DCT

2:25-cv-01049

AGIS Software Development LLC v. Geo Track Labs Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01049, E.D. Tex., 10/17/2025
  • Venue Allegations: Venue is alleged to be proper in any U.S. judicial district because Defendant is not a resident of the United States.
  • Core Dispute: Plaintiff alleges that Defendant’s family location-sharing mobile applications infringe four patents related to methods for creating and managing ad hoc, password-protected digital networks for communication and location tracking.
  • Technical Context: The technology enables groups of users with mobile devices to form temporary, secure networks to share real-time GPS locations and other data on a map, a system originally envisioned for coordinating first responders and military personnel.
  • Key Procedural History: The complaint notes that all four patents-in-suit have undergone and survived Ex Parte Reexamination proceedings at the U.S. Patent and Trademark Office, with all originally issued claims being confirmed as valid and patentable.

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 Issues
2016-10-11 U.S. Patent No. 9,467,838 Issues
2017-08-29 U.S. Patent No. 9,749,829 Issues
2017-11-14 U.S. Patent No. 9,820,123 Issues
2021-05-27 Ex Parte Reexamination Certificate Issues for ’838 Patent
2021-06-08 Ex Parte Reexamination Certificate Issues for ’251 Patent
2021-08-16 Ex Parte Reexamination Certificate Issues for ’829 Patent
2021-09-24 Ex Parte Reexamination Certificate Issues for ’123 Patent
2025-08-27 Accused Product "Updated on" Date noted in Complaint
2025-10-17 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 (Issued Sep. 13, 2016)

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge faced by emergency responders and military units in establishing rapid, temporary, and secure communication networks at the scene of a disaster or operation. Conventional systems often lack the ability for different organizations (e.g., police and fire departments) to easily cross-communicate and share situational awareness data like unit locations without significant pre-coordination (’251 Patent, col. 2:7-39).
  • The Patented Solution: The invention proposes a system where users on mobile devices (e.g., PDAs or cell phones) can join a password-protected network hosted on a central server simply by entering the server's IP address and an agreed-upon network name. Once joined, each device transmits its GPS location and status to the server, which then forwards this information to all other participants in the network, enabling a real-time common operating picture on each user's map display (’251 Patent, Abstract; col. 2:51-67). This server-mediated architecture removes the need for participants to pre-configure their devices with the contact details of other users (’251 Patent, col. 4:10-14).
  • Technical Importance: This method simplifies the creation of dynamic, secure command-and-control networks for groups that need to coordinate in fluid environments without prior technical setup (’251 Patent, col. 2:7-12).

Key Claims at a Glance

  • Independent Claim Asserted: Claim 24 (a system claim) (Compl. ¶22).
  • Essential Elements of Claim 24:
    • A first device programmed to perform operations comprising:
    • Receiving a message from a second device relating to joining a group.
    • Based on receiving the message, participating in the group by sending its own location information to a server and receiving location information of other group devices from the server.
    • Presenting a first interactive, georeferenced map with user-selectable symbols showing the locations of the other devices.
    • Sending a request to the server for a second, different georeferenced map and receiving it.
    • Presenting the second georeferenced map with the user symbols.
    • Identifying user interaction with a symbol to specify an action, and based thereon, using an Internet Protocol to send data to the corresponding second device via the server, where the first device lacks access to the second device's IP address.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,467,838 - Method to Provide Ad Hoc and Password Protected Digital and Voice Networks (Issued Oct. 11, 2016)

The Invention Explained

  • Problem Addressed: This patent, from the same family as the ’251 Patent, addresses the same problem of enabling rapid formation of temporary, secure communication networks for coordinating groups like first responders, who often struggle with interoperability between different organizations (’838 Patent, col. 2:7-39).
  • The Patented Solution: The solution is substantively identical to that described in the ’251 Patent, centering on a server-mediated system where users join a password-protected group to share GPS location and status information on a common map display. The core concept is creating a temporary common operating picture without requiring users to pre-enter each other's contact information or IP addresses (’838 Patent, Abstract; col. 2:51-67).
  • Technical Importance: The technology provides a streamlined method for establishing situational awareness among disparate groups in dynamic, unstructured environments (’838 Patent, col. 2:7-12).

