Autonavigare LLC v. Ford Motor Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: AutoNavigare LLC (Texas)
  • Defendant: Ford Motor Company (Delaware)
  • Plaintiff’s Counsel: Nelson Bumgardner Conroy PC
• Case Identification: 2:26-cv-00079, E.D. Tex., 01/30/2026
• Venue Allegations: Plaintiff alleges venue is proper because Ford has committed acts of patent infringement in the district and maintains a regular and established place of business in Plano, Texas, which it describes as Ford’s “principal office of Ford in the State of Texas.”
• Core Dispute: Plaintiff alleges that Defendant’s vehicle infotainment and navigation systems infringe six patents related to map data management, waypoint display, position correction, route searching, energy consumption prediction, and device integration.
• Technical Context: The patents cover various aspects of in-vehicle navigation and infotainment systems, a key technology area in the modern automotive market focused on enhancing driver guidance and user experience.
• Key Procedural History: The complaint alleges that prior to filing suit, Plaintiff sent a letter to Ford’s general and IP counsel identifying the Asserted Patents and providing claim charts demonstrating infringement. The complaint also references arguments made during the prosecution of several asserted patents to substantiate its position that the claimed inventions were not well-understood, routine, or conventional at the time of invention.

Case Timeline

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

U.S. Patent No. 7,584,049 - "Navigation Method, Processing Method for Navigation System, Map Data Management Device, Map Data Management Program, and Computer Program"

The Invention Explained

• Problem Addressed: The patent describes that, at the time of the invention, navigation systems typically relied on map data stored on fixed media like DVDs, which could only be updated periodically and in their entirety, a cumbersome process (Compl. ¶16; ’049 Patent, col. 9:39-49).
• The Patented Solution: The invention proposes organizing map data into geography-based units called “meshes” (Compl. ¶17, ¶19; ’049 Patent, col. 7:32-33). This structure allows a navigation device to use its existing, stored map data “in combination” with specific, updated map data for an area of interest (e.g., along a route) that is downloaded from a remote source, thereby avoiding the need to replace the entire map database (Compl. ¶17, ¶21-22; ’049 Patent, col. 9:39-49). The complaint references Figure 22 of the patent, which illustrates a user interface that facilitates user selection of data categories and meshes for map updates along a route Compl. ¶20 ’049 Patent, Fig. 22
• Technical Importance: This approach aimed to make map updates more flexible, less memory-intensive, and less costly by enabling partial updates over a network like the Internet Compl. ¶19 ’049 Patent, col. 30:46-33:10

Key Claims at a Glance

• The complaint asserts independent method claim 5 and reserves the right to assert other claims (Compl. ¶79, ¶81).
• Claim 5 of the ’049 Patent contains the following essential elements:
  • A navigation method for a system using map data stored in a fixed recording medium and downloaded update map data in combination.
  • Prompting a selection in a map data update menu.
  • Displaying a specific area distinguishably when it is judged to have update map data.
  • Prompting for an input of at least one selected option in an update category menu.
  • Using the update map data in the specific area based upon the input of the selected option.

U.S. Patent No. 7,640,104 - "Vehicle Navigation System and Method for Displaying Waypoint Information"

The Invention Explained

• Problem Addressed: The patent discloses that prior art navigation systems were limited in their ability to display waypoints (Points of Interest, or POIs). They could not correlate a desired waypoint with the time required to reach it, dynamically update waypoint selection based on real-time traffic, or allow users to specify meaningful constraints, leading to cluttered and irrelevant map displays (Compl. ¶32; ’104 Patent, col. 1:37-43, 2:18-27).
• The Patented Solution: The invention is a system and method where a user can input not only the type of waypoint but also a desired arrival time and permissible deviation in time or distance Compl. ¶33 ’104 Patent, col. 2:6-27, 3:30-50 The system’s route calculation engine then uses real-time traffic and other data to determine predicted arrival times at candidate waypoints, continuously updating these calculations and selectively displaying only those waypoints that satisfy the user’s constraints Compl. ¶33-34 ’104 Patent, col. 3:51-55, 4:4-23 The complaint references Figure 2 of the patent, which shows an exemplary screen displaying a user's request for a pizza restaurant waypoint within a specific time and distance from the route Compl. ¶33 ’104 Patent, Fig. 2
• Technical Importance: This method aimed to provide more accurate, relevant, and uncluttered waypoint guidance by dynamically filtering POIs based on real-time conditions and detailed user preferences Compl. ¶34 ’104 Patent, col. 2:18-27, 6:31-34

Key Claims at a Glance

• The complaint asserts independent method claim 1 and reserves the right to assert other claims, including claims 1-16 (Compl. ¶36, ¶91, ¶93).
• Claim 1 of the ’104 Patent contains the following essential elements:
  • A method for displaying information on a vehicle navigation system having a screen and a data receiver.
  • Displaying a route on the screen.
  • Receiving criteria which identifies desired waypoint(s) along the route.
  • Receiving waypoint(s) by the data receiver.
  • Comparing the received waypoint(s) with the desired waypoint(s).
  • Selectively displaying received waypoint(s) on the screen which correspond to the desired waypoint(s).

