Nearby Systems LLC v. Chevron USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nearby Systems LLC (Texas)
  • Defendant: Chevron U.S.A., Inc. (Pennsylvania)
  • Plaintiff's Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:26-cv-00250, E.D. Tex., 03/25/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has established and maintains a regular and established place of business in the District and has committed acts of patent infringement within the District.
• Core Dispute: Plaintiff alleges that Defendant's "Chevron App" and "Texaco App" for mobile devices infringe four U.S. patents related to combining and displaying mapping content from disparate sources on a mobile device.
• Technical Context: The technology at issue addresses the integration of location-based data, enabling a mobile application to take location information from one context and display it on a map in another, preserving previously displayed map content.
• Key Procedural History: The four asserted patents are part of a single family, sharing a common specification and priority claim dating back to 2007, indicating a long-running prosecution effort to claim various aspects of the core invention.

Case Timeline

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

U.S. Patent No. 9,532,164 - "Mashing Mapping Content Displayed On Mobile Devices"

• Issued: December 27, 2016

The Invention Explained

• Problem Addressed: The patent's background section describes a limitation in prior art mobile mapping services where new mapping content originating from outside a mapping application (e.g., a location selected in a separate email or social media app) could only be displayed on a new, separate digital map, thereby losing the context of any information displayed on a previously viewed map '164 Patent, col. 1:35-42
• The Patented Solution: The invention provides a method and system for selecting "addressable information" in a "disparate application" on a mobile device and, through a mapping command, automatically displaying that information as a new point of interest on an existing map in a map-display application. This allows new content to be "mashed" onto the current map view in addition to any prior mapping content already displayed '164 Patent, abstract '164 Patent, col. 3:1-6 Figures 1A through 1C illustrate this process, showing a point of interest from a social media app being added to an existing map view.
• Technical Importance: This approach addresses the problem of siloed data on mobile devices by enabling a more integrated and contextual user experience where location information from different applications can be aggregated visually on a single map.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶29
• Essential elements of Claim 1 (a system claim) include:
  • A memory storing a first non-browser application and a second non-browser application.
  • A processor executing both applications.
  • A user interface for the first non-browser application.
  • A mapping component within the first non-browser application configured to invoke the second non-browser application when "map-able content" is activated.
  • The second non-browser application is a mapping application.
  • The mapping component transmits the map-able content to an online mapping service that communicates with the second non-browser (mapping) application.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,469,980 - "Mashing Mapping Content Displayed On Mobile Devices"

• Issued: November 5, 2019

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the '164 patent, the '980 patent addresses the same technical problem: the inability of prior art systems to add location information from an external source to an already-existing map view without losing the original map's context '980 Patent, col. 1:28-42
• The Patented Solution: The '980 patent similarly describes a system where addressable information from one application can be selected and displayed on a map within a separate mapping application, preserving the previously displayed content '980 Patent, abstract The specification explains that the system can parse location identifiers from aggregated text and relay them to a mapping application for display '980 Patent, col. 4:32-48
• Technical Importance: This technology enhances the utility of mobile mapping by allowing for dynamic, on-the-fly aggregation of location-based points of interest from various sources into a single, unified visual display.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶46
• Essential elements of Claim 1 (a system claim) include:
  • A memory storing a first non-browser application.
  • A processor executing the first non-browser application.
  • A touch screen displaying the user interface of the first non-browser application.
  • A GPS device determining the mobile device's location.
  • A mapping component of the first non-browser application that communicates with an online mapping service to download and display a map within its user interface, based on the device's location.
  • The memory also stores a second non-browser application that is a mapping application.
  • The mapping component invokes the second non-browser (mapping) application and directs it to transmit a query to obtain driving directions from the mobile device's location to a destination.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,937,145 - "Mashing Mapping Content Displayed on Mobile Devices"

• Issued: March 19, 2024
• Technology Synopsis: Continuing the same patent family, the '145 patent addresses the technical challenge of integrating mappable data from disparate sources onto a single, existing digital map within a mobile mapping application to avoid losing context '145 Patent, col. 1:30-47 The solution involves transmitting a second set of mappable content found outside a mapping application to that application for display in conjunction with previously displayed content '145 Patent, col. 1:48-56
• Asserted Claims: The complaint asserts at least independent claim 1 Compl. ¶63
• Accused Features: The complaint alleges that the Accused Products provide a system for displaying map information on a mobile device to allow a user to identify and navigate to locations Compl. ¶64

U.S. Patent No. 12,185,177 - "Mashing Mapping Content Displayed on Mobile Devices"

• Issued: December 31, 2024
• Technology Synopsis: The '177 patent, also in the same family, is directed to solving the problem of displaying location information from an external application on a new map, which causes the loss of any prior mapping context '177 Patent, col. 1:30-47 The invention facilitates the "mashing" of this external content onto an existing map display, preserving the original visual information '177 Patent, abstract
• Asserted Claims: The complaint asserts at least independent claim 1 Compl. ¶80
• Accused Features: The complaint alleges that the Accused Products, including the Chevron and Texaco Apps, provide a system and method for displaying map information on a mobile device that allows users to find and navigate to Defendant's locations Compl. ¶81

III. The Accused Instrumentality

Product Identification

• The "Chevron App" and the "Texaco App," which are mobile device applications available for download Compl. ¶19 Compl. ¶20 These are collectively referred to as the "Accused Products" Compl. ¶21 No probative visual evidence provided in complaint.

