DCT
2:21-cv-00622
Geographic Location Innovations LLC v. Mattress Depot USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geographic Location Innovations LLC (Texas)
- Defendant: Mattress Depot USA, Inc. (Washington)
- Plaintiff’s Counsel: Holloway IP
- Case Identification: 2:21-cv-00622, W.D. Wash., 05/10/2021
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Washington corporation deemed to reside in the district and because acts of infringement occur in the district where Defendant has a regular and established place of business.
- Core Dispute: Plaintiff alleges that Defendant’s website store locator system infringes a patent related to remotely providing location information and route guidance to a user's device.
- Technical Context: The technology concerns client-server systems for navigation, where a central server sends address coordinates to a positional device, which then calculates a route, aiming to simplify address entry for users.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | '285 Patent Priority Date |
| 2011-03-29 | '285 Patent Issue Date |
| 2021-05-10 | Complaint Filing Date |
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"
The Invention Explained
- Problem Addressed: The patent describes several problems with early-generation GPS devices, including inconsistent address recognition across different devices, the difficulty and danger of manually inputting addresses while driving, and the inefficiency of programming the same destination into multiple vehicles or devices owned by a user ('285 Patent, col. 1:41-2:4).
- The Patented Solution: The invention proposes a client-server system where a user requests a location from a remote server (e.g., via a live operator or a web interface) instead of typing it directly into their navigation device ('285 Patent, col. 2:32-46). The server determines the coordinates for the requested address and transmits them to the user’s "positional information device," which then uses its own location to calculate and display route guidance ('285 Patent, col. 3:15-28; Fig. 3).
- Technical Importance: This approach aimed to overcome the limitations of contemporary telematics systems (like OnStar), which provided live directions but did not, according to the patent, automatically program a vehicle's GPS device with downloadable address data for route calculation ('285 Patent, col. 2:15-31).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 13 ('285 Patent, Compl. ¶22).
- The essential elements of Claim 13 are:
- A server configured to receive a request for an address, determine the address, and transmit it to a positional information device.
- A positional information device that includes:
- a locational information module for determining the device's location.
- a communication module for receiving the address from the server.
- a processing module to receive the address and determine route guidance based on the device's location and the received address.
- a display module for displaying the route guidance.
- A communications network coupling the server and the device.
- An additional limitation wherein the server receives a time and date associated with the request and transmits it with the address, and the device displays the address at the 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. ¶22).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant's "store locator system" (the "System"), available on its website at https://www.mattressdepotusa.com/store-locator/ (Compl. ¶22).
Functionality and Market Context
- The System is described as a "route planner mobile application" integrated into Defendant's website (Compl. ¶23). A user can enter their location and a search radius to find nearby stores. The System then displays store locations on a map and provides an option to receive route guidance (Compl. ¶¶23-25).
- The complaint includes a screenshot showing the initial search interface where a user enters their location and search radius (Compl. p. 6). When a user selects a store, the System can display the store's address and provide turn-by-turn directions from the user's location (Compl. ¶¶25, 28). Another screenshot shows the turn-by-turn directions provided by the system (Compl. p. 11).
