DCT
2:26-cv-00444
Nearby Systems LLC v. Starbucks Corp
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Nearby Systems LLC (Texas)
- Defendant: Starbucks Corporation (Washington)
- Plaintiff's Counsel: Rozier Hardt McDonough PLLC
- Case Identification: 2:26-cv-00444, E.D. Tex., 06/05/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has established and maintains a regular and established place of business in the Eastern District of Texas and has committed the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant's Starbucks Mobile App infringes four U.S. patents related to displaying location-based content by combining mappable data from disparate software applications on a mobile device.
- Technical Context: The technology pertains to the integration of mapping functions within mobile applications, enabling a user to view location data from a primary application (e.g., a retail app) on a map provided by a separate mapping application (e.g., Apple Maps), thereby creating a cohesive, contextual user experience.
- Key Procedural History: The four asserted patents are members of the same patent family, descending from a common priority application filed in 2007. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to these patents.
Case Timeline
| Date | Event |
|---|---|
| 2007-10-12 | Earliest Priority Date for ''164, ''980, ''145, ''177 Patents |
| 2016-12-27 | U.S. Patent No. 9,532,164 Issued |
| 2019-11-05 | U.S. Patent No. 10,469,980 Issued |
| 2024-03-19 | U.S. Patent No. 11,937,145 Issued |
| 2024-12-31 | U.S. Patent No. 12,185,177 Issued |
| 2026-06-05 | 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.
The Invention Explained
- Problem Addressed: The patent's background describes a limitation in prior art mobile device mapping where new location information originating from outside a mapping application (e.g., from an email or social network post) could only be displayed on a new, separate map, thereby losing the context of any previously displayed points of interest '164 Patent, col. 1:36-44
- The Patented Solution: The invention claims a system and method for combining, or "mashing," mappable data from disparate sources onto a single, existing digital map on a mobile device '164 Patent, col. 1:45-54 The system allows a user to select location-based text in a first "non-browser application" and invoke a "second non-browser application" (a mapping app) to display the new location alongside any pre-existing content on the map, preserving the user's context '164 Patent, abstract '164 Patent, figs. 1A-1C
- Technical Importance: This technology addresses a fundamental usability challenge in early smartphone ecosystems by enabling seamless data transfer between different applications, creating a more integrated and fluid user experience for location-based services.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 Compl. ¶26
- The essential elements of independent claim 1 are:
- A storage device of a mobile device storing a first non-browser application and a second non-browser application;
- A processor executing both applications;
- A user interface of the first application configured for the mobile device;
- A mapping component of the first application configured to invoke the second application when map-able content is activated;
- The second application is a mapping application, and the mapping component transmits the map-able 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 the infringement allegations in Exhibit H refer to "this claim (and any asserted dependent claims)" Compl. Ex. H, p. 2
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.
The Invention Explained
- Problem Addressed: Similar to its parent, the '980 patent addresses the problem of location data existing in one application that a user wishes to view on a map from a separate mapping application without losing context '980 Patent, col. 1:21-34
- The Patented Solution: The patent describes a system on a mobile device comprising a first non-browser application with a mapping component. This component uses the device's GPS location to query an online mapping service and display a map within the first application's interface '980 Patent, claim 1 It further details a process where this mapping component invokes a second, separate mapping application and "directs" it to transmit a query to obtain and display driving directions to a destination '980 Patent, claim 1
- Technical Importance: The invention provides a specific technical method for deep integration between a primary application and a dedicated mapping service, moving beyond simple data display to orchestrate complex functions like route generation across application boundaries.
Key Claims at a Glance
- The complaint asserts at least independent claim 1 Compl. ¶43
- The essential elements of independent claim 1 are:
- A system with memory, a processor, a touch screen, and a GPS device;
- A first non-browser application is stored in memory and executed by the processor;
- A mapping component within the first application 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 mapping application;
- The mapping component invokes the second mapping application and directs it to transmit a query to the online service to obtain driving directions from the device's location to a destination;
- The driving directions are displayed in a map by the second mapping application on the touch screen.
- The infringement allegations in Exhibit I refer to "this claim (and any asserted dependent claims)" Compl. Ex. I, p. 2
U.S. Patent No. 11,937,145 - Mashing Mapping Content Displayed On Mobile Devices
- Patent Identification: U.S. Patent No. 11,937,145, Mashing Mapping Content Displayed On Mobile Devices, issued March 19, 2024.
