Activemap LLC v. Lowe's Companies Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Lowe's Companies, Inc. (North Carolina)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-0160, E.D. Tex., 06/09/2026
• Venue Allegations: Venue is based on Defendant maintaining multiple established places of business within the Eastern District of Texas, with a specific store address cited in Tyler, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three patents related to interactive, electronically presented maps.
• Technical Context: The technology concerns systems and methods for linking data presented in a list with corresponding locations on a graphical map, a foundational feature of modern web-based store locators.
• Key Procedural History: The complaint notes that related European patents have been successfully enforced in Germany, and that the underlying technology has been licensed 30 times to companies in various sectors.

Case Timeline

Date	Event
2001-04-30	Earliest Priority Date ('464, '943, '782 Patents)
2013-06-18	U.S. Patent No. 8,468,464 Issued
2019-10-15	U.S. Patent No. 10,444,943 Issued
2021-02-02	U.S. Patent No. 10,908,782 Issued
2026-06-09	Complaint Filing Date

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:
  • Problem Addressed: The patent addresses the limitations of early internet maps, which were static and did not allow for dynamic, two-way interaction between the map itself and information associated with locations on that map Compl. ¶21
  • The Patented Solution: The invention provides a system for two-way interactivity where a user can either select an item from a list (e.g., text information) to see its location on a map, or select a location on the map to retrieve associated information Compl. ¶26 This is accomplished by associating coordinate information with item information, allowing the system to retrieve one based on the other '464 Patent, col. 3:4-13
  • Technical Importance: This approach was described as "foundational" for website store locator functionality, which became a widely deployed feature for retail and service companies Compl. ¶20
• Key Claims at a Glance:
  • The complaint asserts at least independent claim 1 Compl. ¶46
  • The essential elements of system claim 1 include:
    • At least one computer programmed to cause a display device to simultaneously present:
      • a first portion of the map centered at a first x and y coordinate;
      • information on the first map portion related to one or more items;
      • information outside the first map portion responsive to a query and including user-selectable information.
    • The computer is further programmed to, in response to a user selection of information outside the map, present a second map portion centered at a different x or y coordinate.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "at least" claim 1 Compl. ¶46

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

• Patent Identification: U.S. Patent No. 10,444,943 ("'943 Patent"), "Interactive Electronically Presented Map," issued October 15, 2019.
• The Invention Explained:
  • Problem Addressed: As with its related patents, the '943 Patent sought to improve upon prior art electronic maps that lacked rich, two-way interactivity (Compl. ¶21, citing '943 Patent, col. 1:43-60).
  • The Patented Solution: The '943 Patent describes a method for providing an interactive map where a computer receives a user request and, in response, presents a display with a graphical map portion and associated item information. The method then involves receiving a user selection related to one of the items and providing a "second display which is at least partially different from the first display" '943 Patent, claim 1 The specification also details features like a "magnifier" that provides a magnified, movable view of the map, and the ability to have animated images move over the map display (Compl. ¶22; Compl. ¶27, citing '943 Patent, col. 2:60-2:16).
  • Technical Importance: The addition of features like a movable magnifier provided a more intuitive user experience for exploring detailed maps, analogous to using a physical magnifying glass Compl. ¶16
• Key Claims at a Glance:
  • The complaint asserts at least independent claim 1 Compl. ¶63
  • The essential elements of method claim 1 include:
    • A computer receiving a request and, in response, providing a first display that includes a graphical area representation and associated item information for at least two items.
    • Receiving a user input to select information relating to the first of the items.
    • In response, providing a second display which is at least partially different from the first and includes a graphical representation, item information, and additional information about the first item.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "at least" claim 1 Compl. ¶63

U.S. Patent No. 10,908,782 - "Interactive Electronically Presented Map" (Multi-Patent Capsule)

• Patent Identification: U.S. Patent No. 10,908,782 ("'782 Patent"), "Interactive Electronically Presented Map," issued February 2, 2021.
• Technology Synopsis: The '782 Patent, also in the same family, details a method for user interaction with an electronic map. The invention focuses on a user submitting a query for a category of items, the system presenting a display with a map and responsive item information, and then, upon user selection of a specific item, presenting a new map display that is re-centered on the location of the selected item '782 Patent, claim 1
• Asserted Claims: The complaint asserts at least independent claim 1 Compl. ¶80
• Accused Features: The accused features are the interactive store locator functions on the Lowe's website, which allow users to search for stores and see their locations presented on a map (Compl. ¶41; Compl. ¶42).

