DCT
2:25-cv-00494
Modena Navigation LLC v. Honda Motor Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modena Navigation LLC (Texas)
- Defendant: Honda Motor Co., Ltd. (Japan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:25-cv-00494, E.D. Tex., 05/06/2025
- Venue Allegations: Venue is alleged to be proper because 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 in-vehicle infotainment and navigation systems, as well as the related HondaLink application, infringe four patents related to map display modes, dynamic route visualization, and the presentation of location-based activity information.
- Technical Context: The lawsuit concerns core features of modern automotive navigation systems designed to improve driver safety and convenience, such as automatic day/night display switching and the integration of real-time, location-specific data onto a map display.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-18 | Priority Date for U.S. Patent No. 7,385,881 |
| 2006-10-13 | Priority Date for U.S. Patent No. 7,966,124 |
| 2008-04-14 | Priority Date for U.S. Patent No. 8,131,461 |
| 2008-06-10 | U.S. Patent No. 7,385,881 Issues |
| 2009-10-16 | Priority Date for U.S. Patent No. 8,423,286 |
| 2011-06-21 | U.S. Patent No. 7,966,124 Issues |
| 2012-03-06 | U.S. Patent No. 8,131,461 Issues |
| 2013-04-16 | U.S. Patent No. 8,423,286 Issues |
| 2025-05-06 | Complaint Filed |
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 identifies the manual switching of a navigation device’s display between daytime and nighttime modes as inconvenient and a potential source of distraction for a vehicle driver (’881 Patent, col. 1:32-38).
- The Patented Solution: The invention proposes an automated method where an electronic device determines the time of day and automatically switches the display panel. It specifies a "nighttime display mode" with light-colored map information on a dark background to reduce glare, and a "daytime display mode" with dark information on a light background for visibility (’881 Patent, Abstract; col. 2:32-41).
- Technical Importance: This automation aims to enhance driver safety by minimizing glare and distraction, a persistent challenge in automotive human-machine interface design (’881 Patent, col. 1:26-31).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶20).
- Essential elements of claim 1 include:
- A display mode control method for an electronic device with a display panel for showing navigational map information.
- Enabling the electronic device to determine the time of day.
- Enabling the device to operate in a "nighttime display mode" (light shade on dark background) when the time corresponds to nighttime, and a "daytime display mode" (dark shade on light background) otherwise.
- The complaint does not explicitly reserve the right to assert dependent claims.
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: Traditional navigation systems display the current position at the center of the screen, which limits the forward view of the route ahead. This can prevent a driver from seeing upcoming turns or points of interest in advance, potentially compromising driving safety (’124 Patent, col. 2:20-39).
- The Patented Solution: The invention describes a system and method that dynamically adjusts how the map is displayed based on the vehicle’s direction of travel. Specifically, it adjusts a "first displaying parameter" for the current position's location on the screen and a "second displaying parameter" for the map's scale, effectively shifting the map to show more of the path ahead (’124 Patent, Abstract; col. 5:49-65).
- Technical Importance: By providing a more predictive forward-looking view, the technology allows drivers to better anticipate route changes, improving situational awareness and reducing the cognitive load associated with navigation (’124 Patent, col. 2:45-50).
Key Claims at a Glance
- The complaint asserts independent claim 7 (Compl. ¶34).
- Essential elements of claim 7 (a system claim) include:
- A memory for storing a navigation map.
- A signal receiving unit (e.g., GPS).
- A central processing unit that retrieves the current position.
- 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 changes.
- A displaying unit that shows the map and position according to these adjusted parameters.
- The complaint does not explicitly reserve the right to assert dependent claims.
Multi-Patent Capsule: U.S. Patent No. 8,131,461
- Patent Identification: U.S. Patent No. 8,131,461, "Navigation Methods and Systems," Issued March 6, 2012.
- Technology Synopsis: The patent addresses the problem of users being unable to recognize their exact destination upon arrival, particularly in areas with uniform or confusingly arranged streets (’461 Patent, col. 2:26-34). The invention proposes that when a "navigation condition" occurs (such as arrival at the destination), the system displays a "position schematic diagram" that includes the destination, the user's current position, and nearby landmarks to aid recognition (’461 Patent, col. 2:46-55).