- Technology Synopsis: This patent claims a system for displaying location content where a first non-browser application displays a map with a location icon and associated text '145 Patent, claim 1 Upon a user touching the text, a mapping component transmits a query, including the device and icon locations, to an online mapping service, causing a second non-browser application to display a map showing a route between the two locations '145 Patent, claim 1
- Asserted Claims: At least independent claim 1 Compl. ¶60
- Accused Features: The Starbucks Mobile App's system for displaying store locations on a map and, upon user interaction, providing navigational routes to those stores Compl. ¶61
U.S. Patent No. 12,185,177 - Mashing Mapping Content Displayed On Mobile Devices
- Patent Identification: U.S. Patent No. 12,185,177, Mashing Mapping Content Displayed On Mobile Devices, issued December 31, 2024.
- Technology Synopsis: This patent claims a system where a user enters text corresponding to a location into a first non-browser application, which transmits the text to a mapping service and receives map data in response, including a map and at least one point-of-interest '177 Patent, claim 1 The first application then displays this map and point-of-interest. A user selection of the point-of-interest causes a new query to be sent to the mapping service, resulting in a new map display '177 Patent, claim 1
- Asserted Claims: At least independent claim 1 Compl. ¶77
- Accused Features: The Starbucks Mobile App's features that allow users to find and navigate to store locations using map-based interfaces Compl. ¶78
III. The Accused Instrumentality
Product Identification
- The "Starbucks Mobile App" and the associated website and services that support its functionality (the "Accused Products") Compl. ¶¶16-18
Functionality and Market Context
- The complaint alleges the Accused Products are designed to allow customers to locate Starbucks stores Compl. ¶18 The system provides for displaying map information on a mobile device, using data to show text and maps that allow a user to identify and navigate to store locations Compl. ¶27 A screenshot in the complaint's exhibits shows the Starbucks app displaying a map of an area with several store locations, and upon selecting one and tapping "Get directions," it invokes the Apple Maps application to display a route. This visual evidence shows the Starbucks app displaying a list of nearby stores and then interfacing with a separate mapping application to provide turn-by-turn navigation Compl. Ex. H, p. 5 The Starbucks Mobile App is the primary mobile application through which the Defendant interacts with its customers.
IV. Analysis of Infringement Allegations
'164 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a storage device of a mobile device storing a first non-browser application and a second non-browser application; | The mobile device's memory stores the Starbucks Mobile App (first non-browser application) and a mapping application like Apple Maps or Google Maps (second non-browser application). | ¶27 | col. 5:46-54 |
| a processor of the mobile device executing the first non-browser application and the second non-browser application; | The mobile device's processor executes both the Starbucks Mobile App and the separate mapping application. | ¶27 | col. 3:13-21 |
| a mapping component of the first non-browser application configured to invoke the second non-browser application on the mobile device when map-able content displayed on the user interface is activated... | The Starbucks App includes code (the mapping component) that is configured to invoke the Apple/Google Maps application when a user activates map-able content, such as by tapping the "Get Directions" button for a selected store. | ¶26 | col. 6:40-52 |
| wherein the second non-browser application is a mapping application, wherein the mapping component transmits the map-able content to an online mapping service... | The invoked Apple/Google Maps is a mapping application. The Starbucks App's mapping component transmits the location of the selected store to an online mapping service that communicates with the mapping application. | ¶26 | col. 4:46-52 |
- Identified Points of Contention:
- Scope Questions: The analysis may focus on whether simply leveraging a standard operating system API to hand off coordinates to a separate mapping application meets the claim requirement of a "mapping component... configured to invoke" the second application. The defense may argue this is a generic OS function, not a specific configuration as taught in the patent.
- Technical Questions: A key question for the court will be what evidence demonstrates that the Starbucks app's code constitutes a "mapping component" that "transmits the map-able content to an online mapping service" which then "communicate[s] with the second non-browser application." The dispute may center on whether the Starbucks app communicates directly with the online service in this sequence or if it merely passes a destination to the second application, which then handles all communication with its own backend service.
