Geographic Location Innovations LLC v. Bridgestone Retail Operations LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Geographic Location Innovations LLC (Texas)
  • Defendant: Bridgestone Retail Operations, LLC d/b/a Firestone Complete Auto Care (Delaware)
  • Plaintiff’s Counsel: Kizzia Johnson, PLLC
• Case Identification: 3:20-cv-03628, N.D. Tex., 12/11/2020
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s website store locator infringes a patent related to remotely programming a positional information device with address data.
• Technical Context: The technology concerns the field of web-based mapping and navigation, specifically the interaction between a user's device (e.g., a smartphone) and a remote server to find locations and generate driving directions.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) 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 (Issued Mar. 29, 2011)

The Invention Explained

• Problem Addressed: The patent describes the difficulty and potential danger of manually programming addresses into GPS devices. Problems include inconsistent address recognition across different devices (e.g., one device recognizes "Sunny Isles, Fla." while another requires "North Miami Beach"), differing user interfaces, and the safety risks of entering data while driving (’285 Patent, col. 1:42-65; col. 2:5-13).
• The Patented Solution: The invention proposes a client-server system to solve this. A user transmits a request for a location to a remote server, which then determines the location's coordinates and transmits them back to the user's "positional information device" (e.g., a GPS unit or smartphone) for automatic programming and route guidance (’285 Patent, Abstract; col. 9:12-34). This eliminates the need for manual entry on the device itself.
• Technical Importance: This approach aimed to centralize and simplify address entry for navigation systems, making the process safer, faster, and more reliable across a user's multiple devices (’285 Patent, col. 2:27-31).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 13 (Compl. ¶13).
• Independent Claim 13 is directed to a system and includes the following essential elements:
  • A server configured to receive a request for an address not already stored in a positional information device, determine the address, and transmit it to the device.
  • A positional information device (including a locational module, communication module, processing module, and display module).
  • A communications network coupling the server and the device.
  • A requirement that the server receives a time and date associated with the location request, transmits that time and date with the determined address, and the positional information device displays the address at that associated time and date.
• The complaint does not explicitly reserve the right to assert dependent claims, but alleges infringement of "one or more claims, including at least Claim 13" (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's "store locator system," which includes its mobile website (e.g., "https://local.firestonecompleteautocare.com/#start-geolocate"), associated hardware, and software (the "System") (Compl. ¶13).

Functionality and Market Context

The complaint alleges the System functions as a "route planner application" (Compl. ¶14). A user on a device like a smartphone or tablet enters a location, such as a zip code (Compl. ¶15). The System includes a server that receives this request, determines the addresses of nearby Firestone locations, and transmits the determined addresses back to the user's device for display on a map (Compl. ¶15-¶16). The System then provides route guidance from the user's current location, determined via the device's GPS, to the selected store (Compl. ¶17, ¶19). A screenshot provided in the complaint shows the initial user interface for entering a zip code or city. (Compl. p. 4).

IV. Analysis of Infringement Allegations

’285 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be the interpretation of the final "time and date" limitation. The dispute may turn on whether displaying an estimated arrival time (Compl. ¶22, p. 12) satisfies the claim requirement that the device "displays the determined address at the associated time and date." The language could be interpreted to require displaying the address and time data together, or it could be interpreted more narrowly to require a temporal function, such as displaying the address only at a specific future time.
• Technical Questions: The complaint alleges the server receives a request for an address "not already stored in the positional information device." It is an open question what evidence will be presented to establish this negative limitation for any given act of infringement. Additionally, the patent's specification often describes a system centered on a dedicated GPS device, which raises the question of how the claims read on the accused architecture of a web browser on a general-purpose smartphone interacting with a remote website.

V. Key Claim Terms for Construction

"displays the determined address at the associated time and date"

• Context and Importance: This term is critical because the plaintiff's infringement allegation appears to hinge on the accused system's display of an estimated arrival time alongside driving directions (Compl. ¶22). The viability of the infringement claim may depend on whether this functionality meets the claim's requirement. Practitioners may focus on this term because its construction could be dispositive.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the user "may also transmit the time and date that each address will be utilized" and the "GPS device will then display the address at the specified date and time" (col. 10:52-58). This language could be argued to support an interpretation where the time and address are simply displayed concurrently.
  • Evidence for a Narrower Interpretation: The phrase "displays the ... address at the ... time and date" could be argued to imply a temporal trigger, where the address is presented to the user at a specific moment (e.g., as a calendar-like reminder), rather than being part of a persistent display of route information.

"positional information device"

• Context and Importance: The patent was filed in 2006 when dedicated GPS units were common. The accused system operates on modern, multi-function smartphones. The definition of this term will be important for determining if the accused user device (a smartphone running a web browser) is the same as the claimed "device."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the invention may apply to a "hand-held device" but also 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. 4:3-8). This suggests the term is not limited to a single hardware form factor.
  • Evidence for a Narrower Interpretation: The primary embodiment shown in Figure 1 and described in the text is a self-contained, portable GPS unit (’285 Patent, Fig. 1; col. 4:1-36). An opponent could argue that the context of the invention limits the term to devices whose primary purpose is positioning and navigation.

VI. Other Allegations

Indirect Infringement

The complaint makes conclusory allegations of contributory and induced infringement (Compl. ¶13). It does not, however, plead specific facts to support the elements of either claim, such as identifying a specific non-staple component for contributory infringement or alleging specific actions taken with the intent to encourage infringement for inducement.

Willful Infringement

The complaint does not contain allegations of willful infringement.

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

• A core issue will be one of claim construction and factual application: can the display of an estimated arrival time, as alleged in the complaint, satisfy the claim requirement that the system "displays the determined address at the associated time and date"? The case may turn on whether this is construed as a requirement for concurrent data display or a more specific temporal triggering function.
• A second key question will be one of system architecture: does the accused system—a user's general-purpose smartphone accessing a remote website via a browser—constitute the claimed "system" comprising a distinct "server" and "positional information device"? The analysis will likely focus on whether the distributed functionality of the accused website and smartphone maps onto the elements recited in Claim 13.
• An evidentiary question will be one of proof: what evidence can Plaintiff offer to satisfy the negative limitation that a requested address was "not already stored in the positional information device" at the time of the alleged infringement?