DCT

2:25-cv-01205

Autonavigare LLC v. General Motors LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01205, E.D. Tex., 12/11/2025
  • Venue Allegations: Venue is alleged based on General Motors being subject to personal jurisdiction in the district, committing acts of infringement there, and maintaining a regular and established place of business in Roanoke, Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s vehicle infotainment systems infringe six patents related to vehicle navigation, data management, and multimedia device integration.
  • Technical Context: The patents relate to automotive infotainment and navigation systems, which are central features for user experience and functionality in the modern vehicle market.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via a letter that identified the asserted patents and included claim charts, a fact pattern often used to support allegations of willful infringement. The complaint also references arguments made during patent prosecution for the ’049 and ’254 patents, which may be relevant to future claim construction disputes.

Case Timeline

Date Event
2002-07-17 U.S. Patent No. 7,584,049 Priority Date
2004-06-02 U.S. Patent No. 7,653,482 Priority Date
2005-09-05 U.S. Patent No. 7,725,254 Priority Date
2006-02-27 U.S. Patent No. 7,640,104 Priority Date
2009-09-01 U.S. Patent No. 7,584,049 Issues
2009-09-09 U.S. Patent No. 8,694,232 Priority Date
2009-10-06 U.S. Patent No. 7,725,254 Prosecution: Amendment Filed
2009-12-29 U.S. Patent No. 7,640,104 Issues
2010-01-26 U.S. Patent No. 7,653,482 Issues
2010-05-25 U.S. Patent No. 7,725,254 Issues
2010-09-17 U.S. Patent No. 9,766,801 Priority Date
2014-04-08 U.S. Patent No. 8,694,232 Issues
2017-09-19 U.S. Patent No. 9,766,801 Issues
2025-12-11 Complaint Filed

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

U.S. Patent No. 7,584,049 - "Navigation Method, Processing Method for Navigation System, Map Data Management Device, Map Data Management Program, and Computer Program"

The Invention Explained

  • Problem Addressed: At the time of the invention, navigation systems typically relied on map data stored on fixed media like DVDs, which required replacing the entire medium for updates, making the process infrequent and inefficient (Compl. ¶16; ’049 Patent, col. 9:39-49).
  • The Patented Solution: The patent describes organizing map data into discrete geographical units called “meshes” and using a combination of map data stored on a fixed medium with updated map data for specific meshes downloaded from a remote source (Compl. ¶17). This allows for partial and targeted updates, such as for a specific area of interest or along a calculated route, rather than updating the entire map database at once (’049 Patent, col. 30:46-59).
  • Technical Importance: This approach enabled more flexible, efficient, and cost-effective map updates by minimizing the amount of data that needed to be communicated, facilitating the adoption of over-the-air updates for navigation systems (Compl. ¶19; ’049 Patent, col. 31:53-59).

Key Claims at a Glance

  • The complaint asserts independent method claim 5 and discusses independent device claims 7 and 9.
  • The essential elements of independent claim 5 include:
    • Prompting a selection in a map data update menu and displaying a specific area for update.
    • Prompting an input of a selected option in an update category menu and distinguishably displaying the specific area judged to have update map data.
    • Making a display in which a map data update instruction can be inputted.
    • Obtaining the update map data of the specific area when the update instruction is input.
    • Using the obtained update map data.
  • The complaint does not explicitly reserve the right to assert dependent claims but refers broadly to infringement of "one or more claims" (Compl. ¶80).

U.S. Patent No. 7,640,104 - "Vehicle Navigation System and Method for Displaying Waypoint Information"

The Invention Explained

  • Problem Addressed: Prior navigation systems were unable to correlate waypoints (Points of Interest, or POIs) with the time required to reach them, could not dynamically adjust for traffic conditions, and lacked filters for user-specified constraints like time-of-day or deviation distance, leading to cluttered and irrelevant map displays (Compl. ¶32; ’104 Patent, col. 1:37-43, 2:18-27).
  • The Patented Solution: The invention is a method where a user can input criteria for a desired waypoint, including not only its type but also a desired arrival time and a permissible timing or distance deviation (Compl. ¶33). The system then uses real-time data, such as traffic information, to determine which waypoints along the route satisfy these dynamic constraints and selectively displays only those relevant waypoints (’104 Patent, col. 3:51-55). Figure 2 from the ’104 Patent, presented in the complaint, depicts an exemplary screen display for a waypoint search with user-defined time and distance constraints (Compl. p. 16).
  • Technical Importance: This technology allowed for more contextually relevant and personalized waypoint guidance, reducing information overload on the map display and improving the utility of in-vehicle navigation (Compl. ¶34; ’104 Patent, col. 6:31-34).

Key Claims at a Glance

  • The complaint asserts independent method claim 1 and discusses independent claim 10.
  • The essential elements of independent claim 1 include:
    • Displaying a route on the screen.
    • Receiving criteria identifying desired waypoint(s) and a desired time to reach them.
    • Receiving real-time traffic information and/or stochastic traffic modeling.
    • Determining a location of the desired waypoint(s) as a function of the desired time and the traffic information.
    • Selectively displaying the waypoint(s) on the screen that correspond to the desired waypoint(s).
  • The complaint refers broadly to infringement of "one or more claims" (Compl. ¶92).

