Mimzi LLC v. Ford Motor Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mimzi, LLC (Alabama)
  • Defendant: Ford Motor Company (Delaware)
  • Plaintiff’s Counsel: KENT & RISLEY LLC
• Case Identification: 2:25-cv-00604, E.D. Tex., 09/11/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business there.
• Core Dispute: Plaintiff alleges that Defendant’s in-vehicle infotainment systems, which integrate third-party mapping and connectivity services like Apple CarPlay and Google Maps, infringe two patents related to providing location-based information and crowdsourced data to mobile users.
• Technical Context: The technology at issue involves using a mobile device's location and user input, particularly voice commands, to query remote databases and deliver relevant, context-aware information, such as advertisements, traffic data, and other points of interest.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a letter dated October 20, 2023. The complaint also details arguments made during the prosecution of both patents-in-suit to overcome subject-matter eligibility rejections under 35 U.S.C. § 101, asserting that the claims are directed to technological improvements rather than abstract ideas.

Case Timeline

Date	Event
2008-07-29	Earliest Priority Date for ’163 and ’361 Patents
2008-09-10	Google VP Marissa Mayer comments on the "future of search"
2011-01-01	Apple rolls out new voice-recognition capabilities for iPhone
2012-01-01	Article on Google Now published
2017-10-17	U.S. Patent No. 9,792,361 Issues
2021-08-24	U.S. Patent No. 11,100,163 Issues
2023-10-20	Plaintiff sends notice letter to Defendant
2025-09-11	Complaint Filing Date

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

U.S. Patent No. 11,100,163 - “Photographic Memory”

• Patent Identification: U.S. Patent No. 11,100,163, issued on August 24, 2021.

The Invention Explained

• Problem Addressed: The patent’s background section describes the lack of a "centralized computerized repository for all conversations and everything seen or read, that can be searched with a single query," noting that unlike emails, phone calls and in-person meetings are typically ephemeral and not searchable (’163 Patent, col. 1:60-2:2).
• The Patented Solution: The invention proposes a system where data from a mobile device (e.g., audio from a phone call) is transmitted to a server, processed by a speech recognition engine, and stored with metadata such as time and location (’163 Patent, Fig. 1). This creates a searchable record that can be used to retrieve contextually relevant information, such as retrieving a location-based advertisement from a database that is dependent on the user's location and a "spoken keyword" from the user (’163 Patent, Abstract; col. 16:21-27).
• Technical Importance: The technology aims to make real-world, ephemeral data (like conversations) persistent, searchable, and actionable by linking it to specific geographic locations and user inputs, a foundational concept for modern location-based services (Compl. ¶ 15-17).

Key Claims at a Glance

• The complaint asserts independent claims 1, 11, and 22 (Compl. ¶ 17).
• Essential elements of independent claim 1 (a system) include:
  • A communication network interface port.
  • A database system configured to store and retrieve location-based travel information and location-based advertisements.
  • At least one server configured to automatically receive a location and location-based information from a mobile device, retrieve travel information from the database based on that location, retrieve a location-based advertisement from the database based on the location and "at least one spoken keyword," and present the advertisement to the user.
• The complaint asserts dependent claims 3-8 and 10 and reserves the right to assert additional claims (Compl. ¶ 50).

U.S. Patent No. 9,792,361 - “Photographic Memory”

• Patent Identification: U.S. Patent No. 9,792,361, issued on October 17, 2017.

The Invention Explained

• Problem Addressed: The patent identifies a need for a mobile phone user who observes a road hazard to be able to "send a spoken message, with speech-recognized text and location data, to a community searchable database, from which others can be instantly warned" (’361 Patent, col. 1:64-2:5; Compl. ¶ 34).
• The Patented Solution: The invention claims a system where a user provides input to a mobile device, which then determines its location, defines a "user request," and transmits it to a "social network database" containing records of roadway conditions (’361 Patent, Claim 1). The system is also configured to receive location-dependent information from this database and present it to the user, ranked by a "social network ranking factor" such as proximity (’361 Patent, Claim 1; Claim 10). A key feature is the ability for the system to also "communicate a message... for creating a new record in the social network database," enabling a crowd-sourced data model (’361 Patent, Claim 1).
• Technical Importance: The patent describes an architecture for crowd-sourced, real-time data exchange for mobile users, a concept that underpins modern traffic and navigation applications that rely on user-generated reports (Compl. ¶ 34-35).

