DCT
2:25-cv-01068
Nearby Systems LLC v. JPMorgan Chase & Co
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Nearby Systems LLC (Texas)
- Defendant: JPMorgan Chase & Co. (Delaware)
- Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:25-cv-01068, E.D. Tex., 10/24/2025
- 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 Chase Mobile App infringes four patents related to integrating and displaying mapping content from disparate sources on mobile devices.
- Technical Context: The technology at issue involves methods for taking location-based information from one software application and displaying it on a map within a separate mapping application, preserving the context of previously displayed information.
- Key Procedural History: The four asserted patents are part of a single family connected through a series of continuation and continuation-in-part applications. This shared lineage and specification suggests that claim construction arguments and outcomes for one patent may be highly relevant to the others.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-12 | Earliest Priority Date for Asserted Patents |
| 2016-12-27 | U.S. Patent No. 9,532,164 Issued |
| 2019-11-05 | U.S. Patent No. 10,469,980 Issued |
| 2024-03-19 | U.S. Patent No. 11,937,145 Issued |
| 2024-12-31 | U.S. Patent No. 12,185,177 Issued |
| 2025-10-24 | Complaint Filed |
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 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, separate digital map, thereby losing the context of any information the user was previously viewing in their mapping application (’164 Patent, col. 1:29-41).
- The Patented Solution: The invention provides a system where "mappable content" from a first "non-browser application" can be selected and then displayed by a second, separate "mapping application" on the same digital map that was already in use, adding the new point of interest alongside any existing content (’164 Patent, Abstract; col. 1:42-53). Figures 1A through 1C illustrate this process, showing a map with one point of interest (Fig. 1A), then a user selecting an address in another application (Fig. 1B), and finally the new address appearing as a second point of interest on the original map (Fig. 1C) (’164 Patent, col. 2:40-67).
- Technical Importance: This approach describes a technical solution for creating a more integrated user experience, allowing location data from various sources like social media, email, or websites to be aggregated into a single, persistent map view on a mobile device (’164 Patent, col. 1:42-53).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶26).
- Essential elements of Claim 1 include:
- A system with a memory storing a first non-browser application and a second non-browser application.
- A processor for executing both applications.
- A "mapping component" within the first non-browser application.
- The mapping component is configured to "invoke" the second non-browser application when "map-able content" in the first application 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 (mapping) application.
U.S. Patent No. 10,469,980 - "Mashing Mapping Content Displayed On Mobile Devices," Issued November 5, 2019
The Invention Explained
- Problem Addressed: Stemming from the same specification as the ’164 Patent, this patent addresses the same problem: the inability of prior art systems to add location information from an external application to an already-displayed map without losing context (’980 Patent, col. 1:29-41).
- The Patented Solution: The invention provides a system on a mobile device where mappable information found in a "first non-browser application" can be sent to a "second non-browser application" that is a mapping application, which then displays the new location information in conjunction with existing map content (’980 Patent, Abstract). The solution involves communication with an online mapping service and is illustrated in figures showing the selection of an address in a social media app and its subsequent appearance on a pre-existing map (’980 Patent, Fig. 1B-1C).
- Technical Importance: The technology facilitates the aggregation of geographic data from disparate applications into a unified map view, a key function for modern location-aware mobile devices (’980 Patent, col. 1:42-53).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶43).
- Essential elements of Claim 1 include:
- A system with a memory storing a first non-browser application.
- A GPS device for determining the mobile device's location.
- A "mapping component" in the first non-browser application that communicates with an "online mapping service" to display a map.
- The mapping component transmits a query with the device's location to the online mapping service.
- The memory also stores a "second non-browser application that is a mapping application."
- The mapping component "invokes the mapping application" and directs it to transmit a query with both the device's location and a destination location to obtain "driving directions."
