DCT

2:25-cv-01028

Nearby Systems LLC v. Chipotle Mexican Grill Inc

Key Events

Complaint

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Nearby Systems LLC (Texas)
- Defendant: Chipotle Mexican Grill, Inc. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
Case Identification: 2:25-cv-01028, E.D. Tex., 10/08/2025
Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains regular and established places of business within the Eastern District of Texas and has committed acts of patent infringement in the District.
Core Dispute: Plaintiff alleges that Defendant’s Chipotle App infringes four patents related to combining and displaying mapping content from disparate sources on a mobile device's digital map.
Technical Context: The technology concerns integrating location-based data from various mobile applications (e.g., social media, email) onto a single, persistent map, enhancing user experience by preserving context.
Key Procedural History: The asserted patents form a family descending from a common parent application. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving these patents.

Case Timeline

Date	Event
2007-10-12	Earliest Priority Date for all Asserted Patents
2016-12-27	U.S. Patent No. 9,532,164 Issues
2019-11-05	U.S. Patent No. 10,469,980 Issues
2024-03-19	U.S. Patent No. 11,937,145 Issues
2024-12-31	U.S. Patent No. 12,185,177 Issues
2025-10-08	Complaint Filed

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

U.S. Patent No. 9,532,164 - Mashing Mapping Content Displayed On Mobile Devices

The Invention Explained

Problem Addressed: The patent identifies a limitation in prior art mobile mapping services where new mapping content originating from outside a mapping application (e.g., an address in an email) could only be displayed on a new digital map, which would not contain any previously displayed information, thereby losing the user's original mapping context (U.S. Patent No. 9532164, col. 1:31-39).
The Patented Solution: The invention provides a system where "map-able content" from a first application can be used to invoke a second, separate mapping application. This allows the new location information to be displayed on the same digital map that may already contain existing points of interest, preserving the user's context by "mashing" or combining data from different sources onto a single map view (’164 Patent, col. 2:40-53; Figs. 1A-1C).
Technical Importance: This approach allows for a more integrated and seamless user experience, preventing the need to toggle between different map views or re-enter location data when moving between applications that contain geographic information (’164 Patent, Abstract).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶26).
Essential elements of claim 1 include:
- A memory of a mobile device storing a first non-browser application and a second non-browser application.
- A processor executing both applications.
- A mapping component of the first non-browser application configured to invoke the second non-browser application when map-able content is activated.
- The second non-browser application is a mapping application.
- The mapping component transmits the map-able content to an online mapping service that communicates with the second non-browser 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

The Invention Explained

Problem Addressed: Similar to its parent '164 patent, the '980 patent addresses the problem of new mapping content from one application causing a new, separate map to be generated, which "does not contain any other mappable information previously displayed" (U.S. Patent No. 10469980, col. 1:35-39).
The Patented Solution: The '980 patent describes a system on a mobile device with a GPS. A "mapping component" within a first non-browser application communicates with an online mapping service to display a map based on the device's location. This component can then invoke a second, separate mapping application to transmit a query for driving directions to a destination, overlaying this new information on the map (’980 Patent, col. 2:40-53, cl. 1).
Technical Importance: The invention aims to streamline the process of obtaining directions from within a non-mapping application by integrating the device's current location and invoking a dedicated mapping application to perform the routing calculation and display (’980 Patent, Abstract).

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶43).
Essential elements of claim 1 include:
- A memory storing a first non-browser application and a second non-browser mapping application.
- A GPS device determining the mobile device's location.
- A mapping component of the first non-browser application that communicates with an online mapping service to display a map based on the device's location.
- The mapping component invokes the second non-browser mapping application.
- The mapping component directs the mapping application to transmit a query (including the device location and a destination) to the online mapping service to obtain 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

Technology Synopsis: Continuing the theme of the patent family, this patent discloses a system for displaying location-based content. Upon a user's touch of text corresponding to a location icon on a map in a first non-browser application, the system transmits a query to an online mapping service and displays a second map in a second non-browser application showing a route from the mobile device's location to the icon's location (U.S. Patent No. 11937145, cl. 1).
Asserted Claims: At least independent claim 1 (Compl. ¶60).
Accused Features: The complaint alleges the Chipotle App provides a "system and method for displaying map information on a mobile device" that infringes (Compl. ¶61).

U.S. Patent No. 12,185,177 - Mashing Mapping Content Displayed On Mobile Devices

Technology Synopsis: This patent claims a system where a first non-browser application displays a map with points of interest. User selection of a point of interest causes a "mapping component" to transmit a query to an online mapping service, which in turn causes a second non-browser application to display a new map of the selected point of interest (U.S. Patent No. 12185177, cl. 1).
Asserted Claims: At least independent claim 1 (Compl. ¶77).
Accused Features: The complaint accuses the Chipotle App's system for displaying map information used to identify and navigate to store locations (Compl. ¶78).

III. The Accused Instrumentality

Product Identification

The "Chipotle App," which is a mobile device application made available by Defendant for download through the Apple App Store and Google Play Store (Compl. ¶¶16-17).

