Activemap LLC v. Chanel Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Chanel, Inc. (New York)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-00168, E.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains established places of business in the district, specifically identifying a location in Plano, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three U.S. patents related to interactive electronic maps that link geographical displays with associated lists of information.
• Technical Context: The technology at issue concerns the two-way interactive functionality of online maps, a feature that has become foundational for e-commerce, retail, and directory websites.
• Key Procedural History: The complaint asserts that the patent family has been licensed 30 times, related European patents were found to be infringed in German court proceedings, and the 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"

• Issued: June 18, 2013

The Invention Explained

• Problem Addressed: The patent's background section discusses the state of early-Internet online maps, which lacked deep interactivity ʻ464 Patent, col. 1:31-48 The invention sought to provide users with an electronic experience more akin to physically exploring an area of interest by creating a more intuitive and interactive interface ʻ464 Patent, col. 2:36-39
• The Patented Solution: The invention provides for "two-way interactivity" between a graphical map and associated data ʻ464 Patent, col. 3:8-9 A user can select a location on the map to retrieve associated information, and conversely, a user can select an item from an associated list or directory to cause the map to display the corresponding location ʻ464 Patent, col. 3:9-15 ʻ464 Patent, col. 7:44-51 This creates a dynamic link between the visual map and a textual or categorical list of locations.
• Technical Importance: This bidirectional linking of a map display and a data list became a foundational user interface paradigm for online store locators and other interactive directories Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• The essential elements of claim 1 include:
  • A method where a computer causes a display device to simultaneously present a first map portion, information on the map, and user-selectable information outside the map portion.
  • In response to a user selecting information from outside the map portion, the computer causes the display to present a second map portion centered at a new location corresponding to the selection.
  • The second display also presents information on the new map portion, information outside of it, and additional information about the selected item.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

• Issued: October 15, 2019

The Invention Explained

• Problem Addressed: The patent, which shares a specification with the '464 Patent, aims to improve the "presentation and ease of use of electronically presented maps and other area representations" ʻ943 Patent, col. 2:18-20
• The Patented Solution: The invention described in the '943 Patent is a computerized system providing for the interactive presentation of a geographical area and associated information ʻ943 Patent, abstract A key feature is the bidirectional relationship between map elements and data, where selecting an item in a list highlights its map location, and interacting with the map can retrieve associated data, thereby providing "two-way or both direction functionality" ʻ943 Patent, col. 4:27-36 ʻ943 Patent, col. 2:56-65
• Technical Importance: As with the '464 Patent, this technology is described in the complaint as being foundational for modern store locator functionality 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 method where a computer receives a request and presents a first display with a graphical map portion, item information at two or more locations on the map, and user-selectable first information identifying at least two of the items.
  • Upon receiving user input selecting one of the items from the first information, the computer presents a second, different display.
  • The second display includes a portion of the geographical area, item information related to the selected item, second user-selectable information, and additional information about the selected item.
• The complaint does not explicitly reserve the right to assert dependent claims.

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

• Issued: February 2, 2021

Multi-Patent Capsule

• Technology Synopsis: This patent, from the same family as the '464 and '943 patents, addresses the need for more intuitive online map interfaces ʻ782 Patent, col. 1:35-40 The patented solution involves a method where a user's query for a category of items results in a map display, and selecting a specific item from a list of results causes the map to update and re-center on that item's location, presenting a new area representation ʻ782 Patent, claim 1
• Asserted Claims: At least Claim 1 Compl. ¶63
• Accused Features: The complaint accuses Chanel's website store locator of infringement by enabling users to search for boutiques, receive a list of results, and select a specific boutique from that list, which in turn updates the map to focus on and display information for the selected location Compl. ¶¶25-26 Compl. ¶¶62-65

III. The Accused Instrumentality

Product Identification

• The Accused Products are the systems and methods related to the "interactive mapping ecosystem" on Defendant's website, particularly the store locator functionality Compl. ¶¶25-26

