Nearby Systems LLC v. Murphy USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Nearby Systems LLC (Texas)
  • Defendant: Murphy USA Inc. (Delaware)
  • Plaintiff's Counsel: Rozier Hardt McDonough PLLC
• Case Identification: Nearby Systems LLC v. Murphy USA Inc., 2:26-cv-00460, E.D. Tex., 06/09/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant 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 "Murphy Drive Rewards App" infringes four U.S. patents related to displaying and combining location-based content from disparate sources on a mobile device's map interface.
• Technical Context: The technology at issue facilitates the "mash-up" of location data from various mobile applications onto a single, unified map, a foundational feature of modern smartphone navigation and location-based services.
• Key Procedural History: The four asserted patents constitute a single family, with U.S. Patent Nos. 10,469,980, 11,937,145, and 12,185,177 all claiming continuation status from the application that led to the original patent in the family, U.S. Patent No. 9,532,164. The '164 patent itself is a continuation-in-part of an earlier, abandoned application, establishing a long prosecution history.

Case Timeline

Date	Event
2007-10-12	Priority Date for '164, '980, '145, and '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
2026-06-09	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. ¶20

The Invention Explained

• Problem Addressed: The patent describes a limitation in prior art mobile applications where location-based content originating from a non-mapping application (e.g., an email or social media app) could only be displayed on a new, separate map, thereby losing the context of any information already displayed on an existing map '164 Patent, col. 1:33-40
• The Patented Solution: The invention provides a system where "addressable information" from a first non-browser application can be selected and then displayed as a new point of interest on an existing map within a second, separate mapping application, preserving the original map's context '164 Patent, col. 2:41-55 '164 Patent, abstract This creates a "mash-up" of data from different sources on one map.
• Technical Importance: This technology aimed to break down the silos between mobile applications, allowing for a more integrated and seamless user experience when handling location data from various sources like social media, websites, and communications apps '164 Patent, summary

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 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 application is a mapping application, and the mapping component transmits the content to an online mapping service that is configured to communicate with the second mapping application.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringing "one or more claims" Compl. ¶25

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. ¶37

The Invention Explained

• Problem Addressed: Similar to the '164 patent, the '980 patent addresses the problem of fragmented mapping content across different mobile applications '980 Patent, col. 1:21-40
• The Patented Solution: This invention describes a system where a first application uses the device's GPS to determine its location, communicates with an online service to download and display relevant map data (e.g., nearby points of interest), and then, upon user selection, invokes a separate, second mapping application to obtain and display driving directions to a destination '980 Patent, abstract '980 Patent, col. 2:42-53
• Technical Importance: The invention provides a specific workflow for location-aware services, integrating real-time device location with a store-finder function and then handing off the routing task to a dedicated mapping and navigation application.

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶43
• The essential elements of independent claim 1 are:
  • A memory storing a first non-browser application.
  • A processor executing the first application.
  • A touch screen displaying the first application's user interface.
  • A GPS device determining the mobile device's location.
  • A mapping component in the first application that communicates with an online 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 obtain driving directions to a destination.
• The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringing "one or more claims" Compl. ¶42

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 Compl. ¶54
• Technology Synopsis: The patent describes a system where a user interacts with an icon and associated text on a map within a first application. This action triggers a mapping component to query an online service using both the device's location and the icon's location, and subsequently displays a route in a second, separate mapping application '145 Patent, abstract
• Asserted Claims: At least independent claim 1 Compl. ¶60
• Accused Features: The complaint alleges that the "Murphy Drive Rewards App" infringes by providing a system for displaying map information and allowing a user to identify and navigate to Murphy locations 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 Compl. ¶71
• Technology Synopsis: This patent details a system where a user enters text into a first application, which sends the text to an online mapping service to retrieve and display map data with points of interest (POIs). When a user selects a POI, the system transmits a query to the service and uses a second application to display a new map of the selected POI '177 Patent, abstract
• Asserted Claims: At least independent claim 1 Compl. ¶77
• Accused Features: The complaint accuses the "Murphy Drive Rewards App" of infringing with its store locator function, which takes user input, displays stores on a map, and allows selection for details or navigation Compl. ¶78

III. The Accused Instrumentality

Product Identification

The accused products are the "Murphy Drive Rewards App," made available on smartphone app stores, and the associated website "murphyusa.com" Compl. ¶¶16-18

Functionality and Market Context

The "Murphy Drive Rewards App" is alleged to provide customers with a way to locate stores and manage accounts Compl. ¶18 The complaint focuses on the app's store-locator functionality, which allegedly obtains and displays map information to allow a user to find and navigate to Defendant's store locations Compl. ¶27 A composite screenshot provided in the complaint's exhibits shows the "Find a Murphy" map interface from the accused app alongside the Apple Maps interface displaying a route, illustrating the alleged interaction between two non-browser applications Compl. Ex. H, p. 8

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,532,164 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 "Murphy Drive Rewards App" (the first non-browser application) and a native mapping application like Apple Maps or Google Maps (the second non-browser application).	Ex. H, p. 5	col. 10:46-51
a processor of the mobile device executing the first non-browser application and the second non-browser application;	The mobile device's processor runs both the Murphy app and the separate mapping application.	Ex. H, p. 6	col. 10:46-51
a user interface of the first non-browser application configured for the mobile device;	The graphical user interface of the "Murphy Drive Rewards App" as displayed on the mobile device.	Ex. H, p. 7	col. 5:41-44
a mapping component...configured to invoke the second non-browser application...when map-able content displayed on the user interface is activated...	Code within the Murphy app that, upon a user activating "map-able content" (e.g., tapping a "Directions" button for a selected store), invokes the second, separate mapping application.	Ex. H, p. 8	col. 6:45-51
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 second application is a mapping app (e.g., Apple Maps), and the mapping component in the Murphy app allegedly transmits the selected store location to a map server that communicates with the Apple Maps application to display the route.	Ex. H, p. 9	col. 6:51-57

