Activemap LLC v. Childrens Place Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: The Children's Place, Inc. (Delaware)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-0166, 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, including retail stores in Longview and Tyler.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three U.S. patents related to interactive electronic map systems.
• Technical Context: The technology concerns the two-way interactive functionality between a graphical map and an associated list of items, a foundational feature for modern online store locators and directory services.
• Key Procedural History: The complaint alleges the underlying technology has an extensive history, including being licensed 30 times by industry leaders, having related European patents successfully enforced twice in German courts, and the patent family being cited over 300 times in other patents.

Case Timeline

Date	Event
2001-04-30	Priority Date for '464, '943, and '782 Patents
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
2026-06-09	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 electronic maps, which lacked robust, two-way interactivity between the map itself and associated data, such as lists of locations or points of interest. Compl. ¶21 '464 Patent, col. 1:35-53
• The Patented Solution: The invention provides a system where a map display is dynamically linked to an external list of information. A user can select an item from a list (e.g., a store directory), causing the map to re-center on that item's location. Conversely, interacting with the map can retrieve associated information. This creates a two-way interactive experience. '464 Patent, abstract '464 Patent, col. 2:65-3:5
• Technical Importance: This two-way linking of a list and a map became a foundational user interface paradigm for online store locators and other geographically-aware web applications. Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1. Compl. ¶46
• The essential elements of Claim 1 include:
  • A computer programmed to cause a display device to simultaneously present: a first map portion centered at a first coordinate, and information outside the map that is responsive to a query and user-selectable.
  • In response to a user selecting the information outside the map, the computer causes the display device to present: a second map portion instead of the first, where the second map portion is centered at a new, different coordinate.
• Plaintiff reserves the right to assert additional claims. Compl. ¶43

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 seeks to improve the usability and navigation of electronic maps by providing more powerful interactive features beyond what was available in the prior art. Compl. ¶22 '943 Patent, col. 1:33-41
• The Patented Solution: The '943 Patent describes a system with two-way interactivity similar to the '464 Patent, and further details features like a "magnifier" that provides a movable, magnified view of a specific map area without losing the context of the overall map. The system also explicitly covers the user workflow of making a query, receiving a list of results, and selecting an item from that list to update the map display with additional details. '943 Patent, abstract '943 Patent, col. 6:27-48
• Technical Importance: The described methods for querying, filtering, and navigating map data provided a more sophisticated and intuitive user experience for exploring information-rich geographical displays. Compl. ¶¶26-27

Key Claims at a Glance

• The complaint asserts at least independent claim 1. Compl. ¶63
• The essential elements of Claim 1 include:
  • A method where a computer, in response to a request, provides a first display including a map portion and "first information" (e.g., a list) identifying items.
  • The computer then receives user input selecting an item from the "first information."
  • In response, the computer provides a second display that includes a new map portion, item information related to the selection, and "additional information" about the selected item.
• Plaintiff reserves the right to assert additional claims. Compl. ¶43

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

• Patent Identification: U.S. Patent No. 10,908,782, "Interactive Electronically Presented Map", issued February 2, 2021.

The Invention Explained

• Technology Synopsis: The patent discloses a computer-implemented method for providing interactive maps, focusing on the workflow where a user submits a query for a category of items. The system processes the query and presents a display with a list of responsive items alongside a map showing their locations, allowing the user to select an item to re-center the map on its specific location. '782 Patent, claim 1

Key Claims at a Glance

• Asserted Claims: The complaint asserts at least independent claim 1. Compl. ¶80
• Accused Features: The accused functionality is the website's store locator, which allows a user to search for stores (a category), presents a list of results, and displays their locations on an interactive map. Compl. ¶41 Compl. ¶42 Compl. ¶43

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are identified as the interactive store locator feature on Defendant's website ("https://www.childrensplace.com/us/store-locator") and the associated backend systems, servers, and software that enable its functionality. Compl. ¶41 Compl. ¶42 Compl. ¶43

Functionality and Market Context

• The store locator allows a user to enter a location query, such as a city or zip code. A screenshot in the complaint shows a user entering "tyler, texas" into a search field. Compl. Fig. 2 In response, the system presents a split-screen view: on the left, a selectable list of store locations matching the query, and on the right, an interactive map displaying pins at those locations. Compl. Fig. 3 The complaint alleges this functionality is foundational for modern e-commerce websites. Compl. ¶10 Compl. ¶20 This functionality is illustrated in a screenshot showing the store locator interface after a search has been performed. Compl. Fig. 3

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a display device to simultaneously present thereon: a first portion of the map...; and information outside of the first map portion responsive to a query... including user-selectable information	The initial store locator page presents a map of the U.S. ("first portion") and a search box ("information outside") for a user to input a query. The complaint's screenshot shows the interface prior to a user query. Compl. Fig. 2	¶46; Fig. 2	col. 20:2-10
in response to selection of user-selectable information from the user-selectable information outside of the first map portion and responsive to the query...	The user's query for a location ("tyler, texas") results in a list of selectable stores. The act of selecting from this resultant list is the alleged selection.	¶46; Fig. 3	col. 20:11-25
the display device to simultaneously present thereon: instead of the first map portion a second map portion... being at least partially different from the first map portion and being centered at an x coordinate different...	After the search, the system displays a new map zoomed in on the Tyler, TX area. This is alleged to be the "second map portion," which has a different center and zoom level than the initial U.S. map. Compl. Fig. 3	¶46; Fig. 3	col. 20:26-38