'980 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 within the user interface... | The Starbucks App contains a mapping component (code) that communicates with a mapping server to download and display a map of nearby stores within the Starbucks App's own user interface. | ¶44 | col. 4:53-59 |
| wherein the memory stores a second non-browser application that is a mapping application... | The mobile device's memory stores a second, separate mapping application, such as Apple Maps or Google Maps. | ¶44 | col. 4:21-23 |
| 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 Starbucks App's code invokes the separate mapping application (e.g., Apple Maps) and directs it to request driving directions from the user's current location to the selected Starbucks store location. | ¶43 | col. 4:53-65 |
| wherein the driving directions are displayed in a map displayed by the mapping application on the touch screen. | The resulting driving directions are displayed on a map within the invoked Apple Maps or Google Maps application on the device's screen. | ¶43 | col. 5:1-5 |
- Identified Points of Contention:
- Scope Questions: The central dispute may turn on the term "directs the mapping application to transmit a query." The question is whether passing a destination address to another application via a standard API constitutes "directing" it to perform a subsequent network query, or if the claim requires a more explicit command-and-control relationship between the two applications.
- Technical Questions: Evidence will be needed to determine the precise technical interaction between the Starbucks app and the external mapping app. The analysis will question whether the Starbucks app sends a specific instruction to the mapping app to perform a query for directions, or if it simply passes data (a destination coordinate) that the mapping app then independently decides how to process.
V. Key Claim Terms for Construction
For U.S. Patent 9,532,164
- The Term: "mapping component... configured to invoke"
- Context and Importance: This term is the nexus of the claimed system, defining the link between the first and second applications. Its construction will determine whether a generic, OS-provided function for inter-app communication (like opening a URL with location parameters) is sufficient for infringement, or if a more specialized, purpose-built software module is required. Practitioners may focus on this term because the infringement allegation hinges on the nature of the software bridge between the Starbucks app and the OS's native map application.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses relaying data through various means, including user actions like drag-and-drop or using a context menu, which could be interpreted as leveraging general-purpose OS functionalities rather than a highly specialized component '164 Patent, col. 6:4-16
- Evidence for a Narrower Interpretation: The figures and associated description illustrate specific menu options like "Display on Map" or "Add to Existing Map," which suggests a purpose-built function within the first application, potentially supporting a narrower definition of a specifically "configured" component '164 Patent, fig. 1B '164 Patent, col. 6:40-52
For U.S. Patent 10,469,980
- The Term: "directs the mapping application to transmit a query"
- Context and Importance: This term is critical because it defines the level of control the first application must exert over the second. The infringement case rests on whether the Starbucks app is found to be merely providing data to the mapping app, or actively commanding from it a specific action (transmitting a query). The distinction between a data handoff and a command is a technically nuanced point that will be central to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's summary describes the invention in general terms of "combining mappable data from disparate sources" and "transmitting" content, which could be argued to support a less-strict, data-passing interpretation '980 Patent, col. 1:45-54
- Evidence for a Narrower Interpretation: The explicit word "directs" in the claim itself implies a command-and-control relationship, not merely a passive data transfer. The abstract also refers to "invoking a mapping command," which reinforces the idea that the first application is actively instructing the second, supporting a narrower construction requiring proof of such a command '980 Patent, abstract
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents Compl. ¶28 Compl. ¶29 Inducement is alleged based on Defendant providing instructions, advertising, and promoting the use of the Accused Products in an infringing manner Compl. ¶28 Contributory infringement is alleged on the basis that the Accused Products have special features specifically designed for infringement with no substantial non-infringing uses Compl. ¶29
- Willful Infringement: Willfulness is alleged for all four patents based on knowledge acquired, at a minimum, upon the filing of the complaint Compl. ¶30 Compl. ¶47 Compl. ¶64 Compl. ¶81 The complaint further alleges willful blindness based on a purported "policy or practice of not reviewing the patents of others" Compl. ¶31 Compl. ¶48 Compl. ¶65 Compl. ¶82
VII. Analyst's Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim terms "mapping component... configured to invoke" and "directs the mapping application," which imply a purpose-built and commanding software element, be construed broadly enough to read on the Starbucks app's use of what may be standard, general-purpose operating system APIs for passing location data to a separate mapping application?
- A second central question will be one of technical evidence: does discovery on the Starbucks Mobile App's source code and architecture reveal a specific, integrated "mapping component" that actively orchestrates queries and directs external applications, as the patents claim, or will it show that the app simply leverages a generic OS-level service available to any third-party developer, potentially creating a mismatch with the claimed technical operation?
- Finally, the case may raise a question of patentability and obviousness in light of the prosecution history: given the long family of continuation patents building on a 2007 priority date, the court will likely need to scrutinize the specific limitations added in later patents to determine if they represent non-obvious improvements over the prior art and earlier family members, or if they merely claim a fundamental feature of modern smartphone app integration that has become commonplace.
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