Apple Inc v. Piney Woods Mobility LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Apple Inc. (California)
  • Defendant: Piney Woods Mobility LLC (Texas)
  • Plaintiff's Counsel: WILMER CUTLER PICKERING HALE AND DORR LLP
• Case Identification: 5:26-cv-05219, N.D. Cal., 06/01/2026
• Venue Allegations: Apple alleges venue is proper in the Northern District of California because a substantial part of the events giving rise to the dispute occurred in the district. This is based on Piney Woods' alleged business contacts, including that its sole managing member (X One, Inc.) and the sole inventor of the patents-in-suit (Richard D. Haney) are located and conduct business within the district. Additionally, a substantial portion of the research and development for the accused Apple products occurred at Apple's headquarters in Cupertino, CA.
• Core Dispute: Plaintiff Apple Inc. seeks a declaratory judgment that its products, including the iPhone, iPad, Apple Watch, and AirTag, do not infringe U.S. Patent Nos. 8,712,441, 9,031,581, 9,185,522, 9,253,616, 9,615,204, and 9,736,618, which relate to location sharing between mobile devices.
• Technical Context: The technology involves systems and methods for mobile devices to share location data, establish temporary sharing relationships, and receive location-based content, forming a basis for modern social coordination and location-aware applications.
• Key Procedural History: Piney Woods previously filed an infringement complaint against Apple on the same patents in the Western District of Texas on February 26, 2026, but failed to serve the complaint on Apple within the required 90-day period. Apple filed a motion to dismiss that Texas action. Piney Woods also filed suits against AT&T, Samsung, T-Mobile, and Verizon, alleging infringement by, among other things, Apple iPhone and iPad products. All patents-in-suit are now expired.

Case Timeline

Date	Event
2005-04-04	Earliest Priority Date for all Patents-in-Suit
2007-06-01	Apple launches first iPhone
2009-06-01	Apple announces "Find My iPhone" feature
2010-04-01	Apple launches first iPad
2010-11-01	"Find My iPhone" becomes free for iOS users
2011-10-01	Apple launches iCloud and "Find My Friends" application
2014-04-29	U.S. Patent No. 8,712,441 Issues
2015-05-12	U.S. Patent No. 9,031,581 Issues
2015-11-10	U.S. Patent No. 9,185,522 Issues
2016-02-02	U.S. Patent No. 9,253,616 Issues
2016-12-01	Apple launches first AirPods
2017-04-04	U.S. Patent No. 9,615,204 Issues
2017-08-15	U.S. Patent No. 9,736,618 Issues
2019-06-01	Apple merges "Find My iPhone" and "Find My Friends" into "Find My"
2021-04-30	Apple releases AirTag
2025-04-04	'441, '581, '522, and '616 patents expire
2025-07-31	'618 patent expires
2025-08-14	'204 patent expires
2025-11-21	Piney Woods Mobility LLC formed
2025-11-24	X One, Inc. assigns Patents-in-Suit to Piney Woods
2026-02-26	Piney Woods files complaint against Apple in W.D. Texas
2026-03-18	Corrective Assignment for Patents-in-Suit filed with USPTO
2026-05-27	Deadline for Piney Woods to serve its Texas complaint
2026-06-01	Apple files this Complaint for Declaratory Judgment

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

U.S. Patent No. 8,712,441: Methods and Systems for Temporarily Sharing Position Data Between Mobile-Device Users (Issued: April 29, 2014)

The Invention Explained

• Problem Addressed: The patent identifies a need for a system that allows for mutual, or "symmetrical," location sharing between mobile devices, contrasting this with prior art "kid tracking" services that were only one-way (parent-to-child) and could not be reconfigured in the field ʼ441 Patent, col. 1:49-2:10
• The Patented Solution: The invention describes a system centered on a "Buddy Watch Server" that facilitates temporary, permission-based position sharing ʼ441 Patent, abstract A first user sends a request to a second user, and upon acceptance, a "symmetrical position-sharing relationship" is established, allowing both users' devices to exchange and display location data, potentially on a map ʼ441 Patent, col. 2:10-24 ʼ441 Patent, Fig. 2A This relationship can be set to expire after a configurable timeout ʼ441 Patent, abstract
• Technical Importance: The technology provided a framework for creating temporary, permission-based social groups on mobile devices for the purpose of mutual location awareness, a key feature for coordinating group activities.

