DCT

2:25-cv-00600

Mimzi LLC v. Honda Motor Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00600, 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 vehicle infotainment systems equipped with CarPlay infringe patents related to processing spoken user input with location data to provide location-based information, advertisements, and social network-based roadway condition alerts.
  • Technical Context: The technology relates to the integration of voice commands, location services, and network databases in mobile and automotive environments to provide context-aware information and advertising.
  • Key Procedural History: The complaint emphasizes the prosecution history of both asserted patents, noting that the U.S. Patent and Trademark Office considered and ultimately allowed the claims over subject-matter eligibility challenges under 35 U.S.C. § 101. Plaintiff cites arguments made by the applicant during prosecution to distinguish the inventions from abstract ideas by grounding them in specific computer hardware and network improvements.

Case Timeline

Date Event
2008-07-29 Priority Date for ’163 and ’361 Patents
2016-03-28 Examiner issues Advisory Action finding ’361 Patent claims eligible
2017-10-17 U.S. Patent No. 9,792,361 issues
2021-01-29 Applicant files Response to Office Action for ’163 Patent application
2021-08-24 U.S. Patent No. 11,100,163 issues
2023-10-23 Defendant allegedly receives notice of infringement letter
2025-06-04 Complaint filed

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 lack of a unified, searchable repository for all of a person's communications and observations, noting that while emails are searchable, phone calls and in-person conversations are not (ʼ163 Patent, col. 1:52-68). This creates a gap in a person's ability to recall information, a problem the patent analogizes to lacking a "photographic memory" (ʼ163 Patent, col. 1:30-38).
    • The Patented Solution: The invention proposes using a mobile device to record various data inputs (e.g., audio from calls, spoken synopses, photos) and processing them on a server with speech recognition (ʼ163 Patent, Fig. 1). The system creates a searchable transcript and associates it with metadata, such as time and location, which can then be used to retrieve relevant information, including location-based advertisements triggered by spoken keywords (ʼ163 Patent, col. 6:16-22; col. 7:1-8).
    • Technical Importance: The invention describes an architecture for integrating a user's real-world, spoken interactions with location data to enable new forms of information retrieval and targeted advertising.
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 and dependent claims 3-8 and 10 (Compl. ¶39).
    • Independent Claim 1 recites a system for presenting location-based information, with the following essential elements:
      • A communication network interface port.
      • A database system for storing and retrieving location-based travel information and advertisements.
      • A server configured to:
        • Control access to the database.
        • Receive a location from a mobile device.
        • Receive location-based information from the mobile device.
        • Retrieve location-based travel information from the database based on the device's location.
        • Retrieve a location-based advertisement from the database based on the device's location and "at least one spoken keyword."
        • Present the retrieved advertisement to the user.

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

  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes a scenario where a mobile phone user sees a road hazard and should be able to easily report it via a spoken message, with location data, to a "community searchable database" to instantly warn other drivers (ʼ361 Patent, col. 1:64-2:5).
    • The Patented Solution: The invention claims a system where a user provides input to a mobile device, which is combined with location data to form a user request (ʼ361 Patent, Claim 1). This request is sent to a "social network database" containing roadway condition records. The system receives back location-dependent information, which is ranked by a "social network ranking factor" and presented to the user. The system also allows the user to create new records in the database, effectively contributing to the crowd-sourced information (ʼ361 Patent, col. 10:11-20).
    • Technical Importance: This technology describes a framework for crowd-sourcing and disseminating real-time, location-specific information, particularly for roadway conditions, using mobile devices.
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1 and dependent claims 2-3, 5, 7, 10, 11, and 12 (Compl. ¶47).
    • Independent Claim 1 recites a system for presenting social network-provided outputs, with the following essential elements:
      • A hardware data input port to receive user input.
      • A hardware processor to define a user request based on the input and location metadata from a geospatial positioning system.
      • A hardware communication interface port configured to:
        • Transmit the request to a "social network database" of roadway condition records.
        • Receive location-dependent "social network information" from the database.
        • Communicate a message to create a new record in the database.
      • A hardware user interface to present the received information ranked by at least one "social network ranking factor."

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are "Honda and Acura vehicles equipped with CarPlay" (Compl. ¶¶41, 49).
  • Functionality and Market Context: The complaint alleges that these vehicle infotainment systems, through the CarPlay interface, provide functionality that infringes the patents-in-suit (Compl. ¶¶41, 49). This functionality includes receiving voice commands and location data from the user and vehicle, communicating with remote servers and databases (e.g., Apple Maps, Waze, or advertising networks), and presenting location-dependent information, such as traffic alerts, directions, and advertisements, back to the user on the vehicle's display (Compl. ¶¶41, 49).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference representative claim charts (Exhibits G and H) that were not included in the provided documents (Compl. ¶¶41, 49). The infringement analysis is therefore based on the narrative allegations. No probative visual evidence provided in complaint.