Key Claims at a Glance

• The complaint asserts independent claims 1, 16, and 18 (Compl. ¶ 35).
• Essential elements of independent claim 1 (a system) include:
  • A hardware data input port to receive user input.
  • A hardware processor to define a user request based on the input and the device's location.
  • A communication interface to transmit the request to a "social network database" of roadway conditions, receive information back, and communicate a message to create a new record in that database.
  • A user interface to present the received information, which is "ranked according to at least one social network ranking factor."
• The complaint asserts dependent claims 1-3, 5, 7, 10, 11, and 12 and reserves the right to assert additional claims (Compl. ¶ 61, 63).

III. The Accused Instrumentality

Product Identification

Ford and Lincoln vehicles equipped with infotainment systems that integrate smartphone connectivity platforms, such as Apple CarPlay and Android Auto, or feature integrated Google Maps (Compl. ¶ 50, 61). These systems are marketed by Ford under names like SYNC® 4 Technology with Connected Navigation (Compl. ¶ 53, 64).

Functionality and Market Context

The accused systems allow a vehicle's built-in display and controls to interface with a user's smartphone or an embedded navigation service (Compl. ¶ 53). This enables functionality such as displaying maps, providing turn-by-turn directions, and accessing real-time data like traffic conditions and points of interest (Compl. ¶ 53, Exhibit I). The complaint highlights that these systems support voice commands for hands-free operation (Compl. ¶ 55, Exhibit J). A screenshot from Ford's website titled "Voice-Activated App Control" describes the ability to "access vehicle features through the center touchscreen or simply with the sound of your voice" using Apple CarPlay and Android Auto (Compl. ¶ 55, Exhibit J). This integration of vehicle hardware, location data, voice input, and third-party network services forms the basis of the infringement allegations.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; therefore, the infringement theories are summarized below in prose.

’163 Patent Infringement Allegations

The complaint alleges that the accused Ford systems, in combination with a connected smartphone and the backend servers of Apple or Google, meet the limitations of the ’163 Patent (Compl. ¶ 51). The user provides a "spoken keyword" through a voice command to the system, which also knows the vehicle's location via GPS (Compl. ¶ 55, Exhibit J). This input is allegedly used to query a "database system" (e.g., Google Maps servers) that stores and retrieves "location-based travel information" (maps and directions) and "location-based advertisements" (such as sponsored business listings on the map) (Compl. ¶ 17). This information is then presented to the user on the vehicle's display (Compl. ¶ 53). As visual evidence, the complaint provides a screenshot of Ford's website describing how to connect a phone to the SYNC system to use Apple CarPlay (Compl. ¶ 55, Exhibit K).

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the combination of a Ford vehicle, a user's third-party smartphone, and the backend infrastructure of Apple or Google constitutes a single "system" that Defendant "makes" or "uses" under patent law. Another question is whether business listings presented on a map in response to a voice search qualify as "advertisements" that are "relevant to at least one spoken keyword" as required by the claim.
  • Technical Questions: What evidence does the complaint provide that the accused systems distinguish between general "travel information" and "advertisements" and retrieve the latter based on a specific "spoken keyword," as opposed to showing all relevant points of interest based on location alone?

