2:25-cv-00495
Modena Navigation LLC v. Nissan Motor Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modena Navigation LLC (Texas)
- Defendant: Nissan Motor Co., Ltd. (Japan)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:25-cv-00495, 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 infringe four patents related to user interface and display methods for navigation technology.
- Technical Context: The technologies at issue involve automated display adjustments, dynamic map views, and the presentation of point-of-interest information within automotive navigation systems.
- Key Procedural History: The complaint notes that the asserted patents were developed by inventors at MiTAC International Corp., suggesting the patents were acquired by the Plaintiff for purposes of assertion. No prior litigation or post-grant proceedings are 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 |
| 2013-01-01 | Alleged launch period for accused Nissan Rogue products begins |
| 2013-04-16 | ’286 Patent Issue Date |
| 2023-01-01 | Alleged launch period for accused Nissan ARIYA products begins |
| 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 identifies the inconvenience and potential for driver distraction caused by manually switching a navigation display between a daytime mode and a nighttime mode, noting that a bright screen at night can be a "source of distraction and discomfort" (’881 Patent, col. 1:28-39).
- The Patented Solution: The invention describes an automated method where an electronic device determines the time of day and switches the display mode accordingly. The system operates a display panel in a "nighttime display mode" (e.g., light text on a dark background) when the time corresponds to nighttime and a "daytime display mode" (e.g., dark text on a light background) at other times, using components like a clock circuit and microprocessor (’881 Patent, Abstract; col. 2:59-62).
- Technical Importance: By automating the adjustment of screen brightness and contrast based on ambient light conditions associated with the time of day, the invention sought to improve driver comfort and safety (’881 Patent, col. 1:28-39).
Key Claims at a Glance
- The complaint asserts at least independent method claim 1 (Compl. ¶20).
- Claim 1 requires:
- A method for a device with a display for navigational map information, comprising steps of:
- a) enabling the device to determine the time of day;
- b) enabling the device to operate in a nighttime display mode when the time corresponds to nighttime, and a daytime display mode otherwise;
- wherein the 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 other 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: The patent states that conventional navigation systems, which typically place the current position icon at the center of the screen, are inefficient. This configuration results in half the display showing the area a driver has already passed, thereby limiting the view of the route ahead and potentially causing a user to miss turns (’124 Patent, col. 2:11-39).
- The Patented Solution: The invention proposes a system that dynamically adjusts the position of the current location icon on the screen. The icon is shifted away from the center in the direction opposite to travel, which allocates a larger portion of the screen to display the upcoming route (’124 Patent, Abstract; col. 2:61-65). For example, as illustrated in Figure 4A, when traveling north, the current position icon is shifted toward the bottom of the display (’124 Patent, col. 7:1-9).
- Technical Importance: This "look-ahead" display method enhances navigational utility by providing the driver with more advance information about the road ahead, which could improve driving safety (’124 Patent, col. 2:33-39).
Key Claims at a Glance
- The complaint asserts at least independent device claim 7 (Compl. ¶34).
- Claim 7 requires:
- A memory for storing a map;
- A signal receiving unit (e.g., GPS);
- A central processing unit for retrieving the current position;
- wherein the CPU dynamically adjusts a "first displaying parameter" (current position) and a "second displaying parameter" (map view) when the "direction parameter" changes;
- A displaying unit to show the resulting map and position.
- The complaint reserves the right to assert other claims (Compl. ¶33).
U.S. Patent No. 8,131,461 - "Navigation Methods and Systems," Issued March 6, 2012 (Multi-Patent Capsule)
Technology Synopsis
The patent addresses the issue of drivers arriving near a destination but being unable to recognize the exact location, particularly on uniformly arranged streets where navigation systems may terminate prematurely (’461 Patent, col. 1:26-34). The solution is to display a "position schematic diagram" upon the occurrence of a "navigation condition" (e.g., arrival), which shows the destination, the user's current position, and nearby landmarks to aid in final recognition (’461 Patent, Abstract).
Asserted Claims
At least independent system claim 7 (Compl. ¶47).