Functionality and Market Context

• The accused functionality allows a user to search for Chanel retail locations. The system then displays a list of stores and an interactive map showing their geographic locations Compl. p. 7 Figure 2 of the complaint provides a screenshot of the accused store locator after a user searches for "plano," showing an interactive map with multiple store icons and a corresponding suggestion list Compl. p. 7 When a user selects a location, either from the list or the map, the system displays detailed information for that specific store, such as its address and hours, often in an overlay on the map Compl. p. 8 Figure 3 of the complaint shows the user interface after a specific boutique has been selected, displaying its details and providing an option to get directions Compl. p. 8 The complaint alleges this functionality is a critical component of modern e-commerce and retail websites Compl. ¶20

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,468,464 Infringement Allegations

U.S. Patent No. 10,444,943 Infringement Allegations

Identified Points of Contention

• Scope Questions: The patents' priority date is 2001, a different era of web technology. A central issue may be whether claim terms rooted in that context can be construed to read on modern, dynamic web interfaces. For example, a question for the court will be whether a temporary information overlay that appears on top of a map, as shown in the complaint's Figure 3, constitutes a "second display" that is "at least partially different from the first display" as required by claim 1 of the '943 Patent.
• Technical Questions: The infringement theory relies on a sequence of user actions and system responses. A potential point of dispute could be whether the accused system's operation matches every step of the claimed methods. For example, for the '464 patent, a question is what constitutes "information outside of the first map portion," and whether the accused interface presents such information in a manner that meets this limitation before the user makes a selection.

V. Key Claim Terms for Construction

The Term: "simultaneously present" (from Claim 1 of the '464 Patent)

• Context and Importance: This term is critical for defining the required layout of the user interface. The infringement analysis depends on whether the accused map and its associated store list are considered to be presented "simultaneously." Practitioners may focus on this term because the defendant could argue that modern interfaces with dynamic overlays or elements that appear and disappear upon user interaction do not meet the "simultaneously present" requirement in the manner contemplated by the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification's description of displaying a "composite view" that includes an area representation and "associated text information" could support a broad interpretation that covers any concurrent display of map and text elements, regardless of layout ʻ464 Patent, col. 3:42-45
  • Evidence for a Narrower Interpretation: The patent figures consistently depict a static, side-by-side layout with a distinct map area and a separate, non-overlapping text/list area ʻ464 Patent, FIG. 9 This could support a narrower construction limited to interfaces with such a clear spatial separation.

The Term: "information outside of the first map portion" (from Claim 1 of the '464 Patent)

• Context and Importance: This term dictates the spatial relationship between the interactive map and the selectable list of items. Infringement hinges on whether the list of stores in the accused product is located "outside" the map. This is a potentially dispositive issue if, for example, the list is presented as an overlay on top of the map.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: This phrase could be interpreted broadly to mean any information that is not part of the graphical map imagery itself, including a list in an adjacent browser frame or a separate HTML element rendered next to the map canvas ʻ464 Patent, col. 3:44-45
  • Evidence for a Narrower Interpretation: The patent's embodiment shows a clear and distinct textual area separate from the map ʻ464 Patent, FIG. 5 A defendant may argue the term requires a complete spatial separation, and that a list overlaid on a blurred or dimmed portion of the map is not truly "outside" of it.

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement of infringement across all three patents. The basis for this allegation is that Defendant provides instructions to its customers and end users on how to use the accused store locator, which allegedly encourages them to perform the infringing steps Compl. ¶38 Compl. ¶55 Compl. ¶72

Willful Infringement

• Willfulness is alleged based on the theory that Defendant has a "policy or practice against investigating third party patent rights" and has demonstrated "willful blindness" to Plaintiff's patent rights Compl. ¶33 Compl. ¶50 Compl. ¶67 The complaint alleges this conduct makes Defendant liable for direct, indirect, and willful infringement.

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

• A core issue will be one of definitional scope: can claim terms like "simultaneously present" and "information outside of the... map portion," which originate from an early-2000s technological context, be construed to cover the dynamic, overlay-based user interfaces common on the modern web? The outcome of claim construction for these terms may be pivotal.
• A second key question will be one of operational correspondence: does the specific sequence of operations in the accused store locator-from initial search, to display of results, to user selection, to map update-map precisely onto every limitation of the asserted method claims? The dispute may focus on subtle but potentially significant mismatches between the accused functionality and the patented methods.