Geographic Location Innovations LLC v. Michaels Stores Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: Michael's Stores, Inc. (Delaware)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Name: Geographic Location Innovations LLC v. Michael's Stores, Inc.
• Case Identification: 3:19-cv-00316, N.D. Tex., 02/07/2019
• Venue Allegations: Venue is alleged to be proper because Defendant is deemed a resident of the district, has a regular and established place of business there, and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to remotely providing location and navigation information to a user's device.
• Technical Context: The technology concerns systems that allow a user to look up a destination on a remote server, which then sends the location data directly to a navigation-capable device, bypassing manual address entry on the device itself.
• Key Procedural History: The complaint notes that Plaintiff is the owner of the patent-in-suit by assignment. No other significant procedural history, such as prior litigation or administrative proceedings, is mentioned.

Case Timeline

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

U.S. Patent No. 7,917,285 - Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device, issued March 29, 2011

The Invention Explained

• Problem Addressed: The patent describes the difficulty and potential safety risk of manually programming destination addresses into Global Positioning System (GPS) devices, particularly when a user is driving or when different devices have inconsistent interfaces (’285 Patent, col. 1:43-50; col. 2:7-13). It also notes the inconvenience of re-entering the same addresses into multiple devices owned by a single user (’285 Patent, col. 2:1-4).
• The Patented Solution: The invention proposes a system where a user's "positional information device" (e.g., a GPS unit or smartphone) requests a location from a remote server. The server resolves the address, determines its coordinates, and transmits this information back to the device, which then calculates and displays route guidance (’285 Patent, Abstract; Fig. 3). This offloads the task of address lookup and entry from the user's local device to a centralized server.
• Technical Importance: This server-based approach aimed to simplify and centralize the management of navigational data, making it easier for users to obtain route guidance without cumbersome manual input on varied or multiple end-user devices (’285 Patent, col. 2:27-31).

Key Claims at a Glance

• The complaint asserts at least independent claim 13 (’Compl. ¶13).
• The essential elements of Claim 13 are:
  • A server configured to receive a request for an address, determine the address, and transmit it to a positional information device.
  • A positional information device comprising a locational module, a communication module, a processing module for determining route guidance, and a display module.
  • A communications network coupling the server and the device.
  • A specific requirement that the server receives a time and date with the location request, transmits this time and date with the address, and the device displays the address "at the associated time and date."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The accused instrumentality is Defendant's "store locator service" and its associated hardware and software, which is accessible through Defendant's website (the "System") (Compl. ¶13).

Functionality and Market Context

• The System allows a user of a positional information device, such as a smartphone, to find nearby Michael's store locations (Compl. ¶14). The complaint alleges that the user's device sends a request to one or more servers, which then determine the addresses of nearby stores and transmit them back to the device for display on a map (Compl. ¶¶15-16). A screenshot provided in the complaint shows a map interface with turn-by-turn directions to a selected store (Compl. p. 8). The complaint does not contain allegations regarding the specific market positioning of this feature beyond its function as a store finder for a national retailer.

IV. Analysis of Infringement Allegations

’285 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A primary factual question is whether the accused System actually performs the function required by the final "time and date" limitation of Claim 13. The complaint alleges, "on information and belief," that a time and date must be sent to the server to determine traffic conditions (Compl. ¶22). The case may turn on whether evidence shows the System transmits and uses a specific "time and date" from the server to control the display of the address, or if it simply calculates a route based on conditions at the moment of the request.
  • Scope Questions: The dispute may also involve whether a general-purpose smartphone running a web browser meets the definition of the claimed "positional information device" with its integrated modules. A question for the court could be whether the "processing module" (allegedly the mobile website and mapping software) is properly considered part of the "device" itself, as contemplated by the patent.

V. Key Claim Terms for Construction

• The Term: "the positional information device displays the determined address at the associated time and date"

  • Context and Importance: This term is highly specific and appears to be a central point of the infringement allegation. The construction of "at the associated time and date" will be critical. Practitioners may focus on this term because the infringement theory hinges on an inferred functionality (determining traffic conditions) that may or may not be literally present in the accused System.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language does not explicitly require the time and date to be visibly displayed alongside the address, which could support an interpretation where the "display" is simply time-sensitive to the request.
    • Evidence for a Narrower Interpretation: The specification discusses a scenario where a trip itinerary is sent to a device and states, "When the date and time changes, the GPS device will then display the next specified and stored address on the date and time that corresponds to that address" (’285 Patent, col. 10:59-62). This language may support a narrower construction requiring a scheduled or time-gated display function, rather than just an immediate one.

• The Term: "processing module"

  • Context and Importance: The complaint identifies the processing module as "mapping software and the mobile website" (Compl. ¶19). The construction of this term is important for determining whether a system where the key processing logic resides in a website (loaded temporarily in a browser) rather than in a native application or firmware can be considered a "module" of the "positional information device."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that the disclosed system can be implemented in various forms of software and that the described functions can be part of an "application program ... which is executed via the operating system" (’285 Patent, col. 4:45-57). This suggests software, like a website running in a browser, could constitute the module.
    • Evidence for a Narrower Interpretation: Figure 2 depicts the COMPUTER PROCESSING MODULE (120) as a distinct block within the architecture of the device 100, connected by a system bus to other hardware modules like the DISPLAY MODULE and COMMUNICATION MODULE (’285 Patent, Fig. 2). This could support a reading that requires a more integrated component than transient web-based code.

VI. Other Allegations

• Indirect Infringement: The complaint includes a general allegation of contributory and induced infringement, stating Defendant provides the System for use by others (Compl. ¶13). It does not, however, plead specific facts detailing knowledge of the patent and intent to encourage infringement by third-party users, such as through user manuals or specific instructions.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or plead facts to support a finding of pre- or post-suit knowledge of infringement.

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

• A key evidentiary question will be one of operational fact: does Defendant’s store locator system actually receive, transmit, and use an "associated time and date" from the server to gate or control the display of a location, as required by the specific language of Claim 13, or is there a fundamental mismatch between the claim's requirements and the System's actual function?
• A central legal issue will be one of definitional scope: can the combination of a general-purpose smartphone and the software code of a mobile website, temporarily executed within a browser, be construed to meet the limitations of the claimed "positional information device" and its integrated "processing module," or does the patent’s text and figures require a more self-contained, dedicated navigational apparatus?