Activemap LLC v. Half Price Books Records Magazines Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Half Price Books, Records, Magazines, Incorporated (Texas)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00159, E.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains multiple established places of business in the district, including a specific retail location in Tyler, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website, specifically its store locator functionality, infringes three patents related to interactive electronic maps that link geographical locations with associated information.
• Technical Context: The technology at issue involves the two-way interactive functionality common in online store locators, where users can select items from a list to see them on a map or interact with the map to retrieve information about listed items.
• Key Procedural History: The complaint alleges that related European patents have been successfully litigated in Germany, resulting in findings of infringement. It also states that the patent portfolio has been licensed by 30 companies in the technology, automotive, and retail sectors.

Case Timeline

Date	Event
2001-04-30	Earliest Priority Date for Patents-in-Suit ('464, '943, '782 Patents)
2013-06-18	U.S. Patent No. 8,468,464 Issues
2019-10-15	U.S. Patent No. 10,444,943 Issues
2021-02-02	U.S. Patent No. 10,908,782 Issues
2026-02-27	Complaint Filed

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

U.S. Patent No. 8,468,464 - "Interactive Electronically Presented Map"

• Patent Identification: U.S. Patent No. 8,468,464, "Interactive Electronically Presented Map," issued June 18, 2013.

The Invention Explained

• As the parent patent in this family, its technology is described in the specifications of its children patents.
  • Problem Addressed: The patent family addresses the need for a more intuitive and interactive way for users to obtain information about a geographical area from an electronic map, aiming to create an experience "similar in essence to actually walking through the area of interest" '943 Patent, col. 2:36-38
  • The Patented Solution: The invention provides a system for "two-way interactivity" with an electronic map '943 Patent, col. 3:8-9 A user can either select an item or location on the map to retrieve associated information (e.g., contact details), or select an item from a list of information to see its corresponding location indicated on the map '943 Patent, abstract The system can also feature a "magnifier" tool that displays a magnified view of a portion of the map to facilitate navigation and selection '943 Patent, col. 3:23-36
  • Technical Importance: The complaint alleges this two-way linkage between a graphical map interface and associated data was "foundational for store locator website functionality" Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• The complaint does not provide the text of the asserted claim, which prevents a detailed breakdown of its elements.

U.S. Patent No. 10,444,943 - "Interactive Electronically Presented Map"

• Patent Identification: U.S. Patent No. 10,444,943 ("the '943 Patent"), "Interactive Electronically Presented Map," issued October 15, 2019.

The Invention Explained

• This patent emerges from the same family and shares a common specification with the '464 Patent. The problem, solution, and technical importance are as described above. The system architecture involves a server communicating with user devices over a network, with separate databases for graphic map files and text-based item information '943 Patent, Fig. 1

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• Claim 1 is a method claim with the following essential elements:
  • Receiving a request and, in response, providing a "first display" that includes: (a) graphical map information, (b) item information for at least two locations, and (c) "first information" that is user-selectable and identifies at least two items.
  • Receiving user input that selects the user-selectable information for one of the items.
  • In response, providing a "second display" that is at least partially different from the first and includes: (a) a portion of the map, (b) item information related to the selected item, (c) "second information" identifying at least two items, and (d) "additional information" about the selected item.

U.S. Patent No. 10,908,782 - "Interactive Electronically Presented Map"

• Patent Identification: U.S. Patent No. 10,908,782 ("the '782 Patent"), "Interactive Electronically Presented Map," issued February 2, 2021.

The Invention Explained

• This patent, also from the same family, claims a method for interacting with an electronic map. It focuses on a user providing a query for a category of items, receiving a display with a map and a list of items in that category, and then selecting an item from the list, which causes the system to display a new map centered on the location of the selected item '782 Patent, claim 1

Key Claims at a Glance

• Asserted Claims: The complaint asserts at least claim 1 Compl. ¶63
• Accused Features: The complaint alleges that the store locator feature on Defendant's website infringes this patent by allowing users to search for stores and view the results on an interactive map Compl. ¶62 Compl. ¶65

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as the "hardware, firmware, and software applications, together with the systems and backend components" that comprise Defendant's "interactive mapping ecosystem," as implemented on its website, https://www.hpb.com/ Compl. ¶25

Functionality and Market Context

• The core accused functionality is the website's store locator feature Compl. Fig. 2 The complaint provides a screenshot showing a user interface where a search query such as "tyler texas" can be entered to find nearby stores Compl. Fig. 2 A second screenshot shows the results, which include a list of stores on the left and a map on the right displaying numbered pins corresponding to the store locations Compl. Fig. 3 The complaint alleges this functionality is central to Defendant's retail business operations, enabling customers to find its physical store locations Compl. ¶10 Compl. ¶20 Compl. ¶25

IV. Analysis of Infringement Allegations

The complaint does not provide the text of asserted claim 1 of the '464 Patent, nor does it contain a claim chart or detailed element-by-element infringement allegations for this patent. Therefore, a claim chart summary cannot be constructed from the provided documents.

