DCT
2:25-cv-01203
Infogation Corp v. Garmin Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Garmin Ltd. (Switzerland)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:25-cv-01203, E.D. Tex., 12/09/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas based on Defendant’s substantial business in the state, including specific retail locations within the district. As Defendant is a foreign corporation, Plaintiff also invokes the "alien venue rule."
- Core Dispute: Plaintiff alleges that Defendant’s GPS navigation devices infringe a patent related to navigating on non-linearly scaled or "artistic" maps, where user selections on a visually stylized map are translated into real-world geographic coordinates for routing.
- Technical Context: The technology concerns graphical user interfaces for GPS navigation, particularly for use in leisure environments like parks or tourist areas where stylized, non-uniform scale maps are more common than traditional road maps.
- Key Procedural History: The complaint alleges that the patent-in-suit was allowed over extensive prior art considered by three different patent examiners and has been cited by industry participants including Microsoft, Nokia, and Volkswagen.
Case Timeline
| Date | Event |
|---|---|
| 2007-08-11 | ’628 Patent Priority Date |
| 2018-10-23 | ’628 Patent Issue Date |
| 2025-12-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 10,107,628, "METHOD AND APPARATUS FOR NAVIGATING ON ARTISTIC MAPS," issued October 23, 2018 (’628 Patent).
U.S. Patent No. 10,107,628 - METHOD AND APPARATUS FOR NAVIGATING ON ARTISTIC MAPS
The Invention Explained
- Problem Addressed: The patent’s background section describes a shortcoming in conventional GPS devices used for leisure activities, such as touring a zoo or park. On standard, linearly-scaled maps, points of interest may not be visible until a user is very close, making the display "boring" and uninformative for navigation between nearby attractions (’628 Patent, col. 1:38-54).
- The Patented Solution: The invention provides a method for navigating using a "non-linearly scaled map," such as an artistic tourist map where landmarks are shown in exaggerated detail (’628 Patent, Abstract). A user selects a destination on this artistic map displayed on a device. The system then captures the coordinates of the selection, transforms them into a corresponding physical point (latitude and longitude) on a standard geographic map, calculates a route to that point, and synchronizes and displays the resulting navigational direction on the original artistic map (’628 Patent, col. 2:42-51; Fig. 3).
- Technical Importance: This approach allows for a more intuitive and visually engaging user experience in environments where stylized maps are more useful than geographically precise road maps (’628 Patent, col. 1:60-65).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶20).
- The essential elements of claim 1 of the ’628 Patent are:
- Downloading an "artistic map" that is "non-linearly scaled" and has "various objects being exaggeratedly shown."
- Receiving a user's selection of one of the objects on the map.
- Determining a pair of coordinates for a point on the selected object.
- Transforming those coordinates into a physical point (latitude and longitude) on a geographical map that is not being displayed.
- Detecting the device's current location.
- Determining a navigational direction from the current location to the selected object using the geographical map.
- Showing the determined navigational direction on the displayed artistic map.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities include a range of Garmin GPS navigation devices, such as the zūmo® XT2 Motorcycle Navigator, Tread 2 Powersport Navigator, dēzl OTR Series, DriveSmart™ series, and RV series navigators, among others (Compl. ¶19).
Functionality and Market Context
- The complaint alleges these devices provide navigation using various map types. A key feature highlighted is "BirdsEye Direct Satellite Imagery," which allows users to download and navigate with high-resolution satellite images without a subscription (Compl. p. 6). Another referenced feature, "VISUAL ROUTE PLANNER," allows users to plan a custom route on the device, presumably by selecting points on the displayed map (Compl. p. 6). The complaint also points to a "SIMPLE MAP SWITCHING" feature, which allows users to toggle between on-road maps, topographic maps, and satellite imagery (Compl. p. 6). These functionalities are alleged to enable navigation on non-linearly scaled maps as claimed by the patent.
