DCT

2:25-cv-00599

Mimzi LLC v. Hyundai Motor Co

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00599, E.D. Tex., 06/04/2025
  • Venue Allegations: Venue is alleged to be proper on the basis that the defendant is a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicles equipped with the Apple CarPlay system infringe patents related to location-based advertising and crowd-sourced roadway condition reporting.
  • Technical Context: The technology at issue involves in-vehicle infotainment systems that integrate mobile devices to provide users with location-aware information, advertising, and real-time alerts.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter on October 20, 2023. The complaint also details aspects of the prosecution history for both patents, noting that the patent examiner considered and ultimately allowed the claims over subject-matter eligibility concerns under 35 U.S.C. § 101, based on arguments that the inventions were technological improvements and practical applications rooted in computer technology.

Case Timeline

Date Event
2008-07-29 Earliest Priority Date for '163 and '361 Patents
2017-10-17 '361 Patent Issue Date
2021-08-24 '163 Patent Issue Date
2023-10-23 Defendant allegedly received notice of infringement
2025-06-04 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,100,163, Photographic Memory, Issued August 24, 2021

The Invention Explained

  • Problem Addressed: The patent identifies a need for an "easy and unobtrusive way to record and search audio from phone calls and face-to-face conversations," noting that unlike email, such interactions are typically not captured in a searchable format. (’163 Patent, col. 2:31-35). It also describes a scenario where a mobile user who sees a road hazard should be able to send a spoken message with location data to warn others in a community database (’163 Patent, col. 2:21-28).
  • The Patented Solution: The invention provides a system where data from a mobile device (e.g., audio from a call) is sent to a server for processing by a speech recognition engine. (’163 Patent, Fig. 1). This creates a searchable text transcript that is appended with time and location metadata, which can then be stored in a database and searched by the user (’163 Patent, col. 7:21-34). The system is also described as being able to deliver location-based advertisements. (’163 Patent, col. 5:59-64).
  • Technical Importance: The technology aims to create a unified, searchable repository for various forms of communication, linking spoken words to specific times and geographic locations, a concept the complaint ties to the growing demand for mobile, location-aware search capabilities in the late 2000s (Compl. ¶10).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 11, among other dependent claims (Compl. ¶11, ¶39).
  • Independent system claim 1 includes the following essential elements:
    • A communication network interface port.
    • A database system configured to store and retrieve location-based travel information and advertisements.
    • At least one server configured to:
      • Automatically control access to the database.
      • Receive a location and location-based information from a mobile device.
      • Retrieve location-based travel information from the database based on the device's location.
      • Retrieve a location-based advertisement from the database that is dependent on the device's location and "relevant to at least one spoken keyword."
      • Present the retrieved advertisement to the user.
  • The complaint reserves the right to assert other claims, including a number of dependent claims (Compl. ¶39).

U.S. Patent No. 9,792,361, Photographic Memory, Issued October 17, 2017

The Invention Explained

  • Problem Addressed: The patent describes a shortcoming in the art where a mobile phone user observing a road hazard (e.g., a traffic jam or stalled vehicle) lacks an efficient method to "send a spoken message, with speech-recognized text and location data, to a community searchable database" to instantly warn others (’361 Patent, col. 1:64-2:5).
  • The Patented Solution: The invention is a system for presenting "social network provided outputs" to a mobile device based on its location and user input. (’361 Patent, Abstract). A processor defines a user request based on input (e.g., spoken words) and metadata (e.g., GPS location), transmits the request to a "social network database" containing roadway condition records, and receives location-dependent information back. (’361 Patent, Claim 1). The system is further configured to present this information ranked by a "social network ranking factor" and to communicate a message back to create a new record in the database. (’361 Patent, Claim 1).
  • Technical Importance: The technology outlines a framework for crowd-sourced, real-time traffic and hazard reporting systems, where users both consume and contribute location-specific data within a community.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 16, and 18, among other dependent claims (Compl. ¶29, ¶47).
  • Independent system claim 1 includes the following essential elements:
    • A hardware data input port to receive user input.
    • An automated hardware processor to define a user request based on the input and location metadata.
    • An automated hardware communication interface port to transmit the request to a "social network database," receive location-dependent information back, and communicate a message to create a new record.
    • An automated hardware user interface to present the received information ranked according to a "social network ranking factor."
  • The complaint reserves the right to assert other claims, including a number of dependent claims (Compl. ¶47).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "Defendant's Hyundai and Genesis vehicles equipped with CarPlay" (Compl. ¶41, ¶49).

Functionality and Market Context

  • The complaint alleges that these vehicles, through the integration of Apple's CarPlay system into their infotainment units, provide the infringing functionality. The system allows a user's mobile device to interface with the vehicle's display and controls. While the complaint does not provide specific technical details on the operation of CarPlay in Hyundai vehicles, its infringement theory implies that the system uses the device's location services, processes voice commands, and presents location-based information, advertisements, and/or real-time traffic data sourced from a network database (Compl. ¶41, ¶49). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim chart exhibits (Exhibits G and H) that were not attached to the publicly filed document. Therefore, the specific mapping of claim elements to accused functionality is not available for analysis. The infringement theory is summarized below in prose.

