Nearby Systems LLC v. Sephora USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nearby Systems LLC (Texas)
  • Defendant: Sephora USA, Inc. (Michigan, with a principal place of business in California)
  • Plaintiff’s Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:26-cv-00076, E.D. Tex., 01/28/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business within the district and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s "Sephora App" for mobile devices infringes four U.S. patents related to methods for combining and displaying location-based data from different sources on a single digital map.
• Technical Context: The technology at issue involves integrating location data found in non-mapping applications (e.g., social media, websites, email) into a mapping application to display new points of interest on an existing map view.
• Key Procedural History: The four asserted patents are part of the same patent family, with U.S. Patent Nos. 10,469,980, 11,937,145, and 12,185,177 being continuations of the application that ultimately issued as U.S. Patent No. 9,532,164. This shared prosecution history suggests that claim construction arguments and prior art references may have significant overlap across all four patents.

Case Timeline

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

U.S. Patent No. 9,532,164 - Mashing Mapping Content Displayed On Mobile Devices (issued Dec. 27, 2016)

The Invention Explained

• Problem Addressed: The patent family addresses a limitation in prior art mobile mapping systems where new mapping content originating from an external, non-mapping application (e.g., a location mentioned in an email or on a website) could only be displayed on a new, separate digital map, which would not contain any previously displayed information (’980 Patent, col. 1:32-39).
• The Patented Solution: The invention provides a method and system for combining, or "mashing," mappable data from disparate sources onto a single, existing digital map on a mobile device (’980 Patent, summary). This allows a user to select location information in one application (e.g., a street address in a social media app) and have it appear as a new point of interest on a map already being displayed by a separate mapping application, preserving the context of the original map view (’980 Patent, col. 2:54-65; ’980 Patent, FIGS. 1A-1C).
• Technical Importance: This technology enables the creation of dynamic, composite maps that aggregate location data from various user contexts, enhancing the utility of mobile mapping beyond simple searches within a standalone map application Compl. ¶21

Key Claims at a Glance

The complaint asserts at least Claim 1 of the '164 patent Compl. ¶26 As a copy of the '164 patent was not provided with the complaint, its specific claim elements cannot be analyzed. The complaint reserves the right to assert additional claims Compl. ¶25

U.S. Patent No. 10,469,980 - Mashing Mapping Content Displayed On Mobile Devices (issued Nov. 5, 2019)

The Invention Explained

The technology of the ’980 Patent is substantially the same as described for the '164 Patent, focusing on integrating location data from external applications onto a single, persistent map (’980 Patent, abstract).

Key Claims at a Glance

The complaint asserts at least Claim 1 of the ’980 patent Compl. ¶43

• Independent Claim 1 (System Claim):
  • A memory storing a first non-browser application.
  • A processor executing the first non-browser application.
  • A touch screen displaying a user interface of the first non-browser application.
  • A GPS device determining the mobile device's location.
  • A mapping component of the first non-browser application configured to communicate with an online mapping service to download map data and display a map within its user interface.
  • The mapping component transmits a query with the device's location to the online mapping service.
  • The memory also stores a second non-browser application that is a mapping application.
  • The mapping component invokes the mapping application and directs it to transmit a query, including the mobile device's location and a destination, to obtain and display driving directions.

The complaint reserves the right to assert additional claims Compl. ¶42

U.S. Patent No. 11,937,145 - Mashing Mapping Content Displayed On Mobile Devices (issued Mar. 19, 2024)

Technology Synopsis

This patent, part of the same family, concerns the technical method of integrating mappable content from outside a primary mapping application onto a single digital map (’145 Patent, abstract). It addresses the problem of fragmented mapping information by allowing content from different applications to be consolidated into one map view, preserving previously displayed content Compl. ¶¶55-56

Asserted Claims

At least Claim 1 Compl. ¶60

Accused Features

The complaint alleges that the Sephora App's system for displaying map information to allow users to find and navigate to store locations infringes the patent Compl. ¶61

U.S. Patent No. 12,185,177 - Mashing Mapping Content Displayed On Mobile Devices (issued Dec. 31, 2024)

Technology Synopsis

As the latest patent in the asserted family, the '177 patent shares the core technical disclosure of combining external location data onto an existing map display on a mobile device (’177 Patent, abstract). The stated goal is to improve the function of mapping systems by enabling the combination of mappable data from disparate sources onto a single map Compl. ¶72

Asserted Claims

At least Claim 1 Compl. ¶77

Accused Features

The complaint alleges infringement by the Sephora App's provision of a system and method for displaying map information for navigating to store locations Compl. ¶78

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "Sephora App" and its associated website, https://www.sephora.com Compl. ¶¶16-18

Functionality and Market Context

The complaint alleges the Sephora App is a mobile device application designed to allow customers to locate Defendant's stores Compl. ¶18 Its functionality is described as a "system and method for displaying map information on a mobile device... to obtain the data to display text and maps that present information to allow a mobile device user to identify and navigate to locations offering Defendant's products" Compl. ¶27 Compl. ¶44 Compl. ¶61 Compl. ¶78 The complaint does not provide specific technical details about how the app's mapping features operate. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts or provide the exhibits referenced as containing exemplary evidence of infringement Compl. ¶26 Compl. ¶43 Compl. ¶60 Compl. ¶77 The infringement theory is therefore summarized from the complaint's narrative allegations.