The complaint alleges that Honda's vehicles with CarPlay provide the systems claimed in the ’163 and ’361 patents. For the ’163 Patent, the infringement theory centers on the system's ability to deliver targeted, location-based advertising in response to voice inputs (Compl. ¶¶39-41). For the ’361 Patent, the theory focuses on the system's use of applications like Apple Maps or Waze to receive crowd-sourced road condition data from a central database and present it to the user, as well as to allow the user to report new conditions (Compl. ¶¶47, 49).

  • Identified Points of Contention:
    • Scope Questions:
      • A central question for the ’361 Patent will be whether the backend servers and user community of an application like Apple Maps or Waze constitute a "social network database" as that term is used in the patent.
      • Similarly, for the ’361 Patent, it raises the question of what functionality in the accused products corresponds to the "social network ranking factor" required by claim 1.
    • Technical Questions:
      • For the ’163 Patent, a key technical question is how the accused CarPlay system uses a "spoken keyword" to retrieve an advertisement. The analysis may explore whether the system directly uses a transcribed keyword from a general conversation or navigation request, or if it requires a more explicit ad-related query.

V. Key Claim Terms for Construction

For U.S. Patent 11,100,163:

  • The Term: "spoken keyword" (Claim 1)
  • Context and Importance: This term is critical because it links the user's voice input to the retrieval of a location-based advertisement. The infringement analysis depends on whether the accused system's method of triggering ads aligns with the patent's definition of using a "spoken keyword."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests that keywords can be extracted from the general text of any recorded conversation. It states the invention can "use the speech-recognized text, to target the ad to something (a keyword) mentioned one or more times in the conversation" (ʼ163 Patent, col. 6:58-62). This could support a construction where any word spoken by the user and captured by the system can serve as a "spoken keyword."
    • Evidence for a Narrower Interpretation: Other parts of the specification describe a more active process, where a user is "prompted by the phone and asked to provide a brief description" of a photo or video, and the user "can speak the description" (ʼ163 Patent, col. 3:55-61). This might support a narrower construction where the "spoken keyword" must come from a specific, descriptive user utterance rather than passive analysis of a conversation.

For U.S. Patent 9,792,361:

  • The Term: "social network database" (Claim 1)
  • Context and Importance: This term defines the type of database with which the claimed system interacts. Infringement will depend on whether the databases used by the accused CarPlay applications (e.g., Apple Maps, Waze) fall within the scope of this term. Practitioners may focus on this term because its construction could either limit the claims to a specific type of community-focused database or broaden them to cover a wide range of crowd-sourced data systems.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent uses the term in the context of "Location Blogging" where content is "contributed by multiple members of the community" (ʼ361 Patent, col. 1:16-20). This could support a broad reading that covers any database populated with user-generated, location-tagged content.
    • Evidence for a Narrower Interpretation: The primary example provided is a "community searchable database" for warning others of road hazards like a "traffic jam, or a hazard in the road" (ʼ361 Patent, col. 1:64-2:5). This could support a narrower construction limited to databases with a primary purpose of real-time, community-based hazard reporting, potentially excluding general-purpose mapping or navigation databases.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant has actual knowledge of the patents since at least October 23, 2023, from a notice letter (Compl. ¶¶40, 48). It further alleges that Defendant induces infringement by distributing "product literature and website materials" that instruct end users on how to use the accused CarPlay features in a manner that infringes the patents (Compl. ¶¶41, 49).
  • Willful Infringement: The willfulness allegation is based on Defendant's alleged continued infringement after receiving the October 2023 notice letter, which provided actual knowledge of the patents and the alleged infringement (Compl. ¶¶43, 51).

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

This dispute will likely center on issues of claim construction and the specific technical operation of the accused systems. The key questions for the court appear to be:

  • A core issue will be one of definitional scope: Can the term "social network database," described in the patent in the context of "Location Blogging" and community hazard reporting, be construed to cover the large-scale, crowd-sourced mapping and traffic databases used by commercial applications like Apple Maps and Waze?
  • A second key question will be one of technical implementation: Does the accused CarPlay system retrieve advertisements based on a "spoken keyword" in the manner required by the ’163 Patent, and does it employ a "social network ranking factor" as claimed in the ’361 Patent, or is there a fundamental mismatch in how the accused technology operates?
  • An evidentiary question will be what proof Plaintiff can offer that Defendant's product literature and user manuals actively instruct users to perform the full sequence of steps recited in the asserted method claims, which will be critical for the inducement allegations.