Navog LLC v. Panasonic Corp Of North America

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Navog LLC (NM)
  • Defendant: Panasonic Corporation of North America (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:24-cv-00258, W.D. Tex., 05/15/2024
• Venue Allegations: Venue is alleged to be proper in the Western District of Texas because the Defendant maintains an established place of business in the District and has allegedly committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle navigation products infringe a patent related to a GPS-based system for warning drivers of large vehicles about upcoming low-clearance obstacles.
• Technical Context: The technology addresses the prevention of collisions between high-profile vehicles (e.g., trucks, RVs) and low-clearance structures like bridges and tunnels, a significant safety and logistical issue in the transportation industry.
• Key Procedural History: The complaint does not reference any prior litigation involving the patent-in-suit, any post-grant proceedings before the U.S. Patent and Trademark Office, or any prior licensing history.

Case Timeline

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

U.S. Patent No. 10,593,205 - "GPS and Warning System," Issued 03/17/2020

The Invention Explained

• Problem Addressed: The patent describes the problem faced by drivers of commercial trucks, buses, and RVs who risk colliding with structures such as bridges, tunnels, or underpasses that do not offer sufficient vertical clearance for their high-profile vehicles (ʼ205 Patent, col. 1:56-61). Such situations can make it difficult to stop in time and force drivers to find alternative routes, wasting time and resources (ʼ205 Patent, col. 2:1-2).
• The Patented Solution: The invention is a dedicated in-vehicle device that combines a GPS module with a computer module programmed with a database of roadway structures and their specific clearance measurements (ʼ205 Patent, col. 4:40-46). By tracking the vehicle’s location via GPS, the system anticipates the vehicle’s path and, if it is approaching a structure with insufficient clearance, activates a warning mechanism with audible and visual alerts to notify the driver of the "impending danger" (ʼ205 Patent, col. 4:30-35, 50-54). The system is also described as being able to display alternate routes to avoid the hazard (ʼ205 Patent, col. 2:56-59).
• Technical Importance: The technology provides an automated, proactive safety system designed to prevent costly and dangerous low-clearance collisions, which the patent suggests is an improvement over relying on driver memory or static road signage (ʼ205 Patent, col. 2:12-18).

Key Claims at a Glance

• The complaint asserts infringement of one or more claims of the ’205 Patent without specifying them, referring to charts in an unprovided exhibit (Compl. ¶11). The patent’s two independent claims are:
  • Independent Claim 1: A GPS and warning system for an automobile, comprising:
    • A main body with a hollow interior volume
    • A computer module within the body, programmed with "information pertaining to existing roads, bridges, viaducts, and underpasses"
    • A GPS module within the body to provide location information
    • At least one warning mechanism connected to the computer module to provide a "loud audible sound" to warn a driver of impending danger
    • A display screen on the main body to provide visual information, including the height of an approaching structure
    • The computer module processes location information to determine when to signal the warning mechanism and initiates the warning when the device is within a "predetermined distance" of a hazard
  • Independent Claim 6: A combination of an automobile and a GPS and warning system, comprising:
    • An automobile with an engine and passenger compartment
    • A GPS and warning system as described in Claim 1, located within the passenger compartment

III. The Accused Instrumentality

Product Identification

• The complaint accuses "Exemplary Defendant Products" made, used, sold, or imported by Panasonic (Compl. ¶11). The specific products are identified in claim charts attached as Exhibit 2, which was not publicly available with the complaint (Compl. ¶16).

Functionality and Market Context

• The complaint does not describe the specific functionality of the accused products. Given the context of the patent, the accused instrumentalities are likely in-vehicle infotainment or navigation systems that include GPS functionality. The complaint alleges that these products "practice the technology claimed by the '205 Patent" (Compl. ¶16). No allegations are made regarding the products' specific market position.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an unprovided exhibit to detail its infringement allegations (Compl. ¶17). Therefore, a claim chart summary cannot be constructed. The narrative infringement theory alleges that the "Exemplary Defendant Products" contain the necessary components—a processor, GPS, display, and speaker—that are configured to operate in a manner that satisfies all elements of the asserted claims of the ’205 Patent (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The patent claims a system for an "automobile." The applicability of this term to the specific vehicle types in which Panasonic’s systems are installed may become a point of contention.
• Technical Questions: A central question for the court may be whether the "information pertaining to... underpasses" in the accused products includes the specific "underpass clearance measurements" described as a key feature in the patent's specification (ʼ205 Patent, col. 4:45-46). The complaint does not specify whether the accused products access a database of clearance heights or merely a database of bridge and tunnel locations. Another question is whether a general-purpose navigation alert in the accused products performs the specific function of the claimed "warning mechanism" intended to warn of "impending danger" from a low-clearance structure.

V. Key Claim Terms for Construction

"computer module... adapted to be programmed with information pertaining to existing roads, bridges, viaducts, and underpasses" (Claim 1)

• Context and Importance: The definition of the required "information" is critical. The infringement analysis will likely turn on whether this term requires only the location of structures like underpasses, or if it mandates the inclusion of specific dimensional data, such as vertical clearance heights.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the plain language of the claim only requires "information pertaining to" underpasses, which could encompass location data alone without explicit height measurements.
  • Evidence for a Narrower Interpretation: The specification repeatedly emphasizes the importance of clearance dimensions. The abstract states the system uses "the actual measurements of each and every structure," and the detailed description notes the computer is programmed with "underpass 180 clearance measurements" (ʼ205 Patent, Abstract; col. 4:45-46). This language suggests the "information" must include more than just location.

"warning mechanism... adapted to provide a loud audible sound adapted to warn a driver of the automobile of impending danger" (Claim 1)

• Context and Importance: Practitioners may focus on this term because the case may depend on whether a standard, multi-purpose audio alert from a navigation system meets this limitation, or if a more specific or dedicated warning function is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is arguably broad, requiring only a "loud audible sound" to warn of danger, which could potentially read on any generic alert from the accused system’s speakers.
  • Evidence for a Narrower Interpretation: The specification describes the warning in more specific terms: "a flashing warning light and loud, audible alarm will alert the driver to the impending danger" (ʼ205 Patent, col. 4:32-34). This could support an interpretation that the "warning mechanism" must be specifically tied to, and triggered by, the low-clearance threat, rather than being a general-purpose notification feature.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Panasonic distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’205 Patent (Compl. ¶14).

Willful Infringement

• The complaint alleges that its service constitutes "actual knowledge of infringement" and that any continued infringing activity by the Defendant after receiving the complaint is willful (Compl. ¶13-14). No allegations of pre-suit knowledge are made.

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

• A key evidentiary question will be one of technical capability: does the complaint's unprovided evidence show that the accused Panasonic products are programmed with or access a database containing specific "underpass clearance measurements," as detailed in the patent’s specification, or do they merely provide general-purpose navigation that is aware of bridge locations without this specific data?
• A core issue will be one of definitional scope: can the term "warning mechanism," in the context of the patent, be construed to cover a generic audio alert from a multi-function navigation system, or does it require a specialized function dedicated to warning of the specific "impending danger" of a low-clearance collision?