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: Plaintiff alleges venue is proper because Defendant maintains multiple established places of business in 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 selectable information to corresponding geographic locations.
• Technical Context: The technology at issue involves interactive online maps that allow users to find and view points of interest, a foundational feature for modern retail and service industry websites.
• Key Procedural History: The complaint notes that the Activemap patent portfolio has been licensed 30 times and that related European patents were successfully asserted in German courts.

Case Timeline

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

U.S. Patent No. 8,468,464 - INTERACTIVE ELECTRONICALLY PRESENTED MAP, issued Jun. 18, 2013

The Invention Explained

• Problem Addressed: The patent describes a need to improve the "presentation and ease of use of electronically presented maps" by enabling more seamless interaction between map graphics and related data '464 Patent, col. 2:17-20 The invention aims to move beyond static map images to create a more dynamic and intuitive user experience.
• The Patented Solution: The patent discloses a computerized system providing "two-way interactivity," where a user can either select an item from a list to see its location on a map or select a location on the map to see information about that item '464 Patent, col. 3:9-16 This allows a user to navigate between a data-oriented view (e.g., a list of stores) and a spatial view (the map) '464 Patent, col. 3:9-16 The patent also describes a "magnifier" feature that shows a zoomed-in portion of the map alongside the main map view '464 Patent, col. 3:21-40
• Technical Importance: This two-way interactive approach became foundational for store locators, real estate search tools, and other online services that present location-based data to users Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert other claims Compl. ¶29
• Claim 1 is directed to a system whose computer is programmed to:
  • Simultaneously present a first map portion centered at specific coordinates, along with "user-selectable information" located "outside of the first map portion."
  • Receive a user's selection of that information.
  • In response, simultaneously present a "second map portion" that is different from the first and centered at new coordinates corresponding to the selection.
  • The second presentation also includes information on the second map portion, information outside the second map portion, and "additional information" about the item that was selected.

U.S. Patent No. 10,444,943 - INTERACTIVE ELECTRONICALLY PRESENTED MAP, issued Oct. 15, 2019

The Invention Explained

• Problem Addressed: Like its predecessor, the '943 Patent addresses the need for more effective and user-friendly electronic maps that integrate graphical representations with associated data '943 Patent, col. 2:20-25
• The Patented Solution: The patent describes a method for providing interactive displays. The method involves presenting a first display with a geographical area and user-selectable information identifying items within that area '943 Patent, claim 1 Upon receiving a user's selection of an item, the system provides a second, different display that includes a new portion of the geographical area and additional information about the selected item '943 Patent, claim 1 This focuses on the sequence of user interaction and the resulting change in the displayed content.
• Technical Importance: This claimed method defines a common user workflow for online mapping applications, where selecting an item from a list or search result triggers a change in the map view to focus on that specific item Compl. ¶20

Key Claims at a Glance

• The complaint asserts independent claim 1 and reserves the right to assert other claims Compl. ¶46
• Claim 1 is directed to a method comprising the steps of:
  • Receiving a request and, in response, providing a "first display" that includes a graphical map portion and "user-selectable" first information identifying at least two items.
  • Receiving user input selecting information related to the first of the items.
  • In response, providing a "second display" that is at least partially different from the first.
  • This second display includes a new graphical map portion, item information related to the first item, and "additional information about the first item."

Multi-Patent Capsule

• Patent Identification: U.S. Patent No. 10,908,782, INTERACTIVE ELECTRONICALLY PRESENTED MAP, issued Feb. 2, 2021.
• Technology Synopsis: The '782 Patent claims a method for providing interactive maps that begins with a user submitting a query for a category of items. In response, the system displays a map and user-selectable information for multiple items within that category. Upon the user selecting a specific item, the system displays a new, re-centered map view corresponding to that item's location '782 Patent, claim 1
• Asserted Claims: Independent claim 1 is asserted Compl. ¶63
• Accused Features: The complaint alleges that Nordstrom's store locator, which allows users to search for store locations and view them on a map, infringes this patent Compl. ¶¶62, 65

