AGIS Software Development LLC v. Bridgestone Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AGIS Software Development LLC (Texas)
  • Defendant: Bridgestone Corporation (Japan) and Bridgestone Mobility Solutions B.V. (Netherlands)
  • Plaintiff’s Counsel: Fabricant LLP; Truelove Law Firm, PLLC
• Case Identification: 2:25-cv-00938, E.D. Tex., 09/05/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants are not U.S. residents and may be sued in any judicial district. Alternatively, Plaintiff alleges Defendants have regular and established places of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s fleet management platforms, Webfleet and Azuga, infringe four patents related to methods for providing ad hoc, server-mediated, and password-protected digital communication networks.
• Technical Context: The technology enables groups of users with mobile devices to securely share real-time location and status information on a map, facilitating situational awareness and coordination for applications like emergency response and vehicle fleet management.
• Key Procedural History: The complaint notes that all four patents-in-suit previously underwent Ex Parte Reexamination at the U.S. Patent and Trademark Office, and that the claims asserted in this litigation were confirmed to be valid and patentable. This history may be raised by the Plaintiff to suggest the patents' durability against invalidity challenges.

Case Timeline

Date	Event
2004-09-21	Earliest Priority Date for all Patents-in-Suit
2016-09-13	U.S. Patent No. 9,445,251 Issued
2016-10-11	U.S. Patent No. 9,467,838 Issued
2017-08-29	U.S. Patent No. 9,749,829 Issued
2017-11-14	U.S. Patent No. 9,820,123 Issued
2021-05-27	Ex Parte Reexamination Certificate Issued for ’838 Patent
2021-06-08	Ex Parte Reexamination Certificate Issued for ’251 Patent
2021-08-16	Ex Parte Reexamination Certificate Issued for ’829 Patent
2021-09-24	Ex Parte Reexamination Certificate Issued for ’123 Patent
2025-09-05	Complaint Filed

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

U.S. Patent No. 9,445,251 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (’251 Patent)

The Invention Explained

• Problem Addressed: The patent describes the difficulty of coordinating different organizations, such as police and fire departments, during a disaster because their respective communication systems are often incompatible, preventing effective "cross communication" (Compl. ¶13; ’251 Patent, col. 2:21-36). Traditional systems often require pre-entry of user data, which is impractical in rapidly evolving emergency situations (’251 Patent, col. 2:11-18).
• The Patented Solution: The invention provides a system where users can quickly form a temporary, password-protected communication network using mobile devices. A central server manages the network, receiving GPS location and status from each participant and forwarding it to all other group members, allowing their positions to be displayed as symbols on an interactive map (’251 Patent, col. 3:15-28, Fig. 5). This server-mediated architecture allows users to join a network and coordinate activities without needing to know each other's phone numbers or IP addresses in advance (’251 Patent, col. 4:6-14).
• Technical Importance: This approach aimed to lower the barrier to establishing secure, interoperable command-and-control networks, making advanced situational awareness tools accessible for temporary groups in emergency or tactical scenarios (’251 Patent, col. 2:37-49).

Key Claims at a Glance

• Independent Claim 24 is asserted (Compl. ¶23).
• Claim 24 is a system claim directed to a "first device" programmed to perform operations comprising:
  • Receiving a message from a second device relating to joining a group.
  • Participating in the group, which includes sending its own location to a server and receiving the locations of other devices in the group from the server.
  • Presenting a first interactive, georeferenced map with user-selectable symbols showing the locations of the other group devices.
  • Sending a request to the server for a second, different georeferenced map.
  • Receiving and presenting the second georeferenced map with the user-selectable symbols repositioned accordingly.
  • Identifying user interaction with a symbol to specify an action, and based thereon, using an Internet Protocol to send data to the selected device(s) via the server, where the first device does not have access to the IP addresses of the other devices.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,467,838 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (’838 Patent)

The Invention Explained

• Problem Addressed: Similar to the ’251 Patent, the ’838 Patent addresses the need for rapid, ad hoc network formation for coordinating groups like first responders who use different communication systems, a significant challenge during large-scale emergencies (’838 Patent, col. 2:17-34).
• The Patented Solution: The invention describes a system where a user's device joins a group-specific communication network by transmitting a message with a group identifier to a server. Once in the group, the device sends its location to the server and receives location data for other group members, which are then displayed as symbols on a map (’838 Patent, col. 2:50-3:5). This server-based system facilitates secure, real-time collaboration without requiring devices to directly connect to one another (’838 Patent, Fig. 5).
• Technical Importance: The technology provides a framework for creating temporary, secure, and interoperable communication networks that support shared situational awareness on mobile devices, a key capability for coordinated field operations (’838 Patent, col. 2:35-46).