’361 Patent Infringement Allegations

The infringement theory for the ’361 Patent posits that the accused systems function as a conduit to a "social network database" of roadway conditions, such as the real-time traffic and hazard data platforms maintained by Apple and Google (Compl. ¶ 62, 64). A user's request, based on voice or touch input and the vehicle's location, is allegedly transmitted to these servers (Compl. ¶ 62). The servers then return "location-dependent social network information" (e.g., traffic congestion overlays, accident reports), which is presented on the vehicle's display ranked by a "social network ranking factor" such as proximity or severity (Compl. ¶ 35). The complaint also alleges that these systems communicate information back to the network for "creating a new record," such as by passively providing speed and location data to inform traffic models (Compl. ¶ 35). A screenshot from Ford's website explains a feature for "Apple Maps EV Routing for Apple CarPlay," which illustrates the system's use of network-based data for navigation (Compl. ¶ 67, Exhibit M).

• Identified Points of Contention:
  • Scope Questions: Does the term "social network database" as used in the patent read on the infrastructure of a mapping service like Google Maps, which uses aggregated, often anonymous user data rather than the explicit user profiles and connections of a traditional social network?
  • Technical Questions: While the retrieval of crowd-sourced data is a known feature of these systems, what evidence does the complaint provide for the claim element requiring the system to "communicate a message... for creating a new record"? The allegations appear more focused on data consumption than data contribution.

V. Key Claim Terms for Construction

’163 Patent

• The Term: "spoken keyword"
• Context and Importance: This term appears in the limitation for retrieving an advertisement and is central to distinguishing the claimed invention from a system that merely provides location-based information. Its construction will determine whether a general voice search query (e.g., "restaurants near me") meets the limitation, or if a more specific, advertising-focused term is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification broadly discusses using speech recognition to create searchable transcripts of entire conversations, suggesting any recognized word could be a potential keyword (’163 Patent, col. 2:8-13).
  • Evidence for a Narrower Interpretation: The patent also describes a system for "targeted ads" based on keywords mentioned in conversation and user demographics, which could imply a more sophisticated advertising-selection process than a simple map search (’163 Patent, col. 14:1-9; Fig. 5).

’361 Patent

• The Term: "social network database"
• Context and Importance: This term defines the type of backend system the invention interacts with. The viability of the infringement case depends on whether the mapping platforms of Apple and Google fall within its scope. Practitioners may focus on this term because its definition could exclude systems that do not have traditional "social networking" features.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the database as a "community searchable database" for sharing road hazard information, which functionally aligns with crowd-sourced mapping services (’361 Patent, col. 1:64-2:5).
  • Evidence for a Narrower Interpretation: The patent itself does not provide an explicit definition. A defendant could argue that in common parlance at the time of invention, a "social network" required user profiles, connections, and explicit sharing, features not central to the accused mapping services.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by providing vehicles with the accused systems and distributing product literature, website materials, and instructions that encourage end users to use the systems in an infringing manner (Compl. ¶ 55, 66). Specific examples cited include website pages explaining how to connect and use Apple CarPlay with Ford's SYNC system (Compl. ¶ 55, 67).
• Willful Infringement: Willfulness is alleged based on Defendant's purported knowledge of the patents since at least October 23, 2023, the date it allegedly received a notice letter from Plaintiff. The complaint alleges that Defendant's infringement continued after this date, rendering the ongoing infringement willful (Compl. ¶ 57, 69).

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

• A core issue will be one of definitional scope: Can the terms "database system... comprising... location-based advertisements" (’163 Patent) and "social network database" (’361 Patent) be construed to cover the backend mapping and data services of third parties like Apple and Google, or do fundamental technical and architectural differences place the accused systems outside the claims?
• A second central issue will be one of divided infringement: Given that the accused "system" comprises hardware from Defendant, a smartphone from a third party, and network services from another entity (Apple/Google), can Plaintiff establish that Defendant directly infringes by "making," "using," or "selling" the entire claimed system, or will this theory be challenged under the legal standards for divided infringement?
• A third key question will be subject-matter eligibility: Despite the patents surviving examination, the extensive discussion in the complaint regarding prosecution history arguments under 35 U.S.C. § 101 suggests this will be a significant battleground. The case may turn on whether the court views the claims as being directed to a specific technological improvement in user interface and data management or to the abstract idea of collecting, analyzing, and presenting location-based information.