III. The Accused Instrumentality

Product Identification

The accused instrumentality is the "interactive mapping ecosystem" on the Defendant's website, https://www.nordstrom.com/, specifically its store locator feature Compl. ¶25

Functionality and Market Context

• The complaint alleges the accused system enables users to determine store locations via an interactive map display Compl. ¶25 A provided screenshot, Figure 2, shows the Nordstrom "Stores & Events" page with a map of the United States and a search bar for entering a location Compl. p. 7 A subsequent screenshot, Figure 3, shows a zoomed-in map displaying specific Nordstrom store locations in Texas after a search was performed, illustrating the system's response to a user query Compl. p. 8
• This functionality is a common and critical feature for retailers with physical locations, allowing online customers to find and visit brick-and-mortar stores.

IV. Analysis of Infringement Allegations

8,468,464 Patent Infringement Allegations

10,444,943 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The complaint provides screenshots of the map before and after a search but does not show the "user-selectable information" as a distinct list or the "additional information" that appears after selection. A potential issue is whether the interactive pins on the map in Figure 3 constitute "information outside of the first map portion" as required by claim 1 of the '464 Patent.
• Technical Questions: A key question for the '943 Patent will be what constitutes a "second display which is at least partially different from the first display." The analysis may turn on whether the accused website, upon selection of a store, generates an overlay or pop-up on the same display versus loading a fundamentally new page or view that would qualify as a "different" display under the claim's proper construction.

V. Key Claim Terms for Construction

For the '464 Patent:

• The Term: "information outside of the first map portion"
• Context and Importance: This term is central to the structure of the claimed system. Its definition will determine whether the "user-selectable information" must be textually or graphically separate from the map image itself (e.g., a sidebar list) or if it can be read to cover interactive elements superimposed on the map (e.g., clickable pins).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification broadly refers to associating "text, imagery, or other information" with map locations, which may support an argument that clickable icons on the map qualify '464 Patent, col. 2:6-9
  • Evidence for a Narrower Interpretation: Figures in the patent, such as Figure 9, depict a clear separation between the map graphic (30), a list of categories (bottom left), and a distinct information box (510), suggesting that "outside" implies a spatially separate user interface element '464 Patent, Fig. 9

For the '943 Patent:

• The Term: "a second display which is at least partially different from the first display"
• Context and Importance: The infringement analysis depends on whether the accused website's response to a user's selection meets this "different display" requirement. Practitioners may focus on this term because modern web design often uses overlays or pop-up windows rather than full page reloads, and the applicability of this claim language to such designs may be a central point of dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly define "display." An argument could be made that any change in the visual information presented to the user, including the appearance of a new information layer or overlay, renders the display "partially different."
  • Evidence for a Narrower Interpretation: The patent's description of providing "two versions of an area representation," often a smaller and larger view, may suggest that a "different display" requires a more substantial change in the state of the interface, such as a re-rendering of the map itself, rather than simply adding an informational overlay '943 Patent, col. 3:26-30

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement by Defendant's customers (i.e., website users) based on Defendant providing instructions on how to use the store locator feature 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" and "willful blindness" to the existence of the patents-in-suit Compl. ¶33 Compl. ¶50 Compl. ¶67 The complaint does not allege pre-suit knowledge of the specific patents.

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

• A core issue will be one of definitional scope: can claim terms rooted in an earlier era of web design, such as "information outside of the... map portion" and a "second display," be construed to cover the more integrated and dynamic user interfaces of modern websites, where information is often presented in overlays or as interactive elements on the map itself?
• A key evidentiary question will be one of functional mapping: does the accused Nordstrom store locator actually perform the specific, sequential steps required by the asserted method claims? The complaint provides a high-level overview, but the case will likely turn on a detailed, step-by-step comparison of the website's operation against the limitations recited in the patent claims.