U.S. Patent No. 7,653,482 - "On-Vehicle Navigation Apparatus and Subject Vehicle Position Correction Method"

  • Technology Synopsis: The patent addresses the problem of "position jump" in navigation systems, where a vehicle's displayed position inaccurately jumps between closely spaced parallel roads (Compl. ¶39). The disclosed solution uses camera-captured images to detect road marker lines, analyzes this visual data to determine which candidate road the vehicle is actually on, and conditions the map-matching position correction on this determination, thereby improving positioning accuracy (Compl. ¶¶40-41).
  • Asserted Claims: The complaint asserts independent method claim 3 (Compl. ¶104).
  • Accused Features: The complaint accuses GM vehicles equipped with systems that use camera-based position correction, such as those with Super Cruise functionality (Compl. ¶104).

U.S. Patent No. 7,725,254 - "Navigation Device Used for a Route Search"

  • Technology Synopsis: The invention seeks to improve route search accuracy by calculating routing costs at the lane level, rather than the road-segment level (Compl. ¶48). It describes a data structure where a road segment ("link") can have multiple lanes (e.g., left-turn, straight), each with its own associated cost, such as travel time. The route search algorithm then uses these granular, lane-specific costs to find a route with the lowest total cost (Compl. ¶¶49-51). Figure 2 from the ’254 Patent, included in the complaint, illustrates a data structure where map data is organized by links, with each link containing lane information (Compl. p. 23).
  • Asserted Claims: The complaint asserts independent device claim 1 (Compl. ¶116).
  • Accused Features: The complaint accuses the route searching features of GM's Chevrolet/GMC/Buick/Cadillac Google Built-In Infotainment System (Compl. ¶116).

U.S. Patent No. 8,694,232 - "Method of Predicting Energy Consumption, Apparatus for Predicting Energy Consumption, and Terminal Apparatus"

  • Technology Synopsis: The patent addresses shortcomings in predicting vehicle energy consumption, particularly for route planning in electric vehicles (Compl. ¶59). The disclosed method analyzes probe vehicle data to calculate "geographic characteristic values" (e.g., slope, friction) for each road link that are independent of vehicle type or driving style. These intrinsic road values are then combined with a specific vehicle's parameters to generate a more accurate, vehicle-specific energy consumption prediction for use in eco-friendly route searching (Compl. ¶¶60-63).
  • Asserted Claims: The complaint asserts independent method claim 1 (Compl. ¶128).
  • Accused Features: The complaint accuses GM's Google Built-In Infotainment Systems, including EV versions, that have capabilities for predicting energy consumption (Compl. ¶128).

U.S. Patent No. 9,766,801 - "In-Car Information System, In-Car Device, and Information Terminal"

  • Technology Synopsis: This invention describes a system for integrating a smartphone ("information terminal") with a vehicle's infotainment system ("in-car device") (Compl. ¶68). The system architecture involves the smartphone running an "application manager" that transmits a video signal for displaying a menu of applications to the in-car device. The in-car device displays this menu on its screen and sends user actuation information (e.g., from a touch panel) back to the smartphone to control the applications (Compl. ¶69).
  • Asserted Claims: The complaint asserts independent device claim 2 (Compl. ¶140).
  • Accused Features: The complaint accuses various GM infotainment systems that support smartphone integration via wired or wireless connections, such as systems that implement Apple CarPlay or Android Auto (Compl. ¶140).

III. The Accused Instrumentality

  • Product Identification: The complaint collectively identifies the accused instrumentalities as infotainment systems in Chevrolet, Buick, GMC, and Cadillac vehicles (Compl. ¶5). Specific systems named include the Chevrolet/GMC/Buick/Cadillac Google Built-In Infotainment System (including EV versions), Chevrolet/GMC/Buick Infotainment 3 System, Buick Ultrawide Infotainment System, Cadillac Next Gen Infotainment System, and Cadillac OLED Infotainment System with Super Cruise functionality (Compl. ¶¶81, 93, 104, 116, 128, 140).
  • Functionality and Market Context: The accused products are integrated vehicle systems that provide core in-car functionality, including navigation, driver assistance, and multimedia device integration (Compl. ¶5). The complaint alleges these systems incorporate the specific patented technologies, including methods for partial map updates, time-based waypoint filtering, camera-assisted positioning, lane-cost-based routing, energy consumption prediction for EVs, and control of smartphone applications through the vehicle's display (Compl. ¶¶81, 93, 104, 116, 128, 140). These features represent key functionalities marketed to consumers in modern vehicles.

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; therefore, the narrative infringement theories are summarized below in prose.

U.S. Patent No. 7,584,049 Infringement Allegations

The complaint alleges that GM’s Google Built-In Infotainment System infringes at least method claim 5 of the ’049 Patent (Compl. ¶81). The infringement theory is that these systems perform map updates by combining on-board map data with downloaded data for specific geographic areas, allegedly corresponding to the claimed “meshes” (Compl. ¶17). This process is allegedly facilitated by a user interface that allows the user to select categories of data to update for a specific area or along a route, thereby performing the sequence of steps recited in the claim (Compl. ¶20). Figure 22 from the ’049 Patent, reproduced in the complaint, illustrates a user interface for selecting categories of map data to be updated along a route, which supports the plaintiff's theory of how the patented method is implemented (Compl. p. 9).

