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-0168, E.D. Tex., 06/09/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains multiple established places of business in the district, including a specific retail location in Plano, Texas.
• Core Dispute: Plaintiff alleges that Defendant's website store locator functionality infringes three patents related to interactive electronic map technology.
• Technical Context: The technology involves systems and methods for creating two-way interactivity between a graphical map display and associated data lists, a foundational element of modern web-based store locators.
• Key Procedural History: The complaint alleges that the patented technology has been licensed to 30 companies and that related European patents were successfully asserted in two German court proceedings where the defendants were found guilty of infringement.

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 Issued
2019-10-15	U.S. Patent No. 10,444,943 Issued
2021-02-02	U.S. Patent No. 10,908,782 Issued
2026-06-09	Complaint Filed

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

U.S. Patent No. 8,468,464 - "Interactive Electronically Presented Map"

• Issued: June 18, 2013 (the '464 Patent)

The Invention Explained

• Problem Addressed: The patent's background describes a technological environment where electronically presented maps were available online (e.g., from MapQuest), but implies these systems lacked sophisticated, two-way user interactivity between the map itself and associated information about points of interest on the map '464 Patent, col. 1:40-52
• The Patented Solution: The invention provides a system for "two-way interactivity," which "allows a user to take advantage of a displayed area representation as well as information available through the system about items associated with locations on the area representation" '464 Patent, col. 3:5-9 A user can select an item from a list to see its location highlighted on the map, and conversely, a user can interact with a location on the map to retrieve associated information from the list, with the system capable of re-centering the map display in response to user selections '464 Patent, claim 1 '464 Patent, Fig. 9
• Technical Importance: The technology aimed to transform static digital maps into dynamic, interactive interfaces, creating a more intuitive way for users to explore geographical data and its associated details online Compl. ¶10 Compl. ¶24

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• Claim 1 of the '464 Patent includes the following essential elements:
  • A system with at least one computer programmed to cause a display device to simultaneously present a first map portion centered at a specific x/y coordinate, along with user-selectable information outside the map portion responsive to a query.
  • In response to a user selecting information from outside the map, the system is programmed to present a second map portion that is at least partially different and centered at a new x/y coordinate related to the selection.
  • The system is further programmed to respond to a subsequent, different selection by presenting yet another map portion centered at a different coordinate.
• The complaint reserves the right to assert additional claims Compl. ¶43

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

• Issued: October 15, 2019 (the '943 Patent)

The Invention Explained

• Problem Addressed: The complaint, citing the patent, states that at the time of the invention, there were no "computerized systems and methods for providing an electronically map, or any presented interactive area representation, with information associated with the map" (Compl. ¶21, citing '943 Patent, col. 1:43-50).
• The Patented Solution: The patent describes a method for providing an interactive display where a computer receives a user request (e.g., for a category of items) and presents a display with a map and a list of items '943 Patent, claim 1 When the user selects an item from the list, the system presents a new display where the map portion is re-centered on the selected item's location, thereby creating a bidirectional link between the listed data and the graphical map '943 Patent, col. 3:4-23 The patent also details a "magnifier feature" that can provide a magnified view of a portion of the map '943 Patent, col. 3:24-40
• Technical Importance: This method provided a foundational framework for linking databases of location information with graphical map interfaces, enabling the development of features like store locators Compl. ¶10 Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶63
• Claim 1 of the '943 Patent is a method claim that includes the following essential steps:
  • A computer receives a request and provides a first display that includes a graphical map portion, information about items on the map, and user-selectable information identifying at least two of those items.
  • The computer receives a user input selecting the first of the items.
  • In response, the computer provides a second, different display that includes a new graphical map portion and additional information about the selected first item.
• The complaint reserves the right to assert additional claims Compl. ¶43

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

• Issued: February 2, 2021 (the '782 Patent)
• Technology Synopsis: As a continuation of the same patent family, the '782 Patent claims a method for providing an interactive electronic map. The method involves a computer receiving a query for a category of items, presenting a map centered at a first coordinate along with a list of items in that category, and upon user selection of an item from the list, presenting a new map display centered at a different coordinate corresponding to the selected item's location '782 Patent, claim 1
• Asserted Claims: The complaint asserts at least independent claim 1 Compl. ¶80
• Accused Features: The complaint alleges that the store locator feature on Defendant's website infringes the '782 Patent Compl. ¶41 Compl. Count III

III. The Accused Instrumentality

Product Identification

• The Accused Products are Defendant's website, "https://www.chanel.com/us/", and the associated "interactive mapping ecosystem" that enables its store locator functionality Compl. ¶41

Functionality and Market Context

• The Accused Products provide a store locator feature where a user can search for a location, such as "Plano, TX, USA" Compl. ¶43, Fig. 2 The system then displays a list of Chanel boutiques and retailers on the left side of the screen and a corresponding map with location pins on the right Compl. ¶43, Fig. 2 A screenshot in the complaint shows the Chanel website interface, though the citation for this figure incorrectly references a URL for a different company, "tileshop.com" Compl. ¶43, p. 23, Fig. 2
• When a user selects a specific location from the list, the system displays detailed information for that boutique, such as its address and hours, and may adjust the map view to focus on that location Compl. p. 24, Fig. 3 The complaint alleges this functionality is part of an ecosystem that includes servers, cloud-based infrastructure, and software that collectively perform the infringing methods Compl. ¶41

