2:22-cv-01366
Social Positioning Input Systems LLC v. Valve Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Social Positioning Input Systems, LLC (Wyoming)
- Defendant: Valve Corporation (Washington)
- Plaintiff’s Counsel: Meyler Legal, PLLC
- Case Identification: 2:22-cv-01366, W.D. Wash., 09/27/2022
- Venue Allegations: Venue is alleged to be proper as Defendant is a Washington corporation with its principal place of business in the district, and is thus deemed to reside there.
- Core Dispute: Plaintiff alleges that Defendant’s products, including hardware and software for asset locating services, infringe a patent related to remotely programming positional information devices.
- Technical Context: The technology at issue concerns systems and methods for simplifying the entry of location data into navigational devices, such as vehicle GPS units, by using a remote server.
- Key Procedural History: The asserted patent is a continuation of a prior application, which itself is a continuation of an earlier application, establishing a chain of prosecution history. The complaint incorporates by reference an infringement claim chart (Exhibit B) which analyzes U.S. Patent No. 9,300,723, a different patent than the one formally asserted in the complaint's infringement count (U.S. Patent No. 9,261,365).
Case Timeline
| Date | Event |
|---|---|
| 2006-04-28 | Earliest Priority Date for ’365 Patent |
| 2016-02-16 | Issue Date for U.S. Patent No. 9,261,365 |
| 2022-09-27 | Complaint Filing Date |
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" (issued Feb. 16, 2016)
The Invention Explained
- Problem Addressed: The patent identifies several problems with contemporary GPS devices, including the difficulty and time-consuming nature of manually inputting addresses, inconsistencies in address recognition between different devices, the safety risk of programming a device while driving, and the inefficiency of entering the same address into multiple devices owned by one user (’365 Patent, col. 1:53 - col. 2:25).
- The Patented Solution: The invention proposes a system where a user can communicate a desired location to a remote service, for instance, through a telematics link in a vehicle (’365 Patent, col. 9:7-14). This remote service or server resolves the location into geographic coordinates (e.g., latitude and longitude) and transmits them directly to the user's positional information device, which then calculates and displays route guidance (’365 Patent, col. 9:51 - col. 10:7; Fig. 4). The system is also described as enabling a user to access addresses stored on one device (e.g., a home computer) and send them to another (e.g., a vehicle's GPS) (’365 Patent, Fig. 5).
- Technical Importance: The technology aimed to improve the safety and user experience of in-vehicle navigation by offloading the complex and distracting task of address entry from the user to a remote, automated system (’365 Patent, col. 2:38-44).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims, including at least Claim 1" (Compl. ¶13).
- Independent Claim 1 of the ’365 Patent recites a method with the following essential elements:
- 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" of the requesting device.
- Receiving the retrieved address at the requesting device.
- The server performs the intermediate steps of determining a "second identifier" for the sending device based on the first identifier, and then retrieving the requested address from that sending device.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The complaint identifies the accused product as "Vive (or HTC Vive) featuring SteamVR tracking, and any associated hardware, apps, or other software" (Compl. ¶13). The complaint’s Exhibit B, however, analyzes the "Steam Deck" portable gaming device (Compl. Ex. B, p. 23).
Functionality and Market Context
The complaint describes the accused products broadly as "associated hardware and software for asset locating services" (Compl. ¶13). The infringement chart in Exhibit B provides more detail on the Steam Deck, describing it as an "all-in-one portable PC gaming" device that connects to the internet via WiFi and to peripherals such as headsets via Bluetooth (Compl. Ex. B, p. 23). A screenshot from Defendant's website shows marketing for the Steam Deck, highlighting its wireless connectivity features (Compl. Ex. B, p. 24). The complaint does not provide further technical details on the operation of the HTC Vive or SteamVR tracking.
IV. Analysis of Infringement Allegations
The complaint asserts infringement of U.S. Patent No. 9,261,365 (Compl. ¶13, ¶18). However, the incorporated claim chart in Exhibit B alleges infringement of a different patent, U.S. Patent No. 9,300,723, by the Steam Deck product line (Compl. ¶19; Ex. B). The following analysis summarizes the allegations as presented in Exhibit B. The patent specification for U.S. Patent No. 9,300,723 was not provided with the complaint; therefore, patent specification citations for the claim elements are not available.