  • Identified Points of Contention: A primary point of contention may be definitional. The analysis will likely question whether the data structures used by GM's modern infotainment systems for map updates (e.g., tiled map services) meet the specific definition and structural characteristics of a “mesh” as disclosed and claimed in the patent. Further, there may be disputes over whether the accused systems perform the exact sequence of "prompting" and "displaying" steps required by the asserted method claim.

U.S. Patent No. 7,640,104 Infringement Allegations

The complaint alleges that a range of GM infotainment systems infringe at least claim 1 of the ’104 Patent (Compl. ¶93). The theory posits that when a user searches for a waypoint (POI), the accused systems receive criteria that include a desired arrival time and/or deviation constraints (Compl. ¶33). The systems are then alleged to use real-time traffic data to determine which POIs satisfy these criteria and selectively display only those results, thereby practicing the patented method (Compl. ¶33, ¶36).

  • Identified Points of Contention: The analysis will likely focus on the claim limitation "determining a location of said desired waypoint(s) ... as a function of said desired time." A key technical question will be whether the accused systems actually calculate a geographic location based on the time input, or if they perform a potentially different function: calculating an estimated time of arrival (ETA) at pre-defined, fixed waypoint locations and then filtering that list of waypoints based on the user's desired time. The distinction between determining a location versus filtering by ETA could be a central issue for both claim construction and infringement.

V. Key Claim Terms for Construction

For U.S. Patent No. 7,584,049:

  • The Term: "the map data being managed in units of a mesh"
  • Context and Importance: The applicability of the patent to modern map systems will depend on the scope of this term. Practitioners may focus on this term because GM's accused products likely use a modern map tiling architecture, and whether that architecture falls within the definition of a "mesh" as understood from the patent's intrinsic evidence will be a dispositive issue.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a general statement that "a mesh can be a geography-based division of data" (’049 Patent, col. 7:32-33), which could support an interpretation covering any system that divides map data into geographic tiles.
    • Evidence for a Narrower Interpretation: The patent's figures and detailed description disclose a specific data structure including "full mesh management information," "blocks," and "individual mesh management information" (’049 Patent, Figs. 4-6; col. 7:3-67). This detailed embodiment may be used to argue for a narrower construction limited to systems with these specific structural attributes.

For U.S. Patent No. 7,640,104:

  • The Term: "determining a location of said desired waypoint(s) ... as a function of said desired time"
  • Context and Importance: This term is at the heart of the claimed method. The infringement analysis may turn on whether the accused functionality—likely filtering a list of known POIs by their calculated ETAs—is functionally equivalent to "determining a location" as required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's abstract states the invention determines "the location of the desired waypoint along the route as a function of the desired time" (’104 Patent, Abstract). This language could be argued to broadly cover any process where the "desired time" is an input used to select and display a waypoint's location.
    • Evidence for a Narrower Interpretation: The detailed description explains that the system "determines the predicted arrival time at candidate waypoints" (’104 Patent, col. 3:51-52). This language suggests that the waypoint locations are fixed candidates and the system's novel step is calculating arrival times to filter them, not calculating a new geographic location itself. This may support a narrower construction that requires the system to first calculate a geographic point on the route corresponding to the desired time and then find a waypoint at that point.

VI. Other Allegations

  • Indirect Infringement: For all asserted patents, the complaint alleges induced infringement under 35 U.S.C. § 271(b). The allegations are based on GM allegedly encouraging and instructing customers to use the accused features through advertisements, user manuals, and online instructional materials (Compl. ¶¶83-84, 94-95, 106-107, 118-119, 130-131, 141-142).
  • Willful Infringement: Willfulness is alleged for all asserted patents. The complaint bases this on alleged pre-suit knowledge from a detailed notice letter sent to GM's counsel and executives, which included claim charts, as well as continued infringement after the filing of the lawsuit (Compl. ¶¶12, 86, 97, 109, 121, 133, 144).

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

  • A core issue will be one of definitional scope: can the term "mesh," which is described in the ’049 Patent with specific data management structures, be construed to cover the modern, tiled data architectures likely used in GM's accused Google Built-In navigation system?
  • A key evidentiary question will be one of functional operation: does the accused waypoint search feature perform the claimed step of "determining a location ... as a function of said desired time" as recited in the ’104 Patent, or does it perform a technically distinct, and potentially non-infringing, process of filtering a list of fixed-location waypoints by their calculated estimated time of arrival?
  • A central strategic question will concern portfolio cohesion: given the assertion of six patents covering a wide range of distinct technologies—from data structures and UI methods to camera-based positioning and EV energy prediction—the case may either proceed as a broad attack on GM's infotainment platform or fracture into several independent technical and legal battles, each turning on its own unique claim construction and infringement evidence.