U.S. Patent No. 7,653,482 - “On-Vehicle Navigation Apparatus and Subject Vehicle Position Correction Method”

• Technology Synopsis: The patent addresses the problem of GPS “position jump,” where a navigation system abruptly and erroneously shifts a vehicle’s displayed position between closely spaced roads Compl. ¶39 The patented solution incorporates image-based analysis of camera-captured road marker lines to determine the vehicle’s actual lane of travel, thereby improving position correction accuracy and preventing erroneous map matching Compl. ¶40
• Asserted Claims: The complaint asserts at least method claim 3 (Compl. ¶102, ¶104).
• Accused Features: Ford’s SYNC and Digital Experience infotainment systems with Super Cruise functionality are accused of infringing Compl. ¶104

U.S. Patent No. 7,725,254 - “Navigation Device Used for a Route Search”

• Technology Synopsis: The patent addresses the complexity of route searching in prior art systems, which did not account for different costs (e.g., travel time) of traveling in different lanes of the same road segment (Compl. ¶47-48, ¶54). The invention describes using lane-specific costs in route search algorithms, storing map data in structures that associate costs with specific lanes of a road link to improve the accuracy and efficiency of route searching Compl. ¶48, ¶50-51 The complaint highlights patent Figures 2, 4, and 5, which depict data structures for storing lane-specific information and costs (Compl. ¶50; '254 Patent, Fig. 2, 4, 5).
• Asserted Claims: The complaint asserts at least device claim 1 (Compl. ¶114, ¶116).
• Accused Features: Ford’s Digital Experience infotainment systems with built-in navigation are accused of infringing Compl. ¶116

U.S. Patent No. 8,694,232 - “Method of Predicting Energy Consumption, Apparatus for Predicting Energy Consumption, and Terminal Apparatus”

• Technology Synopsis: The patent addresses shortcomings in prior art methods for predicting vehicular energy consumption, which were unreliable when probe vehicle data was sparse or inaccurate Compl. ¶59 The patented solution is a system that collects probe vehicle data and calculates "geographic characteristic values" for each road link—values that reflect energy attributes of the roadway itself (e.g., slope) independent of vehicle type. These values are then used to compute more reliable energy consumption predictions for any vehicle type (Compl. ¶60, ¶62).
• Asserted Claims: The complaint asserts at least method claim 1 (Compl. ¶126, ¶128).
• Accused Features: Ford’s Digital Experience infotainment systems with capabilities that support predicting energy consumption are accused of infringing Compl. ¶128

U.S. Patent No. 9,766,801 - “In-Car Information System, In-Car Device, and Information Terminal”

• Technology Synopsis: The patent discloses a novel interface allowing an in-car device (infotainment system) and an information terminal (smartphone) to communicate and exchange parameters Compl. ¶68 The system allows the information terminal to generate a menu that is displayed and controlled by the in-car device, enabling control over applications running on the terminal Compl. ¶68-69
• Asserted Claims: The complaint asserts at least device claim 2 (Compl. ¶138, ¶140).
• Accused Features: Ford’s SYNC and Digital Experience infotainment systems that support integration of multimedia devices like smartphones are accused of infringing Compl. ¶140

III. The Accused Instrumentality

Product Identification

• The complaint identifies several accused product lines, including Ford and Lincoln vehicles equipped with the "Ford/Lincoln Digital Experience Infotainment System" and the "Ford/Lincoln SYNC 3/4/4A/4A Expanded Infotainment System" (Compl. ¶5, ¶81, ¶93, ¶104, ¶116, ¶128, ¶140).

Functionality and Market Context

• The accused products are described as vehicle infotainment systems that provide capabilities for navigation, driver assistance, and multimedia device integration Compl. ¶5 The infringement allegations target specific functionalities within these systems, such as how they manage and update map data, search for and display waypoints, perform vehicle position correction, calculate routes, predict energy consumption, and interface with external devices like smartphones (Compl. ¶81, ¶93, ¶104, ¶116, ¶128, ¶140). The complaint alleges these systems are fundamental to the operation of the accused Ford and Lincoln vehicles and that Ford derives substantial revenues from their sale Compl. ¶8

IV. Analysis of Infringement Allegations

’049 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement analysis may turn on the construction of "in combination" Compl. ¶21 A key question for the court will be whether the accused system’s use of downloaded data to supplement or replace on-board data meets the claimed requirement of using both sources "in combination" as taught by the patent. Another point of contention may be the term "mesh," as the court will need to determine if Ford's data management architecture falls within the scope of the patent's specific "mesh" data structures (Compl. ¶23).
• Technical Questions: A factual question will be what evidence demonstrates that the accused Ford systems distinguishably display a "specific area" that is "judged to have update map data" based on a user's category selection, as required by claim 5, versus merely offering a generic update for a selected region Compl. ¶27

’104 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central issue may be the meaning of "selectively displaying." The court will need to determine if this requires displaying only waypoints that strictly meet all user criteria, as suggested by the patent's goal of reducing clutter Compl. ¶34, or if it can be read more broadly to cover systems that prioritize or highlight matching waypoints among a larger list.
• Technical Questions: The complaint alleges the invention remedied the inability of prior systems to "dynamically update waypoint selection based on traffic flow conditions" Compl. ¶32 An evidentiary question for the court will be whether the accused Ford systems actually perform the claimed dynamic, real-time comparison or if their waypoint filtering relies primarily on static data.

