DCT

3:13-cv-01880

Wireless Mobile Devices LLC v. LG Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:13-cv-01880, N.D. Tex., 12/12/2013
  • Venue Allegations: The complaint alleges venue is proper because each defendant is deemed to reside in the district, has committed acts of infringement in the district, has transacted business involving the accused products in the district, and/or has regular and established places of business there.
  • Core Dispute: Plaintiff alleges that certain LG mobile devices, sold by the other named defendants, infringe six patents related to mobile device management, off-board navigation, and location-based point-of-interest searching with user ratings.
  • Technical Context: The patents-in-suit relate to foundational technologies for modern smartphones, including over-the-air software updates and location-aware search functionalities that are central to the mobile application ecosystem.
  • Key Procedural History: This filing is a Second Amended Complaint. The complaint references the filing of an "Original Complaint" as the basis for establishing defendants' notice for the purposes of contributory infringement allegations.

Case Timeline

Date Event
2000-03-10 Priority Date for ’604 Patent
2001-08-16 Priority Date for ’365, ’315, ’939, ’826, and ’371 Patents
2003-05-06 Issue Date for U.S. Patent No. 6,560,604
2006-07-25 Issue Date for U.S. Patent No. 7,082,365
2008-01-22 Issue Date for U.S. Patent No. 7,321,826
2010-12-21 Issue Date for U.S. Patent No. 7,856,315
2011-09-06 Issue Date for U.S. Patent No. 8,014,939
2011-10-18 Launch of Android Operating System v4.x (accused software)
2011-11-16 Launch of Google Maps Application v6.x (accused software)
2012-07-09 Launch of Android Operating System v4.1 and Google Now Service (accused software)
2012-11-27 Issue Date for U.S. Patent No. 8,301,371
2013-12-12 Complaint Filing Date

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

U.S. Patent No. 6,560,604 - System, method, and apparatus for automatically and dynamically updating options, features, and/or services available to a client device

  • Issued: May 6, 2003

The Invention Explained

  • Problem Addressed: The patent describes the process of updating or reconfiguring numerous, geographically dispersed client devices (such as wireless pagers) as burdensome and inefficient. Conventional methods required manual redevelopment of client software, wasteful broadcast downloads of configuration information to all devices, or requiring users to return devices to a service center (col. 2:15-44).
  • The Patented Solution: The invention proposes a client-server system where a client device's features and user interface are defined by "templates" stored locally. When the client device requests information from a server, it includes a version identifier for its current template. The server compares this version to the latest version in its master database. If the client's template is outdated, the server’s response includes both the requested data and a "template update," which automatically reconfigures the client device on-the-fly (Abstract; col. 3:5-24).
  • Technical Importance: This system enabled efficient, on-demand, over-the-air updates for resource-constrained mobile devices, avoiding the cost and inconvenience of broadcast updates or physical device recalls (col. 2:51-55).

Key Claims at a Glance

  • The complaint asserts at least independent claim 14 (Compl. ¶17).
  • Claim 14 is a client apparatus claim with the following essential elements:
    • A client template database for storing one or more templates defining the apparatus configuration.
    • A transmitter for sending a client request to a server.
    • A receiver for receiving a server response that includes a template identifier.
    • A client controller that determines if the server response includes template update information and, if so, updates a corresponding template in the database with that information.

U.S. Patent No. 7,082,365 - Point of interest spatial rating search method and system

  • Issued: July 25, 2006

The Invention Explained

  • Problem Addressed: The patent notes that existing point of interest (POI) search systems were non-spatial (relying on static inputs like city or zip code) and lacked sophisticated rating capabilities. Navigational devices could find nearby POIs but could not filter or rank them based on qualitative metrics like user ratings (col. 1:14-44).
  • The Patented Solution: The invention describes a system that integrates a mobile device's real-time location with a search engine that incorporates "rating metrics." It allows a user to perform spatial searches (e.g., within a radius of the current location) and to filter or sort results based on ratings from various sources, such as aggregate user scores, to find the "highest rated POI" (Abstract; col. 2:15-24).
  • Technical Importance: The technology combined real-time location-based services with crowd-sourced or curated ratings, a foundational concept for modern mobile search and discovery applications that provide contextually relevant results (col. 2:3-11).