  • '163 Patent Infringement Allegations
    The complaint alleges that the accused vehicles practice at least claims 1, 3-8, and 10 of the ’163 Patent (Compl. ¶39). The narrative infringement theory suggests that the vehicle's infotainment system, operating with CarPlay, functions as the claimed system. It allegedly receives location data from the integrated mobile device and user input via spoken commands. Based on this input, the system is alleged to retrieve and present location-based advertisements, thereby satisfying the elements of claim 1, including the retrieval of an ad "relevant to at least one spoken keyword" (Compl. ¶11, ¶41).

  • '361 Patent Infringement Allegations
    The complaint alleges that the accused vehicles practice at least claims 1-3, 5, 7, 10, 11, and 12 of the ’361 Patent (Compl. ¶47). The narrative theory posits that the accused vehicles, via CarPlay, provide a system for presenting social network-provided information. This is allegedly accomplished when a user provides input (e.g., a voice query about traffic), and the system uses the device's location to query a networked database (such as Apple Maps or Google Maps). The system then allegedly presents ranked, location-dependent results, such as real-time traffic conditions, and allows users to contribute reports, thereby creating new records in the "social network database" (Compl. ¶29, ¶49).

  • Identified Points of Contention:

    • Scope Questions: A central question may be whether the term "social network database" as used in the ’361 patent, which describes a "community searchable database" for road hazards (’361 Patent, col. 1:64-2:5), can be construed to read on the commercial mapping and traffic services (e.g., Apple Maps) accessible through CarPlay.
    • Technical Questions: The complaint does not specify how Hyundai's vehicles meet the limitation in claim 1 of the ’163 Patent of retrieving an advertisement "relevant to at least one spoken keyword." A point of contention will likely be what evidence demonstrates this specific causal link between a spoken word and a presented ad, as opposed to more general location or behavioral ad targeting.
    • Legal Questions: Because the accused functionality involves both Hyundai's vehicle hardware and Apple's CarPlay software, the case may raise questions of divided infringement, centering on whether Hyundai, as a single entity, performs all the steps of the asserted claims or controls and directs the performance of the steps it does not perform itself. The complaint lacks detailed allegations on this point.

V. Key Claim Terms for Construction

  • Term: "social network database" (’361 Patent, Claim 1)

    • Context and Importance: The infringement case for the ’361 Patent hinges on whether the backend data source used by the accused CarPlay systems (e.g., Apple Maps) qualifies as a "social network database." Practitioners may focus on this term because its construction will likely determine whether the accused system falls within the scope of the claims.
    • Intrinsic Evidence for a Broader Interpretation: The patent describes a "community or collective photographic memory, where the content is contributed by multiple members of the community" (’361 Patent, col. 1:18-21). This could support an interpretation that includes any database with crowd-sourced or user-contributed data, such as the traffic and hazard reporting features of modern mapping applications.
    • Intrinsic Evidence for a Narrower Interpretation: The patent also refers to ranking information based on "social network credibility or social network popularity of the Location Blog poster" (’361 Patent, col. 16:2-5). This language may support a narrower construction requiring features more typical of traditional social networks, such as user profiles and explicit credibility metrics, which may not be present in a commercial mapping service.

  • Term: "relevant to at least one spoken keyword" (’163 Patent, Claim 1)

    • Context and Importance: This term defines the required connection between a user's speech and a presented advertisement. The case may turn on how direct and explicit this connection must be.
    • Intrinsic Evidence for a Broader Interpretation: The specification suggests a broad link, stating the invention can "use the speech-recognized text, to target the ad to something (a keyword) mentioned one or more times in the conversation" (’163 Patent, col. 5:61-64). This could be argued to cover any ad triggered by a mentioned term.
    • Intrinsic Evidence for a Narrower Interpretation: The term "relevant" itself implies a substantive connection. A defendant could argue that this requires more than a simple keyword trigger and necessitates a contextual relationship between the speech and the ad's content, potentially narrowing the claim scope away from general, non-contextual advertising.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the patents (Compl. ¶41, ¶49).
  • Willful Infringement: Willfulness is alleged for both patents based on Defendant’s alleged actual knowledge of the patents. The complaint pleads that this knowledge was established no later than October 23, 2023, the date Defendant allegedly received a notice letter from Plaintiff. The willfulness allegation is directed at Defendant's conduct after receiving this notice (Compl. ¶43, ¶51).

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

  • A core issue will be one of definitional scope: Can the term "social network database", which the ’361 Patent associates with community contributions and poster credibility, be construed to cover the large-scale, commercially operated mapping and traffic data services utilized by Apple's CarPlay?
  • A second key issue will concern divided infringement and evidentiary proof: As the accused functionality relies on an integration of Defendant's vehicle and Apple's software, a central question will be whether Plaintiff can demonstrate that Defendant, as a single actor, meets all limitations of the asserted claims, or directs or controls the other actors involved.
  • Finally, a critical question of functional specificity will be whether the advertising presented in the accused vehicles meets the ’163 Patent’s requirement of being "relevant to at least one spoken keyword," and what evidence will be required to prove this direct, causal link versus more generalized forms of targeted advertising.