- Asserted Claims: Independent claim 7 (Compl. ¶47).
- Accused Features: The complaint alleges that Honda's systems, upon reaching a set destination, indicate on the display that the destination has been reached and terminate navigation, which allegedly constitutes the claimed act of displaying a position schematic diagram upon termination of the navigation process (Compl. ¶48).
Multi-Patent Capsule: U.S. Patent No. 8,423,286
- Patent Identification: 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 systems where users must query and review location-based information (e.g., points of interest, promotions) from a text-based list, which is described as inconvenient and distracting for a driver (’286 Patent, col. 1:43-54). The solution involves receiving "activity information" with latitude and longitude data and displaying corresponding icons directly on the navigation map at their specific locations, potentially including reminder messages when the user is nearby (’286 Patent, Abstract).
- Asserted Claims: Independent claim 13 (Compl. ¶59).
- Accused Features: The Honda Prologue, operating with the HondaLink App, is accused of infringing by providing real-time information for locations such as charging stations, displaying them as icons on the map, and allowing user interaction with those icons (Compl. ¶60-61).
III. The Accused Instrumentality
- Product Identification: The complaint targets a broad set of "Accused Vehicles" and "Accused Products," including Honda and Acura vehicles equipped with the "Honda Infotainment System," "Acura True Touchpad Interface," and the "HondaLink App" (Compl. ¶12, 15). The Honda CR-V and Honda Prologue are identified as exemplary products for the infringement allegations (Compl. ¶19, 59).
- Functionality and Market Context: The accused instrumentalities are integrated in-vehicle navigation and infotainment systems. The complaint alleges these systems perform several key functions: automatically switching the display brightness and color scheme based on ambient conditions (Compl. ¶21-22); providing specialized map views for upcoming intersections (Compl. ¶36, p.12); displaying a notification upon arrival at a destination (Compl. ¶48); and displaying icons for points of interest like EV charging stations directly on the map via a connected application (Compl. ¶61). A screenshot from a Honda promotional video shows the HondaLink App displaying available EV charging stations on a map (Compl. p.20). The complaint asserts that Honda is one of the largest automotive manufacturers in the United States, suggesting the widespread use of the accused systems (Compl. ¶2).
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 Honda CR-V performs the step of enabling the electronic device to determine the time of day. | ¶21 | col. 3:5-10 |
| 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 Honda CR-V automatically adjusts its display brightness based on the time of day, switching modes. A user manual screenshot shows the display changes to "Night display mode" when headlights are turned on. | ¶21-22, p.7 | col. 3:11-28 |
| 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. | The Honda CR-V operates its display with a light shade on a dark background in nighttime mode and a dark shade on a light background in daytime mode. | ¶21 | col. 2:32-41 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a system that switches display modes based on a "sunlight sensor" and "Headlights (Auto/On/Off)" status, as shown in the provided user manual evidence (Compl. p.7), meets the claim limitation of "enabl[ing] the electronic device to determine the time of day." The patent specification describes implementing this step with a "clock circuit" and a "predetermined time period" defined by start and end times (’881 Patent, col. 2:59-62; col. 3:11-14), raising the question of whether sensing ambient light is equivalent to determining the time of day as contemplated by the patent.
’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 Honda CR-V comprises memory such as internal flash memory, SSD, or SD card for storing a navigation map. | ¶35 | col. 4:13-15 |
| a signal receiving unit for receiving at least one positioning signals from a position system via an antenna; | The Honda CR-V comprises a GPS antenna to receive positioning signals. | ¶35 | col. 4:16-20 |
| a central processing unit... for retrieving the current position according to the received positioning signals; | The Honda CR-V comprises an infotainment and/or telematic CPU that retrieves the current position. | ¶35 | col. 4:21-25 |
| 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; | The CPU dynamically adjusts these parameters. The "Intersection View Screen" is provided as an example where the system displays a view of an upcoming intersection. | ¶35, p.12 | col. 5:15-20 |
| a displaying unit for displaying the current position and the navigation map... according to the first displaying parameter and the second displaying parameter. | The infotainment display shows the current position and map according to the adjusted parameters. | ¶35 | col. 4:31-34 |
- Identified Points of Contention:
- Technical Questions: The complaint alleges that the CPU "dynamically adjusts" the two specified display parameters but does not detail the mechanism. The provided visual evidence of an "Intersection View Screen" (Compl. p.12) shows a modified view, but it raises the evidentiary question of whether this feature actually implements the specific two-parameter adjustment method taught by the patent (which involves shifting the current position icon off-center to maximize the forward view) or if it is a different function, such as a simple zoom-in on an upcoming turn.
