parameter and the second displaying parameter | The Toyota RAV4 comprises a displaying unit for displaying the current position and the navigation map in a navigation information frame according to the first displaying parameter and the second displaying parameter (e.g., the infotainment display). | ¶35 | col. 4:31-39 |
Identified Points of Contention
- Scope Question: The central dispute for the ’124 Patent may be the scope of "dynamically adjusts a first displaying parameter of the current position." The complaint alleges this functionality but does not provide visual evidence (such as before-and-after screenshots) of the specific off-center shifting described in the patent's preferred embodiments. The question for the court is whether this claim language reads on conventional "heading-up" map views, or if the patent's disclosure limits the claim to the specific technique of moving the position icon to maximize the forward view.
V. Key Claim Terms for Construction
For the ’881 Patent
- The Term: "when the time of day corresponds to nighttime" (from Claim 1)
- Context and Importance: This term's construction is central because the accused product allegedly uses both "time and ambient light" to trigger the display mode change (Compl. p. 7). Practitioners may focus on this term to determine if a multi-factor trigger system falls within the scope of a claim reciting a single condition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the claim only requires the condition to be met when nighttime occurs, and does not explicitly exclude other, concurrent conditions. The patent's objective is to automate the switch to solve a nighttime glare problem, a purpose that is still served even if an ambient light sensor is also used ('881 Patent, col. 1:26-38).
- Evidence for a Narrower Interpretation: The specification's only described embodiment relies on a clock circuit and a "predetermined time period" defined by start and end times ('881 Patent, col. 3:5-13; col. 4:10-12). A party could argue this context limits the claim to a purely time-based determination, excluding systems where an ambient light sensor could prevent the switch from occurring during the "predetermined time period."
For the ’124 Patent
- The Term: "dynamically adjusts a first displaying parameter of the current position" (from Claim 7)
- Context and Importance: The infringement case for this patent depends on whether the accused system performs this specific action. The term's definition will distinguish between general map reorientation and the specific off-center shifting that appears to be the core of the invention.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general. A party might argue that any non-static display of the current position, such as rotating the map in a "heading-up" view, constitutes a "dynamic adjustment" of its display parameter.
- Evidence for a Narrower Interpretation: The specification and figures consistently illustrate this adjustment as physically moving the current position icon away from the center to create an asymmetric view that shows more of the road ahead ('124 Patent, Figs. 4A, 4B; col. 7:1-10, col. 7:46-49). A party could argue that this disclosure limits the term to this specific off-center shifting functionality.
VI. Other Allegations
Indirect Infringement
- The complaint alleges induced infringement for all asserted patents. The factual basis for inducement is Defendant's alleged act of supplying customers with the accused vehicles along with "Owner's Manuals," product literature, and other instructional materials that purportedly instruct users on how to operate the infringing features in an intended manner (Compl. ¶¶ 26, 39, 51, 64).
Willful Infringement
- Willfulness is alleged for all asserted patents based on both pre- and post-suit conduct. The complaint alleges post-suit knowledge as of the filing date. It further alleges pre-suit willfulness through a theory of willful blindness, asserting that Defendant "adopted a policy of not reviewing the patents of others" despite a high probability it would discover its infringing activities (Compl. ¶¶ 25, 38, 50, 63).
VII. Analyst’s Conclusion: Key Questions for the Case
- A question of technical operation: For the ’881 Patent, does the accused system's "Automatic" display mode, which is "Based on time and ambient light," meet the claim limitation requiring a switch "when the time of day corresponds to nighttime"? The outcome will likely depend on evidence showing whether the ambient light sensor can override or prevent the time-based switch.
- A question of claim scope: For the ’124 Patent, can the term "dynamically adjusts a first displaying parameter of the current position" be construed to cover conventional "heading-up" map views, or is its meaning limited by the specification to the specific technique of shifting the position icon off-center to maximize the forward view?
- A question of pleading sufficiency: The case will test whether allegations of a corporate "policy of not reviewing the patents of others" are sufficient, without more specific factual averments of knowledge, to sustain a claim for willful infringement under a theory of willful blindness.