DCT

2:26-cv-00434

Nearby Systems LLC v. Dollar Tree Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00434, E.D. Tex., 05/26/2026
  • Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because the defendants have established and maintained regular and established places of business within the District and have committed alleged acts of patent infringement there.
  • Core Dispute: Plaintiff alleges that Defendant's "Dollar Tree Mobile App" infringes four U.S. patents related to displaying location-based content from different application sources on a single digital map on a mobile device.
  • Technical Context: The technology addresses the integration of mapping functions within mobile applications, specifically the ability to take location data from one application and display it on a map, potentially within a separate, dedicated mapping application.
  • Key Procedural History: The four asserted patents are part of a single family, originating from an application filed in 2007. The patents-in-suit are continuations or continuations-in-part of each other, suggesting a shared specification and a long-running prosecution effort to cover various aspects of the core invention.

Case Timeline

Date Event
2007-10-12 Earliest Priority Date for '164, '980, '145, '177 Patents
2013-08-03 Application for '164 Patent Filed
2016-11-08 Application for '980 Patent Filed
2016-12-27 '164 Patent Issued
2019-09-13 Application for '145 Patent Filed
2019-11-05 '980 Patent Issued
2024-02-08 Application for '177 Patent Filed
2024-03-19 '145 Patent Issued
2024-12-31 '177 Patent Issued
2026-05-26 Complaint Filed

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

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

  • Patent Identification: U.S. Patent No. 9,532,164, "Mashing Mapping Content Displayed On Mobile Devices," issued December 27, 2016 Compl. ¶1 Compl. ¶23

The Invention Explained

  • Problem Addressed: The patent addresses the problem of siloed information in mobile applications, where location data found in a non-mapping application (e.g., an email or social media post) could only be displayed on a new, blank map, disconnected from any previously existing map content Compl. ¶24 '980 Patent, col. 1:31-39
  • The Patented Solution: The invention describes a system where location-based information from a "first non-browser application" can be selected and displayed on a map within a "second non-browser application" (a mapping app), combining the new information with any pre-existing map content Compl. ¶24 '980 Patent, col. 3:1-7 This allows for "mashing" content from disparate sources onto a single, unified map view '980 Patent, summary of the invention
  • Technical Importance: This approach improves the functionality of mobile devices by allowing a seamless transition of location data between different applications, creating a more integrated and useful user experience.

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '164 patent Compl. ¶29
  • The essential elements of independent Claim 1, based on the allegations in the complaint's Exhibit H, include:
    • A storage device storing a first and a second non-browser application.
    • A processor executing both applications.
    • A user interface for the first application.
    • A "mapping component" in the first application configured to "invoke" the second (mapping) application when "map-able content" is activated.
    • The mapping component transmits the content to an online mapping service configured to communicate with the second application.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent but makes general allegations of infringing "one or more claims" Compl. ¶28

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

  • Patent Identification: U.S. Patent No. 10,469,980, "Mashing Mapping Content Displayed On Mobile Devices," issued November 5, 2019 Compl. ¶1 Compl. ¶40

The Invention Explained

  • Problem Addressed: As a continuation, the '980 patent addresses the same problem as the '164 patent: the inability in prior art systems to easily transfer location-based content from a non-mapping application onto an existing map that may already contain other points of interest '980 Patent, col. 1:25-39
  • The Patented Solution: The '980 patent's claimed solution is a mobile device system where a "mapping component" within a first application communicates with an online service to download and display map data based on the device's GPS location, and can also "invoke" a second, separate mapping application to obtain and display driving directions to a selected destination '980 Patent, claim 1 The system is designed to integrate data from one app into the context of another, as illustrated in the patent's figures showing a new point of interest being added to a pre-existing map '980 Patent, FIG. 1C
  • Technical Importance: The invention facilitates a more integrated user experience by allowing applications to leverage the functionality of dedicated mapping services for tasks like turn-by-turn navigation.

