Nearby Systems LLC v. Exxon Mobile Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nearby Systems LLC (Texas)
  • Defendant: Exxon Mobil Corporation (New Jersey)
  • Plaintiff's Counsel: Rozier Hardt McDonough PLLC
• Case Identification: 2:26-cv-00260, E.D. Tex., 03/29/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has established and maintains regular places of business within the Eastern District of Texas and has committed acts of patent infringement in the District.
• Core Dispute: Plaintiff alleges that Defendant's Exxon App for mobile devices infringes four patents related to methods for displaying mapping content from disparate sources on a single, integrated map.
• Technical Context: The technology at issue concerns the integration of location-based data from one mobile application into a separate mapping application, a foundational capability for modern mobile software ecosystems.
• Key Procedural History: The four asserted patents are part of the same patent family, descending from a common parent application. This shared lineage may raise issues of prosecution history estoppel or consistent claim construction across the patents-in-suit.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent's background describes a limitation in prior art mobile mapping systems where new location information originating from outside a mapping application could only be displayed on a new, separate digital map, losing the context of any previously displayed map content '980 Patent, col. 1:35-42
• The Patented Solution: The invention provides a system on a mobile device where a first non-browser application (e.g., an email or social media app) can identify mappable content and invoke a second, separate non-browser mapping application to display that new content on the same map view, thereby combining information from disparate sources '980 Patent, abstract '980 Patent, col. 3:1-11
• Technical Importance: This approach facilitates the creation of "mashups" on mobile devices, allowing data from various applications to be aggregated and visualized on a single map, which is a core feature of modern integrated mobile software Compl. ¶22

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶27
• Claim 1 of the '164 patent includes these essential elements:
  • A system with a storage device on a mobile device 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 application configured to invoke the second 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 configured to communicate with the second non-browser application.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

The Invention Explained

• Problem Addressed: As with the related '164 patent, the technology addresses the challenge of integrating location data from one application into another without losing the existing map context '980 Patent, col. 1:35-42
• The Patented Solution: The '980 patent claims a system where a first non-browser application uses a mapping component to communicate with an online service to display a map based on the device's GPS location. The system then stores a second non-browser mapping application, and the mapping component of the first application invokes the second to transmit a query for driving directions from the device's location to a selected destination '980 Patent, abstract '980 Patent, claim 1
• Technical Importance: The invention refines the data mashup concept by claiming the specific, commercially significant workflow of identifying a point of interest in one application and seamlessly transitioning to a dedicated mapping application for turn-by-turn navigation Compl. ¶39

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶44
• Claim 1 of the '980 patent includes these essential elements:
  • A system with a memory storing a first non-browser application and a processor executing it.
  • A touch screen displaying the user interface of the first application.
  • A GPS device determining the mobile device's location.
  • A mapping component in the first application that communicates with an online mapping service to download and display a map 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 mapping application and directs it to transmit a query (including device location and a destination) to the online service to obtain driving directions.
  • The driving directions are displayed on a map by the mapping application on the touch screen.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

• Technology Synopsis: This patent covers a system where a user's touch on text within a first non-browser application causes a mapping component to transmit a query, including the device location and the icon's location, to an online mapping service Compl. ¶56 In response, a second non-browser application displays a second map showing a route between the two locations '145 Patent, claim 1
• Asserted Claims: At least independent claim 1 is asserted Compl. ¶61
• Accused Features: The accused functionality is the Exxon App's feature for displaying map information and, upon user interaction, providing navigation to selected locations offering Defendant's products Compl. ¶62

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

• Technology Synopsis: This patent claims a system where a first application receives text input from a user, transmits it to a mapping service, and displays a map with points-of-interest (POIs) Compl. ¶73 When a user selects one of the POIs, the mapping component transmits a new query to the online service, and in response, a second non-browser application displays a new map of the selected POI '177 Patent, claim 1
• Asserted Claims: At least independent claim 1 is asserted Compl. ¶78
• Accused Features: The complaint accuses the Exxon App's system for displaying map information on a mobile device to allow users to identify and navigate to Defendant's locations Compl. ¶79

III. The Accused Instrumentality

Product Identification

• The accused products are mobile device applications controlled by Defendant, identified as the "Exxon App" and the "Exxon Mobil Rewards + Mobile Application" (Compl. ¶17; Compl. ¶18; Compl. ¶19, Compl. ¶p. 2).

