Activemap LLC v. Petco Health Wellness Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Activemap LLC (New York)
  • Defendant: Petco Health and Wellness Company, Inc. (Delaware)
  • Plaintiff's Counsel: Garteiser Honea, PLLC
• Case Identification: 2:26-cv-0171, E.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains multiple established places of business in the Eastern District of Texas, 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 maps that link geographical displays with selectable lists of information.
• Technical Context: The technology at issue involves the integration of interactive maps with databases of location-based information, a system that has become a foundational feature for online store locators and other geographic search services.
• Key Procedural History: The complaint asserts that the underlying technology has been licensed 30 times and that related European patents were successfully asserted in two German court proceedings, suggesting a history of enforcement and commercial recognition of the patent portfolio.

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 describes the limitations of early electronic maps and identifies a need for more intuitive and interactive ways for users to access information associated with geographic locations Compl. ¶19 '464 Patent, col. 1:29-38
• The Patented Solution: The invention provides for a "two-way interactivity" between a map and an associated list of information (e.g., businesses) '464 Patent, col. 3:6-11 A user can select an item from a list of search results, which causes the system to display a map centered on that item's location. Conversely, interacting with a location on the map can bring up its associated information '464 Patent, abstract The system is designed to allow a user to explore an area digitally in a manner "similar in essence to actually walking through the area of interest" '464 Patent, col. 1:59-62
• Technical Importance: This interactive, dual-mode approach of navigating via either a list or a map became a foundational element for user-friendly online store locators and directory services Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• Essential elements of claim 1 include:
  • A computer causing a display device to simultaneously present a first map portion and "information outside of the first map portion" (e.g., a list) that is responsive to a query and is user-selectable.
  • In response to a user selecting information from that outside list, the computer causes the display to present a second map portion instead of the first.
  • The second map portion is centered at a different x or y coordinate than the first 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," issued October 15, 2019

The Invention Explained

• Problem Addressed: The patent addresses the need to improve the usability of electronic maps by more effectively associating displayed graphical areas with related textual or supplementary information Compl. ¶19 '943 Patent, col. 1:32-41
• The Patented Solution: The patented method involves a computer receiving a request and presenting a "first display" containing a map portion and user-selectable information identifying multiple items (e.g., a list of stores) '943 Patent, abstract When a user selects one of the items from the list, the system responds by providing a "second display" that is different from the first, presenting graphical and item information related to the selected item '943 Patent, col. 20:50-col. 21:22 This creates a query-and-response loop between the user, the list, and the map display.
• Technical Importance: This method provided a structured, interactive way for users to drill down from a general query to specific, geographically-contextualized information, which is a core function of modern online locators Compl. ¶20

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• Essential elements of claim 1 include:
  • Receiving a request and providing a first display with a graphical area and user-selectable information for two or more items.
  • Receiving a user input selecting the information for one of the items.
  • In response, providing a second, different display that includes graphical information and item information related to the selected item.
  • The second display also includes additional, user-selectable 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 describes a method where a computer receives a query for a category of items, such as "city agencies," and in response displays a map centered at a first coordinate along with a list of items matching the category '782 Patent, col. 20:23-40 When a user selects an item from that list, the system presents a new map display that is centered at a second, different coordinate corresponding to the selected item's location, thereby enabling dynamic, query-driven map navigation '782 Patent, col. 20:53-col. 21:10
• Asserted Claims: Claim 1 Compl. ¶63
• Accused Features: The Petco store locator website is accused of infringing by allowing users to search for stores, displaying the results in a list next to a map, and updating the map's center point when a user selects a specific store from the list Compl. ¶¶62-65

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as the interactive mapping ecosystem on Defendant's website, specifically the store locator functionality Compl. ¶¶25-26

Functionality and Market Context

The accused functionality allows a user to input a location to find nearby Petco stores Compl. ¶26 The system then presents an interactive map displaying store locations as pins, alongside a corresponding list of those same stores with addresses and other details Compl. ¶26 Figure 2 in the complaint shows the initial user interface after a search, displaying a broad geographic map and search input fields Compl. Fig. 2 Figure 3 shows the results of a search for "Tyler, TX, USA," with a more focused map and a user-selectable list of the relevant store location Compl. Fig. 3 The complaint alleges this type of functionality is foundational for retail websites Compl. ¶20

IV. Analysis of Infringement Allegations

'464 Patent Infringement Allegations

'943 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The infringement theory for the '464 Patent relies on the term "simultaneously present." A potential dispute may arise over whether the accused system's display of a map and a list, and the subsequent replacement of the map view upon user selection, meets the specific temporal and structural requirements of this term as used in the claim.
• Technical Questions: A central evidentiary question may be whether the accused system's functionality matches the full sequence recited in the claims. For instance, the complaint alleges the map re-centers from a first coordinate to a different second coordinate upon user selection, but the provided screenshots do not explicitly show this A-to-B transition, raising a question of what evidence the complaint provides to support this element of the claimed method.

V. Key Claim Terms for Construction

• The Term: "simultaneously present" '464 Patent, Claim 1

  • Context and Importance: This term is central to the structure of the claimed invention, defining the required relationship between the map portion and the "information outside" of it (the list). Its construction will determine whether a system that dynamically updates or replaces screen elements, rather than showing them all statically at once, falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's description of "two-way interactivity" could support a construction where elements presented as part of a single, interactive user session are considered "simultaneous," even if they are not all visible on the screen at the exact same instant '464 Patent, col. 3:6-11
    • Evidence for a Narrower Interpretation: The claim language "simultaneously present thereon" and figures in the patent family (e.g., '943 Patent, Fig. 5) depict a map, a magnified view, and a list all displayed concurrently on the same screen. This may support a narrower construction requiring all recited elements to be co-located on the display at the same time.

• The Term: "a second map portion ... centered at an x coordinate different from the first x coordinate" '464 Patent, Claim 1

  • Context and Importance: This limitation defines the specific change that must occur on the map in response to a user's selection from the list. The infringement analysis will depend on whether the accused system's map update (e.g., zooming in, panning) constitutes a "re-centering" to a "different" coordinate as required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a system that allows a user to "take advantage of a displayed area representation" to find a desired location, suggesting the core concept is responsive navigation, which could broadly cover any map movement that focuses on the selected item '464 Patent, col. 3:11-15
    • Evidence for a Narrower Interpretation: The claim's use of precise geometric language ("centered at an x coordinate different from") could support a narrow construction requiring a literal calculation and change of the map's mathematical center point, as opposed to a simple zoom or pan that keeps the original center point within the new, larger view.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides instructions to its customers on how to use the accused store locator, thereby encouraging them to perform the steps of the patented methods Compl. ¶34 Compl. ¶51 Compl. ¶68
• Willful Infringement: Willfulness is alleged based on "willful blindness," with the complaint asserting on information and belief that Defendant has a "policy or practice against investigating third party patent rights" 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 the term "simultaneously present," as used in the '464 Patent, be construed to cover a web interface where a map view is dynamically replaced in response to a user's selection from a list, or does it require a stricter, concurrent display of both the "before" and "after" elements?
• A key evidentiary question will be one of functional operation: does the accused store locator, in practice, perform the specific claimed step of re-centering the map from a first coordinate to a demonstrably different coordinate upon user selection, and what technical evidence will be required to prove this specific mode of operation?
• A final question will relate to patent validity: given the 2001 priority date and the subsequent proliferation of interactive online maps, the case may involve significant disputes over whether the claimed inventions were truly novel and non-obvious over the state of the art at the time of invention.