DCT
2:25-cv-00786
Nearby Systems LLC v. U Haul Intl Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Nearby Systems LLC (Texas)
- Defendant: U-Haul International, Inc. (Nevada) and U-Haul Co. of Texas (Texas)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-00786, E.D. Tex., 08/12/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendants maintain regular and established places of business within the district and have committed acts of patent infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s mobile application and website, which allow users to find and map company locations, infringe patents related to combining location data from one source onto an existing map display in another.
- Technical Context: The technology at issue addresses the integration of mappable data from disparate applications onto a single map on a mobile device, a common feature in modern location-based services.
- Key Procedural History: The three asserted patents are part of the same family, with the ’980 and ’145 patents being continuations that claim priority to the same 2007 application as the parent ’164 patent. The complaint does not mention any prior litigation or administrative proceedings involving these patents.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-12 | Earliest Priority Date for '164, '980, and '145 Patents |
| 2013-08-03 | Application filed for '164 Patent |
| 2016-11-08 | Application filed for '980 Patent |
| 2016-12-27 | '164 Patent Issued |
| 2019-09-13 | Application filed for '145 Patent |
| 2019-11-05 | '980 Patent Issued |
| 2024-03-19 | '145 Patent Issued |
| 2025-08-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,532,164 - “Mashing Mapping Content Displayed on Mobile Devices,” issued December 27, 2016
The Invention Explained
- Problem Addressed: The patent describes a limitation in prior art mobile devices where new mapping content originating from outside a dedicated mapping application (e.g., an address in an email) could only be displayed on a new digital map, which caused any previously displayed mappable information to be lost. (’164 Patent, col. 1:29-37).
- The Patented Solution: The invention is a system where a first "non-browser application" can invoke a second "mapping application." This allows "map-able content" (like an address) selected in the first application to be transmitted to and displayed on the mapping application's existing map, in conjunction with any content already being shown, thereby preserving context. (’164 Patent, Abstract; col. 2:42-53).
- Technical Importance: This method provides for a more seamless and integrated user experience by allowing location-based data from various sources to be aggregated onto a single, persistent map view. (’164 Patent, col. 1:38-48).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶29).
- Essential elements of claim 1 include:
- A storage device of a mobile device storing a first non-browser application and a second non-browser application.
- A processor executing both applications.
- A user interface for the first non-browser application.
- A mapping component within the first application that is configured to invoke the second application (which is a mapping application) when "map-able content" is activated.
- The mapping component transmits the content to an online mapping service that communicates with the second (mapping) application.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 10,469,980 - “Mashing Mapping Content Displayed On Mobile Devices,” issued November 5, 2019
The Invention Explained
- Problem Addressed: The patent background notes the popularity of mapping services but identifies a need for improved methods of relaying address information from various sources on an electronic device for display on a common map. (’980 Patent, col. 1:12-18).
- The Patented Solution: The invention claims a system on a mobile device that includes a "first non-browser application" containing a "mapping component." This component uses the device's GPS to determine its location, communicates with an online mapping service, and can invoke a separate "second non-browser application" (a mapping application) to transmit a query and display driving directions from the device's current location to a destination. (’980 Patent, Abstract; col. 15:1-16:8).
- Technical Importance: The claimed architecture facilitates interoperability, allowing general-purpose applications to leverage the specialized functions of dedicated mapping apps and powerful online services to provide integrated navigation features. (’980 Patent, col. 8:12-24).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶46).
- Essential elements of claim 1 include:
- A memory storing a first non-browser application and a processor to execute it.
- A touch screen displaying the user interface of the first non-browser application.
- A GPS device for determining the mobile device's location.
- A mapping component within the first application that communicates with an online mapping service.
- A memory storing a second non-browser application that is a mapping application.
- The mapping component invokes the mapping application to transmit a query, including the device location and a destination, to obtain and display driving directions.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,937,145 - “Mashing Mapping Content Displayed On Mobile Devices,” issued March 19, 2024
- Technology Synopsis: This patent addresses the integration of location data between applications on a mobile device by claiming a system where a first non-browser application can, upon a user's touch of associated text, transmit a query to an online mapping service. This action prompts a separate, second non-browser mapping application to display a map showing a route based on that query. (Compl. ¶¶ 57-58; ’145 Patent, Claim 1).
- Asserted Claims: The complaint asserts independent claim 1. (Compl. ¶63).
- Accused Features: The U-Haul App is accused of infringing by providing a system that allows users to select a U-Haul location and display map and navigation information. (Compl. ¶¶ 63-64).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the "U-Haul App" mobile application and the associated website, https://www.uhaul.com/, collectively referred to as the "Accused Products." (Compl. ¶¶ 19, 21).
Functionality and Market Context
- The complaint alleges the Accused Products provide a system and method for displaying map information on a mobile device or computer. (Compl. ¶¶ 30, 47, 64). Their function is to allow customers to locate U-Haul stores, obtain data to display text and maps, and use this information to identify and navigate to those locations. (Compl. ¶¶ 21, 30).
- Exhibit G, cited in the complaint, reportedly includes a screenshot illustrating the U-Haul App displaying a map with plotted U-Haul locations. (Compl. ¶30, Ex. G).
- The complaint alleges Defendants operate numerous business locations within the Eastern District of Texas, but does not provide further details on the market positioning of the Accused Products. (Compl. ¶10).