Multi-Patent Capsule: U.S. Patent No. 11,937,145 - "Mashing Mapping Content Displayed On Mobile Devices," Issued March 19, 2024
- Technology Synopsis: This patent, from the same family, also discloses a system for overcoming siloed mapping data on mobile devices. The invention allows location-based content from a "first non-browser application" to be selected and displayed on a map within a separate mapping application, preserving the context of any previously shown map content and potentially showing a route (Compl. ¶55; ’145 Patent, Abstract, Cl. 9).
- Asserted Claims: At least Claim 1 is asserted (Compl. ¶60). Claim 7 is also an independent claim.
- Accused Features: The complaint accuses the Chase App's functionality for displaying map information that allows users to identify and navigate to Chase locations (Compl. ¶61).
Multi-Patent Capsule: U.S. Patent No. 12,185,177 - "Mashing Mapping Content Displayed On Mobile Devices," Issued December 31, 2024
- Technology Synopsis: As another continuation, this patent describes a system for integrating location information from different applications onto a single map. The technology enables a user to select "mappable content" in one application and have it displayed by a separate mapping application on a pre-existing map view, thereby avoiding a loss of context (Compl. ¶72; ’177 Patent, Abstract).
- Asserted Claims: At least Claim 1 is asserted (Compl. ¶77).
- Accused Features: The Chase App's system for displaying map information and allowing users to navigate to locations like ATMs and branches is accused of infringement (Compl. ¶78).
III. The Accused Instrumentality
- Product Identification: The primary accused instrumentality is the "Chase Mobile: Bank & Invest App" ("Chase App"), a mobile device application provided by Defendant (Compl. ¶16, ¶18).
- Functionality and Market Context: The Chase App is alleged to be a mobile application that, among other functions, is "designed to allow Defendant's customers to locate branches and ATM" (Compl. ¶18). The complaint alleges the app provides a system for displaying map information on a mobile device, which presents information allowing a user to "identify and navigate to locations offering Defendant's products" (Compl. ¶27). The complaint references Exhibit H as "Exemplary Evidence of Use" showing this functionality (Compl. ¶27). This visual, as described, demonstrates the accused map interface for locating Chase's branches or ATMs (Compl. ¶27).
IV. Analysis of Infringement Allegations
The complaint does not contain or attach detailed claim charts. The following tables summarize the infringement theory based on the narrative allegations in the complaint.
’9,532,164 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system for displaying location-based content... comprising: a memory of a mobile device storing a first non-browser application and a second non-browser application; a processor... | The Chase App is a mobile application that runs on a mobile device with a processor and memory. | ¶18, ¶27 | col. 15:5-12 |
| a mapping component of the first non-browser application configured to invoke the second non-browser application... when map-able content displayed on the user interface is activated... | The Chase App is alleged to provide a system for displaying map information, which is activated by the user to locate Chase products. | ¶27 | col. 15:13-20 |
| wherein the second non-browser application is a mapping application... | The system provided by the Chase App allegedly involves displaying map information. | ¶27 | col. 15:21-22 |
| wherein the mapping component transmits the map-able content to an online mapping service configured to communicate with the second non-browser application. | The Chase App allegedly obtains data to display maps, suggesting communication with a mapping service. | ¶27 | col. 15:23-26 |
’10,469,980 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A system... comprising: a memory... storing a first non-browser application; a processor... a touch screen... | The Chase App is a mobile application that runs on a touch-screen mobile device with a processor and memory. | ¶18, ¶44 | col. 15:2-10 |
| a GPS device of the mobile device determining a location of the mobile device... | Mobile devices running the Chase App contain GPS devices to determine location for mapping purposes. | ¶44 | col. 15:11-12 |
| a mapping component... configured to communicate with an online mapping service to download map data and display a map within the user interface of the first non-browser application... | The Chase App displays maps of branch/ATM locations, which requires downloading map data from a service. | ¶44 | col. 15:13-18 |
| wherein the memory stores a second non-browser application that is a mapping application... | The system is alleged to allow users to "navigate to locations," which may involve a separate mapping application. | ¶44 | col. 16:21-23 |
| wherein the mapping component invokes the mapping application and directs the mapping application to transmit a query including the location of the mobile device and a destination location... to obtain driving directions... | The complaint alleges the Chase App allows users to "navigate to locations," which may be construed as obtaining driving directions via an invoked mapping application. | ¶44 | col. 16:24-32 |
Identified Points of Contention:
- Architectural Questions: The infringement theory for both the ’164 and ’980 patents appears to rely on a specific two-app architecture: a "first non-browser application" (Chase App) containing a "mapping component" that "invokes" a "second non-browser application" (a mapping app). A central question will be whether the Chase App, which likely integrates mapping using a software development kit (SDK) rather than launching a fully separate application, meets this claimed structure. The complaint does not provide specific evidence on this architectural point.