Key Claims at a Glance

• Independent Claim 54 is asserted (Compl. ¶32).
• Claim 54 is a system claim directed to a "first device" programmed to perform operations comprising:
  • Joining a communication network for a group by transmitting a message with a group identifier.
  • Participating in the group by sending its location to a first server and receiving locations of other group devices from the server.
  • Presenting a first interactive, georeferenced map with a first set of user-selectable symbols showing the locations of other group devices.
  • Sending a request to a second server for a different georeferenced map.
  • Receiving and presenting the second georeferenced map with a second set of symbols.
  • Identifying user interaction selecting a symbol and specifying an action, and based thereon, sending data to the selected device(s) via the first server.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,820,123 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (’123 Patent)

• Technology Synopsis: The patent discloses a system for mobile devices to join and participate in secure, server-mediated groups for sharing location information on interactive maps. A key aspect involves identifying a user's selection of a symbol on the map by searching for the nearest symbol to the coordinates of the user's touch on the display, enabling interaction with specific group members (’123 Patent, Abstract; col. 15:19-39).
• Asserted Claims: At least Claim 23 is asserted (Compl. ¶41).
• Accused Features: The complaint alleges that the Accused Products' functionalities for establishing groups, displaying user locations as symbols on a map, and allowing users to interact with those symbols infringe the ’123 Patent (Compl. ¶44-45).

U.S. Patent No. 9,749,829 - “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (’829 Patent)

• Technology Synopsis: The patent describes a system where a second device can request to join a group that includes a first device. The system allows for repeated sharing of location information and remote control operations between group members, mediated by a server. It also details receiving updated location information and repositioning a corresponding symbol on a map display (’829 Patent, Abstract; col. 17:60-18:19).
• Asserted Claims: At least Claim 34 is asserted (Compl. ¶50).
• Accused Features: The complaint alleges that the Accused Products' features for forming and joining groups, sharing location information, displaying and updating user symbols on a map, and enabling remote interaction infringe the ’829 Patent (Compl. ¶53-54).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the "Webfleet and Azuga" fleet management platforms, including their associated software applications (e.g., Webfleet mobile, Webfleet work app, Azuga mobile), servers, and configured mobile devices (Compl. ¶18).

Functionality and Market Context

The complaint alleges the Accused Products provide real-time vehicle and asset tracking, allowing fleet managers to see vehicle locations on a map (Compl. ¶19, p. 8). A screenshot from a Webfleet video demonstrates a map view showing multiple vehicles and their status across a wide geographic area (Compl. p. 10). The products are alleged to include functionalities for forming and joining groups, displaying map information with symbols for users, sharing locations, and communicating via text or other messages (Compl. ¶¶19, 27). Additional screenshots show features for creating vehicle groups, sending predefined messages, and setting up alerts, which allegedly support these capabilities (Compl. p. 14).

IV. Analysis of Infringement Allegations

’251 Patent Infringement Allegations

Claim Element (from Independent Claim 24)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first device programmed to perform operations comprising: receiving a message from a second device, wherein the message relates to joining a group;	The Accused Products are configured to allow devices to establish and join groups and to exchange messages for that purpose via servers.	¶26-27	col. 9:36-46
based on receiving the message from the second device, participating in the group, wherein participating in the group includes sending first location information to a server and receiving second location information from the server...	Once in a group, a user's device sends its location information to a server and receives location information of other group members for display on a map.	¶26-27	col. 3:15-28
presenting, via an interactive display of the first device, a first interactive, georeferenced map and a plurality of user-selectable symbols corresponding to the plurality of second devices, wherein the symbols are positioned on the first georeferenced map...	The Accused Products display interactive maps with symbols representing the real-time locations of other users, vehicles, or assets in the fleet or group. A screenshot depicts such a map with multiple vehicle icons.	¶19, 26, p. 10	col. 6:38-59
sending, from the first device to the server, a request for a second georeferenced map different from the first georeferenced map, wherein the request specifies a map location;	The system allows users to retrieve different map information from multiple sources, for example by moving the map screen or selecting different map types.	¶26-27	col. 4:38-44
using an Internet Protocol to send data to the one or more second devices via the server, wherein the first device does not have access to respective Internet Protocol addresses of the second devices.	User interaction with a symbol on the map allegedly permits data to be sent to other devices, with the communication being mediated by a server such that devices do not have direct IP-level access to each other.	¶26-27	col. 4:6-14

Identified Points of Contention

• Scope Questions: A central question may be whether the accused products' features for filtering vehicles or creating administrative groupings constitute "joining a group" and "participating in the group" as those terms are used in the patent. The defense may argue that these are passive monitoring functions, whereas the patent specification suggests a more active, collaborative network context (e.g., for first responders).
• Technical Questions: The complaint alleges a server-mediated architecture where client devices do not have access to each other's IP addresses. A key technical question will be whether the Accused Products' architecture actually operates in this manner, or if there are circumstances where peer-to-peer or direct IP communication occurs.