[U.S. Patent No. 9,300,723] Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) at least one media terminal disposed in an accessible relation to at least one interactive computer network, | The Steam Deck product connects to the internet (interactive computer network) via WiFi, and peripherals like headsets (media terminal) connect to the device via Bluetooth. | ¶18; Ex. B, p. 25 | Not Available |
| b) a wireless range structured to permit authorized access to said at least one interactive computer network, | The Headset is connected to the Steam Deck via a Bluetooth wireless range. Access is authorized via Steam accounts requiring a username and password, or two-factor authentication. | ¶18; Ex. B, pp. 27-29 | Not Available |
| c) at least one media node disposable within said wireless range, wherein said at least one media node is detectable by said at least one media terminal, | The Steam Deck (media node) is detectable by a headset (media terminal) when it is within the Bluetooth wireless range. | ¶18; Ex. B, p. 30 | Not Available |
| g) said at least one media node and said at least one media terminal being structured to transmit said at least one digital media file there between via said communication link | The Steam Deck (media node) and a connected headset (media terminal) are structured to transmit game audio and chat data (digital media file) between them over the Bluetooth communication link. | ¶18; Ex. B, p. 38 | Not Available |
- Identified Points of Contention:
- Pleading Discrepancy: The most significant issue is the mismatch between the patent asserted in the complaint's formal counts ('365 Patent) and the patent analyzed in the incorporated infringement chart ('723 Patent). This raises a threshold question as to which patent and infringement theory Defendant is expected to defend against.
- Scope Questions (for the '365 Patent): Assuming the case proceeds under the '365 Patent, a central dispute may arise over whether the terminology of the patent, which is directed to vehicle GPS navigation, can be read to cover virtual reality or gaming technology. For example, does the position of a user in a VR playspace, as tracked by SteamVR, constitute an "address" for the purpose of "route guidance" as contemplated by the patent (’365 Patent, col. 4:13, 11:23)?
- Technical Questions (for the '365 Patent): A key factual question will be whether the accused Vive or SteamVR systems practice the claimed method of sending a request to a server to retrieve address information stored on another, separate device, as required by Claim 1. The complaint lacks specific allegations detailing such a data flow.
V. Key Claim Terms for Construction
Analysis is based on Claim 1 of the ’365 Patent, as it is the lead claim identified in the complaint body.
The Term: "address"
Context and Importance: This term is critical because the infringement theory appears to require mapping the concept of a geographical "address" onto location data within a gaming or VR system. The patent's examples focus exclusively on street addresses for vehicle navigation (e.g., "19333 Collins Avenue, Sunny Isles, Fla.") (’365 Patent, col. 2:60-63). Practitioners may focus on whether the term is limited to this context or can be interpreted more broadly.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification also uses more general terms like "destination information" and "location of interest," which could suggest a meaning beyond just a civic street address (’365 Patent, col. 2:12, 12:30-31).
- Evidence for a Narrower Interpretation: The patent’s background, abstract, and detailed description consistently frame the invention in the context of "Global Positioning System (GPS) devices" and solving problems related to vehicle navigation, which may support limiting the term "address" to physical, geographical locations used for that purpose (’365 Patent, Abstract; col. 1:20-24).
The Term: "positional information device"
Context and Importance: The definition of this term is central to determining if the accused hardware (e.g., a Steam Deck, VR headset) falls within the scope of the claims. The complaint alleges that devices like the HTC Vive are covered (Compl. ¶13).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that the device is not limited to vehicle-mounted units and explicitly includes a "hand-held device" as an embodiment (’365 Patent, col. 3:15-18).
- Evidence for a Narrower Interpretation: The claims and specification consistently tie the function of the "positional information device" to providing "route guidance" (’365 Patent, col. 4:13-14, 11:23-25). This functional requirement may be used to argue that a device that does not provide travel directions from one point to another is not a "positional information device" as claimed.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" (’Compl. ¶16).
- Willful Infringement: The willfulness allegation appears to be based on post-suit conduct. The complaint alleges that "At least since being served by this Complaint and corresponding claim chart, Defendant has actively, knowingly, and intentionally continued to induce infringement" (Compl. ¶17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold procedural question will be one of pleading clarity: the court will need to address the fundamental discrepancy between the GPS-related '365 Patent asserted in the complaint's legal counts and the media-system '723 Patent analyzed in the incorporated infringement chart.
- Assuming the case proceeds on the asserted '365 Patent, a core issue will be one of definitional scope: can terms such as "address" and "positional information device", which are rooted in the patent's context of vehicle GPS navigation, be construed broadly enough to cover the components, data, and functions of a modern gaming or virtual reality system?
- A key evidentiary question will be one of operational correspondence: what evidence will be presented to show that the accused VR and gaming systems perform the specific, multi-step method of Claim 1, which involves a "requesting device" and a "sending device" communicating through a server to transfer a stored "address"?