Activemap LLC v. Lucky OpCo LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Lucky OpCo LLC (Delaware)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00161, E.D. Tex., 02/27/2026
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining multiple established places of business within the Eastern District of Texas, specifically retail store locations in Allen and Frisco, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three patents related to interactive electronic maps that link a graphical map display with a corresponding list of locations.
• Technical Context: The technology at issue involves the two-way interactive functionality common in online mapping tools, where selecting an item in a text-based list updates a corresponding map view, and vice-versa.
• Key Procedural History: The complaint alleges that the patent portfolio is well-established, with a family of patents cited over 300 times by major technology companies. It also notes that related European patents were successfully asserted in Germany and that the technology has been licensed 30 times.

Case Timeline

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

U.S. Patent No. 8,468,464 - "INTERACTIVE ELECTRONICALLY PRESENTED MAP"

The Invention Explained

• Problem Addressed: The patent describes the need for improved electronic maps that allow for more intuitive, two-way interaction between a graphical map and associated data, such as lists of businesses or points of interest '464 Patent, col. 1:20-34
• The Patented Solution: The invention is a computerized method for presenting an interactive map where a user can select information from a list presented "outside" the map area, causing the map to update and re-center on the location corresponding to the selected list item '464 Patent, abstract This creates a reciprocal link where the map can be navigated via the associated text list, and the list can be used to explore the map '464 Patent, col. 3:6-15
• Technical Importance: This two-way interactivity between a list and a map became a foundational element for online store locators and other applications involving geo-referenced data Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• Claim 1 of the '464 Patent is a method claim with the following essential elements:
  • Simultaneously presenting on a display a first map portion centered at a first coordinate and user-selectable information (a list) outside of that map portion.
  • In response to a user selecting an item from the list, presenting a second map portion that is at least partially different from the first and is centered at a new coordinate corresponding to the selected item.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,444,943 - "INTERACTIVE ELECTRONICALLY PRESENTED MAP"

The Invention Explained

• Problem Addressed: As a continuation within the same patent family, the '943 Patent addresses the same technical challenge of creating a seamless interactive experience between a graphical map and its associated data points '943 Patent, col. 1:31-42
• The Patented Solution: The patent describes a method where a computer system provides a "first display" containing a map and a selectable list of items. When a user selects an item from the list, the system generates a "second display" that is different from the first and includes additional information about the selected item '943 Patent, abstract The invention emphasizes the system's response to user input to transition between different informational states '943 Patent, col. 4:16-24
• Technical Importance: The claimed method provides a structured way to implement interactive location-based searches, a functionality the complaint alleges is foundational to e-commerce store locators Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• Claim 1 of the '943 Patent is a method claim with the following essential elements:
  • Providing a "first display" that includes a map portion and a user-selectable list identifying at least two items.
  • Receiving user input selecting one of the items from the list.
  • In response, providing a "second display" that is at least partially different from the first and includes additional information about the selected item.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,908,782 - "INTERACTIVE ELECTRONICALLY PRESENTED MAP"

• Technology Synopsis: This patent, also in the same family, addresses the problem of linking list-based information with map-based locations '782 Patent, col. 1:35-41 The solution is a system where a user query for a category of items returns a map display centered at a first coordinate and a selectable list; selecting an item from that list causes the system to present a new map display centered at a different coordinate corresponding to the selected item '782 Patent, abstract
• Asserted Claims: At least independent claim 1 Compl. ¶63
• Accused Features: The accused functionality is the Defendant's website store locator, which allows a user to search for a location, receive a map and a list of stores, and interact with the list to update the map view (Compl. ¶25; Compl. ¶26, Compl. ¶Fig. 3).

