DCT
2:25-cv-00496
Modena Navigation LLC v. Hyundai Motor Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modena Navigation LLC (Texas)
- Defendant: Hyundai Motor Company and Kia Motors Corporation (Republic of Korea)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP
- Case Identification: 2:25-cv-00496, E.D. Tex., 05/06/2025
- Venue Allegations: Venue is asserted in any U.S. judicial district on the basis that Defendants are not residents of the United States.
- Core Dispute: Plaintiff alleges that Defendants’ in-vehicle infotainment and navigation systems infringe four patents related to user interface and navigation functionalities, including automatic display mode switching, dynamic map orientation, end-of-route displays, and the presentation of point-of-interest information.
- Technical Context: The lawsuit concerns the software and hardware features of modern automotive navigation systems, a highly competitive and technologically dense area of the automotive market.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history concerning the patents-in-suit. It does, however, allege willful infringement based on a theory of willful blindness dating back to the issuance of each patent.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-18 | U.S. Patent No. 7,385,881 Priority Date |
| 2006-10-13 | U.S. Patent No. 7,966,124 Priority Date |
| 2008-04-14 | U.S. Patent No. 8,131,461 Priority Date |
| 2008-06-10 | U.S. Patent No. 7,385,881 Issued |
| 2009-10-16 | U.S. Patent No. 8,423,286 Priority Date |
| 2011-06-21 | U.S. Patent No. 7,966,124 Issued |
| 2012-03-06 | U.S. Patent No. 8,131,461 Issued |
| 2013-04-16 | U.S. Patent No. 8,423,286 Issued |
| 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 inconvenience and potential distraction caused by manually switching a vehicle navigation display between a daytime mode and a nighttime mode (’881 Patent, col. 1:35-38).
- The Patented Solution: The invention provides an automatic method for controlling the display mode. The system determines the time of day and switches the display to a "nighttime display mode," which shows information in a light shade against a dark background, or a "daytime display mode," which shows information in a dark shade against a light background, without user intervention ('881 Patent, Abstract; col. 2:26-41).
- Technical Importance: This automation aimed to reduce driver distraction and improve visual ergonomics in vehicles by matching the display's brightness and contrast to ambient lighting conditions.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶21).
- Claim 1 requires a method with the following steps:
- enabling an electronic device to determine the time of day;
- enabling the device to operate the display panel in a nighttime mode when the time of day corresponds to nighttime, and a daytime mode otherwise;
- wherein the navigational map 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 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 Traveling Direction, Issued June 21, 2011
The Invention Explained
- Problem Addressed: Conventional navigation systems that keep the current-position icon fixed at the center of the screen are inefficient, as they dedicate significant screen area to the route already traveled, limiting the view of the path ahead and potentially affecting driver safety (’124 Patent, col. 2:20-40).
- The Patented Solution: The invention proposes a navigation device that dynamically adjusts the map display based on the vehicle's direction of travel. As the direction changes, the system adjusts both the on-screen position of the current-location icon and the display scale of the map to maximize the visible portion of the upcoming route ('124 Patent, Abstract; col. 2:50-67).
- Technical Importance: This technique seeks to provide a more forward-looking and information-rich navigation display, allowing drivers to better anticipate turns and other route features.
Key Claims at a Glance
- The complaint asserts independent claim 7 (Compl. ¶35).
- Claim 7 requires a navigation device comprising:
- a memory for storing a navigation map;
- a signal receiving unit for receiving positioning signals;
- a central processing unit (CPU) that retrieves the current position and dynamically adjusts a "first displaying parameter" (of the current position) and a "second displaying parameter" (of the map) when the "direction parameter" of the current position changes;
- a displaying unit to display the map and position according to these parameters.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 8,131,461 - Navigation Methods and Systems, Issued March 6, 2012
- Technology Synopsis: The patent addresses potential user confusion when a navigation route terminates in a complex or unfamiliar area (’461 Patent, col. 1:26-34). The invention is a system that, upon the occurrence of a "navigation condition" such as reaching the destination, displays a "position schematic diagram" showing the destination, the user's current position, and potentially landmarks to aid in final recognition ('461 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 7 (Compl. ¶48).