’838 Patent Infringement Allegations

Claim Element (from Independent Claim 54)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first device programmed to perform operations comprising: joining a communication network corresponding to a group, wherein joining the communication network comprises transmitting a message including an identifier corresponding to the group;	The Accused Products are configured to allow users to establish and join groups by exchanging messages with servers, which function as joining a communication network.	¶35-36	col. 10:39-46
participating in the group, wherein participating in the group includes sending first location information to a first server and receiving second location information from the first server...	After joining, devices send their location to a server and receive location data of other group members, which enables shared situational awareness.	¶35-36	col. 3:15-28
presenting, via an interactive display of the first device, a first interactive, georeferenced map and a first set of one or more user-selectable symbols corresponding to a first set of one or more of the second devices...	The products display maps showing symbols that correspond to the locations of other devices or vehicles in the user's group or fleet.	¶35-36	col. 6:38-59
sending, to a second server, a request for second georeferenced map data different from the first georeferenced map data;	The system permits users to request and display additional maps, for example by moving the map screen or selecting different map layers or sources.	¶35-36	col. 4:38-44
identifying user interaction with the interactive display selecting one or more of the second set of user-selectable symbols... and... sending third data to the selected one or more second devices via the first server.	The system allegedly permits a user to select one or more symbols on the map and, based on that interaction, send data to the corresponding devices via the server. A screenshot shows a messaging interface integrated with the map view.	¶35-36, p. 18	col. 7:8-14

Identified Points of Contention

• Scope Questions: The claim requires sending a request to a "second server" for different map data. The infringement analysis may turn on whether the accused architecture uses distinct servers for location data versus map data in a way that maps to this limitation, or if a single server or server cluster handles both functions.
• Technical Questions: Similar to the ’251 patent analysis, a key question will be the precise technical nature of "joining a group." What specific messages are transmitted, and does the act of applying a display filter in the accused products meet the claim requirement of "transmitting a message including an identifier corresponding to the group"?

V. Key Claim Terms for Construction

• The Term: "participating in the group" (’251 Patent, Claim 24)

  • Context and Importance: This term is central because infringement hinges on whether the accused products' functions—such as a fleet manager viewing vehicles on a map—constitute "participating." The Plaintiff will likely argue this term broadly covers being part of the location-sharing system, while the Defendant may argue it requires more active, mutual collaboration as contemplated by the patent's first-responder examples.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim itself defines participation as including the acts of "sending first location information to a server and receiving second location information from the server," suggesting the core technical exchange is what defines participation (’251 Patent, col. 18:66-19:2).
    • Evidence for a Narrower Interpretation: The specification's detailed examples focus on coordination among emergency units (e.g., the "Katrina Fire" network) where all members are active collaborators (’251 Patent, col. 11:4-12). This context may support an interpretation requiring mutual, real-time interaction rather than passive monitoring.

• The Term: "user-selectable symbol" (’251 Patent, Claim 24; ’838 Patent, Claim 54)

  • Context and Importance: The claims require presenting and interacting with these symbols. The dispute may focus on whether the vehicle icons in the accused products, which a user can click on to get more information or send a message, meet this definition. Practitioners may focus on this term to determine if it requires more than a simple clickable map icon.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes symbols as representing "communication net participants having cellular phones" and being associated with location data, which aligns with the general function of map icons in a tracking system (’251 Patent, col. 6:61-64).
    • Evidence for a Narrower Interpretation: The specification details that selecting a symbol can bring up a "matrix of layered software switches" to perform functions like initiating calls or sending data (’251 Patent, col. 6:38-43). This could support a narrower construction requiring the symbol to be a gateway to a specific, multi-function control interface, not just a simple information pop-up.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant instructs its customers on how to use the infringing features through publicly available "training videos, demonstrations, brochures, installations, and/or user guides" (Compl. ¶¶24, 33, 42, 51). The complaint provides numerous URLs to such materials (Compl. ¶20, pp. 23-24).
• Willful Infringement: The complaint alleges that Defendant has had knowledge of the patents "since at least the issuance date of the Patents-in-Suit" (Compl. ¶17). The prayer for relief requests a judgment that infringement has been "willful and deliberate" (Compl. p. 38, ¶b).

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

• A core issue will be one of definitional scope: can terms rooted in the patent's context of ad hoc, collaborative networks for first responders, such as "joining a group" and "participating in the group," be construed to cover the features of a commercial fleet management system where the primary interaction may be one of administrative monitoring?
• A second key issue will be one of architectural mapping: do the Accused Products' client-server architectures practice the specific communication pathways claimed in the patents, particularly the requirements for server-mediated data exchange where client devices lack IP addresses of other clients, and the potential use of a "second server" for map data?
• A third question will be evidentiary: given the successful Ex Parte Reexaminations of all four patents, the dispute may focus heavily on the factual evidence of infringement, requiring a detailed technical comparison of how the Accused Products actually function against the specific limitations recited in the asserted claims.