Key Claims at a Glance

• The complaint identifies asserted independent claim 1 Compl. ¶32
• Independent Claim 1 of the '441 Patent recites the following key elements for a method of sharing position data:
  • Receiving a first request from a first device to set up a position-sharing relationship.
  • Transmitting a second request to a second device, inviting the second user to accept.
  • Receiving a message from the second device indicating acceptance.
  • Establishing the position-sharing relationship responsive to the acceptance.
  • Transmitting the first position data to the second device and the second position data to the first device.
  • A "wherein" clause requiring the second user to be one of "multiple buddies" and further comprising steps of noting position data for all devices, calculating a "center of gravity," and displaying a subset of buddies based on that center of gravity.
• The complaint also identifies asserted dependent claims 3-6, 9-17, 20-24, and 27-33 Compl. ¶32

U.S. Patent No. 9,031,581: Apparatus and Method for Obtaining Content on a Cellular Wireless Device Based on Proximity to Other Wireless Devices (Issued: May 12, 2015)

The Invention Explained

• Problem Addressed: As part of the same patent family, the '581 patent addresses the broader context of enabling location-aware services, building on the ability to determine the relative location of mobile devices.
• The Patented Solution: The patent describes an apparatus on a cellular device that uses a "group code" to establish a relationship with other devices ʼ581 Patent, claim 7 Once authorized by the user, the device determines its proximity to other devices in the group, transmits this information to a "network destination," and in response, receives and presents location-dependent content to the user ʼ581 Patent, claim 7 The system is also designed to repeat this process when proximity changes, allowing for updated, geospatially-dependent information ʼ581 Patent, claim 7
• Technical Importance: This technology outlines a system for proximity-based content delivery, a foundational concept for location-aware advertising, social networking alerts, and other context-sensitive mobile applications.

Key Claims at a Glance

• The complaint identifies asserted independent claims 7 and 21 Compl. ¶40
• Independent Claim 7 of the '581 Patent recites the following key elements for an apparatus on a cellular wireless device:
  • Prompting a user for authorization to establish a relationship with other wireless devices associated with a common "group code."
  • Responsive to authorization, determining the proximity of the cellular device to geolocations of the other devices.
  • Transmitting information to a network destination to facilitate identification of the device's location.
  • Receiving "content dependent on the location" from the network destination.
  • Presenting the content to the user.
  • A "wherein" clause requiring the device to detect a change in proximity, repeat the transmission to the network, and receive updated geospatially-dependent information.
• The complaint also identifies asserted dependent claims 12 and 22 Compl. ¶40

U.S. Patent No. 9,185,522: Apparatus and Method to Transmit Content to a Cellular Wireless Device Based on Proximity to Other Wireless Devices

• Issued: November 10, 2015.
• Technology Synopsis: This patent describes a server-side apparatus for delivering location-dependent content. The server receives information identifying a mobile device's position relative to geolocations that share a "group code," selects content based on this position, and automatically transmits it to the device for display Compl. ¶49
• Asserted Claims: Independent claims 1 and 21; dependent claims 10-12, 14-17, 20, 30-32, and 34-40 Compl. ¶48
• Accused Features: Apple's "Find My" service is accused of infringement, with Apple arguing that the service does not use a "group code" and that its end-to-end encryption prevents the server from accessing or selecting content based on user location Compl. ¶50

U.S. Patent No. 9,253,616: Apparatus and Method for Obtaining Content on a Cellular Wireless Device Based on Proximity

• Issued: February 2, 2016.
• Technology Synopsis: This patent is highly similar to the '581 patent, describing a device-side apparatus that establishes relationships via a "group code," determines proximity to other devices, communicates with a network destination, and receives/presents location-dependent content Compl. ¶57
• Asserted Claims: Independent claims 1 and 14; dependent claims 2, 9-10, and 20-21 Compl. ¶56
• Accused Features: Apple's "Find My" service is accused, with Apple again arguing that it does not use a "group code" and that its end-to-end encrypted network does not "facilitate identification by the network destination" Compl. ¶58 Compl. ¶59

U.S. Patent No. 9,615,204: Techniques for Communication Within Closed Groups of Mobile Devices