'943 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
receiving a request and in response, providing for presentation... in a first display which includes... graphical information representing a first portion of a geographical area;... and first information... identifying at least a first and a second of the two or more items...	The system receives the user's search for "tyler, texas" (the request) and presents a display with a map of the area and a list identifying two stores ("BROADWAY SQUARE" and "LONGVIEW TOWN CROSSING"). Compl. Fig. 3	¶63; Fig. 3	col. 21:35-49
receiving user input... to select user-selectable information relating to the first of the two or more items from the user-selectable information...	The user is able to click on one of the store names in the displayed list, which is the alleged user input selecting the item.	¶63; Fig. 3	col. 21:50-54
in response... providing for presentation... in a second display which... includes... graphical information representing a portion of the geographical area... and additional information about the first item...	The complaint alleges that upon selection of a store from the list, the system presents a new display with an updated map and additional details about the selected store, consistent with the patent's teachings.	¶63; ¶¶22-26	col. 21:54-67

Identified Points of Contention

• Scope Questions: The patents describe and depict stylized, self-contained map illustrations Compl. Fig. 1 An issue may be whether the term "map" as used in the claims can be construed to cover the accused system's use of standard, data-driven map tiles provided by a third-party service, Mapbox. Compl. Fig. 3
• Technical Questions: For the '464 Patent, a key question may be whether the accused system's simultaneous display of a map and a list meets the claim requirement of presenting a "second map portion instead of the first map portion" in response to a selection, which could suggest a sequential replacement of views rather than a simultaneous, split-screen update.

V. Key Claim Terms for Construction

• The Term: "information outside of the first map portion" ('464 Patent, claim 1)

• Context and Importance: This term is critical to the infringement analysis of the '464 Patent. The defendant may argue that its list of stores, displayed simultaneously alongside the map from the outset of the interaction, is not "outside" the map portion in the manner contemplated by the claim. The plaintiff's case may depend on this term being construed to mean spatially adjacent on the same screen.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes embodiments where item information is provided "together with the area representation, e.g., on display including the area representation and the additional information," which may support a simultaneous, side-by-side presentation. '464 Patent, col. 3:61-4:5
  • Evidence for a Narrower Interpretation: The structure of claim 1 recites presenting a "first portion," then, "in response to selection," presenting "a second map portion instead of the first." This language may support an interpretation that requires a sequence of distinct screen views, where one view replaces another, rather than a single, persistent split-screen layout that is merely updated.

• The Term: "magnifier" ('943 Patent and '464 Patent specifications)

• Context and Importance: While not in the asserted independent claims, the complaint heavily discusses the "magnifier feature" (Compl. ¶¶22; Compl. ¶27; Compl. ¶34), suggesting it is a core part of the patented technology. Practitioners may focus on this term because its construction would be central if any dependent claims reciting it are asserted. The dispute would question whether a standard zoom function on a modern map constitutes a "magnifier."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states that "the term 'position indicator' encompasses a magnifier," which could support construing it broadly to include any function that indicates and zooms into a map location. '943 Patent, col. 6:50-52
  • Evidence for a Narrower Interpretation: The specification describes specific embodiments of the magnifier, such as a magnified view displayed in a separate circular window "outside of the map itself" or as an overlay that gives the "appearance resembling that of a magnifying glass." '943 Patent, col. 7:20-25 Compl. ¶¶27-29 This could support limiting the term to these more complex, specific implementations.

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 Products. Compl. ¶55 Compl. ¶72 Compl. ¶89 The allegations state Defendant encourages use of the interactive features which allegedly practice the claimed methods. Compl. ¶54
• Willful Infringement: Willfulness is alleged based on Defendant's purported "policy or practice against investigating third party patent rights," which the complaint frames as "willful blindness." Compl. ¶50 Compl. ¶67 Compl. ¶84 This allegation is based on alleged knowledge of the patent and is pleaded to meet the standard for surviving a motion to dismiss.

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

• A core issue will be one of definitional scope: can claim terms rooted in the context of early 2000s self-contained software (e.g., "map", "magnifier") be construed to cover modern web applications that integrate modular, third-party mapping services like Mapbox?
• A second central question will be one of operational sequence: does the accused store locator, which presents a continuously updated, side-by-side map and list, perform the specific, sequential steps of presenting a "first" display and then replacing it with a "second" display "instead of" the first, as required by the literal language of claim 1 of the '464 patent?
• An evidentiary question will be one of functional proof: for claims requiring a multi-step user interaction, such as claim 1 of the '943 patent, the plaintiff will need to provide evidence that the accused system performs each step of the claimed sequence, including the system's response after a user selects an item from a generated list.