V. Key Claim Terms for Construction
For the ’881 Patent:
- The Term: "determine the time of day"
- Context and Importance: The infringement reading for claim 1 hinges on this term. The complaint alleges infringement based on the accused system's use of a sunlight sensor and headlight status to trigger display mode changes (Compl. p.7). Whether this functionality falls within the scope of "determin[ing] the time of day" will be a critical issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the overall purpose of the invention is to automate the switch between day and night modes for driver convenience and safety (’881 Patent, col. 1:39-45). Any automated means of distinguishing day from night, including sensing ambient light levels, could be argued to achieve this purpose and thus fall under a functional interpretation of the term.
- Evidence for a Narrower Interpretation: A party could argue that the specification provides a specific structure for this function, teaching the use of a "clock circuit 16" to "generate the time of day" and comparing it to a "predetermined time period" set by the user (’881 Patent, col. 2:59-62; Fig. 2). This may support a narrower construction limited to methods that rely on a clock rather than an ambient light sensor.
For the ’124 Patent:
- The Term: "dynamically adjusts a first displaying parameter of the current position and a second displaying parameter of the navigation map"
- Context and Importance: This term defines the core technical action of the invention. The infringement case depends on proving that the accused Honda systems perform this specific, two-part adjustment. Practitioners may focus on this term because the complaint's allegations are conclusory and rely on generalized features like an "Intersection View Screen."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the term should be read broadly to cover any automatic adjustment to both the position icon and the map scale/view in response to travel direction, as this aligns with the patent's stated goal of providing more relevant route information (’124 Patent, col. 2:45-50).
- Evidence for a Narrower Interpretation: A party could point to specific embodiments and figures in the patent that illustrate a distinct methodology. Figures 4A and 4B, for example, show the current position icon (30) being moved significantly off-center to dedicate a larger portion of the screen (e.g., 65% or 80%) to the direction of travel (’124 Patent, col. 7:1-41). This could support a narrower construction requiring a non-centered position icon and an asymmetric map display, which may differ from a simple intersection zoom feature.
VI. Other Allegations
- Indirect Infringement: For all four patents, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The factual basis for inducement is Honda’s act of supplying the Accused Products to customers along with instructional materials, such as owner's manuals and "how-to" videos, that allegedly instruct end-users on how to operate the infringing features (e.g., Compl. ¶26, 39, 51, 64). The complaint includes screenshots of what appear to be owner's manuals to support this claim (Compl. p.9, p.17).
- Willful Infringement: Willfulness is alleged for all asserted patents. The complaint pleads two theories: (1) that Honda has knowledge of its infringement at least as of the filing of the complaint, and (2) that Honda has been "willfully blind" to its infringement since the issuance date of each patent by maintaining an alleged corporate policy of not reviewing the patents of others (e.g., Compl. ¶25, 38, 50, 63).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the phrase "determine the time of day" from the ’881 Patent, which the specification links to a clock circuit and set time periods, be construed broadly enough to read on the accused system's method of using a sunlight sensor and headlight status to switch display modes?
- A key evidentiary question will be one of functional equivalence: does the accused systems’ "Intersection View Screen" feature perform the specific, two-parameter adjustment of both the on-screen vehicle position and the map scale based on travel direction, as required by the ’124 Patent, or is there a fundamental mismatch in the technical operation?
- The case will also present a question of technological evolution: can the term "activity information" in the ’286 Patent, described in the context of dynamic events and time-limited promotions, be interpreted to cover the display of relatively static points of interest like EV charging stations, a now-common feature in navigation systems?