Key Claims at a Glance

  • Independent Claim Asserted: Claim 54 (a system claim) (Compl. ¶31).
  • Essential Elements of Claim 54:
    • 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 exchanging location information with a first server.
    • Presenting a first interactive, georeferenced map with a first set of symbols for other group devices.
    • Sending a request to a second server for second, different georeferenced map data and receiving that data.
    • Presenting a second georeferenced map with a second set of symbols.
    • Identifying user interaction with symbols to specify an action and, based thereon, sending data to the selected devices via the first server.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 9,820,123 - Method to Provide Ad Hoc and Password Protected Digital and Voice Networks (Issued Nov. 14, 2017)

  • Patent Identification: U.S. Patent No. 9,820,123, “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (Compl. ¶9).
  • Technology Synopsis: This patent describes a similar system for ad hoc location-sharing networks. The asserted claim adds specific detail on how a user selects another participant's icon on the map display, claiming a method of identifying the symbol nearest to the coordinates where the user touches the screen (’123 Patent, col. 15:25-col. 16:1). This "nearest neighbor" selection logic is a key element of the patented method.
  • Asserted Claims: Independent Claim 23 (Compl. ¶40).
  • Accused Features: The complaint alleges that the Accused Products' functionality of allowing a user to tap on or near a symbol on the map to select that user infringes the claimed "nearest symbol" search method (Compl. ¶¶43-44).

U.S. Patent No. 9,749,829 - Method to Provide Ad Hoc and Password Protected Digital and Voice Networks (Issued Aug. 29, 2017)

  • Patent Identification: U.S. Patent No. 9,749,829, “Method to Provide Ad Hoc and Password Protected Digital and Voice Networks” (Compl. ¶10).
  • Technology Synopsis: This patent also covers the core ad hoc networking technology. The asserted claim is framed from the perspective of a device receiving and accepting an invitation to join a group. It further includes steps related to one device remotely controlling another, where a user sends a message via the server that causes the recipient's device to perform a specified action (’829 Patent, col. 17:54-col. 18:4).
  • Asserted Claims: Independent Claim 34 (Compl. ¶49).
  • Accused Features: The complaint alleges that the Accused Products' process of one user accepting another's invitation to join a group infringes the claim. It also makes a general allegation that the products permit sending messages related to remote control (Compl. ¶¶52-53).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are identified as "Family Locator and Find my Phone – Family Locator mobile applications," along with associated desktop applications, web applications, servers, and services (Compl. ¶17).

Functionality and Market Context

  • The complaint alleges the Accused Products are location-sharing applications that allow users to form or join groups (e.g., a "family") to stay connected and ensure safety (Compl. ¶¶18, 26). Key functionalities described include real-time location tracking on a private map, viewing location history, and private chat channels (Compl. ¶26). A support page screenshot shows that new members can be added to a family group via an invitation code, a process mediated by the application's servers (Compl. p. 14). The complaint provides an app store screenshot indicating the application has over 10 million downloads (Compl. p. 7).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,445,251 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; A user receives an invitation message from another user to join a "family" group within the app (Compl. p. 14). ¶26 col. 10:40-45
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... After joining, the user's device sends its location to a server and receives the locations of other group members for display. ¶26 col. 2:60-67
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 at respective positions... The app displays a map showing icons representing each group member at their respective real-time locations (Compl. p. 12). ¶26 col. 6:40-49
sending, from the first device to the server, a request for a second georeferenced map different from the first georeferenced map...; receiving, from the server, the second georeferenced map... A user moving or zooming the map screen is alleged to constitute a request for a new or different map from the server, which the server then provides. ¶26 col. 4:39-41
identifying user interaction with the interactive display selecting one or more of the user-selectable symbols... specifying an action and, based thereon, using an Internet Protocol to send data to the one or more second devices via the server... A user selects another user's symbol on the map and initiates a communication, such as a private chat message, which is sent through the application's server to the other user's device (Compl. p. 7). ¶26 col. 7:8-14
wherein the first device does not have access to respective Internet Protocol addresses of the second devices. The communication between devices is alleged to be mediated by the server, without a direct peer-to-peer connection that would expose the IP addresses of the participants to each other. ¶26 col. 3:15-24
  • Identified Points of Contention:
    • Scope Questions: Does the term "group" as used in the patent, which is described in the context of temporary, ad-hoc emergency networks, read on the more persistent "family" groups created in the accused consumer application?
    • Technical Questions: Does a user panning or zooming a map in the accused app constitute a "request for a second georeferenced map different from the first," as required by the claim, or is it merely a request for additional data tiles for a single, continuous map?
    • Evidentiary Questions: What evidence does the complaint provide that communication is handled "via the server" in a way that prevents one device from having "access to [the] Internet Protocol addresses of the second devices"?