IV. Analysis of Infringement Allegations
'164 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a storage device of a mobile device storing a first non-browser application and a second non-browser application; | The complaint alleges the U-Haul App is the first non-browser application, and a native mapping program on the device (e.g., Apple Maps) is the second non-browser application. | ¶¶29-30, Ex. G | col. 2:23-35 |
| a mapping component of the first non-browser application configured to invoke the second non-browser application...when map-able content...is activated to display a map... | The U-Haul App allegedly contains a component that, when a user activates map-able content (e.g., taps on a store location), invokes the separate mapping application to display a map. | ¶¶29-30, Ex. G | col. 2:42-53 |
| wherein the mapping component transmits the map-able content to an online mapping service configured to communicate with the second non-browser application. | The U-Haul App is alleged to transmit the selected location data to an online service, which in turn provides map data to the invoked mapping application. | ¶¶29-30, Ex. G | col. 4:54-61 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the U-Haul App's functionality constitutes "invok[ing]" a "second non-browser application." The analysis may turn on whether displaying a map via an API call within the U-Haul App's own interface satisfies this limitation, or if it requires a full context switch to a separate, standalone mapping application.
- Technical Questions: The complaint's allegations are high-level. A key factual dispute will likely concern the actual software architecture of the U-Haul App and whether it contains a "mapping component" that functions in the specific manner required by the claim.
’980 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a GPS device of the mobile device determining a location of the mobile device | The accused U-Haul App allegedly uses the mobile device’s GPS to determine the user's current location for mapping and navigation purposes. | ¶47, Ex. H | col. 9:19-23 |
| a mapping component of the first non-browser application configured to communicate with an online mapping service... | The complaint asserts the U-Haul App contains software that communicates with an online mapping service to download and display map data. Exhibit H is cited as exemplary evidence of this system. (Compl. Ex. H). | ¶47, Ex. H | col. 14:10-15 |
| wherein the mapping component invokes the mapping application...to transmit a query including the location of the mobile device and a destination location...to obtain driving directions... | The U-Haul App is alleged to invoke a separate mapping application, passing it the user's GPS location and a selected store location as a query to obtain and display a route. | ¶47, Ex. H | col. 16:1-8 |
- Identified Points of Contention:
- Scope Questions: As with the ’164 patent, the interpretation of "invokes the mapping application" will be critical. The dispute may focus on whether this requires launching a separate app or if an embedded map view controlled by an external API is sufficient.
- Technical Questions: It raises the question of what evidence demonstrates that the U-Haul app transmits a query with both the device location and a destination to an online service via a separate invoked mapping application, as opposed to handling these steps internally or in a different sequence.
V. Key Claim Terms for Construction
The Term: "mapping component" (asserted in '164 and '980 patents)
- Context and Importance: This term defines a core structural element of the claimed system. Its construction will be critical to determining whether the U-Haul App's software architecture meets the claim limitations, as the dispute will likely focus on whether the app’s code for handling maps constitutes this specific component.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the component in functional terms as code that provides "functionality of receiving location information from other applications." (’980 Patent, col. 8:14-16). This could support a broad definition covering any software routine performing the claimed function.
- Evidence for a Narrower Interpretation: Patent figures depict the "MAPPING COMPONENT" as a distinct block, separate from the "DISPLAY APPLICATION" and the "MAPPING APPLICATION," which could support a narrower construction requiring a structurally independent module. (’980 Patent, Figs. 10A-10B).
The Term: "invoke" / "invokes" (asserted in '164 and '980 patents)
- Context and Importance: The infringement theory hinges on the first application "invoking" the second. Practitioners may focus on this term because its definition will determine whether an in-app map display via an API call reads on the claim, or if the claim requires the operating system to switch focus to a separate, foregrounded mapping application.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the process as the mapping application being "automatically presented (e.g., launches, become visible, displayed, etc.)," which could arguably cover making a map visible within the first app's UI. (’980 Patent, Abstract).
- Evidence for a Narrower Interpretation: The specification also describes a process where the first application may be "closed/minimized/reduced to a background process" when the mapping application is restored to "full view," suggesting a distinct application-switching event managed by the operating system. (’980 Patent, col. 3:12-21).
VI. Other Allegations
- Indirect Infringement: The complaint alleges Defendants induce infringement by providing the Accused Products and distributing instructions that guide customers to use them in an infringing manner. (Compl. ¶¶ 31, 48, 65). Contributory infringement is alleged on the basis that the Accused Products have special features designed for infringement that are not staple articles of commerce suitable for substantial non-infringing use. (Compl. ¶¶ 32, 49, 66).
- Willful Infringement: Willfulness allegations are based on Defendants' knowledge of the patents from the date of the complaint's filing. (Compl. ¶¶ 33, 50, 67). The complaint further alleges, on information and belief, that Defendants have a "policy or practice of not reviewing the patents of others," constituting willful blindness. (Compl. ¶¶ 34, 51, 68).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural mapping: does the software architecture of the U-Haul App align with the specific, multi-part structure recited in the asserted claims? The case may turn on factual evidence of whether the app contains a distinct "mapping component" that "invokes" a separate "mapping application," or if it operates as a more integrated system.
- A second key issue will be one of claim scope: the dispute will likely center on the proper construction of the term "invokes." Resolution of this issue will determine whether the claims require a full operating system-level switch to a separate mapping program (e.g., Apple Maps or Google Maps) or if they can be read more broadly to cover an API call that renders a map within the U-Haul App's own user interface.
- A final evidentiary question will be one of intent: to support the willfulness claim, a central challenge for the Plaintiff will be to produce evidence substantiating its "information and belief" allegation that Defendants maintained a policy of willful blindness towards the patent rights of others.