U.S. Patent No. 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 "Murphy Drive Rewards App."	Ex. I, p. 5	col. 15:3-5
a processor of the mobile device executing the first non-browser application;	The mobile device's processor runs the "Murphy Drive Rewards App."	Ex. I, p. 5	col. 15:6-8
a GPS device of the mobile device determining a location of the mobile device...	The mobile device's built-in GPS functionality determines the user's current location.	Ex. I, p. 7	col. 15:12-14
a mapping component...configured to communicate with an online mapping service to download map data and display a map within the user interface of the first non-browser application...	Code within the Murphy app communicates with a mapping server to download map data and display nearby stores on a map inside the app's own interface.	Ex. I, p. 8	col. 15:15-20
wherein the map data is based on the location of the mobile device;	The map data showing nearby stores is based on the current location of the user's device as determined by the GPS.	Ex. I, p. 9	col. 15:23-25
wherein the memory stores a second non-browser application that is a mapping application, and	The mobile device's memory also stores a separate, second mapping application such as Apple Maps or Google Maps.	Ex. I, p. 10	col. 15:26-28
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 obtain driving directions...	The Murphy app invokes the second mapping app (e.g., Apple Maps) and provides it with the user's current location and the selected store's location to generate driving directions.	Ex. I, p. 11	col. 15:29-35

Identified Points of Contention

• Scope Questions: A central question may be the scope of the term "mapping component." The patents describe this component as relaying information and invoking other applications. The defense may argue that the accused app's use of standard operating system functions (e.g., URL schemes to launch a separate maps app) does not constitute the specific "mapping component" described and claimed in the patents.
• Technical Questions: For the '164 patent, a key question is whether the accused system's "mapping component" actually "transmits the map-able content to an online mapping service configured to communicate with the second non-browser application." An alternative and common architecture is for the first app to simply launch the second app with a destination address, and the second app then independently communicates with its own backend service. The distinction between these two data flows could be determinative for infringement.

V. Key Claim Terms for Construction

From the '164 Patent

• The Term: "mapping component"
• Context and Importance: This term defines the active technological element that enables the claimed invention. The outcome of the case may turn on whether the accused app's code, which likely uses standard operating system APIs to launch a separate map application, falls within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification of the related '980 patent describes the component in functional terms as a "software module receiving location information and relaying it to a mapping application" '980 Patent, col. 5:5-8, which may support an interpretation covering any code that performs this function.
  • Evidence for a Narrower Interpretation: The specification also provides more specific examples, such as "an ActiveX control; a widget, an application on a PDA, etc." '980 Patent, col. 3:20-24 A party could argue that the term should be limited to such specific implementations rather than any generic code block.

From the '980 Patent

• The Term: "directs the mapping application to transmit a query"
• Context and Importance: This phrase is critical for defining the nature of the interaction between the first and second applications. Infringement will depend on whether the Murphy app's action of launching a separate map app constitutes "directing" that app to perform a query, or if it is merely a passive handoff of data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any action causing the second app to perform the query, such as launching it via a URL scheme that includes the destination address, satisfies the "directs" limitation.
  • Evidence for a Narrower Interpretation: The term "directs" may suggest a level of command or control that is absent when one sandboxed application simply launches another. A defendant could argue that this requires a more integrated API-level interaction than what is implemented in the accused system.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for all asserted patents. Inducement is based on Defendant allegedly providing the accused app and distributing instructions, advertisements, and user guides that encourage infringing use Compl. ¶28 Compl. ¶45 Compl. ¶62 Compl. ¶79 Contributory infringement is based on allegations that the accused app has special features specifically designed for infringement and is not a staple article of commerce with substantial non-infringing uses Compl. ¶29 Compl. ¶46 Compl. ¶63 Compl. ¶80

Willful Infringement

The complaint alleges willful infringement based on two theories. First, it alleges post-suit willfulness, stating Defendant has had knowledge of the patents "at least as of the date when it was notified of the filing of this action" Compl. ¶30 Compl. ¶47 Compl. ¶64 Compl. ¶81 Second, it alleges pre-suit willful blindness, based "on information and belief" that Defendant has a "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 term "mapping component," which the patents describe with specific examples like widgets and ActiveX controls, be construed to cover modern app development practices, such as making standard API calls to an operating system to launch a separate, sandboxed mapping application?
• A key evidentiary question will be one of technical mechanism: does the accused system operate as claimed by transmitting content to an online service that is configured to communicate with the second application, or does it follow a simpler, more common architecture where the first app merely passes a destination address to the second app, which then independently handles all communication with its own backend services?
• A third question will concern patentability: given the prosecution history and the state of mobile app development at the time of the earliest priority date (2007), a court will need to examine whether the claimed inventions, which center on inter-app communication for mapping, represent a patent-eligible improvement over conventional computer functionality or are directed to an abstract idea. The complaint preemptively argues the claims are not abstract Compl. ¶21 Compl. ¶38 Compl. ¶55 Compl. ¶72