U.S. Patent No. 9,467,838 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; A user joins a group by sending a message, such as by using an "Invitation code," which serves as a group identifier (Compl. p. 14). ¶35 col. 10:40-45
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... Once in the group, the device sends its location to a server and receives location information for other group members from that server. ¶35 col. 2:60-67
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 app displays a map with icons for group members at their locations (Compl. p. 8). ¶35 col. 6:40-49
sending, to a second server, a request for second georeferenced map data different from the first georeferenced map data; receiving, from the second server, the second georeferenced map data; A user moving the map screen or selecting a different map type (e.g., satellite) is alleged to request different map data from a server. ¶35 col. 4:39-41
identifying user interaction with the interactive display selecting one or more of the second set of user-selectable symbols... specifying an action and, based thereon, sending third data to the selected one or more second devices via the first server. A user selects another user's icon and initiates an action, such as sending a chat message, which is transmitted via the server. ¶35 col. 7:8-14
  • Identified Points of Contention:
    • Scope Questions: Similar to the ’251 patent, a central question may be whether the claim's scope is limited by the specification's focus on temporary, ad-hoc networks for professional use.
    • Technical Questions: Does requesting new map tiles while panning qualify as requesting "second georeferenced map data different from the first," or does this language require a more discrete change, such as switching map layers or types? The complaint's allegations appear to cover both possibilities (Compl. ¶35).

V. Key Claim Terms for Construction

For the ’251 Patent:

  • The Term: "a second georeferenced map different from the first georeferenced map"
  • Context and Importance: This term is critical because infringement hinges on the allegation that users request and receive different maps, which the complaint links to common actions like panning and zooming. The defendant may argue that such actions involve retrieving new data for a single, continuous map, not requesting a discretely "different" map.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses requesting "maps, satellite images, and the like" from a server, suggesting that different types of map data or data for different geographical areas could be considered distinct maps (’251 Patent, col. 4:39-41).
    • Evidence for a Narrower Interpretation: The claim language "a second... map different from the first" could be interpreted to require two distinct map objects, rather than a seamless stream of data tiles for a single map interface. The patent does not explicitly define what constitutes a "different" map.

For the ’838 Patent:

  • The Term: "joining a communication network corresponding to a group"
  • Context and Importance: The construction of this term may determine whether the patent's scope is limited to the temporary, emergency-response context described in the specification or can extend to the persistent, consumer-oriented "family groups" of the accused product. Practitioners may focus on this term to argue for or against limitation of the claims by the specification's disclosure.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad and does not contain temporal or contextual limitations like "ad hoc" or "emergency." It recites a technical process of joining a network that could apply in any context.
    • Evidence for a Narrower Interpretation: The Abstract, Background, and Summary of the Invention sections of the patent heavily emphasize the problem of coordinating "Military, first responder, and other public and private emergency groups" in "temporary" networks at the "scene of a disaster" (’838 Patent, Abstract; col. 2:7-20). This context could be used to argue for a narrower construction of the claim terms.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all four patents. The factual basis for this allegation is Defendant's purported creation and distribution of "training videos, demonstrations, brochures, installations, and/or user guides" that allegedly instruct customers on how to use the Accused Products in a manner that performs the claimed methods (Compl. ¶¶19, 23, 32, 41, 50).
  • Willful Infringement: The complaint alleges that Defendant has had knowledge of its infringement "since at least the issuance date of the Patents-in-Suit" (Compl. ¶16). The prayer for relief requests a judgment that the infringement has been "willful and deliberate" and seeks treble damages (Compl. p. 30-31, ¶¶b, e).

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

  • A core issue will be one of definitional scope: can the claims, which are described in the patents' specifications as solving problems for temporary, ad-hoc emergency response networks, be construed broadly enough to cover the persistent, consumer-focused "family group" functionality of the accused location-sharing application?
  • A key evidentiary question will be one of technical implementation: does the accused product's method for handling map data (e.g., panning and zooming) and selecting user icons meet the specific, multi-step functional requirements of the asserted claims, such as requesting a "different" map or using a "nearest symbol" search algorithm?