• Issued: April 4, 2017.
• Technology Synopsis: This patent describes a device-side apparatus that allows a user to define groups of other mobile devices. It then transmits a request to other group members seeking their agreement to share location, and subsequently displays a map depicting the locations of the group members who have agreed Compl. ¶65
• Asserted Claims: Independent claims 1 and 17; dependent claims 2-4, 7-8, 10, 12-14, 18, 21-22, and 25 Compl. ¶64
• Accused Features: Apple's "Find My" service is accused, with Apple arguing that its products do not permit users to establish groups for sharing location, but rather only allow one-way sharing to specific, user-selected friends without a request/agreement protocol Compl. ¶66

U.S. Patent No. 9,736,618: Techniques for Sharing Relative Position Between Mobile Devices

• Issued: August 15, 2017.
• Technology Synopsis: This patent describes a device-side apparatus for establishing an "ad hoc communication session" with a second device. The first device sends a request for the session, and upon acceptance, transmits its GPS position and direction of travel to the second device Compl. ¶73
• Asserted Claims: Independent claims 1, 18, 19, and 36; dependent claims 2-8, 10, 12-16, 20-26, 28-29, and 31-35 Compl. ¶72
• Accused Features: Apple's "Find My" service is accused, with Apple contending that its products do not establish an "ad hoc communication session" or transmit data "subject to acceptance," but instead use a one-way sharing model Compl. ¶74

III. The Accused Instrumentality

Product Identification

The complaint collectively refers to a wide range of Apple hardware and software as the "Accused Apple Products" Compl. ¶¶1-4 The core accused functionality resides within Apple's "Find My" application and network, which incorporates features from the earlier "Find My iPhone" and "Find My Friends" applications Compl. ¶24

Functionality and Market Context

The "Find My" application allows Apple device users to share their location with other users Compl. ¶28 According to the complaint, this sharing is a "one-way action" initiated when a user elects to share their location with a friend by selecting them from their contacts and sending the location for a chosen duration Compl. ¶28 Compl. ¶42 The complaint alleges that this process does not involve the acceptance of a request by the receiving user Compl. ¶28 Apple also alleges that the Find My network is end-to-end encrypted, making a user's location information unavailable to Apple itself Compl. ¶42 Compl. ¶50

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

U.S. Patent No. 8,712,441 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving, from the first device, a first request to set up a position-sharing relationship between the first and second users;	Apple asserts its products do not practice this limitation because location sharing is a one-way action initiated by a user and "does not involve the acceptance of any request."	¶34; ¶28	col. 2:10-15
transmitting a second request to the second device, the second request inviting the second user to accept the position-sharing relationship;	Apple asserts its products do not transmit an invitation to be accepted; the sharing is described as a one-way push of information from the first user.	¶34; ¶28	col. 2:15-18
receiving a message from the second device indicating acceptance of the position-sharing relationship;	As Apple alleges no request is sent or accepted, it follows that no message indicating acceptance is received.	¶34; ¶28	col. 2:18-20
establishing the position-sharing relationship responsive to the acceptance;	Apple alleges no relationship is established responsive to acceptance; sharing is user-initiated and does not require acceptance.	¶34; ¶28	col. 2:20-21
transmitting the first position data to the second device and the second position data to the first device;	Apple's non-infringement theory is premised on location sharing being a "one-way action," which may raise the question of whether this element requiring two-way, or symmetrical, data transmission is met.	¶34; ¶28	col. 2:22-24

• Identified Points of Contention:
  • Scope Questions: A central issue may be whether the user-initiated, one-way "Share Your Location" function in Apple's "Find My" application Compl. ¶28 can be construed to meet the claim limitations of a "request," "inviting... to accept," and "acceptance" that establish a "position-sharing relationship." The patent's focus on "symmetrical position sharing" ʼ441 Patent, abstract may be contrasted with Apple's description of its functionality as a "one-way action" Compl. ¶28
  • Technical Questions: A factual question for the court will be how the handshake and data exchange process in Apple's "Find My" network technically operates, and whether it includes any implicit request-and-acceptance protocol that could be argued to meet the claim limitations, despite Apple's characterization.