Functionality and Market Context

• The Exxon App is a publicly available application for smartphones and tablets, distributed through platforms like the Apple App Store and Google Play Store Compl. ¶18 Compl. Ex. F Compl. Ex. G Its relevant functionality allows users to find Exxon locations on a digital map and then obtain driving directions to a selected location Compl. ¶19 Compl. ¶28 The complaint alleges that the app accomplishes this by interfacing with separate, third-party mapping applications, such as Apple Maps or Google Maps, that are also stored on the user's device Compl. Ex. I, p. 5 The complaint includes a screenshot showing the Exxon App presenting the user with a choice to get directions via "Apple Maps" or "Google Maps" Compl. Ex. I, p. 8 Another visual depicts the Exxon App displaying a map of a selected station and, after the user requests directions, the Apple Maps application displaying a route to that station Compl. Ex. I, p. 5

IV. Analysis of Infringement Allegations

'164 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether a "system" as claimed can be formed by two separately developed and distributed applications (e.g., the Exxon App and Apple Maps) that interact only through standard operating system protocols. The defense may argue they are not a single, infringing system.
  • Technical Questions: The final element of claim 1 requires that the mapping component of the first application transmits content to an online mapping service. A key factual question will be what evidence shows the Exxon App's component performs this step, versus simply passing coordinates to the second mapping application, which then independently communicates with its own online service.

'980 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A point of contention may be whether the Exxon App's component "directs" the second mapping application to transmit a query. The defense might argue that the first app merely provides a destination coordinate, and the second app independently decides how and whether to query its own online service, thus not meeting the "directs" limitation.
  • Technical Questions: The analysis may turn on the technical implementation of the interaction between the two applications. What level of control or instruction does the Exxon App exert over the third-party mapping app, beyond what is available through a standard, public API provided by the mobile operating system?

V. Key Claim Terms for Construction

• The Term: "mapping component"

• Context and Importance: This term appears in the independent claims of all asserted patents and is central to the infringement theory. Its definition will determine what part of the first non-browser application (the Exxon App) must perform the claimed actions. Practitioners may focus on this term because its construction could decide whether a simple button that makes an operating system call is sufficient to meet the limitation, or if a more complex, integrated software module is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification refers to "mapping functionality" that can be part of a simple pop-up context menu, suggesting it can be a lightweight feature rather than a substantial software block '980 Patent, col. 9:5-8
  • Evidence for a Narrower Interpretation: The patent figures depict the "MAPPING COMPONENT" as a distinct architectural block within the "DISPLAY APPLICATION," which may support an argument that it must be a structurally separate and identifiable module within the first application's code '980 Patent, Fig. 10A, element 1002

• The Term: "invoke"

• Context and Importance: This term is critical for defining the required relationship between the first and second non-browser applications. The dispute will question whether launching a separate application via a standard, public operating system protocol (e.g., a URL scheme) constitutes "invoking" in the claimed sense.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The abstract describes the second application being "automatically presented (e.g., launches, become visible, displayed, etc.)," which supports a broad definition that includes simply causing the second application to open and become the active program on screen '980 Patent, abstract
  • Evidence for a Narrower Interpretation: The defense may argue that the context of the invention implies a tighter integration than a simple handoff. However, the specification also describes the process as the mapping application being "re-opened (i.e. brought to the forefront of the display, becoming an active application...)," which appears consistent with a standard application launch and may limit arguments for a narrower construction '980 Patent, col. 4:45-48

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents Compl. ¶29 Compl. ¶30 The inducement allegation is based on Defendant providing the Exxon App, advertising its features, and providing instructions that allegedly guide users to infringe Compl. ¶29 The contributory infringement allegation is based on the assertion that the app's mapping and navigation features are specially designed for an infringing use and have no substantial non-infringing uses Compl. ¶30
• Willful Infringement: The complaint alleges willful infringement for all four patents, asserting that Defendant had knowledge of the patents at least as of the filing of the action Compl. ¶31 Compl. ¶48 Compl. ¶65 Compl. ¶82 It further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" Compl. ¶32 Compl. ¶49 Compl. ¶66 Compl. ¶83

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

• A core issue will be one of system definition: can a "system" as recited in the claims be formed by the combination of Defendant's Exxon App and a separate, third-party mapping application (e.g., Apple Maps), where the two applications are independently distributed and interact only through standard, publicly available operating system protocols?
• A second central question will be one of claim construction and scope: can the term "mapping component," described as part of the first application, be construed to perform actions that may factually be carried out by the second, separate mapping application, such as transmitting content to an online mapping service for the purpose of generating directions?
• A key evidentiary question will be one of technical agency: what proof will be offered to demonstrate that the Exxon App's "mapping component" itself performs the claimed step of transmitting data to an online service, as opposed to merely handing off a set of coordinates to a third-party application which then independently communicates with its own backend service?