- Accused Features: The accused functionality is the end-of-route display in Defendants' navigation systems, which allegedly indicates when a destination is reached and terminates the navigation process, thereby triggering the claimed display (Compl. ¶¶15, 49).
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 text-based lists for finding points of interest, which it describes as inconvenient and potentially unsafe for a driver (’286 Patent, col. 1:47-55). The solution is a method to receive "activity information" (e.g., business promotions, events) and display corresponding "activity icons" directly on the navigation map at their geographic locations, with optional reminders when the user approaches one ('286 Patent, Abstract).
- Asserted Claims: The complaint asserts independent claim 13 (Compl. ¶60).
- Accused Features: The accused functionality is the ability of Defendants' systems, exemplified by the Hyundai IONIQ, to provide and display real-time information for locations like charging stations—including availability and connector types—as icons on the map (Compl. ¶¶16, 61-62).
III. The Accused Instrumentality
- Product Identification: The accused products are Defendants' infotainment systems, including the "Connected Car Navigation Cockpit (ccNC)," and navigation systems incorporated into a wide range of Hyundai, Kia, and Genesis vehicles. The Hyundai Tucson is identified as a representative product for the '881, '124, and '461 patents, while the Hyundai IONIQ is identified as representative for the '286 patent (Compl. ¶¶13-16, 20, 34, 47, 59).
- Functionality and Market Context: The complaint alleges these systems contain features that directly map to the patented technologies. This includes automatically adjusting display brightness for day and night (Compl. ¶¶22-23), providing dynamic route guidance that indicates upcoming turns (Compl. ¶37), displaying an end-of-route notification (Compl. ¶49), and overlaying real-time point-of-interest data, such as EV charging station status, on the navigation map (Compl. ¶¶61-62). The complaint provides a screenshot of the Hyundai Tucson display settings menu, which includes an "Auto-adjust Brightness" option that "varies depending on the ambient brightness" (Compl. p. 7).
IV. Analysis of Infringement Allegations
'881 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a display mode control method to be implemented in an electronic device having a display panel for showing navigational map information... | Defendant, through the use and provision of the Hyundai Tucson, performs a display mode control method. | ¶22 | col. 2:46-48 |
| a) enabling the electronic device to determine the time of day | The Hyundai Tucson performs the step of enabling the electronic device to determine the time of day. A provided screenshot notes that brightness can be adjusted based on "whether it's day or night." | ¶¶22-23 | col. 2:48-50 |
| 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 Hyundai Tucson performs the step of operating the display in a nighttime or daytime mode based on the time of day. A screenshot shows an "Auto-adjust Brightness" feature. | ¶¶22-23 | col. 2:50-52 |
| wherein the navigational map information is shown on the display panel in a light shade against a dark background when...in the nighttime display mode, and in a dark shade against a light background when...in the daytime display mode | The navigational map information is allegedly shown in a light shade against a dark background in nighttime mode and a dark shade against a light background in daytime mode. | ¶22 | col. 2:32-41 |
- Identified Points of Contention:
- Scope Question: A primary issue may be the interpretation of "determine the time of day." The complaint alleges the system determines the time of day (Compl. ¶22), but a supporting screenshot references adjustment based on "ambient brightness" (Compl. p. 7). This raises the question of whether an ambient light sensor meets the claim limitation, or if the claim, in light of the patent's disclosure of a "clock circuit" ('881 Patent, col. 2:59-61), requires a specific time-based determination.