Accused Features
The complaint alleges that when an accused Nissan vehicle reaches a set destination, its navigation system indicates on the display that the destination has been reached, and this functionality is alleged to be the claimed display of a "position schematic diagram" upon termination of the navigation process (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 (Multi-Patent Capsule)
Technology Synopsis
The patent aims to improve upon systems that display points of interest as text-based lists, which the patent describes as not "convenient enough" and less intuitive (’286 Patent, col. 1:47-52). The invention proposes receiving "activity information" with geographic coordinates and displaying corresponding "activity icons" directly on the navigation map, and also providing a reminder message when the device is within a predetermined distance of an activity location (’286 Patent, Abstract).
Asserted Claims
At least independent device claim 13 (Compl. ¶59).
Accused Features
The Nissan ARIYA's navigation system is accused of infringing by receiving real-time information (e.g., for EV charging stations) and displaying icons for those locations on the map (Compl. ¶¶ 60-61). The complaint provides screenshots showing a list of charging stations and their placement as icons on a map view (Compl. p. 19).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are in-vehicle infotainment and navigation systems, including "NissanConnect" and "NissanConnect Services," which are installed in a wide range of Nissan vehicles (the "Accused Vehicles") (Compl. ¶¶ 12-15). The Nissan Rogue is cited as an exemplary product for the '881, '124, and '461 patents, while the Nissan ARIYA is cited as exemplary for the '286 patent (Compl. ¶¶ 19, 33, 46, 58).
Functionality and Market Context
The complaint alleges these systems provide core navigation functions. Specific accused functionalities include automatically adjusting display brightness between day and night modes (Compl. ¶22), dynamically adjusting the map view based on travel direction (Compl. ¶35), displaying a confirmation screen upon arrival at a destination (Compl. ¶48), and displaying icons for points of interest such as EV charging stations on the map (Compl. ¶¶ 60-61). A screenshot from a Nissan Rogue shows a display settings menu with a "Day/Night" option, corroborating the presence of this feature (Compl. p. 6). Another screenshot from a Nissan ARIYA shows a map with icons for charging stations, one of the accused features for the '286 Patent (Compl. p. 19). These systems are central components of the user experience in modern Nissan vehicles.
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 accused Nissan Rogue system performs the step of enabling the electronic device to determine the time of day, as shown by the clock on its display. | ¶21, p. 6 | col. 2:59-62 |
| 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 accused system's display brightness can automatically adjust based on the time of day, operating in a nighttime mode when the time corresponds to nighttime and a daytime mode otherwise. | ¶21-22 | col. 3:6-14 |
| 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 complaint alleges the accused system operates 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
- Technical Questions: Claim 1 requires the mode to switch when the "time of day corresponds to nighttime." The complaint alleges the system adjusts "based on the time of day" (Compl. ¶22). A question for the court will be what method the accused system uses to determine "nighttime" (e.g., a fixed clock schedule, GPS-based sunset/sunrise data, or an ambient light sensor) and whether that method falls within the scope of the claim.
- Scope Questions: The claim is a method claim. The complaint alleges that Nissan "performs" the method "through the use and provision" of its vehicles (Compl. ¶21). This raises the question of whether Nissan's own actions (e.g., testing, demonstrations) constitute direct infringement, or if the infringement theory relies primarily on indirect infringement based on the actions of end-users.
’124 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a central processing unit...for retrieving the current position according to the received positioning signals; | The accused Nissan Rogue system includes a CPU (e.g., infotainment and/or telematic CPU) that retrieves the vehicle's current position from GPS signals. | ¶35 | col. 4:22-26 |
| 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 complaint alleges the CPU dynamically adjusts the display of the current position and the navigation map when the vehicle's direction of travel changes. | ¶35 | col. 2:61-65 |
| 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 accused system includes an infotainment display that shows the current position and navigation map. | ¶35 | col. 4:31-34 |
Identified Points of Contention
- Technical Questions: The core of claim 7 is the dynamic adjustment of the map to provide a "look-ahead" view. The complaint asserts this functionality in a conclusory manner (Compl. ¶35). The visual evidence provided for this patent is a list of features from an owner's manual which does not depict the claimed map-shifting behavior (Compl. p. 11). A central factual question will be whether the accused systems actually perform the specific off-center map adjustment described in the patent's specification.
