Activemap LLC v. Nordstrom Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Nordstrom, Inc. (Washington)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00163, 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, including a specific retail location in Allen, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three patents related to interactive electronic maps that link geographical representations with associated data lists.
• Technical Context: The technology concerns systems and methods for two-way interaction between an electronic map and a list of items, a foundational concept for modern online store locators and other interactive mapping services.
• Key Procedural History: The complaint alleges that related European patents have been found to be infringed in German court proceedings. It also notes that the underlying technology has been licensed by 30 companies and that the patent family has been cited over 300 times by other technology companies in their own patent applications.

Case Timeline

Date	Event
2001-04-30	Earliest Priority Date for Patents-in-Suit
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

• Problem Addressed: The patent addresses the limitations of static electronic maps by seeking to create a more intuitive and interactive user experience Compl. ¶20 The background of the invention discusses the need to go beyond simple electronic presentation to allow for interactive use with related information Compl. ¶9
• The Patented Solution: The invention describes a computerized method where a map and a list of items are displayed simultaneously Compl. ¶10 Selecting an item from the list causes the map view to change and center on the item's location, while also displaying additional information about that item. Conversely, interacting with the map can highlight corresponding items in the list, creating a two-way linkage between the geographical and textual data '464 Patent, abstract '464 Patent, col. 4:1-15
• Technical Importance: This two-way interactive functionality was described by the Plaintiff as "foundational for store locator website functionality" and has been widely adopted across various industries Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• The essential elements of independent claim 1 include:
  • Causing a display device to simultaneously present a first map portion and information outside the map responsive to a query.
  • In response to a user selecting information from outside the map, causing the device to present a second, different map portion centered at a new coordinate.
  • The new display includes information on the second map portion, updated information outside the map, and additional information about the selected item.

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

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

The Invention Explained

• Problem Addressed: The patent's background section describes the state of the art as presenting electronic maps but notes a need for improved interactivity and association with related information, such as directories or lists of places Compl. ¶9 '943 Patent, col. 1:29-47
• The Patented Solution: The '943 Patent discloses a system that presents an interactive map where a user can select information (e.g., text or an image) to trigger the presentation of related details, such as a hyperlink or contact information '943 Patent, abstract It also describes a "magnifier" feature that allows for internal navigation by showing a magnified view of a portion of the map, which moves as the user navigates the main map '943 Patent, col. 3:24-44
• Technical Importance: The technology provides a method for linking graphical map data with textual or list-based data, a core feature for user-friendly online directories and locators Compl. ¶10

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• The essential elements of independent claim 1 include:
  • Providing a first display with graphical map information, item information at two or more locations, and a user-selectable list identifying at least two items.
  • Receiving user input selecting information for a first item from the list.
  • In response, providing a second, different display that includes graphical map information, item information related to the first item, an updated list, and additional information about the selected first item.

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

• Patent Identification: U.S. Patent No. 10,908,782, "Interactive Electronically Presented Map," issued February 2, 2021.
• Technology Synopsis: The '782 Patent, from the same family, describes a method for providing an interactive map based on a user query for a category of items '782 Patent, claim 1 The system receives a query, presents a map centered at a first coordinate along with a list of responsive items, and upon user selection of an item from the list, presents a new map view centered at a different coordinate corresponding to the selected item '782 Patent, abstract '782 Patent, claim 1
• Asserted Claims: At least Claim 1 is asserted Compl. ¶63
• Accused Features: The accused features are the systems and methods supporting the interactive store locator on the Defendant's website, which allegedly receive user queries and present interactive map-and-list results Compl. ¶25 Compl. ¶¶62-65

III. The Accused Instrumentality

Product Identification

The "Accused Products" are the hardware, software, and backend systems that constitute the "interactive mapping ecosystem" on Defendant's website Compl. ¶25 Compl. ¶26

Functionality and Market Context

The complaint alleges that the Accused Products provide store locator functionality Compl. ¶25 As depicted in the complaint's visual evidence, this system allows a user to search for stores, which are then displayed as selectable icons on a map interface Compl. Fig. 2 Compl. Fig. 3 Figure 2 in the complaint shows the initial "Stores & Events" page with a map of the United States Compl. Fig. 2 Figure 3 shows a zoomed-in map view with user-selectable icons representing individual store locations, which is responsive to a user query Compl. Fig. 3 The complaint positions this functionality as a widely adopted and commercially significant feature for retail websites Compl. ¶10

IV. Analysis of Infringement Allegations

8,468,464 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a method for providing an interactive electronic map, comprising: at least one computer causing a display device to simultaneously present thereon: a first portion of the map centered at a first x coordinate and at a first y coordinate...	The Nordstrom website server allegedly causes a user's browser to display a map of a geographical area, such as the United States, centered on an initial view.	¶25; Fig. 2	col. 20:53-56
information outside of the first map portion responsive to a query relating to the map including user-selectable information;	The website allegedly presents a search bar and, upon query, a list of store locations that is separate from the map display and contains user-selectable entries.	¶25; Fig. 2	col. 20:62-65
the at least one computer causing, 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...	Upon a user selecting a store from a list or search results, the server allegedly causes the browser to display a new, different map view, such as a zoomed-in or re-centered map.	¶25; Fig. 3	col. 21:1-8
the second map portion being at least partially different from the first map portion and being centered at an x coordinate different from the first x coordinate, or at a y coordinate different from the first y coordinate, or at x and y coordinates different from the first x and y coordinates;	The complaint alleges that selecting a store result changes the map view to a new state, such as by zooming in and centering on the selected store's location, which involves a different center coordinate or zoom level.	¶25; Fig. 3	col. 21:9-15
and additional information about the user-selectable information that was selected from outside of the first map portion;	When a store is selected, the system allegedly displays additional details about that specific store, such as its address, hours, or available services. The complaint does not provide a specific screenshot of this detailed view.	¶25	col. 21:26-29