For each of the four asserted patents, the complaint alleges that the Sephora App provides a system and method for displaying map information on a mobile device to help users identify and navigate to store locations Compl. ¶27 Compl. ¶44 Compl. ¶61 Compl. ¶78 This general functionality is alleged to infringe at least claim 1 of each patent. The complaint lacks specific factual allegations tying the operation of the Sephora App to the individual limitations of any asserted claim.

• Identified Points of Contention:
  • Architectural Questions: A central question may be whether the architecture of the Sephora App aligns with the specific architecture recited in the claims. For example, claim 1 of the ’980 patent requires a "first non-browser application" with a "mapping component" that "invokes" a separate "second non-browser application." The analysis may question whether the Sephora App, in simply displaying a map (potentially via an embedded API), meets the claimed structure of two distinct non-browser applications interacting in this specific manner.
  • Scope Questions: The patent specification emphasizes combining content from "disparate applications," such as adding a location from a social media app to a separate mapping app (’980 Patent, FIGS. 1B-1C). A potential point of contention is whether the Sephora App, which is alleged to display its own store locations, performs the claimed invention, or if the claims require combining content from distinct third-party sources.

V. Key Claim Terms for Construction

Analysis is based on claim 1 of the provided ’980 Patent.

• The Term: "invokes the mapping application and directs the mapping application"

  • Context and Importance: This phrase describes the relationship between the first application (containing the external data) and the second application (the mapping app). The construction of this term will be critical to determining whether an application that uses an embedded map view or calls a mapping API, without launching a fully separate application, can infringe.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes "relaying" information to a mapping application, which could suggest that any form of data transfer, including an API call, is sufficient (’980 Patent, col. 2:5-7).
    • Evidence for a Narrower Interpretation: The specification describes a process where the mapping application is "minimized" and then "re-opened" or "restored into full view," which suggests a process involving two distinct, concurrently running applications (’980 Patent, col. 3:12-20; ’980 Patent, col. 3:48-51). This may support a narrower construction requiring a formal application launch or context switch.

• The Term: "mapping component of the first non-browser application"

  • Context and Importance: Practitioners may focus on this term because the infringement analysis will depend on identifying a corresponding structure within the accused Sephora App. The claim requires this component to be part of the first application and to be the actor that "invokes" the second.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the component generally as a "software module" or code capable of providing functionality, which could be read broadly to cover various software implementations (’980 Patent, col. 2:5-7; ’980 Patent, col. 8:12-14).
    • Evidence for a Narrower Interpretation: The patent's figures, particularly FIG. 10B, depict the "MAPPING COMPONENT" (1022) as an architecturally distinct block from the "DISPLAY APPLICATION" (1024) and the "MAPPING APPLICATION" (1026) (’980 Patent, FIG. 10B). This could support an argument that the component must be a separable module, not merely integrated code coextensive with the first application itself.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the Sephora App and encourages its use through advertising, promotion, and instructions Compl. ¶28 Compl. ¶45 Compl. ¶62 Compl. ¶79 Contributory infringement is alleged on the basis that the accused products contain "special features" that are not "staple articles of commerce suitable for substantial non-infringing use" Compl. ¶29 Compl. ¶46 Compl. ¶63 Compl. ¶80
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the patents as of the filing of the lawsuit Compl. ¶30 Compl. ¶47 Compl. ¶64 Compl. ¶81 The complaint further alleges that Defendant maintains a "policy or practice of not reviewing the patents of others," constituting willful blindness Compl. ¶31 Compl. ¶48 Compl. ¶65 Compl. ¶82

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

• A primary issue will be one of architectural correspondence: Does the Sephora App's software architecture embody the specific, multi-part structure recited in the claims, particularly the requirement for a "mapping component" within a "first non-browser application" that "invokes" and "directs" a separate "second non-browser application," or is there a fundamental mismatch between the claimed system and the accused product's use of integrated mapping APIs?
• A second core issue will be one of definitional scope: Can the patented concept of "mashing mapping content" from "disparate sources," illustrated in the specification by combining data from distinct third-party applications like social media, be construed to cover an application that primarily plots its own proprietary data (i.e., store locations) onto a base map?
• Finally, a key evidentiary question will be one of factual substantiation: Given the complaint’s lack of specific technical allegations, the case may turn on what evidence is produced to demonstrate how the accused app's actual operation meets each limitation of the asserted claims, moving from the general allegation of "displaying map information" to a detailed element-by-element mapping.