- Scope Questions: The claim recites adjusting a "first displaying parameter" (position) and a "second displaying parameter" (map). The patent specification links these to specific technical implementations, such as shifting the icon's pixel coordinates based on a "reverse relation" to the travel direction (’124 Patent, col. 5:53-64). It remains a question whether the accused system's display adjustments, if any, fall within the scope of these claim terms as they would be construed by a court.
V. Key Claim Terms for Construction
For the ’881 Patent
- The Term: "time of day corresponds to nighttime" (Claim 1)
- Context and Importance: This phrase is the trigger for the claimed automated function. Its definition is critical because it determines whether various methods of detecting night (e.g., fixed time, GPS sunset data, ambient light sensor) infringe. Practitioners may focus on this term because its construction could either limit the claim to a simple clock function or broaden it to cover more advanced, sensor-based systems.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general. The specification refers to a "predetermined time period correspond[ing] to nighttime," which could be argued to encompass any technically reasonable definition of night (’881 Patent, col. 3:10-12).
- Evidence for a Narrower Interpretation: The only embodiment disclosed shows a graphical user interface with user-configurable "start and end times" (e.g., 7:00 PM to 6:00 AM) (’881 Patent, col. 3:12-14, Fig. 3). A party could argue the claim should be limited to this time-based implementation.
For the ’124 Patent
- The Term: "dynamically adjusts a first displaying parameter of the current position" (Claim 7)
- Context and Importance: This term captures the core inventive concept of shifting the map view. Its construction will determine whether any on-screen repositioning of the user icon infringes, or only the specific "look-ahead" shifting taught in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "dynamically adjusts" itself does not inherently limit the type of adjustment, potentially covering any non-static change to the icon's position in response to vehicle movement.
- Evidence for a Narrower Interpretation: The specification describes a specific rule for this adjustment: a "reverse relation" where the icon is shifted to the screen's trailing quadrant to maximize the view of the leading quadrant (e.g., moving north shifts the icon south on the screen) (’124 Patent, col. 5:53-64). An argument could be made that the claims should be limited to an adjustment that follows this principle.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement for all asserted patents. The factual basis for inducement is Nissan's alleged provision of "instructions on how to operate the infringing technology" to customers and end-users through owner's manuals, websites, product literature, and other publications (e.g., Compl. ¶¶ 26, 39, 51, 64).
Willful Infringement
The complaint alleges willful infringement, asserting that Nissan had knowledge of its infringement at least from the filing date of the complaint. It further pleads pre-suit willfulness under a theory of willful blindness, alleging that Nissan "adopted a policy of not reviewing the patents of others" with the "subjective belief that there was a high probability that Defendant would learn of its infringing activities" (e.g., Compl. ¶¶ 25, 38, 50, 63).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of technical proof: The complaint makes several conclusory allegations about how the accused systems function (e.g., the dynamic map-shifting of the '124 patent). Can the Plaintiff produce specific technical evidence from discovery to demonstrate that the accused Nissan systems operate in the precise manner required by the patent claims, or will a mismatch in technical operation be revealed?
- A second core issue will be one of definitional scope: The infringement analysis for patents like the '881 patent (defining "nighttime") and the '461 patent (defining a "position schematic diagram") will depend heavily on claim construction. Will the court adopt a broader interpretation of these terms, or will it limit them to the specific embodiments disclosed in the patents, potentially placing the accused features outside the claims' scope?
- Finally, a central question for damages will be one of scienter: The complaint's pre-suit willfulness theory rests on an alleged "policy of not reviewing patents." Can the Plaintiff prove that Nissan was willfully blind to the asserted patents specifically, or will any potential finding of willfulness be limited to Nissan's conduct after receiving notice of the lawsuit?