IV. Analysis of Infringement Allegations
’628 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| downloading from a network into a computing device an artistic map, the artistic map being non-linearly scaled and including various objects being exaggeratedly shown... | The Garmin devices download "BirdsEye Direct Satellite Imagery," which the complaint implicitly characterizes as a non-linearly scaled map with exaggeratedly shown objects. | ¶19, p. 6 | col. 8:26-34 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object; | The "VISUAL ROUTE PLANNER" feature allows a user to "plan a custom route on the device," which involves selecting destinations on the displayed map. | ¶19, p. 6 | col. 8:39-41 |
| transforming in the computing device the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map not being shown on the display... | This functionality is inherent in GPS operation, where selecting a point on any map display requires translation to real-world latitude and longitude for routing. | ¶20 | col. 8:46-54 |
| detecting a current location of the computing device in the geographical map; | The accused products are GPS navigators that inherently detect their current location to provide routing. | ¶19 | col. 8:55-56 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected; and | The accused devices perform standard GPS routing to calculate a path from the user's current location to a selected destination. | ¶19 | col. 8:57-60 |
| showing the navigational direction on the artistic map being displayed. | The calculated route and directions are displayed over the selected map, such as the BirdsEye satellite imagery. | ¶19, p. 6 | col. 8:61-63 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the definition of an "artistic map." The complaint's theory appears to equate Garmin's "BirdsEye Direct Satellite Imagery" and "topographic maps" with the "artistic map" of the claims (Compl. p. 6). The question for the court will be whether these map types, which are based on real-world data, fall within the scope of a term the patent illustrates with stylized, human-drawn examples like a zoo map (’628 Patent, Fig. 1).
- Technical Questions: The complaint alleges infringement through features like "SIMPLE MAP SWITCHING" (Compl. p. 6). A technical question is whether this feature performs the specific "transforming" and "showing" steps as claimed, or if it constitutes a simpler process of layering a standard route calculation over different, independent map image sets.
V. Key Claim Terms for Construction
The Term: "artistic map"
Context and Importance: This term is foundational to the infringement case. Whether the accused satellite and topographic maps meet this definition will be a critical point of contention. Practitioners may focus on this term because the patent’s examples are stylized illustrations, whereas the accused functionality involves photorealistic or data-driven maps.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the map as "non-linearly scaled" where "points of interests are exaggeratedly displayed," a characteristic Plaintiff may argue applies to satellite imagery where certain features are prominent or annotated (’628 Patent, col. 4:4-6).
- Evidence for a Narrower Interpretation: The patent’s title is "Navigating on Artistic Maps," and its primary embodiments are a zoo map (Fig. 1) and a botanical garden map (Fig. 2), suggesting the term is limited to manually created, illustrative maps designed for aesthetic or thematic purposes rather than geographic accuracy.
The Term: "objects being exaggeratedly shown"
Context and Importance: This phrase qualifies "artistic map" and is key to determining its scope. The parties will likely dispute what constitutes "exaggeration" in the context of the accused products.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that on such maps, "animals are even exaggeratedly shown on the map 302 to show their respective exhibits" (’628 Patent, col. 3:38-40). Plaintiff could argue this applies to any non-proportional representation, such as large icons or detailed renderings of landmarks on a satellite map.
- Evidence for a Narrower Interpretation: Defendant may argue the term requires a deliberate, artistic distortion of an object's size or shape for visual effect, which is distinct from the way features naturally appear or are annotated in satellite or topographic imagery.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides instructions and advertising that encourage users to operate the accused devices in an infringing manner (Compl. ¶30, ¶33).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’628 Patent upon service of the complaint (Compl. ¶29). The complaint also alleges willful blindness, asserting on information and belief that Defendant has a practice of not reviewing the patent rights of others before launching products (Compl. ¶34).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "artistic map," rooted in the patent’s context of stylized zoo and park illustrations, be construed to cover the data-driven satellite and topographic imagery used by the accused Garmin navigation devices?
- A key evidentiary question will be one of technical equivalence: does the functionality of the accused devices, such as the "BirdsEye Direct Satellite Imagery" feature, operate by performing the claimed multi-step process of transforming coordinates from a non-linear map to a separate geographic map for routing and then re-displaying the result, or does it utilize a different technical architecture, such as merely overlaying route data on various map tile sets?