'124 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A navigation device...comprising: a memory for storing a navigation map; a signal receiving unit for receiving at least one positioning signals... | The Hyundai Tucson is a navigation device comprising memory (internal flash, SSD, SD card) and a signal receiving unit (GPS antenna). | ¶36 | col. 4:10-20 |
| a central processing unit...for retrieving the current position...; 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 infotainment/telematic CPU allegedly retrieves the current position and dynamically adjusts display parameters when a direction parameter changes. A screenshot shows the system providing lane guidance as the vehicle approaches a turn (Compl. p. 12). | ¶36 | col. 5:16-25 |
| 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 infotainment display allegedly displays the current position and map according to the adjusted parameters. | ¶36 | col. 4:13-14 |
- Identified Points of Contention:
- Technical Question: The core of claim 7 is the specific manner of "dynamically adjust[ing]" the display parameters. The patent describes a specific relationship where the current position icon is shifted away from the center of the screen to show more of the route ahead ('124 Patent, col. 5:50-67). The complaint alleges this functionality occurs (Compl. ¶36) but provides a screenshot of lane guidance (Compl. p. 12), which may not, on its own, demonstrate the claimed off-center shifting and re-scaling. A key evidentiary question will be what proof exists that the accused systems perform this specific dynamic adjustment as described in the patent.
V. Key Claim Terms for Construction
For the '881 Patent
- The Term: "determine the time of day"
- Context and Importance: This term is central to how the automatic switching is triggered. Its construction will determine whether infringement can be proven by systems that react to ambient light levels rather than an internal clock. Practitioners may focus on this term because the accused product's own description points to "ambient brightness" (Compl. p. 7), creating a potential mismatch with the patent's explicit disclosure of a "clock circuit" ('881 Patent, FIG. 1).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is plain and does not specify the means of determination. A party could argue that sensing low ambient light is a way to "determine" that the "time of day" corresponds to nighttime.
- Evidence for a Narrower Interpretation: The only embodiment disclosed in the patent uses a "clock circuit 16...operable so as to generate the time of day" ('881 Patent, col. 2:59-61). A party could argue this disclosure limits the claim's scope to methods using an actual time-keeping component.
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 limitation defines the novel function of the claimed device. The case may turn on whether any dynamic change to the map view infringes, or if only the specific off-centering and re-scaling method described in the patent meets the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "displaying parameter" is general and could be argued to cover a wide range of on-screen adjustments that occur in response to a change in travel direction.
- Evidence for a Narrower Interpretation: The specification provides a detailed rule for this adjustment, describing a "reverse relation" for the icon's position and a "positive relation" for the map's scale ('124 Patent, col. 5:50-67). Figures 4A and 4B illustrate this by showing the icon moving to the lower-right corner of the screen when traveling northwest. A party could argue this detailed description defines the scope of the claimed "dynamic adjustment."
VI. Other Allegations
- Indirect Infringement: The complaint alleges Defendants induce infringement by supplying customers with products along with instructions on how to use the allegedly infringing features, citing owner's manuals, websites, and other product literature (Compl. ¶¶27, 40, 52, 65). Contributory infringement is also alleged on the basis that the accused components are material to the inventions, not staple articles of commerce, and are known to be especially adapted for infringement (Compl. ¶¶29, 42, 54, 67).
- Willful Infringement: Willfulness is alleged based on two theories. First, knowledge as of the filing of the complaint. Second, pre-suit willfulness based on willful blindness, with the complaint asserting that Defendants adopted a policy of not reviewing patents of others and thereby remained willfully blind to the patents-in-suit since their issuance dates (Compl. ¶¶26, 39, 51, 64).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of definitional scope: For the '881 patent, can the claim term "determine the time of day" be met by a system that relies on an ambient light sensor, or is it limited by the patent’s disclosure to systems using a clock-based function?
- A key dispute for the '124 patent will be one of functional correspondence: Does the accused navigation system's map display perform the specific, direction-based off-centering and re-scaling of the current position icon and map view as required by Claim 7, or is there a fundamental mismatch in technical operation that the complaint's general allegations do not address?
- A third major question will concern willfulness: The complaint's allegations of pre-suit willfulness rest entirely on a "willful blindness" theory. A significant challenge for the Plaintiff will be to develop factual evidence supporting this theory of a deliberate policy of patent avoidance, which is necessary to pursue enhanced damages for any pre-suit infringement.