III. The Accused Instrumentality

• Product Identification: The Accused Products are the "interactive mapping ecosystem" available on Defendant's website, including its store locator functionality Compl. ¶41 This encompasses the associated hardware, software, servers, and cloud-based infrastructure Compl. ¶41
• Functionality and Market Context:
  • The complaint alleges the accused website allows users to input a location, such as "tyler, texas," to view a map displaying nearby store locations Compl. ¶¶41-42 A screenshot provided in the complaint shows an initial search interface with a map background Compl. Fig. 2, p. 23 This figure, from the Lowe's website, depicts a search bar for location entry over a map view. A subsequent screenshot shows the result of a search: a map populated with numbered pins indicating store locations, alongside a list of those stores with addresses and other details Compl. Fig. 3, p. 24 This second figure illustrates the website displaying a map with user-selectable store information in response to a user's query.
  • The complaint characterizes the underlying technology as "foundational for store locator website functionality" and notes it has been "widely deployed by companies in all regions and sectors," suggesting significant commercial placement and importance Compl. ¶10 Compl. ¶20

IV. Analysis of Infringement Allegations

8,468,464 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A system for providing an interactive electronic map, comprising: at least one computer programmed to cause a display device to simultaneously present thereon:	The Accused Products comprise a system of servers and software that present the interactive map on the Lowe's website Compl. ¶41	¶41	col. 2:20-24
a first portion of the map centered at a first x coordinate and at a first y coordinate;	The Lowe's website displays a map centered on or near a user-queried location Compl. Fig. 3	¶43	col. 4:55-60
information on the first map portion related to one or more items associated with a geographic area represented by the first map portion;	The displayed map includes selectable pins representing Lowe's store locations Compl. Fig. 3	¶43	col. 3:1-4
information outside of the first map portion responsive to a query relating to the map including user-selectable information;	The website displays a list of stores with addresses and details, which is outside the map portion itself but responsive to the user's search query Compl. Fig. 3	¶43	col. 4:5-15
wherein the at least one computer is programmed to cause, in response to selection of user-selectable information from the user-selectable information outside of the first map portion...the display device to simultaneously present thereon: instead of the first map portion a second map portion, in relation to the information selected, the second map portion being...centered at an x coordinate different from the first x coordinate...	When a user selects a store from the list, the system is alleged to re-center the map on the selected store's location, thereby presenting a second map portion centered at a different coordinate.	¶43	col. 4:5-15

10,444,943 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...comprising: the at least one computer receiving a request and in response, providing for presentation on the display device in a first display which includes...graphical information representing a first portion of a geographical area...	The Lowe's website server receives a user's search query (e.g., for "tyler, texas") and provides a first display containing a map of that area Compl. Fig. 2 Compl. Fig. 3	¶43	col. 3:8-14
...and item information for presentation at two or more locations on the first portion of the geographical area related to two or more respective items...and first information...identifying at least a first and a second of the two or more items...	The first display includes pins on the map and a corresponding list identifying multiple Lowe's store locations Compl. Fig. 3	¶43	col. 4:1-4
receiving user input to the at least one computer to select user-selectable information relating to the first of the two or more items from the user-selectable information...	A user clicks on or otherwise selects one of the stores from the displayed list (Compl. ¶43).	¶43	col. 4:5-9
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 and includes...additional information about the first item...	Upon selection, the website presents a new or updated display. This is alleged to include an updated map view and/or additional details about the selected store, such as store hours and phone number, which is different from the initial display Compl. Fig. 3	¶43	col. 4:9-15