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A system for providing an interactive electronic map, comprising: at least one computer programmed to cause a display device to simultaneously present thereon: a first portion of the map centered at a first x coordinate and at a first y coordinate;	The Accused Products present an initial map view, which the complaint alleges is a map portion centered at a coordinate.	¶43, Fig. 2	col. 8:31-39
information outside of the first map portion responsive to a query relating to the map including user-selectable information;	The system displays a list of boutique locations and categories to the left of the map, which is alleged to be user-selectable information responsive to a user's query (e.g., typing "plano").	¶43, Fig. 2	col. 8:49-55
wherein the at least one computer is further programmed to cause, in response to selection of user-selectable information from the user-selectable information outside of the first map portion... the display device to simultaneously present thereon: instead of the first map portion a second map portion, in relation to the information selected, the second map portion being at least partially different from the first map portion and being centered at an x coordinate different from the first x coordinate...	When a user selects a location from the list, the system allegedly presents a new, re-centered map view corresponding to the selection.	¶26; p. 24, Fig. 3	col. 8:56-66

'943 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A method implemented by at least one computer... comprising: the at least one computer receiving a request and in response, providing for presentation on the display device in a first display which includes... graphical information representing a first portion of a geographical area; [and] first information, all or a portion of which is user-selectable, identifying at least a first and a second of the two or more items...	The system receives a user's search query (e.g., for "plano") and in response presents an initial display showing a map and a user-selectable list of Chanel locations.	¶43, Fig. 2	col. 2:44-54
the method further comprising receiving user input to the at least one computer to select user-selectable information relating to the first of the two or more items...	A user selects a specific boutique from the list, providing input to the system.	p. 24, Fig. 3	col. 4:1-15
and in response, the at least one computer providing for presentation on the display device in a second display which is at least partially different from the first display and includes... graphical information representing a portion of the geographical area; [and] additional information about the first item...	In response to the selection, the system presents a new display with an updated map view and additional details about the selected boutique, such as its address and hours.	p. 24, Fig. 3	col. 4:1-15

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the term "centered", as used in the '464 Patent, requires a precise geometric alignment with a specific coordinate, or if it can be read more broadly to mean "focused on" or "displaying" a general area. The infringement analysis may turn on how the accused system determines its initial and subsequent map views and whether that process meets the claim's definition of being "centered."
  • Technical Questions: The method claims in the '943 and '782 Patents require a specific sequence of receiving a request, providing a first display, receiving a selection, and providing a second display. A point of contention could be whether the user interactions with the Chanel website (e.g., typing a search term, clicking a result) and the resulting screen updates precisely match the sequence and elements recited in the claims, or if there is a mismatch in the operational logic.

V. Key Claim Terms for Construction

• The Term: "centered at a first x coordinate and at a first y coordinate" '464 Patent, claim 1

  • Context and Importance: This term is critical because infringement of claim 1 of the '464 Patent depends on showing that the accused system presents map portions that are "centered" at specific, changing coordinates in response to user selections. Practitioners may focus on this term because the specific technical implementation of how a map view is generated and focused in a modern web application may differ from the more direct coordinate-based manipulation envisioned in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses the general concept of displaying a map and having a position indicator "move to the appropriate location on the map" in response to a selection, which may support a less rigid definition focused on the general location of interest rather than a precise geometric center (Compl. ¶35, citing '943 Patent at 6:27-8:43, which has a similar specification).
    • Evidence for a Narrower Interpretation: The patent describes using the "position indicator's coordinates to index item information" and associates items with specific coordinate information, suggesting a system grounded in precise x/y data points '464 Patent, col. 8:49-55 This could support an argument that "centered" implies the geometric center of the map display must align with the specific coordinates of the selected item.

• The Term: "responsive to a query" '464 Patent, claim 1; "responsive to the request" '943 Patent, claim 1

  • Context and Importance: The claims require the displayed information to be "responsive" to a user query or request. The definition of what constitutes a "query" or "request" and what makes the subsequent display "responsive" will be central to the infringement analysis. The dispute may focus on whether a simple page load, a click on a map, or only a typed search term qualifies as the claimed "query."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes user input broadly to include pointing devices like a mouse, touch screens, and keyboards, which could support an interpretation where any user interaction that changes the display is a "query" '943 Patent, col. 4:60-65
    • Evidence for a Narrower Interpretation: The specification provides specific examples of queries, such as a "category query" that returns a list of all items in that category (e.g., "restaurants") or a query for a specific item name '943 Patent, col. 5:3-16 This could support a narrower construction requiring a structured search or filtering operation, not just any user click.

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, including functionality to "share your location with others" Compl. ¶55 Compl. ¶72 Compl. ¶89 This is alleged to demonstrate an intent for customers to perform the infringing acts Compl. ¶54 Compl. ¶71 Compl. ¶88
• Willful Infringement: The complaint alleges willful infringement based on Defendant's purported "policy or practice against investigating third party patent rights," which Plaintiff characterizes as willful blindness to the infringement Compl. ¶50 Compl. ¶67 Compl. ¶84 This alleged knowledge, combined with continued infringement, is asserted to render Defendant liable for willful infringement Compl. ¶50

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

• A core issue will be one of definitional scope: can the claim term "centered at a... coordinate", which is rooted in a system of precise x/y coordinate manipulation, be construed to read on the dynamic, responsive rendering of a map view in a modern web application? The court's interpretation of this term may be dispositive for the '464 patent.
• A key evidentiary question will be one of functional sequence: does the user workflow on the accused Chanel website-from initial search to selecting a result-perform the specific, sequential steps of receiving a "query," providing a "first display," receiving a "selection," and providing a "second display" as strictly recited in the asserted method claims, or is there a fundamental mismatch in the operational logic?
• A third pivotal issue will concern willfulness: what factual evidence, beyond the formulaic allegation of a "policy or practice against investigating third party patent rights," can Plaintiff produce to demonstrate that Defendant acted with the requisite knowledge or willful blindness required to sustain a claim for willful infringement?