Activemap LLC v. Tile Shop LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: The Tile Shop, LLC (Delaware)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-0167, 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 location in Plano, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three U.S. patents related to interactive electronic map interfaces.
• Technical Context: The technology involves interactive online maps that create a dynamic, two-way link between a graphical map display and associated data lists, a feature the complaint describes as foundational for modern web-based store locators.
• Key Procedural History: The complaint asserts that related European patents were found to be infringed in two German court cases. It also states that the underlying technology has been licensed 30 times and that the U.S. patent family has been cited over 300 times by numerous technology companies.

Case Timeline

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's background describes a need for electronic maps to move beyond static displays and provide more intuitive, two-way interactivity between graphical map locations and associated data, such as business listings '464 Patent, col. 2:25-32 '464 Patent, col. 3:9-16
• The Patented Solution: The invention provides a system where a user's selection of an item from a list of information presented outside the map causes the map display to re-center on the coordinates corresponding to that selected item. This creates a dynamic link where interacting with a data list directly manipulates the graphical map view '464 Patent, abstract '464 Patent, claim 1
• Technical Importance: This approach of linking a selectable list to a dynamic map is described in the complaint as a foundational technology for store locator website functionality Compl. ¶20

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 Compl. ¶29
• Claim 1 of the '464 Patent includes the following essential elements:
  • A system with a computer programmed to cause a display device to simultaneously present a first portion of a map centered at a first coordinate and, separately, "information outside of the first map portion" that is user-selectable.
  • In response to a user's selection of that outside information, the computer is programmed to present a "second map portion" that is centered at a different coordinate corresponding to the selection.

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 Compl. ¶14

The Invention Explained

• Problem Addressed: The patent addresses the challenge of presenting and interactively using electronic area representations and their associated information in a way that is intuitive for users Compl. ¶19 '943 Patent, col. 1:31-36
• The Patented Solution: The patent describes a method where a computer provides a "first display" containing a map portion and a user-selectable list of items. Upon receiving user input selecting an item from the list, the computer provides a "second display" that is at least partially different from the first, such as an updated map view corresponding to the selected item '943 Patent, abstract '943 Patent, claim 1 The system architecture is depicted as comprising a server, databases for graphics and text, and user devices connected via a network '943 Patent, Fig. 1
• Technical Importance: This method provides a framework for creating interactive web applications, such as store locators, where user interaction with data elements dynamically updates a corresponding visual map Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 Compl. ¶46
• Claim 1 of the '943 Patent includes the following essential elements:
  • A method where a computer provides a "first display" that includes a graphical map portion and a user-selectable list identifying at least two items.
  • The computer receives user input selecting one of the items from the list.
  • In response, the computer provides a "second display" that is at least partially different from the first and includes information related to the selected item.

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

• Patent Identification: U.S. Patent No. 10,908,782, "Interactive Electronically Presented Map," issued February 2, 2021 Compl. ¶14
• Technology Synopsis: This patent describes a method for providing interactive maps where a computer receives a user query for a category of items and, in response, displays a map centered at a first coordinate. When the user selects a specific item from the results, the system presents a second display with the map centered at a new coordinate corresponding to the selected item '782 Patent, abstract '782 Patent, claim 1
• Asserted Claims: At least Claim 1 Compl. ¶63
• Accused Features: The complaint accuses Defendant's website store locator, which allegedly allows users to search for stores and view their locations on an interactive map that updates based on user selections Compl. ¶25 Compl. ¶26

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as the hardware, software, and backend systems comprising Defendant's interactive mapping ecosystem, as implemented on its website, "https://www.tileshop.com/", and particularly its store locator feature Compl. ¶25 Compl. ¶26

Functionality and Market Context

The complaint alleges the accused website provides an interactive store locator that enables customers to find physical retail locations Compl. ¶¶25-26 A user can input a location query, such as "plano, texas," into a search field presented alongside a map Compl. Fig. 2 In response, the system allegedly presents a list of store results next to a map showing pins at the corresponding store locations, allowing users to select a specific store for more information Compl. Fig. 3 Figure 3 in the complaint shows the results for the "plano, texas" query, displaying a store list on the left and a map with location pins on the right Compl. Fig. 3

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: A potential issue may be the construction of "information outside of the first map portion." The question could arise whether a results list displayed adjacent to the map within the same browser view qualifies as being "outside" the map portion as required by the claim.
  • Evidentiary Question: The complaint provides a visual of the search results list next to the map Compl. Fig. 3, but it does not include a visual showing the map re-centering after a user selects an item from that list. A key evidentiary question will be whether the accused system actually performs the claimed function of presenting a "second map portion" centered at a new coordinate upon user selection.

'943 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: The construction of a "second display which is at least partially different from the first display" may become a central point of contention. The question is whether a dynamic update to the map (e.g., re-centering or zooming via an AJAX call without a full page reload) constitutes a "second display" under the patent's claim language.
  • Technical Question: What specific user action (e.g., clicking the store name versus a "Directions" button) triggers the presentation of the alleged "second display," and what is the precise technical nature of that resulting display?

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, as the accused instrumentality presents the map and the store list adjacent to one another within the same webpage. The case may turn on whether this adjacent list is considered "outside" the map. Practitioners may focus on this term because its construction will determine if the spatial layout of the accused website meets the claim's structural limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes storing map graphics and text information in separate databases, which may support an interpretation that "outside" refers to a logical or data-source separation, not strictly a visual one '464 Patent, col. 14:17-24
    • Evidence for a Narrower Interpretation: Figures in the patent depict the map and the associated list as visually distinct and separate components of the user interface, which could support a narrower construction requiring clear visual separation on the screen '464 Patent, Fig. 5

• The Term: "a second display" '943 Patent, Claim 1

  • Context and Importance: This term is central to the method claim of the '943 Patent, particularly in the context of modern dynamic web applications. The infringement allegation depends on whether an in-page update of the map constitutes a "second display." Practitioners may focus on this term because web technologies have evolved since the patent's priority date, raising questions about how the term applies to non-static webpages.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's summary focuses on the functional result of providing updated information in response to user input, without limiting the mechanism to a full page reload, suggesting any user-perceptible change could be considered a "second display" '943 Patent, abstract '943 Patent, col. 3:9-16
    • Evidence for a Narrower Interpretation: The language of providing a "first display" and then a "second display" could be argued to imply a sequence of discrete screens, potentially suggesting a more significant change than a dynamic content update within a single, persistent webpage.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides instructions and encourages its customers to use the accused store locator in a manner that directly infringes the patents-in-suit Compl. ¶34 Compl. ¶51 Compl. ¶68 The act of advertising and making the infringing functionality available to end-users is cited as a basis for inducement Compl. ¶37 Compl. ¶54 Compl. ¶71
• Willful Infringement: Willfulness is alleged based on the theory of willful blindness. The complaint asserts, on information and belief, that Defendant has a policy or practice of not investigating third-party patent rights, which allegedly constitutes the requisite knowledge for willful infringement Compl. ¶33 Compl. ¶50 Compl. ¶67

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

• A core issue will be one of definitional scope: can claim terms drafted in the era of static web pages, such as "information outside of the first map portion" ('464 Patent) and "a second display" ('943 Patent), be construed to cover the integrated and dynamically-updating interfaces common in modern web design?
• A key evidentiary question will be one of functional proof: while the complaint alleges a complete infringing process, its visual evidence shows the inputs and initial outputs but not the crucial final step. The case will likely require technical evidence to demonstrate that a user's selection from the store list actually causes the accused system to re-center the map to new coordinates, thereby completing the method required by the asserted claims.