V. Key Claim Terms for Construction

’049 Patent, Claim 5

• The Term: "in combination"
• Context and Importance: This term appears in the claim preamble and is central to distinguishing the invention from prior art that simply replaced old data. The infringement case for this patent may depend on whether Ford's systems are found to "use" both stored and downloaded data together, or if they merely overwrite stored data with downloaded data. Practitioners may focus on this term because it defines the core novelty alleged by the patentee: the synergistic use of two data sources Compl. ¶21-22
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent abstract states the invention is a "navigation method for providing navigation by using map data," which could suggest that any method of using both sources to provide navigation meets the definition. The general description of benefits also focuses on avoiding full replacement of the recording medium (Compl. ¶19; ’049 Patent, col. 30:46-53).
  • Evidence for a Narrower Interpretation: The specification states, "The navigation system achieved in the embodiment, on the other hand, uses the map data in the recording medium 2 and updated map data in combination" (’049 Patent, col. 9:45-49), contrasting it with prior art that used a recording medium "alone." This suggests a specific operational mode, not just the presence of two data types on the system.

’104 Patent, Claim 1

• The Term: "selectively displaying"
• Context and Importance: This term is critical for distinguishing the claimed method from simple POI search filters. The patent emphasizes its ability to "avoid display clutter by selectively presenting only those waypoints that satisfy the user's timing and deviation constraints" Compl. ¶34 Infringement will hinge on whether Ford's systems perform this specific, curated display function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself, "selectively displaying received waypoint(s) on the screen which correspond to the desired waypoint(s)," could be argued to cover any non-random display where corresponding waypoints are prioritized or made more prominent.
  • Evidence for a Narrower Interpretation: The patent’s background explicitly criticizes prior systems that "cluttered map displays with irrelevant POIs" ’104 Patent, col. 2:25-27 and the specification highlights as an improvement the ability to present "only those waypoints that satisfy the user's... constraints" Compl. ¶34 This suggests "selectively displaying" requires exclusion of non-corresponding waypoints, not just highlighting them.

VI. Other Allegations

Indirect Infringement

• For all asserted patents, the complaint alleges that Ford knowingly induces infringement by its customers. The factual basis for this allegation includes Ford’s dissemination of advertisements, user manuals, and online instructional materials that allegedly "specifically teach and encourage" users to operate the accused infotainment systems in an infringing manner (Compl. ¶83-84, ¶94-95, ¶106-107, ¶118-119, ¶130-131, ¶141-142).

Willful Infringement

• The complaint alleges willful infringement for all asserted patents. This allegation is based on alleged pre-suit knowledge, stemming from a detailed letter with infringement contentions sent by AutoNavigare to Ford’s counsel, and alleged post-suit knowledge from the service of the complaint itself. The complaint alleges that despite this knowledge, Ford has "continued its infringing conduct and disregarded an objectively high likelihood of infringement" (Compl. ¶12, ¶86, ¶97, ¶109, ¶121, ¶133, ¶144).

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

This lawsuit presents a broad challenge to core features of modern automotive infotainment technology. The outcome will likely depend on the court’s resolution of several key technical and legal questions:

• A recurring issue will be one of definitional scope and temporal relevance: can the specific technical solutions described in patents from the 2000s, such as managing map data in "meshes" or "selectively displaying" waypoints, be construed to cover the potentially more complex and integrated functionalities of Ford's current SYNC and Digital Experience systems? The court will need to determine if the accused products practice the claimed inventions or achieve similar results through fundamentally different technological means that post-date the patents.
• A key evidentiary question will be one of functional operation versus claimed method: across multiple patents, the case will require a granular comparison between how the accused Ford systems actually operate and the specific steps recited in the asserted method claims. For example, does Ford's system use downloaded and stored data "in combination" as required by the ’049 patent, or does it simply overwrite old data? Does it perform the dynamic, real-time waypoint arrival calculations required by the ’104 patent, or does it use a more conventional filtering method?
• Finally, a central question for damages and willfulness will be one of knowledge and intent: what was the nature and timing of Ford’s knowledge of the asserted patents? The court will examine the sufficiency of the pre-suit notice alleged by Plaintiff to determine if Ford’s conduct rises to the level of willful infringement, which could expose it to enhanced damages.