Key Claims at a Glance

  • The complaint asserts at least claims 1-10, 12, 13, 15, and 38-46 (Compl. ¶27). Independent claim 1 is representative.
  • Claim 1 is a method claim with the following essential elements:
    • Retrieving real-time position information of a mobile device via a global positioning system.
    • Receiving a search criteria specifying a spatial distance from the device and a pre-defined geographical area.
    • Retrieving, from a database, location information for at least one POI located within the specified area.
    • Determining a distance between the device's position and the POI's location.
    • Displaying the retrieved location information and the determined distance.

U.S. Patent No. 7,856,315 - Method and system for enabling an off board navigation solution

  • Issued: December 21, 2010

Technology Synopsis

The patent relates to a system where a mobile device sends its location to a remote server, which then calculates a navigation route and sends the solution back to the device. This off-boarding of the computational task conserves the limited processing and memory resources of the mobile device (Compl. ¶35; ’315 Patent, Abstract).

Asserted Claims

At least claims 9-14 and 16 (Compl. ¶37).

Accused Features

LG mobile devices running the Google Maps Application v6.x and higher on the Android Operating System v4.x, which are alleged to perform off-board navigation (Compl. ¶37).

U.S. Patent No. 8,014,939 - Point of interest spatial rating search

  • Issued: September 6, 2011

Technology Synopsis

This patent, from the same family as the ’365 patent, describes methods for searching for POIs based on a user's location and rating criteria. It appears to cover different aspects or embodiments of the core location-based, rating-filtered search technology (Compl. ¶45).

Asserted Claims

At least claims 9-16 and claims 24, 25, 27, and 30 (Compl. ¶47, ¶52).

Accused Features

LG devices running Google Maps Application v6.x on Android v4.x, as well as devices running the Google Now Service on Android v4.1 and higher, are accused of performing the claimed POI searches (Compl. ¶47, ¶52).

U.S. Patent No. 7,321,826 - Point of interest spatial rating search

  • Issued: January 22, 2008

Technology Synopsis

This patent, also from the family of the ’365 patent, describes systems and methods for conducting spatial POI searches that incorporate rating information. It provides further claim coverage for the core inventive concept of combining location, search criteria, and ratings (Compl. ¶60).

Asserted Claims

At least claims 1-5 and 11-15 (Compl. ¶62).

Accused Features

LG mobile devices running the Google Maps Application v6.x on the Android Operating System v4.x are accused of infringement (Compl. ¶62).

U.S. Patent No. 8,301,371 - Point of interest spatial rating search method and system

  • Issued: November 27, 2012

Technology Synopsis

This patent, also from the family of the ’365 patent, further covers methods and systems for POI searches using spatial and rating criteria. Allegations for this patent also include contributory infringement, focusing on the collection of rating information from users (Compl. ¶70, ¶87).

Asserted Claims

At least claims 1-3, 5-9 and claims 10-14, 17 (Compl. ¶72, ¶87).

Accused Features

LG devices running Google Maps and Google Now are accused of infringing claims related to retrieving and collecting POI rating information (Compl. ¶72, ¶87).

III. The Accused Instrumentality

Product Identification

The complaint identifies two classes of accused instrumentalities:

  1. For the ’604 patent, LG mobile devices that support the Open Mobile Alliance Device Management (OMA-DM) specification (Compl. ¶17).
  2. For the remaining patents, LG mobile devices (including the Enact, Optimus G, G2, Google Nexus 4, and others) that run specific software versions: Google Maps Application v6.x and higher on Android Operating System v4.x and higher; and the Google Now Service on Android Operating System v4.1 and higher (Compl. ¶27, ¶37, ¶47, ¶52, ¶62, ¶72, ¶87).