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "area representation" as used in the patents, which originated with stylized, illustrated maps (e.g.,'943 Patent, Fig. 9), can be construed to cover the more conventional, data-driven map interface used by the accused website.
  • Technical Questions: The infringement theories depend on the accused website presenting a "second map portion" or "second display" in response to a user selection. A point of contention may be whether the accused functionality-such as highlighting a pin and showing an information pop-up-meets the claims' requirements for a new map portion "centered at a... different... coordinate" ('464 Patent) or a "second display which is at least partially different" ('943 Patent), or if this represents a functionally distinct, non-infringing operation.

V. Key Claim Terms for Construction

• The Term: "area representation"

• Context and Importance: This term is fundamental to all asserted patents and defines the core subject matter. The defendant will likely seek to narrow its scope to the specific embodiments shown in the patent, while the plaintiff will argue for a broader meaning to encompass modern web maps. The outcome of its construction will be critical to determining infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly states that ""Map" and "area representation" are used herein in a broad sense and may encompass a variety of geographic and non-geographic areas" '943 Patent, col. 2:20-23 Compl. ¶23 This language may support a construction that is not limited to the specific figures.
  • Evidence for a Narrower Interpretation: The patent figures consistently depict a specific, artistically-rendered, two-dimensional illustrated map (e.g., '943 Patent, Fig. 9; Compl. p. 5). A party could argue that these consistent examples define the true scope of the invention as understood at the time of filing, potentially limiting the term to exclude the type of functional, data-layered map used by the accused website.

• The Term: "a second map portion... centered at an x coordinate different from the first x coordinate" ('464 Patent, claim 1)

• Context and Importance: This term defines the specific interactive step required for infringement of the '464 Patent. Practitioners may focus on this term because the infringement allegation hinges on whether the accused website's response to a user selection (e.g., displaying an info-box) constitutes presenting a new map portion that is re-centered, or if it is merely an overlay on the existing map portion.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent describes a system of two-way interactivity where selecting text information can be used to "position the position indicator on the map," which suggests a change in the map's focus or center '943 Patent, col. 3:14-23
  • Evidence for a Narrower Interpretation: The claim language is specific, requiring a "second map portion" that is "centered" differently. This suggests more than a simple overlay is required. An argument could be made that if the patentees intended to cover a simple information pop-up, they would have claimed it as such, rather than using language that implies a change in the underlying map's viewpoint.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by providing instructions to its customers and end-users on how to use the accused store locator features, including how to "share your location with others" Compl. ¶55 Compl. ¶72 Compl. ¶89 It is also alleged that Defendant encourages infringing use through its advertising Compl. ¶54
• Willful Infringement: The complaint alleges willful infringement based on a theory of willful blindness, asserting that Defendant has a "policy or practice against investigating third party patent rights" Compl. ¶50 Compl. ¶67 Compl. ¶84 The allegations also suggest that infringement continued with knowledge of the patents after some form of notice was provided Compl. ¶52

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

• A core issue will be one of definitional scope: can the term "area representation," which is rooted in the patents' disclosure of a specific, stylized graphical map, be construed broadly enough to read on the functionally different, data-driven interface of the accused website's modern store locator?
• A second central question will be one of functional operation: does the accused website, in response to a user selecting a store from a list, actually perform the claimed step of presenting a "second map portion... centered at a... different... coordinate," as required by claim 1 of the '464 patent? The case may turn on evidence showing whether the accused system re-centers the underlying map view or merely presents an information overlay, and whether the latter meets the specific requirements of the asserted claims.
• Finally, the willfulness claim raises an evidentiary question of intent: can Plaintiff prove that Defendant maintained a policy of "willful blindness" toward third-party patent rights, or that it had the requisite knowledge of infringement, sufficient to meet the high standard for enhanced damages?