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '980 patent Compl. ¶46
  • The essential elements of independent Claim 1 include:
    • A mobile device with memory, a processor, a touch screen, and a GPS device.
    • A "first non-browser application" with a "mapping component."
    • The mapping component is configured to communicate with an "online mapping service" to download map data based on the GPS location.
    • The memory also stores a "second non-browser application" which is a mapping application.
    • The mapping component "invokes" the mapping application and "directs" it to transmit a query to obtain driving directions.
    • The driving directions are displayed in a map on the touch screen.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" Compl. ¶45

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

  • Multi-Patent Capsule: U.S. Patent No. 11,937,145
    • Patent Identification: U.S. Patent No. 11,937,145, "Mashing Mapping Content Displayed On Mobile Devices," issued March 19, 2024 Compl. ¶1 Compl. ¶57
    • Technology Synopsis: This patent, part of the same family, addresses combining mappable data from disparate sources onto a digital map Compl. ¶58 It specifically claims a system where a touch on text in a first application's user interface causes a mapping component to transmit a query (including the device's location and the icon's location) to an online mapping service, which then displays a second map with a route in a second application '145 Patent, claim 1
    • Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶63
    • Accused Features: The accused features are the Dollar Tree Mobile App's system and method for displaying map information, which allegedly allows a user to identify and navigate to store locations Compl. ¶64

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

  • Multi-Patent Capsule: U.S. Patent No. 12,185,177
    • Patent Identification: U.S. Patent No. 12,185,177, "Mashing Mapping Content Displayed On Mobile Devices," issued December 31, 2024 Compl. ¶1 Compl. ¶74
    • Technology Synopsis: This patent, also in the same family, claims a system for displaying location-based content Compl. ¶75 The claimed invention involves a user selecting a point-of-interest in a first application, which causes a mapping component to transmit a query to an online service; in response, the system displays a second map with the selected point-of-interest in a second application '177 Patent, claim 1
    • Asserted Claims: The complaint asserts at least Claim 1 Compl. ¶80
    • Accused Features: The accused features are the Dollar Tree Mobile App's system and method for displaying map information to locate and navigate to defendant's stores Compl. ¶81

III. The Accused Instrumentality

Product Identification

  • The "Dollar Tree Mobile App," available on smartphone app stores, and the website https://www.dollartree.com/ (collectively, the "Accused Products") Compl. ¶¶19-21

Functionality and Market Context

  • The complaint alleges the Dollar Tree Mobile App is designed to allow customers to locate Dollar Tree stores (Compl. ¶21). The app's functionality includes displaying store locations on a map within the app's own user interface Compl. Ex. I, p. 5 The complaint includes a screenshot from the app's store locator feature, which shows a map view with icons representing nearby stores Compl. Ex. I, p. 5 The app also provides an option to get directions, which, according to the complaint's evidence, launches a separate, third-party mapping application (e.g., Apple Maps) to display a route from the user's current location to the selected store Compl. Ex. I, pp. 10-12

IV. Analysis of Infringement Allegations

9,532,164 Infringement Allegations

The complaint does not provide sufficient detail for analysis of infringement of the '164 patent in a claim chart format, as the referenced Exhibit H was not provided with sufficient detail to construct a chart with specification citations. The narrative theory alleges that the Dollar Tree Mobile App (the first non-browser application) invokes a separate mapping app like Apple Maps (the second non-browser application) when a user requests directions to a store, thereby transmitting map-able content to an online mapping service Compl. Ex. H, pp. 7-9

