WirelessWerx IP LLC v. Google LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wirelesswerx IP LLC (Texas)
  • Defendant: Google LLC (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 6:22-cv-01056, W.D. Tex., 10/07/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains regular and established places of business within the district, and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s Google Map products infringe a patent related to methods for mapping in a multi-dimensional space, such as within multi-story buildings.
• Technical Context: The technology at issue concerns systems for precise location tracking in environments where GPS is often inadequate, such as inside buildings, by using a network of local wireless nodes.
• Key Procedural History: The complaint was filed on October 7, 2022. Subsequently, an Inter Partes Review (IPR) proceeding, IPR2023-00850, was initiated against the patent-in-suit. The IPR concluded with a certificate issued on February 28, 2025, cancelling all 30 claims of the patent. This post-filing invalidation of the asserted patent is a case-dispositive event.

Case Timeline

Date	Event
2004-11-05	'203 Patent Priority Date
2012-11-20	'203 Patent Issue Date
2022-10-07	Complaint Filing Date
2023-05-12	IPR2023-00850 Filed
2025-02-28	IPR Certificate Issued Cancelling All Claims of the '203 Patent

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

U.S. Patent No. 8,315,203 - Mapping in a Multi-Dimensional Space

• Patent Identification: U.S. Patent No. 8,315,203, Mapping in a Multi-Dimensional Space, issued November 20, 2012.

The Invention Explained

• Problem Addressed: The patent identifies a limitation in conventional GPS tracking systems, which often fail to provide a "precise location" within complex structures like multi-story buildings. A user's device might be physically closer to a location node on an adjacent floor, leading to inaccurate positioning (’203 Patent, col. 1:47-53).
• The Patented Solution: The invention proposes a system using a plurality of stationary wireless "nodes" (e.g., Bluetooth transceivers) arranged in a multi-dimensional space, such as on different floors of a building. A mobile device communicates with these nodes to determine its position. The system uses an algorithm to identify the "most practically near node," which considers accessibility, not just physical proximity, thereby enabling more accurate three-dimensional mapping within a structure (’203 Patent, Abstract; col. 5:55-68). Figure 19A illustrates this concept with nodes placed on multiple floors of a building communicating with a central system.
• Technical Importance: The technology aimed to overcome the limitations of GPS for indoor navigation and asset tracking, a significant challenge for location-based services in dense, vertical urban environments (’203 Patent, col. 1:31-44).

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert others (Compl. ¶16, ¶21).
• Essential elements of independent claim 1 include:
  • A method for developing a map using a geographical zone containing a plurality of "spaced apart nodes" arranged in a "multi-dimensional sense" within a building having multiple elevational levels.
  • Sending data communications between nodes, users, and control stations.
  • Affecting a "three-dimensional" mapping based on the placement of the nodes.
  • A step wherein the system narrows the plurality of nodes to the "most practically near node," which explicitly involves excluding a node that may be physically closer but is on a different, less accessible elevational level.

III. The Accused Instrumentality

Product Identification

• The complaint identifies "Google's Map products" as the Accused Instrumentalities (Compl. ¶14).

Functionality and Market Context

• The complaint does not describe the specific architecture or functionality of Google's Map products. It provides only a general reference to a partnership-related webpage (Compl. ¶14). The complaint does not provide sufficient detail for analysis of the technical operation of the accused products.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" that purports to describe how Google's Accused Products infringe claim 1; however, this exhibit was not attached to the filed complaint (Compl. ¶21). The complaint itself offers only a conclusory allegation of infringement. It states that the defendant directly infringes "by making, using, testing, selling, offering for sale and/or importing into the United States Defendant's Accused Products" (Compl. ¶16). Without the claim chart or more detailed factual allegations, the specific theory of infringement is not articulated.

• Identified Points of Contention:
  • Scope Questions: A central question would be whether "Google's Map products," a software-based service relying primarily on GPS, Wi-Fi positioning, and cellular data, can be said to practice a method that requires a pre-configured, physical network of "nodes" within a building.
  • Technical Questions: The complaint provides no evidence that the accused products perform the specific claim step of identifying a "most practically near node" by excluding a physically closer but less accessible node on a different floor. The infringement analysis would hinge on whether Google's location algorithms perform this specific function as claimed.

V. Key Claim Terms for Construction

• The Term: "nodes"

• Context and Importance: The claims are grounded in a physical arrangement of "nodes." The definition of this term is critical to determining if a software-based service like Google Maps, which does not typically rely on a proprietary, pre-installed network of dedicated hardware, can infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent occasionally refers generally to "location transmitters or nodes," which might be argued to encompass a range of wireless signal sources (’203 Patent, col. 25:6-7).
  • Evidence for a Narrower Interpretation: The specification provides a more specific definition, describing a "location node" as a "stationary programmable device with a wireless transceiver, which is 'Bluetooth™' capable for example, and a micro-controller" (’203 Patent, col. 5:41-44). This language suggests a specific piece of installed hardware rather than ambient, third-party Wi-Fi access points.

• The Term: "most practically near node"

• Context and Importance: This term is a key point of novelty, distinguishing the invention from merely identifying the strongest signal. Infringement requires showing that the accused system performs the claimed logic of excluding a physically closer node in favor of a more "practical" one. Practitioners may focus on this term because it appears to be a crucial limitation for overcoming prior art.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue the term functionally covers any algorithm that selects a location reference point based on factors beyond simple distance, such as floor level or other contextual data available to a mapping service.
  • Evidence for a Narrower Interpretation: The specification ties the term directly to physical accessibility within a building, providing the example of a device on a second floor being "most practically near" a node on that same floor, even if a node on the first floor ceiling is closer in absolute distance (’203 Patent, col. 5:55-68). This suggests the term requires a calculation based on the physical layout and accessibility of a structure.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement. The sole count is for direct infringement under 35 U.S.C. §271(a) (Compl. ¶16).
• Willful Infringement: The complaint makes conclusory allegations that Defendant "made no attempt to design around the claims" and "did not have a reasonable basis for believing that the claims of the '203 Patent were invalid" (Compl. ¶17-18). It does not allege pre-suit knowledge of the patent.

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

1. Case Viability: The foremost issue is the legal effect of the Inter Partes Review decision that cancelled all claims of the '203 Patent. As the sole asserted patent is now invalid, the central question is not one of infringement, but on what basis the case can proceed, with dismissal being the expected outcome.

2. Fundamental Mismatch in Technology: Had the patent remained valid, a key question would be one of technical applicability: does the architecture of Google's public mapping service—which leverages GPS, Wi-Fi, and cell tower data—align with the patent's claimed method, which is rooted in a system of dedicated, physically installed "nodes" within a multi-story structure?

3. Definitional Scope: A dispositive claim construction issue would have been the interpretation of "most practically near node". The case would have turned on whether this requires a specific, accessibility-based algorithm as described in the patent's examples, or if it could be construed more broadly to cover any contextual location-selection logic used by modern mapping services.