U.S. Patent No. 9,031,581 Infringement Allegations

Claim Element (from Independent Claim 7)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
prompt a user... for authorization to establish a relationship with one or more other wireless devices associated with a group code common to said other wireless devices...	Apple alleges its products do not use a "group code" and that sharing does not involve a prompt for authorization to establish a relationship, but is instead initiated by a user with a chosen friend.	¶42; ¶42 p. 14	col. 13:9-14
determine, from signals received from one or more of the wireless devices having the common group code, proximity...	Apple alleges its products do not use a "group code" to determine proximity; relationships are based on user contacts, not a common code.	¶42; ¶42 p. 14	col. 13:14-18
transmit information to a network destination... the information to facilitate identification by the network destination of location of the cellular wireless device...	Apple asserts its products do not "facilitate identification by the network destination" because the Find My network is end-to-end encrypted, and user location is unavailable to Apple.	¶42; ¶42 p. 14	col. 13:19-23
receive responsive to identification of the location by the network destination content dependent on the location...	Because Apple alleges the network cannot identify the location, it follows that the device cannot receive content responsive to such identification.	¶42	col. 13:24-26

• Identified Points of Contention:
  • Scope Questions: A key dispute will concern the term "group code." The court will need to determine if Apple's system of sharing between users who are contacts (e.g., in an address book) meets the definition of a "group code common to said other wireless devices," as the patent requires.
  • Technical Questions: The allegation that the Find My network's end-to-end encryption makes user location "unavailable to Apple" Compl. ¶42 raises a factual and legal question: does a system that is technically unable to decrypt user data at the server level still "facilitate identification by the network destination" as claimed? This may turn on whether "network destination" is interpreted to be the server itself or the end-user's device.

V. Key Claim Terms for Construction

For U.S. Patent No. 8,712,441

• The Term: "position-sharing relationship"
• Context and Importance: The existence of a "relationship" established through a request/acceptance protocol is a cornerstone of claim 1 and a central point of Apple's non-infringement argument Compl. ¶34 Practitioners may focus on this term because its definition will determine whether Apple's one-way, user-initiated sharing model falls within the claim scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses various uses like group activities and work group coordination ʼ441 Patent, abstract, which could suggest "relationship" covers any consensual, multi-party location sharing, regardless of the precise handshake mechanism.
  • Evidence for a Narrower Interpretation: The abstract explicitly describes a process where a server "facilitates symmetrical position sharing" after receiving a request and an acceptance, and the claim language recites these discrete steps ʼ441 Patent, abstract ʼ441 Patent, claim 1 This could support an interpretation requiring a formal, multi-step, server-mediated handshake to form the "relationship."

For U.S. Patent No. 9,031,581

• The Term: "group code"
• Context and Importance: Apple's non-infringement defense for the '581, '522, and '616 patents hinges on its assertion that the Accused Products "do not use a 'group code' to share users' location information" Compl. ¶42 Compl. ¶50 Compl. ¶58 The construction of this term is therefore dispositive for these patents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term is not explicitly defined. A party might argue that any shared secret or common identifier used to associate a group of devices, even one managed implicitly by a server based on user contacts, could constitute a "group code."
  • Evidence for a Narrower Interpretation: The specification describes embodiments related to "TalkControl" and joining "talk groups" (e.g., '581 patent, related application data). This context may support a narrower definition where "group code" requires an explicit, user-shared alphanumeric code for forming ad-hoc communication groups, distinct from a system based on pre-existing contact lists.

VI. Other Allegations

• Indirect Infringement: Apple seeks a declaratory judgment that it does not induce or contribute to infringement of the Patents-in-Suit Compl. p. 26 The complaint states that Apple "has not caused, directed, requested, or facilitated any such infringement, much less with specific intent to do so" and that the products have substantial non-infringing uses Compl. ¶29 Compl. ¶35
• Willful Infringement: The complaint does not allege willfulness. Rather, as part of its declaratory judgment action, Apple asserts it had "no knowledge" of the patents or the alleged infringement before they expired Compl. ¶35 Compl. ¶43 Compl. ¶51 Compl. ¶59 This allegation is positioned to preemptively defend against any future charge of willful infringement by Piney Woods.

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

• A primary issue will be one of definitional scope: does Apple's user-initiated, one-way location sharing feature, as described in its "Find My" service, constitute a "position-sharing relationship" established via a "request" and "acceptance" as recited in the '441 patent, or is there a fundamental difference in the protocol?
• A second core question will address technical operation and claim scope: can the patents' requirement for a "group code" to associate devices be met by Apple's system, which relies on users' existing contact lists? This analysis may determine infringement for a significant portion of the asserted patent portfolio ('581, '522, '616 patents).
• A key evidentiary and legal question will be one of network functionality: does Apple's end-to-end encrypted network, which Apple claims makes user location data "unavailable to Apple" at the server, still "facilitate identification by the network destination" as required by the claims, and does it "select... content dependent on the position" if the server cannot access location data?