Geographic Location Innovations LLC v. GameStop Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: GameStop Corp. (Delaware)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Identification: 3:19-cv-00935, N.D. Tex., 04/17/2019
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed a resident of the district, has a regular and established place of business in the district, and because acts of infringement occur in the district.
• Core Dispute: Plaintiff alleges that Defendant’s website store locator service infringes a patent related to remotely programming a positional information device with location data.
• Technical Context: The lawsuit concerns the technology of location-based services, specifically the interaction between a user's device (e.g., a smartphone) and a remote server to find and receive directions to points of interest.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

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"

• Patent Identification: 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, inconvenience, and potential safety hazard of manually programming addresses into GPS devices, particularly while driving or when an address format is not recognized by the device (’285 Patent, col. 2:5-13). It also notes the inefficiency of entering the same address into multiple different devices owned by a user (’285 Patent, col. 2:1-4).
• The Patented Solution: The invention proposes a system where a user's "positional information device" communicates with a remote server over a network. The user can request location information (e.g., an address) from the server, which then resolves the address into geographic coordinates and transmits them directly to the user's device. This allows for the automatic programming of the device for route guidance without manual entry (’285 Patent, Abstract; col. 9:11-47). The system can be initiated through various means, including voice commands to a live operator or interaction with a website (’285 Patent, col. 9:11-30).
• Technical Importance: This approach aimed to streamline the user experience for navigation devices by offloading the task of address lookup and entry from the local device to a more powerful remote server, enhancing both safety and convenience (’285 Patent, col. 2:26-30).

Key Claims at a Glance

• The complaint asserts infringement of "at least Claim 13" (’285 Patent, col. 14:26-49; Compl. ¶13).
• Independent Claim 13 recites a system comprising:
  • A server configured to receive a request for an address, determine the address, and transmit it.
  • A positional information device, which includes a locational information module, a communication module, a processing module, and a display module.
  • A communications network coupling the server and the device.
  • The server receives a time and date associated with the request and transmits it with the determined address.
  • The positional information device displays the determined 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 GameStop's store locator service ("the System"), which includes its mobile website (https://www.gamestop.com/stores) and associated server-side hardware and software (Compl. ¶13).

Functionality and Market Context

• The System allows a user to find nearby GameStop stores. Based on the complaint's allegations and supporting visuals, the user's device (e.g., a smartphone) can determine its own location, which is used by the System to display a list and map of nearby stores (Compl. ¶¶14, 17). The screenshot provided shows a prompt from "www.gamestop.com" asking for permission to "Know your location" (Compl. p. 7).
• After a store is selected, the System can provide route guidance from the user's current location to the selected store (Compl. ¶19). A screenshot illustrates turn-by-turn directions presented on a map interface (Compl. p. 8). The complaint alleges the System's servers receive the user's request, determine the store addresses, and transmit them back to the user's device for display and routing (Compl. ¶¶15, 16).

IV. Analysis of Infringement Allegations

’285 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a general-purpose smartphone running a web browser constitutes a "positional information device" as that term is used in the patent. The patent's specification often refers to "GPS device" and was filed in 2006, before the modern smartphone ecosystem was established (’285 Patent, col. 1:13).
  • Technical Questions: The final limitation of Claim 13 requires that the server transmit a "time and date" and that the device "displays the determined address at the associated time and date." The complaint alleges this is used for determining traffic conditions (Compl. ¶22). A potential point of contention is whether the accused GameStop system actually performs this specific function. The defense may argue that while the system operates in real-time, it does not have the specific scheduling or itinerary-planning functionality described in the patent, where an address is displayed at a specific, pre-determined time and date (’285 Patent, col. 10:55-62).

V. Key Claim Terms for Construction

• The Term: "positional information device"

• Context and Importance: The construction of this term is fundamental to the infringement analysis. The accused instrumentality is a user's smartphone or tablet accessing a website (Compl. ¶14), not a dedicated navigation unit. Practitioners may focus on this term to determine if the patent's scope, originating from a 2006 priority date, can read on modern general-purpose computing devices.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the invention may apply to "any type of navigation or positional information device including but not limited to a vehicle-mounted device, a GPS receiver coupled to a desktop computer or laptop, etc." (’285 Patent, col. 4:5-9). It also explicitly contemplates use with a "personal digital assistant (PDA)" (’285 Patent, col. 4:29-30), a precursor to the modern smartphone.
  • Evidence for a Narrower Interpretation: The patent's primary example throughout the description and figures is a "global positioning system (GPS) device" (’285 Patent, Fig. 1; col. 4:1-4). The detailed description of the device's components (e.g., specific buttons for input) may be argued to describe a dedicated hardware unit rather than a software application running on a general-purpose device.

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

• Context and Importance: This limitation appears to add a specific temporal display function to the claim. Its interpretation is critical because a simple, real-time store locator may not perform this function as claimed. The dispute may center on whether this requires a specific calendaring or scheduling feature.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: One could argue this language simply means the display happens at the time the information is sent and received, without requiring a delay or future scheduling. The complaint itself makes a broad allegation that this function is met (Compl. ¶22).
  • Evidence for a Narrower Interpretation: The specification describes this functionality in the context of creating a trip itinerary, where different addresses are scheduled for use at different times and dates. For example, it 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 suggests a specific function beyond merely displaying a location upon immediate request.

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory allegation of contributory and inducement infringement (Compl. ¶13), but does not plead specific facts to support the requisite knowledge or intent beyond describing the general operation of the accused System.
• Willful Infringement: The complaint does not contain an allegation of willful infringement.

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

• A core issue will be one of definitional scope: can the term "positional information device," conceived in an era of dedicated GPS units and PDAs, be construed to cover a modern, general-purpose smartphone rendering a standard website in a browser?
• A key evidentiary question will be one of functional performance: does the accused store locator’s real-time display of location information meet the specific claim requirement that the device "displays the determined address at the associated time and date," or does that language require a more complex scheduling or itinerary-planning function that the accused system may not possess?