Activemap LLC v. Childrens Place Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: The Childrens Place, Inc. (Delaware)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-0166, 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 within the district, specifically citing retail store locations in Longview and Tyler, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website, specifically its store locator functionality, infringes three U.S. patents related to interactive electronic maps that link geographical representations with associated lists of information.
• Technical Context: The technology at issue pertains to the two-way interactive functionality common in online mapping tools, such as store locators, where user interactions with a map can update a data list, and user interactions with the list can update the map display.
• Key Procedural History: The complaint states that the asserted patent family has been licensed 30 times and that related European patents were successfully asserted twice in German courts, suggesting a history of enforcement. The patents-in-suit are also alleged to be part of a family cited over 300 times by other patents.

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 addresses the limitations of early electronic maps, which lacked a seamless, two-way interactive relationship between a graphical map and associated data, such as lists of businesses or points of interest '943 Patent, col. 1:32-48
• The Patented Solution: The invention provides a computerized system for an interactive map where a user can select information from a list, causing the system to display the corresponding location on the map. Conversely, a user can select a location on the map to retrieve associated information. The system also describes a "magnifier" feature to show a detailed, magnified view of a portion of the map simultaneously with the broader, unmagnified view '943 Patent, col. 2:54-65 '943 Patent, abstract
• Technical Importance: This two-way interactivity between a visual map and a data list became a core element for features like online store locators, which the complaint alleges the invention was "foundational for" Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 of the '464 Patent Compl. ¶29
• Claim 1 of the '464 Patent is a system claim with the following essential elements:
  • At least one computer programmed to cause a display device to simultaneously present a first portion of a map and information outside the map portion responsive to a query.
  • The information outside the map includes user-selectable information.
  • In response to a user selecting that information, the system presents a second map portion that is different from the first.
  • The system must also be programmed to respond to a different user selection from information outside the second map portion to present a third map portion.
• 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 in the same family as the '464 Patent, the '943 Patent addresses the same technical problem: the lack of fluid, two-way interactivity in prior art electronic map systems '943 Patent, col. 1:32-48
• The Patented Solution: The patent describes a method for providing an interactive display where a request for information (e.g., a query) results in a display showing a map portion and a list of associated items. User selection of an item from that list then causes the system to update the display to show a different map portion corresponding to the selected item, along with updated item information '943 Patent, col. 2:54-65 '943 Patent, abstract
• Technical Importance: The method described captures the interactive search-and-refine workflow that is central to modern online directory and locator services Compl. ¶10

Key Claims at a Glance

• The complaint asserts at least independent claim 1 of the '943 Patent Compl. ¶46
• Claim 1 of the '943 Patent is a method claim with the following essential elements:
  • Receiving a request and, in response, providing a first display that includes graphical information (a map portion) and user-selectable first information identifying at least two items.
  • Receiving user input to the at least one computer to select user-selectable information related to the first of the two items.
  • In response, providing a second display that is different from the first, which includes a different map portion and user-selectable second information.
• 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

The '782 Patent, also in the same family, claims a method for providing interactive electronic maps. The method involves receiving a query for a category of items, displaying a map centered at a first coordinate pair along with a list of items in that category, and in response to a user selecting an item from the list, displaying a new map centered at a second, different coordinate pair corresponding to the selected item '782 Patent, abstract

Asserted Claims

At least claim 1 Compl. ¶63

Accused Features

The accused features are part of the Defendant's "interactive mapping ecosystem," specifically the store locator function on its website Compl. ¶25 Compl. ¶26

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Defendant's website (Store Locator) and the associated "interactive mapping ecosystem" that provides its store locator functionality Compl. ¶¶25-26

Functionality and Market Context

The complaint alleges that the accused store locator allows users to determine store locations via an interactive map display Compl. ¶25 A screenshot in the complaint shows an interface where a user can input a location like "tyler, texas" to find stores Compl. Fig. 2 A second screenshot shows the resulting display, which includes a map with store location markers and a corresponding list of store details to the side Compl. Fig. 3 The complaint alleges this system is used in Defendant's regular course of business to make, use, and sell its products Compl. ¶25 Compl. ¶31

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

'943 Patent Infringement Allegations

Identified Points of Contention

• Technical Questions: A screenshot in the complaint shows the result of a user searching for "tyler, texas" Compl. Fig. 3 The complaint alleges this functionality infringes, but the provided visuals do not explicitly demonstrate the reciprocal nature of the claimed invention (e.g., clicking a point on the map to highlight the corresponding item in the list, or clicking a list item to re-center the map). The core dispute may turn on whether the accused system actually performs the specific sequence of user selections and responsive display changes required by the claims.
• Scope Questions: The complaint's visual evidence includes a screenshot of an input field for a user to enter a query Compl. Fig. 2 A potential point of contention may be whether entering an initial search query constitutes "selecting user-selectable information" from information already presented "outside of the...map portion," as some claims may require, or if the claims are directed to selections made after an initial map and list are already displayed.

V. Key Claim Terms for Construction

• The Term: "in response to selection of user-selectable information"
• Context and Importance: This phrase appears in the independent claims of both the '464 and '943 patents and is central to the required interactivity. The infringement analysis depends on what user action qualifies as a "selection" and what system reaction qualifies as being "in response" to it. Practitioners may focus on this term because the complaint's infringement theory appears to rely on the system's reaction to an initial user query, which may or may not be the type of "selection" contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The summary of the invention describes a system where a user can "input or select, based on a query or otherwise, information relating to one or more items," which causes a map update '943 Patent, col. 2:62-67 This language could support construing "selection" broadly to include the submission of a query.
  • Evidence for a Narrower Interpretation: The detailed description often describes the selection process in the context of an already-displayed list of categories or items. For example, "Upon selection or input of the category 'theaters', a list of theaters...will be displayed. Selection of a theater from the list will cause the position indicator to move" '943 Patent, col. 11:7-12 This could support a narrower reading where the "selection" must be from a pre-populated list, not the initial query itself.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by its customers (end users of the website) Compl. ¶34 Compl. ¶51 The basis for inducement includes Defendant allegedly providing instructions to users on how to operate the store locator, which is alleged to be an infringing use Compl. ¶38 Compl. ¶55
• Willful Infringement: Willfulness is alleged based on Defendant's purported "policy or practice against investigating third party patent rights," which Plaintiff characterizes as "willful blindness" that constitutes knowledge of the patents-in-suit Compl. ¶33 Compl. ¶50 Compl. ¶67

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

• A core issue will be one of demonstrated functionality: does the accused store locator actually perform the specific, sequential, and reciprocal interactions required by the claims? The complaint alleges this functionality exists, but the provided evidence focuses on the initial display of a map and list, leaving open the evidentiary question of whether subsequent user selections from that list cause the claimed map updates.
• A key question of claim construction will be the scope of "selection of user-selectable information." The case may turn on whether this term can be construed to cover a user's initial text-based search query, or if it is limited to a subsequent choice from a list of items that the system has already presented in response to that query.
• A final question will be one of timing and knowledge for willfulness. The complaint relies on a "willful blindness" theory to establish pre-suit knowledge. The viability of this allegation will depend on whether the court finds such a pleading sufficient to infer that Defendant deliberately shielded itself from knowledge of Plaintiff's specific patent rights.