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as the Defendant's interactive mapping ecosystem, including its website, associated software, servers, and backend components Compl. ¶25 The complaint provides the store locator feature as an exemplary implementation Compl. ¶26

Functionality and Market Context

• The complaint alleges the accused system provides map displays and enables interaction between the map and a list of store locations Compl. ¶25 A screenshot shows a user can enter a location query, such as "plano texas," to receive search results Compl. p. 7, Fig. 2 A subsequent screenshot shows the website then displays a list of store locations alongside a map indicating the position of those stores Compl. p. 8, Fig. 3 The complaint alleges this type of functionality is foundational for modern e-commerce websites Compl. ¶10

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

'943 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The claims of the '943 Patent recite transitioning from a "first display" to a "second display." A potential point of contention is whether a dynamic update on a single webpage, such as using AJAX to refresh a map view or information pane without a full page reload, constitutes a "second display which is at least partially different" as required by the claim. The interpretation of this term may depend on the technological context at the time of the invention.
• Technical Questions: The complaint relies on user-facing screenshots to allege infringement. An issue for the court may be whether the underlying software architecture and data processing methods of the Accused Products perform the specific steps recited in the method claims. For instance, what evidence does the complaint provide that the system generates and centers a "second map portion" in the specific manner claimed, as opposed to merely panning a single, larger map image?

V. Key Claim Terms for Construction

• Term: "a second display which is at least partially different from the first display" ('943 Patent, Claim 1)
• Context and Importance: The definition of this term may be central to the infringement analysis for the '943 Patent. The Accused Product appears to be a modern web application that likely updates content dynamically on a single page. Whether this dynamic update qualifies as a "second display" or if the term requires a more distinct transition (e.g., a full page load) will be a key question.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's summary and background focus on the overall interactive functionality of linking a map and associated data in two directions '943 Patent, col. 2:54-67 Parties favoring a broader construction may argue "display" refers to the state of information presented to the user at a moment in time, regardless of the underlying web technology.
  • Evidence for a Narrower Interpretation: The detailed description and figures, which illustrate distinct views and layouts, could support a narrower reading '943 Patent, Figs. 5-9 Parties favoring a narrower view may argue that the transition between presenting a general list and presenting details for a specific item implies a more significant change in the presented content than a simple map re-center.
• Term: "user-selectable information outside of the first map portion" ('464 Patent, Claim 1)
• Context and Importance: This term defines the spatial relationship between the interactive list and the map itself. The infringement allegation rests on the accused store locator having a list of locations presented separately from the map graphic.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent figures consistently depict the map and the associated text/list information in separate areas of the screen '464 Patent, Figs. 5-9 This graphical separation in the embodiments may support a plain-meaning interpretation where "outside" means physically non-overlapping on the user interface.
  • Evidence for a Narrower Interpretation: A party might argue that the term implies a functional separation, not just a graphical one. However, the consistent visual depiction of physical separation in the specification provides strong evidence for a straightforward spatial meaning. The strength of a narrower interpretation may depend on arguments made during prosecution, which are not detailed in the complaint.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement by Defendant's customers Compl. ¶34 Compl. ¶51 Compl. ¶68 The factual basis alleged is that Defendant provides instructions to end users on how to use the Accused Products, including "how to 'share your location with others'" Compl. ¶38 Compl. ¶55 Compl. ¶72
• Willful Infringement: Willfulness is alleged based on Defendant's purported "policy or practice against investigating third party patent rights," which the complaint characterizes as "willful blindness" Compl. ¶33 Compl. ¶50 Compl. ¶67 The complaint does not allege that Defendant had specific knowledge of the patents-in-suit prior to the lawsuit.

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

• A core issue will be one of temporal scope: can the term "second display," rooted in the patent's early-2000s priority date, be construed to read on the dynamic, single-page content updates common in modern web applications, or does the claim require a more discrete page transition characteristic of older web technology?
• A second key question will be one of evidentiary proof: beyond the user-interface screenshots provided, what evidence can be developed to demonstrate that the Accused Product's underlying software architecture and method of operation meet the specific, sequential limitations of the asserted method claims?
• A final dispositive issue, particularly for damages, will be one of scienter: can the Plaintiff's allegations of a general "policy against investigating" patents, absent any pleading of specific knowledge of the patents-in-suit, satisfy the standard for willful infringement?