- Functional Questions: For the ’980 patent, the analysis may turn on whether the Chase App's function to "navigate to locations" (Compl. ¶44) satisfies the more specific requirement of invoking a separate mapping application to "obtain driving directions" (Cl. 1). The evidence presented will need to distinguish between simply displaying a location on an embedded map versus handing off a navigation task to a separate, dedicated application like Google Maps or Apple Maps.
V. Key Claim Terms for Construction
The Term: "mapping component" (’164 Patent, Cl. 1; ’980 Patent, Cl. 1)
- Context and Importance: The definition of this term is central to determining if the accused system has the required structure. Practitioners may focus on whether this term requires a discrete software module within the first application, or if it can be construed more broadly as any code that causes map data to be displayed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the component functionally, as one that "may receive user input containing address/location information" and "relay/transmit the received... information to display application 1004" (’980 Patent, col. 14:24-32). This could support an interpretation not tied to a specific architectural implementation.
- Evidence for a Narrower Interpretation: Figure 10A depicts "MAPPING COMPONENT" (1002) and "DISPLAY APPLICATION" (1004) as two separate boxes within a single computing device (1000), which could suggest they are distinct modules (’980 Patent, Fig. 10A).
The Term: "invokes" (’164 Patent, Cl. 1; ’980 Patent, Cl. 1)
- Context and Importance: This term's construction will be critical in determining whether the interaction between the Chase App and its mapping functionality constitutes infringement. The dispute may center on whether "invokes" requires launching a separate, distinct application process, or if it can cover displaying an embedded map view powered by an SDK within the same application.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract states the map-display application may be "automatically presented (e.g., launches, become visible, displayed, etc.)" (’980 Patent, Abstract). The inclusion of "become visible" and "displayed" could support a broader construction that includes an embedded map view appearing on screen.
- Evidence for a Narrower Interpretation: The flow diagram in Figure 2 depicts a process of minimizing one application (step 202), opening another (step 204), and then re-opening the first (step 208), which suggests a user-level switch between distinct applications rather than an integrated function (’980 Patent, Fig. 2).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by providing the Chase App and materials that "guide users to use the Accused Products in an infringing manner" (Compl. ¶28, ¶45, ¶62, ¶79). Contributory infringement is alleged based on the app having "special features that are specially designed to be used in an infringing way" with no substantial non-infringing uses (Compl. ¶29, ¶46, ¶63, ¶80).
- Willful Infringement: Willfulness is alleged based on Defendant's knowledge of the patents from the date of the complaint's filing (post-suit knowledge) (Compl. ¶30, ¶47, ¶64, ¶81). The complaint also alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" (Compl. ¶31, ¶48, ¶65, ¶82).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: can the claimed system, which recites a "first non-browser application" that "invokes" a "second non-browser application," be construed to cover a single, integrated mobile app that uses an embedded mapping SDK for its location-display features?
- A key evidentiary question will be one of functional operation: what technical evidence will show that the Chase App's feature to "navigate to locations" performs the specific claimed step of invoking a separate mapping application to "obtain driving directions," as required by the ’980 patent, versus merely plotting points on an internal map view?
- An early procedural question may arise regarding pleading sufficiency: do the complaint's high-level, nearly identical allegations for four distinct patents provide plausible factual support for infringement of each asserted claim's specific limitations, or will they be challenged as conclusory?