'943 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method implemented by at least one computer for providing user-interactive displays...the at least one computer receiving a request and in response, providing for presentation on the display device in a first display...	The Defendant's web server receives a user's request for the store locator page.	¶25	col. 14:1-12
which includes at least all of: graphical information representing a first portion of a geographical area; item information for presentation at two or more locations...and first information...identifying at least a first and a second of the two or more items...	The store locator page initially displays a map and a search box.	¶25; Fig. 2	col. 2:44-48
receiving user input to the at least one computer to select user-selectable information relating to the first of the two or more items...	A user enters a location query, such as "tyler texas," into the search box.	Fig. 2	col. 4:62-64
and in response, the at least one computer providing for presentation on the display device in a second display which is at least partially different from the first display...	The website updates to display a list of stores and a map with pins indicating their locations.	Fig. 3	col. 3:56-62
and includes at least all of: graphical information representing a portion of the geographical area; item information, related to at least the first item...second information, identifying at least the first and the second...and additional information about the first item...	The results page shows a map centered on the search area, a list including the HPB Tyler store with its address, and pins on the map for multiple stores. This is shown in a screenshot of Defendant's website displaying store locations responsive to a query Compl. Fig. 3	¶25; Fig. 3	col. 2:48-59

• Identified Points of Contention:
  • Scope Questions: A primary question may be whether the claim sequence of a "first display," "receiving user input," and a "second display" reads on the accused product's operation. The defense may argue that a user typing a query into a search box on a single webpage, which then dynamically updates with results, constitutes a single continuous display event rather than the two distinct displays required by the claim.
  • Technical Questions: What evidence does the complaint provide that a user entering a text query (e.g., "tyler texas") constitutes selecting from "user-selectable information" that "identif[ies] at least a first and a second" item, as claim 1 requires? The claim language may suggest that the user must select from a pre-populated list or set of options, raising the question of whether a free-text search meets this limitation.

V. Key Claim Terms for Construction

• The Term: "a second display which is at least partially different from the first display" '943 Patent, claim 1

• Context and Importance: The infringement analysis for the '943 Patent may depend on whether the initial store locator page and the subsequent results page are construed as two separate "displays." Practitioners may focus on this term because if the accused website is found to use only a single, dynamically updated display, it may not infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not explicitly define "display," which may support an argument for its plain and ordinary meaning, where any significant change to the information presented on the screen could render it a "partially different" display.
  • Evidence for a Narrower Interpretation: The claim structure recites a sequence of discrete steps (providing a first display, receiving input, providing a second display). This structure could support an interpretation that a "display" refers to a distinct screen or page load, rather than a dynamic update of existing on-screen elements.

• The Term: "user-selectable information" '943 Patent, claim 1

• Context and Importance: This term is critical because the infringement theory appears to equate a user's text entry into a search field with the act of "select[ing]" this information. The viability of the infringement claim may depend on whether a search query qualifies as a selection of pre-identified information.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification notes that user input can "include a query requesting information" '943 Patent, col. 4:62-64, which could support construing a user-typed search as a form of "selection."
  • Evidence for a Narrower Interpretation: The claim language states the "user-selectable information" is part of the "first display" and "identif[ies] at least a first and a second of the two or more items." This language may suggest that the information must be presented to the user as a discrete, selectable option (like a hyperlink or button) before the user acts, potentially excluding a free-form text entry.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement by providing instructions to customers and end users on how to use the Accused Products Compl. ¶38 Compl. ¶55 Compl. ¶72 It also alleges contributory infringement by distributing an article of commerce intended for an infringing use Compl. ¶37 Compl. ¶54 Compl. ¶71
• Willful Infringement: The complaint alleges willful infringement based on Defendant's purported "policy or practice against investigating third party patent rights," which it claims constitutes "willful blindness" to Plaintiff's patent rights Compl. ¶33 Compl. ¶50 Compl. ¶67 The allegations are based on pre-suit knowledge.

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

• A core issue will be one of definitional scope: can the claim term "select user-selectable information," which in the patent context appears to relate to choosing from presented options, be construed to cover a user independently typing a free-text geographical query into a search box?
• A key question of claim interpretation will be whether the accused website's process of dynamically loading search results onto a single page constitutes the sequential "first display" and "second display" recited in the method claims, or if it represents a single, continuous user experience that falls outside the patent's scope.
• An evidentiary question will be what facts Plaintiff can develop to support its allegation of "willful blindness," which is pleaded on information and belief and relies on a boilerplate assertion of a corporate policy against investigating patent rights.