10,469,980 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a memory of a mobile device storing a first non-browser application; The mobile device's memory stores the Dollar Tree Mobile App. Ex. I, p. 5 col. 13:40-44
a GPS device of the mobile device determining a location of the mobile device... The app prompts the user to "Enable My Location" and uses the phone's "location services" feature to determine the user's position. Ex. I, p. 7 col. 15:10-14
a mapping component of the first non-browser application configured to communicate with an online mapping service to download map data and display a map... The Dollar Tree Mobile App contains code that communicates with a map server to download map data and display a map of nearby stores within the app's user interface. Ex. I, p. 8 col. 14:1-24
wherein the memory stores a second non-browser application that is a mapping application... The mobile device's memory stores a separate mapping application, such as Apple Maps or Google Maps. Ex. I, p. 10 col. 15:20-23
wherein the mapping component invokes the mapping application and directs the mapping application to transmit a query including the location of the mobile device and a destination location to the online mapping service to obtain driving directions... The user selecting "Get Directions" in the Dollar Tree app invokes the separate Apple Maps application and passes it the destination store's location, causing it to obtain and display driving directions. Ex. I, pp. 11-12 col. 16:1-6
wherein the driving directions are displayed in a map displayed by the mapping application on the touch screen. The Apple Maps application displays the calculated route on a map on the device's touch screen. Ex. I, p. 13 col. 16:6-9
  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the claimed "mapping component" of the "first non-browser application" reads on the functionality of the Dollar Tree app. The defense may argue that a button that simply launches a separate, pre-installed mapping application (e.g., Apple Maps) using a standard URL scheme is not the integrated "component" described in the patent.
    • Technical Questions: The infringement theory raises the question of which entity performs the claimed actions. Claim 1 of the '980 patent requires the first app's "mapping component" to "invoke" and "direct" the second app to "transmit a query." The complaint's evidence shows the Dollar Tree app launching Apple Maps, which then appears to handle the query and routing itself. The court may need to determine whether this hand-off satisfies the active "directs" limitation or if there is a fundamental mismatch in the operational sequence.

V. Key Claim Terms for Construction

  • The Term: "mapping component"

  • Context and Importance: The definition of this term is critical because infringement hinges on whether the accused Dollar Tree app contains such a component that performs the claimed functions. A narrow definition requiring significant integrated mapping logic within the first app could favor the defendant, while a broader definition covering a simple button that launches an external map URL could favor the plaintiff.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the component as a module that can "relay/transmit" address information to a separate display application, which may support a view that it primarily acts as an intermediary '980 Patent, col. 14:30-34
    • Evidence for a Narrower Interpretation: The specification also describes the component as being part of a "map generating and map-display application" and shows it as a distinct block within a "DISPLAY APPLICATION" '980 Patent, FIG. 10A '980 Patent, col. 9:50-54 This may support an interpretation that the component must be more than a simple hyperlink and possess some inherent mapping or data processing capabilities.

  • The Term: "directs the mapping application to transmit a query"

  • Context and Importance: This term is central to the infringement analysis of the '980 patent. The case may turn on whether the Dollar Tree app "directs" Apple Maps to act, or merely provides it with data (a destination address) that Apple Maps then acts on independently. Practitioners may focus on this term because it suggests a level of command and control.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent's overall purpose is to enable interoperability. A court could find that in this context, "directs" should be given its plain and ordinary meaning, which could include providing the necessary information (the destination) that causes the query to be transmitted.
    • Evidence for a Narrower Interpretation: The word "directs" implies a command. The defense may argue that simply passing an address via a URL scheme does not "direct" the receiving application to do anything; the receiving application's own code makes the decision to "transmit a query." The specification does not appear to provide an explicit definition of "directs," leaving it open to construction based on the technical context.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by asserting that the defendants provide the Accused Products and distribute instructions and advertisements that guide users to use them in an infringing manner Compl. ¶31 Compl. ¶48 Contributory infringement is alleged on the basis that the Accused Products contain special features designed for infringement that are not staple articles of commerce and have no substantial non-infringing use Compl. ¶32 Compl. ¶49
  • Willful Infringement: Willfulness is alleged based on knowledge of the patents since at least the filing of the complaint (post-suit knowledge) Compl. ¶33 Compl. ¶50 The complaint also alleges willful blindness based on an asserted "policy or practice of not reviewing the patents of others" Compl. ¶34 Compl. ¶51

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

  • A core issue will be one of claim construction and scope: can the term "mapping component," described in the patent as an integrated part of a first application, be construed to cover a feature in the Dollar Tree app that launches a separate, pre-installed mapping application like Apple Maps? This question will determine if the architecture of the accused system falls within the patent's claims at a foundational level.
  • A key evidentiary question will be one of operational functionality: does the accused system's act of passing a destination address to Apple Maps satisfy the claim limitation that the first application's component "directs" the second application to "transmit a query"? The resolution will depend on whether this hand-off is seen as a command, as the term "directs" implies, or merely a data transfer that the second app acts upon independently.