Functionality and Market Context

The complaint alleges the Accused Products are designed to allow customers to locate Defendant's stores, manage accounts, and place orders (Compl. ¶18). The core accused functionality is the provision of a "system and method for displaying map information on a mobile device... to obtain the data to display text and maps that present information to allow a mobile device user to identify and navigate to locations offering Defendant's products" (Compl. ¶27). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references Exhibits G and H, which purport to contain exemplary evidence of infringement for the ’164 and ’980 patents, respectively (Compl. ¶¶26, 43). As these exhibits were not provided, a claim chart summary cannot be constructed. The narrative infringement theory is summarized below.

’164 Patent Infringement Allegations: The complaint alleges that the Chipotle App provides a system for displaying map information on a mobile device that infringes claim 1 (Compl. ¶27). The theory suggests the Chipotle App functions as the "first non-browser application" whose "mapping component" transmits location data to an online service and invokes a "second non-browser application" to display the map with combined content.
’980 Patent Infringement Allegations: The complaint puts forth a similar theory for the ’980 patent, alleging the Chipotle App provides a system for displaying map information that allows users to identify and navigate to store locations (Compl. ¶44). The infringement read appears to be that the Chipotle App (the first application) uses its mapping component to invoke a separate mapping application (the second application) to obtain and display driving directions.
Identified Points of Contention:
- Architectural Questions: A central question may be whether the Chipotle App's architecture matches the claimed two-application structure. Does the Chipotle App, as the alleged "first non-browser application," contain a "mapping component" that "invokes" a separate "second non-browser application" (e.g., Apple Maps or Google Maps) as required by the claims? Or, does the Chipotle App utilize an integrated mapping framework (e.g., an SDK) that operates within the confines of the single Chipotle App, potentially raising a question of whether the "second non-browser application" limitation is met?
- Scope Questions: The construction of "mapping component" will be pivotal. Practitioners may observe that the claims describe this component as part of the "first non-browser application" but also as the entity that "invokes" the second application and "transmits" data to an online service. The court may need to determine if this component is merely an API call or if it must be a more substantial, distinct software module within the first application.

V. Key Claim Terms for Construction

The Term: "mapping component" (’164 Patent, cl. 1; ’980 Patent, cl. 1)
Context and Importance: This term appears in the independent claims of both lead patents and defines the software element responsible for bridging the two claimed applications. Its construction will be critical to determining if the accused app's architecture infringes, as the dispute may center on whether an API call to a mapping SDK constitutes the claimed "mapping component."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the component could be a "top-most application appearing on top of other applications, allowing the user to drag-and-drop," an "ActiveX control," or a "widget," implying it can take various forms (’980 Patent, col. 4:18-24). This may support an interpretation that covers a range of software integrations, including SDKs or APIs.
- Evidence for a Narrower Interpretation: Figure 10A shows "MAPPING COMPONENT" (1002) as a distinct block within the "computing device" (1000) and separate from the "DISPLAY APPLICATION" (1004), which in turn communicates with a remote "MAPPING APPLICATION" (1010) (’980 Patent, Fig. 10A). This could support a narrower reading requiring a structurally separate and distinct module, not just an integrated function call.
The Term: "invokes the second non-browser application" (’164 Patent, cl. 1) / "invokes the mapping application" (’980 Patent, cl. 1)
Context and Importance: This action is central to the claimed two-application system. The infringement analysis will likely turn on what technical action constitutes "invoking." If the Chipotle App displays a map within its own user interface via an SDK, the question will be whether this is "invoking" a separate application or merely using a library within the same application.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes a scenario where a mapping application may be "closed/minimized/reduced to a background process" when the first application is opened, and then "restored into full view" to display new data (’164 Patent, col. 3:11-21). This language of process management could support a broad definition of "invoke" that includes bringing a backgrounded application to the foreground.
- Evidence for a Narrower Interpretation: The specification also discusses launching a "new instance" of a display application or causing an application to "launch" (’164 Patent, col. 6:10, col. 9:30-31). This may support a narrower interpretation requiring the operating system to start a new process or fully switch the user context to a distinct, separate application, rather than simply drawing a map within the first application's view.

VI. Other Allegations

Indirect Infringement: For all asserted patents, the complaint alleges induced infringement based on Defendant's actions of "advising or directing customers," "advertising and promoting," and "distributing instructions that guide users" to use the Chipotle App in an infringing manner (e.g., Compl. ¶28). Contributory infringement is alleged on the basis that the Accused Products have "special features that are specially designed to be used in an infringing way and that have no substantial uses other than ones that infringe" (e.g., Compl. ¶29).
Willful Infringement: Willfulness is alleged for all asserted patents, based on Defendant having knowledge of the patents "at least as of the date it was notified of the filing of this action" (e.g., Compl. ¶30). The complaint further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (e.g., Compl. ¶31).

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

This case will likely hinge on questions of technical and architectural correspondence between the accused app and the specific claim language. The central issues for the court may be:

A core issue will be one of architectural scope: does the "two non-browser application" structure recited in the claims require two distinct, separately executing applications from the user's and operating system's perspective, or can it be satisfied by a single application that integrates mapping functionality through a software development kit (SDK)?
A key evidentiary question will be one of functional operation: what technical mechanism does the Chipotle App employ to display maps and directions? The case may turn on whether the evidence shows the app "invokes" a separate mapping application process, as the patents describe, or if it simply makes API calls to a mapping service and renders the results within its own interface.
A related question of claim construction will be central: what is the scope of a "mapping component" that is part of a first application but also "invokes" and "directs" a second, separate application? The definition of this term will likely determine whether the claims read on modern mobile app development practices.