DCT
2:21-cv-00523
Social Positioning Input Systems v. Automile
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Social Positioning Input Systems, LLC (Texas)
- Defendant: Automile, Inc. (Delaware)
- Plaintiff’s Counsel: Kizzia Johnson, PLLC
- Case Identification: 2:21-cv-00523, D. Utah, 09/03/2021
- Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant is deemed to reside in the district and maintains a regular and established place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s asset tracking platform and associated hardware infringe a patent related to systems for remotely requesting and sharing location information between positional devices via a server.
- Technical Context: The technology operates in the vehicle and asset telematics field, a market segment focused on providing real-time location data for fleet management, logistics, and monitoring.
- Key Procedural History: The complaint does not allege any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | Earliest Priority Date for ’365 Patent |
| 2016-02-16 | U.S. Patent No. 9,261,365 Issues |
| 2021-09-03 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,261,365 - Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device
- Patent Identification: U.S. Patent No. 9,261,365, "Device, System and Method for Remotely Entering, Storing and Sharing Addresses for a Positional Information Device," issued February 16, 2016.
The Invention Explained
- Problem Addressed: The patent describes challenges with contemporary GPS devices, including the difficulty and potential danger of manually programming destination addresses, inconsistencies in how different devices recognize location names, and the inefficiency of programming the same routes into multiple vehicles individually (’365 Patent, col. 1:53-col. 2:25).
- The Patented Solution: The invention discloses a system where a user of a "requesting" device can obtain location information associated with a separate "sending" device without manual entry (’365 Patent, Abstract). A user sends a request to a central server, which then identifies the appropriate sending device, retrieves a stored address from it, and transmits that address back to the requesting device for route guidance (’365 Patent, col. 13:56-col. 14:1). The system architecture, involving user devices communicating through a central server, is illustrated in Figure 3 of the patent (’365 Patent, Fig. 3).
- Technical Importance: This architecture aimed to simplify the user experience by centralizing the task of address lookup and retrieval, thereby allowing users to easily and safely program GPS devices remotely or share addresses between devices (’365 Patent, col. 2:40-44).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶13).
- The essential elements of Claim 1, a method claim, are:
- Sending a request from a "requesting positional information device" to a server for an address stored in a "sending positional information device." The request includes a "first identifier" for the requesting device.
- Receiving the retrieved address at the requesting device.
- The method specifies that the server performs an intermediate step: it uses the "first identifier" to determine a "second identifier" for the sending device, and then uses that second identifier to retrieve the requested address that is "stored in" the sending device.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the "Automile asset tracking platform, and any associated hardware, apps, or other software," which includes the "Automile Box" hardware device (Compl. ¶13, p. 5).
Functionality and Market Context
- The Automile product is an asset tracking system that provides real-time GPS location data for fleet management (Compl. ¶14). A user operating a software application on a mobile device or computer (the "requesting" device) can view the live location of an asset on a map (Compl. ¶15). The asset is equipped with an "Automile Box," a hardware unit with its own SIM card and GPS, which functions as the "sending" device that transmits its location to the Automile server (Compl. ¶15, p. 5). The server then provides this location data to the user's application (Compl. ¶16). A screenshot in the complaint depicts the user interface showing "Real-time live tracking" of assets on a map (Compl. p. 4).
IV. Analysis of Infringement Allegations
’365 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| sending a request from a requesting positional information device to a server for at least one address stored in at least one sending positional information device, the request including a first identifier of the requesting positional information device; | The complaint alleges a user sends a request from a mobile device or desktop to the Automile server to obtain an asset's real-time location. The request includes the user's login ID and password, which is alleged to be the "first identifier." | ¶15 | col. 13:56-61 |
| receiving at the requesting positional information device, from the server, a retrieved at least one address...wherein the server determines a second identifier for identifying the at least one sending positional information device based on the received first identifier and retrieves the requested at least one address stored in the identified at least one sending positional information device. | The server is alleged to receive the user's request and login ID (first identifier). It then determines the unique ID of the tracker device associated with that user account (the "second identifier"). The server then retrieves the asset's GPS location ("stored address") and transmits it back to the user's device for display. A screenshot shows the registration process where a device's serial number is linked to an account (Compl. p. 9). | ¶¶16, 17 | col. 14:62-col. 15:1 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether retrieving a device's current, real-time GPS location falls within the scope of retrieving "at least one address stored in" the device. The patent specification frequently frames the invention in the context of retrieving pre-programmed destination addresses or waypoints, raising the question of whether a transient, live coordinate is an "address stored in" the device as contemplated by the patent (’365 Patent, col. 2:10-14). The complaint appears to equate these concepts by referring to "the real-time location (e.g., stored address) of an asset" (Compl. ¶15).
- Technical Questions: A factual dispute may arise over where the location address is stored and from where it is retrieved. The complaint alleges the server "retrieves the at least one address stored in the at least one sending positional information device" (Compl. ¶17). It is a technical question whether the Automile Box hardware actually stores its address for retrieval by the server, or if it simply transmits its live coordinates to the server, with the server then storing and providing that data upon request. The distinction between retrieval from the server's database versus retrieval from the sending device's memory may be a critical point of contention.
V. Key Claim Terms for Construction
- The Term: "at least one address stored in at least one sending positional information device"
- Context and Importance: The viability of the infringement claim may depend on the construction of this phrase. The dispute will likely center on whether this language is limited to pre-programmed, static destination addresses residing in the sending device's memory, or if it can also encompass the device's own dynamic, real-time GPS coordinates that are transmitted to a server.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes storing information in "internal or removable memory" and does not explicitly exclude a device's own location coordinates from being "stored information" (’365 Patent, col. 1:36-44). Plaintiff may argue that for a device to transmit its coordinates, those coordinates must first be determined and held in some form of memory, thus qualifying as "stored."
- Evidence for a Narrower Interpretation: The patent’s background repeatedly discusses the problem of manually programming destination addresses into GPS units (’365 Patent, col. 1:53-59). The examples provided, such as retrieving addresses for a trip itinerary, consistently refer to destination points rather than the current location of the device itself (’365 Patent, col. 13:4-16). This context suggests the term "address stored in" refers to user-saved destination data.
VI. Other Allegations
- Indirect Infringement: The complaint includes a general allegation of contributory infringement and inducement in violation of 35 U.S.C. § 271 (Compl. ¶13). It does not, however, plead specific facts to support these claims, such as referencing user manuals, marketing materials, or other evidence of intent to encourage infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the claim phrase "at least one address stored in... a sending positional information device," which the patent specification links to pre-programmed destinations, be construed to cover the live, real-time GPS coordinates of an asset tracking device?
- A key evidentiary question will be one of technical operation: Does the accused Automile server retrieve location data that is factually "stored in" the memory of the hardware box on the asset, as the claim requires, or does the server simply receive a real-time data stream from the box and retrieve location data from its own database? The architectural distinction between these two models of data retrieval will likely be central to the infringement analysis.