Functionality and Market Context

• The complaint alleges the Accused Products are designed to allow customers to manage accounts and locate nearby Chevron and Texaco locations Compl. ¶21 Functionally, they are alleged to provide a system for displaying map information on a mobile device by obtaining data to display text and maps, which in turn allows a user to identify and navigate to specific locations offering Defendant's products Compl. ¶30 Compl. ¶47

IV. Analysis of Infringement Allegations

The complaint references exemplary evidence of infringement in Exhibits M and N, which were not provided. The following analysis is based on the narrative allegations in the complaint.

'9,532,164 Infringement Allegations

Identified Points of Contention

• Scope Questions: Claim 1 requires a "first non-browser application" that "invokes" a "second non-browser application." A likely point of dispute is whether a single, self-contained app (e.g., the Chevron App) that uses a standard operating system API to pass an address to a separate, pre-existing default mapping app (e.g., Apple Maps or Google Maps) meets this two-application architectural requirement. The definition of "invoke" may be central to this question.
• Technical Questions: The claim requires the "mapping component of the first non-browser application" to transmit content to an "online mapping service." It may be contested whether the accused Chevron or Texaco app itself performs this transmission, or whether that function is performed entirely by the separate mapping application after it has been launched with the location data.

'10,469,980 Infringement Allegations

Identified Points of Contention

• Scope Questions: Claim 1 of the '980 patent requires the "first non-browser application" to both display a map within its own interface and invoke a "second non-browser application" to get driving directions. This raises the question of whether the accused apps perform both functions as claimed, or if they only perform one (e.g., hand-off a location to an external map app without displaying a map internally first).
• Technical Questions: What evidence does the complaint provide that the "mapping component" of the accused Chevron or Texaco app is the entity that "directs the mapping application to transmit a query"? It is possible that the first app merely passes a destination address, and the second mapping application independently formulates and transmits its own query for directions, which may not align with the claim's specific language.

V. Key Claim Terms for Construction

• The Term: "invokes" (from claim 1 of the '164 patent and claim 1 of the '980 patent)

  • Context and Importance: This term is critical because the infringement theory for both lead patents requires the "first" application (the accused app) to "invoke" a "second" application (a mapping app). The construction of "invokes" will determine whether simply using a standard OS-level function to launch a separate, pre-installed mapping app meets this limitation, or if a more specific and integrated software action is required.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a user selecting text and then choosing a "Map" command from a menu, which causes a mapping application to be presented '980 Patent, Figs. 7A-7C '980 Patent, col. 9:47-54 This sequence may support an interpretation where "invoke" means any user- or system-initiated action that causes a separate mapping application to launch and display the relevant data.
    • Evidence for a Narrower Interpretation: The specification describes an embodiment where the first application is "closed/minimized/reduced to a background process" and may later be "restored into full view," displaying the new data in conjunction with the original data '980 Patent, col. 3:12-21 This could suggest "invokes" requires a specific application lifecycle relationship where the first application manages the process and integrates the result, rather than just performing a simple handoff.

• The Term: "mapping component of the first non-browser application" (from claim 1 of the '164 patent and claim 1 of the '980 patent)

  • Context and Importance: This component is recited as performing the key inventive steps. Practitioners may focus on this term because Defendant may argue that its app does not contain a special "mapping component," but rather uses generic operating system services available to any app to interact with the device's default map application. The question is whether such a standard API call constitutes a "component of the first non-browser application."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the component in functional terms as a module that receives and relays location information '980 Patent, col. 4:16-24 '980 Patent, Fig. 3A This may support a broad definition where any code within the first application that prepares and transmits location data for mapping purposes qualifies as the "mapping component."
    • Evidence for a Narrower Interpretation: The patent figures depict the "MAPPING COMPONENT" as a distinct architectural block within the "DISPLAY APPLICATION" on the client device, separate from the external "MAPPING APPLICATION" service '980 Patent, Fig. 10A This could support a narrower construction requiring a discrete, identifiable software module within the first app, not merely the use of an external OS-level service.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all four asserted patents. The inducement theory is based on allegations that Defendant provides the Accused Products with the specific intent to cause infringement by, for example, distributing instructions and advertising their infringing use Compl. ¶31 Compl. ¶48 The contributory infringement theory alleges the Accused Products have special features specifically designed for infringement that are not staple articles of commerce and have no substantial non-infringing uses Compl. ¶32 Compl. ¶49
• Willful Infringement: Willfulness is alleged for all four patents. The primary basis is alleged post-suit knowledge, stating Defendant had knowledge of the patents "at least as of the date when it was notified of the filing of this action" Compl. ¶33 Compl. ¶50 Compl. ¶67 Compl. ¶84 The complaint also alleges willful blindness based on an asserted "policy or practice of not reviewing the patents of others" Compl. ¶34 Compl. ¶51 Compl. ¶68 Compl. ¶85

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

• A core issue will be one of architectural scope: does a self-contained mobile app using a standard operating system API to hand off an address to a separate, pre-installed default mapping application (e.g., Apple Maps) satisfy the claim requirements for a "first non-browser application" containing a "mapping component" that "invokes" a "second non-browser application"?
• A key evidentiary question will be one of functional allocation: do the accused Chevron and Texaco apps themselves contain a "mapping component" that performs the claimed step of communicating with an "online mapping service" to download map data or obtain directions, as recited in the asserted claims, or is that function performed entirely by the separate mapping application after it is launched?
• The viability of the willful infringement claim will likely depend on whether the Plaintiff can produce evidence to substantiate its allegation of a pre-suit "policy or practice of not reviewing the patents of others," which would be necessary to elevate the claim beyond a standard allegation based on notice from the complaint itself.