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: ...providing for presentation on the display device in a first display 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... 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 Nordstrom website allegedly presents a map with store locations marked by icons, along with a search interface or list identifying those stores.	¶25; Fig. 2; Fig. 3	col. 20:30-49
the method further comprising 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 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 at least all of: ...additional information about the first item...	The complaint alleges that when a user selects a store icon or list item, the system provides additional information about that store. This is a core part of the infringement theory, though not explicitly shown in the complaint's figures.	¶25; ¶30	col. 21:3-23
second information, identifying at least the first and the second of the two or more items responsive to the request, all or a portion of which is user-selectable...	The new display allegedly continues to show a list of stores, which may be updated or remain the same, allowing for further user selection.	¶25; Fig. 3	col. 21:13-18

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "map" as used in the patents, which appears to be based on static image files from the early 2000s (e.g.,'943 Patent, Fig. 9), can be construed to cover the dynamic, tiled, and interactive web-based mapping services used in the accused store locator. Similarly, whether the accused product's standard "zoom" functionality meets the definition of the patents' "magnifier" feature, which is described as a distinct, movable element, may be a point of dispute '943 Patent, col. 7:1-9
  • Technical Questions: The complaint alleges infringement of specific method steps, but provides limited detail on the precise operation of the accused website. A key question for the court will be whether the accused system's process for receiving a query and updating the display technically meets the specific sequence and limitations of the asserted claims. For example, claim 1 of the '464 patent requires presenting a "second map portion" that is "centered at an x coordinate different" from the first; evidence will be needed to show if the accused system's behavior (e.g., zooming in place versus panning to a new location) always satisfies this limitation.

V. Key Claim Terms for Construction

Term: "map" / "geographical area"

• Context and Importance: The patents have a 2001 priority date, and their specifications describe map implementations based on technologies of that era, such as specific GIF files '943 Patent, col. 14:25-30 The accused product uses a modern, dynamic web-mapping interface. The construction of "map" will be critical to determining if the claims cover current technology.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests "area representation" is meant in a "broad sense" and is not limited to geographical maps, citing examples like printed circuit boards and celestial bodies '943 Patent, col. 2:15-31 This language may support an interpretation that is not strictly limited to the specific embodiments shown.
  • Evidence for a Narrower Interpretation: The detailed descriptions and figures consistently depict a specific implementation using a static image, such as the "FLATIRONONLINEMAP" example '943 Patent, Fig. 9 A defendant may argue that the claims should be limited to this disclosed structure, which differs from modern tiled-map services.

Term: "information outside of the first map portion" (from '464 Patent)

• Context and Importance: This term defines the list or directory of items that is interactively linked to the map. Its construction will determine what user interface elements (e.g., a simple search result list, a categorized directory) fall within the claim scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes this element in broad terms, analogizing it to a "categorical directory" with listings similar to a telephone yellow pages book '464 Patent, col. 8:46-53 This could be argued to cover any list of selectable items presented alongside a map.
  • Evidence for a Narrower Interpretation: The figures in the patents consistently show a distinct, structured list of categories (e.g., "Schools," "Shops") presented adjacent to the map display '943 Patent, Fig. 9 This may support an argument that the term requires a more formally structured directory, rather than a simple, transient list of search results.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides instructions to customers on how to use the allegedly infringing store locator functionality on its website Compl. ¶38 Compl. ¶55 Compl. ¶72 The complaint also makes a general allegation of contributory infringement Compl. ¶34 Compl. ¶51 Compl. ¶68
• 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. ¶33 Compl. ¶50 Compl. ¶67 The complaint does not allege that Defendant had pre-suit knowledge of the specific patents-in-suit.

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

• A core issue will be one of definitional scope: can key terms from patents with a 2001 priority date, such as "map" (based on static image files) and "magnifier" (described as a distinct movable element), be construed to cover the modern technologies used in the accused store locator, such as dynamic tiled maps and in-place zoom functionality?
• A second central question will be one of technical evidence: does the operation of the accused Nordstrom website meet the specific, ordered method steps recited in the asserted independent claims? Given the high-level nature of the complaint, the case will depend on evidence demonstrating a precise correspondence between the system's functionality and each claim limitation.
• A final key question will relate to willfulness: can the Plaintiff develop evidence beyond its formulaic allegation of a "policy against investigating" patents to establish that the Defendant acted with the requisite knowledge and intent for a finding of willful or induced infringement, especially in the apparent absence of pre-suit notice?