Navog LLC v. Paragon Software Systems Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Navog LLC (New Mexico)
  • Defendant: Paragon Software Systems Limited (United Kingdom)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-00043, E.D. Tex., 01/22/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s software products infringe a patent related to a GPS-based system for warning drivers of large vehicles about low-clearance obstacles.
• Technical Context: The technology addresses collision avoidance for high-profile vehicles, such as commercial trucks and RVs, which require specialized navigation warnings not always present in standard consumer GPS systems.
• Key Procedural History: No prior litigation or other procedural history is mentioned in the complaint.

Case Timeline

Date	Event
2015-12-13	’205 Patent Priority Date
2016-12-12	’205 Patent Application Filing Date
2020-03-17	’205 Patent Issue Date
2026-01-22	Complaint Filing Date

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

U.S. Patent No. 10,593,205 - *GPS and Warning System*

The Invention Explained

• Problem Addressed: The patent addresses the problem faced by drivers of commercial trucks, buses, and RVs who risk colliding with low-clearance structures such as bridges, tunnels, and underpasses because conventional navigation systems may not provide adequate warning. (’205 Patent, col. 1:56-68).
• The Patented Solution: The invention is a dedicated GPS monitoring and alarm system that contains a database of low-clearance structures, including their specific measurements and GPS coordinates. (’205 Patent, col. 2:31-44). When the vehicle, whose height has been entered into the system, approaches a structure with insufficient clearance, the device provides a loud audible alarm, a flashing light, and visual information on a display screen, and is adapted to suggest alternate routes to avoid the danger. (’205 Patent, col. 2:40-49, col. 4:20-35).
• Technical Importance: The technology aims to provide a reliable, dedicated safety system to prevent costly and dangerous collisions involving high-profile vehicles. (’205 Patent, col. 1:12-18).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," referencing "Exemplary '205 Patent Claims" identified in an attached chart. (’205 Patent, col. 6:11-54; Compl. ¶11). Independent claim 1 is representative.
• Essential Elements of Independent Claim 1:
  • A "main body" forming a "hollow interior volume."
  • A "computer module" within the hollow volume, programmed with information about roads, bridges, and underpasses.
  • A "GPS module" within the hollow volume to provide location information.
  • At least one "warning mechanism" connected to the computer module, adapted to provide a "loud audible sound" to warn of impending danger from low-clearance obstacles.
  • A "display screen" on the main body's outer surface to provide visual information, including the height of an approaching obstacle and alternate routes.
• The complaint does not explicitly reserve the right to assert dependent claims, but its reference to "one or more claims" suggests this possibility. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products." (Compl. ¶11). The specific products are not named in the body of the complaint but are referenced as being identified in an attached Exhibit 2, which was not filed with the public complaint. (Compl. ¶16-17).

Functionality and Market Context

The complaint alleges that the "Exemplary Defendant Products" practice the technology claimed by the ’205 Patent. (Compl. ¶16). This suggests the accused products are navigation and routing systems that provide warnings to drivers about road hazards or restrictions. The complaint alleges these products are made, used, sold, and imported by the Defendant and its customers. (Compl. ¶11). The complaint does not provide sufficient detail for analysis of the products' specific functionality or market positioning beyond the general allegation of infringement.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an "Exhibit 2" that was not publicly filed. (Compl. ¶17). It therefore does not contain specific, element-by-element infringement allegations in its narrative text. The complaint asserts a general theory of direct infringement, alleging that Defendant's "Exemplary Defendant Products" satisfy all elements of the asserted claims. (Compl. ¶16). It further alleges direct infringement occurs through Defendant's internal testing and use of these products. (Compl. ¶12). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's focus on a physical device and the likely software-based nature of Defendant's products, the infringement analysis may raise several questions:

• Scope Questions: A primary question may be whether the claim term "main body," which "forms a hollow interior volume" containing distinct "computer" and "GPS" modules, can be construed to read on general-purpose computing hardware (e.g., a smartphone, tablet, or in-cab fleet computer) running Defendant's software. The patent figures and description consistently depict a standalone, dedicated hardware unit. (’205 Patent, Figs. 1-3).
• Technical Questions: What evidence does the complaint provide that the accused products' warning features constitute a "warning mechanism... adapted to provide a loud audible sound," as required by the claim? Another question is whether the accused products' functionality for suggesting new routes in response to traffic or road closures performs the specific function of displaying "alternate routes for the automobile to travel to avoid dangers posed by the existing roads, bridges, viaducts, and under-passes," as claimed. (’205 Patent, col. 6:39-43).

V. Key Claim Terms for Construction

The Term: "main body"

Context and Importance

This term appears in claim 1 and is described as forming a "hollow interior volume" that contains the computer and GPS modules. (’205 Patent, col. 6:14-15). The construction of this term is critical because the accused products are likely software systems that run on third-party, general-purpose hardware. The case may turn on whether a smartphone or other generic computer can be considered the claimed "main body."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The claims do not specify the material, size, or shape of the "main body," which may support an argument that the term should not be limited beyond its plain and ordinary meaning of a principal part of a device.
• Evidence for a Narrower Interpretation: The specification and figures consistently depict the "main body" as the housing of a single, dedicated, self-contained electronic device. (’205 Patent, Figs. 1-3; col. 4:37-39, describing "main body 110"). This could support an interpretation limiting the term to a dedicated hardware housing rather than a general-purpose device like a smartphone.

The Term: "automobile"

Context and Importance

Claim 1 recites a system "for an automobile." (’205 Patent, col. 6:12). The definition of this term is important because the patent's background and abstract exclusively discuss the problems faced by drivers of "truckers, bus and RV drivers," which are high-profile vehicles not always classified as "automobiles." (’205 Patent, Abstract; col. 1:33-35).

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: Parties may argue that "automobile" should be given its ordinary meaning, which can broadly include any self-propelled passenger vehicle, potentially encompassing trucks and buses. The use of the more generic term in the claim, contrasted with the specific examples in the specification, could be argued as an intentional choice to claim more broadly.
• Evidence for a Narrower Interpretation: The specification's repeated and exclusive focus on "truckers, bus and RV drivers" and "commercial vehicles" could support an argument that the invention is limited to that context, and the term "automobile" should be construed in light of that specific problem domain. (’205 Patent, col. 1:33-35, 56-57; col. 4:13-15).

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant knowingly and intentionally induces infringement by selling its products to customers and distributing "product literature and website materials" that instruct end users on how to use the products in an infringing manner. (Compl. ¶14-15). Knowledge is alleged to exist "at least since being served by this Complaint." (Compl. ¶15).

Willful Infringement

The complaint alleges that service of the complaint itself "constitutes actual knowledge of infringement." (Compl. ¶13). It further alleges that "Despite such actual knowledge, Defendant continues to... sell... products that infringe the '205 Patent." (Compl. ¶14). This forms the basis for a claim of post-suit willful infringement. The prayer for relief also requests that the case be declared "exceptional" under 35 U.S.C. § 285. (Compl. p. 5, ¶E.i.).

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

• A core issue will be one of definitional scope: can the claim term "main body," which is described in the patent as a physical housing for a dedicated device, be construed to cover general-purpose hardware (like a smartphone or fleet computer) running the accused software?
• A second central question will be evidentiary: given the complaint's reliance on an unfiled exhibit, can the Plaintiff produce sufficient technical evidence to demonstrate that the functionality of Defendant's accused software products maps directly onto the specific elements of the patent's claims, particularly the requirements for a "loud audible sound" warning and the display of "alternate routes" specifically to avoid low-clearance dangers?
• Finally, the dispute may involve a question of patentable subject matter in practice: does the infringement theory improperly attempt to cover the abstract idea of warning a driver of a route-based hazard—a task performed by software on a generic computer—using a patent that describes and claims a specific, physical apparatus?