Functionality and Market Context

  • The complaint alleges that the accused devices perform functions central to modern smartphone utility. For the ’604 patent, the accused functionality is the remote management and configuration of devices via the OMA-DM standard (Compl. ¶17). For the other patents, the functionality is location-based searching for points of interest using applications like Google Maps, which allows users to find nearby businesses, and Google Now, which proactively provides context-aware information (Compl. ¶27, ¶52).
  • The complaint names LG Electronics, a major global manufacturer, as well as all major U.S. wireless carriers (AT&T, Verizon, T-Mobile, and Sprint) as defendants, suggesting the accused products have broad distribution and significant market presence (Compl. ¶2-9).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint provides high-level infringement allegations without detailed, element-by-element mappings. The narrative infringement theory for the ’604 patent is that by supporting the OMA-DM standard, the devices necessarily practice the claimed invention. For the ’365 patent and its family, the theory is that by running the specified versions of Google Maps and Android, the devices necessarily perform the claimed methods of spatial, rating-based POI searching.

Identified Points of Contention

  • Evidentiary Questions: The complaint's reliance on industry standards (OMA-DM) and commercial software (Google Maps) raises the question of what evidence will be required to prove that these systems, as implemented on the accused devices, practice every limitation of the asserted claims. A key point of contention for the ’604 patent may be whether compliance with the OMA-DM specification is sufficient to establish infringement of the specific "template"-based update mechanism claimed.
  • Scope Questions: For the ’365 patent family, a central dispute may concern the scope of the term "rating". The analysis will question whether the algorithmic sorting and relevance ranking within Google's services can be construed as the "spatial rating search" described in the patents, which often refer to explicit user-generated scores.

V. Key Claim Terms for Construction

The Term: "template" (from ’604 Patent, Claim 14)

  • Context and Importance: The entire inventive concept of the ’604 patent revolves around using "templates" to configure a client device. The definition of this term will be critical to determining whether the data objects and configuration parameters used in the accused OMA-DM protocol fall within the scope of the claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a template's function broadly as defining "a configuration of the client device" and specifying the "layout or format of information presented to the user" (col. 3:28-30; col. 9:61-64). This functional language may support an interpretation that covers any data structure that dictates device configuration and display.
    • Evidence for a Narrower Interpretation: The patent provides specific examples of templates with a defined structure comprising a "header", "content", and "actions" portion, each populated with specific descriptors (col. 11:23-24; FIG. 4A, 4D). This may support a narrower construction limited to data structures exhibiting this tripartite organization.

The Term: "rating" (from ’365 Patent, Claim 1 and related patents)

  • Context and Importance: The patents in the ’365 family are directed to "spatial rating search." The construction of "rating" is central to whether the accused Google Maps and Google Now services, which use complex algorithms to rank results, infringe claims that appear rooted in user-generated scores.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The background section discusses concepts like an "aggregate average user rating response," which could support a broad definition encompassing any system that aggregates data to rank POIs (col. 2:1-2).
    • Evidence for a Narrower Interpretation: The specification provides explicit examples of rating metrics, such as "decor, service, food, price, location, etc." on a "scale of 1-40" (col. 2:30-35). This language could be used to argue that the term "rating" is limited to explicit, multi-faceted scoring systems and does not cover general relevance or popularity rankings.

VI. Other Allegations

Indirect Infringement

For U.S. Patent No. 8,301,371, the complaint alleges contributory infringement against all defendants (Compl. ¶72, ¶75, ¶78, ¶81, ¶84, ¶87, ¶90, ¶93, ¶96, ¶99). The allegations are based on defendants providing devices that are a "material component" of the claimed inventions, have "no substantial non-infringing uses" as they relate to the patent, and that defendants had notice of the patent at least as of the filing of the Original Complaint (Compl. ¶72, ¶74, ¶87-89). The complaint also asserts that end users of the devices are direct infringers (Compl. ¶73, ¶88).

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement.

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

This case will likely center on the tension between the specific embodiments disclosed in the patents and the broad, standards-based functionality of the accused products. The key questions for the court appear to be:

  • A core issue will be one of definitional scope: can the term "template," as described in the ’604 patent with specific structural examples, be construed broadly enough to encompass the data objects and management protocols of the OMA-DM standard?
  • A second key issue of definitional scope will be: does the term "rating", as used in the ’365 patent family, cover the complex, algorithm-driven relevance and popularity rankings of modern search services like Google Maps, or is it limited to the explicit, user-generated scoring systems described in the specification?
  • A central evidentiary question will be one of functional mapping: what level of technical evidence is required to demonstrate that the high-level operations of the accused software platforms perform the specific, multi-step functions required by the asserted claims, particularly given the complaint’s conclusory allegations?