IV. Analysis of Infringement Allegations
'285 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a server configured to receive a request for an address...to determine the address...and to transmit the determined address to the positional information device | Defendant's servers receive a user's request for a store location, determine the address(es) of the relevant store(s), and transmit the address information to the user's device (e.g., smartphone or computer). | ¶24 | col. 8:12-15; Fig. 3 |
| the positional information device including a locational information module for determining location information of the positional information device | The user's smartphone utilizes its GPS capability (the "location information module") to determine its own location for the system. | ¶26 | col. 5:5-14 |
| a communication module for receiving the determined address...from the server | The user's device (e.g., smartphone) uses its cellular or network transceiver (the "communication module") to receive the store address from Defendant's server. | ¶27 | col. 6:40-54 |
| a processing module configured to receive the determined address...and determine route guidance based on the location of the positional information device and the determined address | The "mapping software and the mobile website" on the user's device act as the "processing module," which determines route guidance based on the user's GPS location and the received store address. A screenshot shows a map with a calculated route from point A to point B (Compl. p. 10). | ¶28 | col. 3:1-6 |
| a display module for displaying the route guidance | The screen on the user's smartphone or computer (the "display module") displays the map and turn-by-turn directions. | ¶29 | col. 3:7-9 |
| a communications network for coupling the positional information device to the server | The System uses the cellular network and/or the Internet as the communications network to connect the user's device to the server. | ¶30 | col. 8:15-18 |
| wherein the server receives a time and date associated with the requested at least one location and transmits the associated time and date with the determined address...and the positional information device displays the determined address at the associated time and date | The server allegedly receives the time and date of the request and transmits it with the address, and the user's device displays the address with this associated time and date. | ¶31 | col. 10:51-61 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether a general-purpose device like a smartphone or computer running a web browser meets the claim definition of a "positional information device" with its enumerated "modules." The defense may argue that the patent's specification describes a more integrated, dedicated device ('285 Patent, Fig. 1-2), whereas the accused system involves disparate software components (a web browser, mapping APIs) running on standard hardware.
- Technical Questions: The complaint alleges that the "mapping software and the mobile website" constitute the "processing module" that determines route guidance (Compl. ¶28). The case may turn on whether the route calculation is performed on the user's device as claimed, or if it is performed on the server side and merely transmitted to the user's device for display.
- Evidentiary Questions: The complaint's allegation regarding the "time and date" limitation is conclusory (Compl. ¶31). It is unclear what evidence supports the server transmitting a specific request time that is then used by the client device to "display" the address at that time, as required by the claim.
V. Key Claim Terms for Construction
The Term: "positional information device"
Context and Importance: This term's construction is fundamental. The infringement theory depends on casting a user's smartphone or computer as the claimed "device." Practitioners may focus on whether the term requires a single, integrated apparatus or if it can be read to cover a general-purpose computer executing web-based software.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 13 itself defines the device functionally by its required modules (locational, communication, processing, display), which could support an argument that any apparatus containing these functional components qualifies. The specification also states the invention can be applied 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).
- Evidence for a Narrower Interpretation: The primary embodiment described is a dedicated, handheld unit with integrated hardware components like an input module, storage module, and specific buttons ('285 Patent, Fig. 1-2; col. 4:16-36). The term's repeated use in the context of "GPS device" ('285 Patent, col. 1:12) may suggest a device whose primary purpose is navigation, not a general-purpose computer.
The Term: "processing module"
Context and Importance: The location of the route determination—client-side or server-side—is a critical technical question. The definition of "processing module" will determine whether the accused system's architecture meets this claim element.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires the module to "determine route guidance," a functional definition that could encompass various software implementations. The complaint alleges this is met by "mapping software and the mobile website" (Compl. ¶28).
- Evidence for a Narrower Interpretation: The specification describes the "computer processing module 120" as an integrated component of the device 100 that interacts with other internal modules via a system bus ('285 Patent, col. 4:39-43; Fig. 2). This could support an argument that the "processing module" must be a distinct component of the "positional information device" itself, rather than a transient web application or processes controlled by a remote server.
VI. Other Allegations
- Indirect Infringement: The complaint makes a conclusory allegation of contributory infringement and inducement (Compl. ¶22). It does not, however, plead specific facts supporting Defendant's knowledge of the patent or intent to encourage infringement by its users, such as by referencing user manuals or advertising materials that instruct on the use of the accused features.
- Willful Infringement: The complaint does not contain an explicit 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," described in the patent's embodiments as an integrated, dedicated unit, be construed to cover a general-purpose computer or smartphone running a standard web browser?
- A key technical question will be one of architectural mapping: does the accused website perform route calculation on the user's device (client-side), as required by the claim's "processing module," or is the route calculated on Defendant's server and simply sent to the user's browser for display?
- An evidentiary question will be whether Plaintiff can substantiate its allegation that the accused system practices the final limitation of Claim 13, which requires the server to transmit a "time and date" that the device then uses to "display the determined address at the associated time and date."