DCT
2:26-cv-00853
Infogation Corp v. Visioglobe SAS
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: Visioglobe SAS (France)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:26-cv-00853, E.D. Tex., 09/21/2026
- Venue Allegations: Plaintiff alleges venue is proper under the alien-venue rule because Defendant is a foreign corporation.
- Core Dispute: Plaintiff alleges that Defendant’s indoor mapping and navigation software infringes a patent related to navigation using non-linearly scaled, artistic maps.
- Technical Context: The technology at issue involves using stylized, visually-rich maps for user interaction while relying on underlying, non-displayed geographic coordinate data for route calculation.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2007-08-11 | ’628 Patent Priority Date |
| 2018-10-23 | ’628 Patent Issue Date |
| 2026-09-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,107,628 - "Method and Apparatus for Navigating on Artistic Maps"
- Patent Identification: U.S. Patent No. 10,107,628, titled "Method and Apparatus for Navigating on Artistic Maps," issued on October 23, 2018.
The Invention Explained
- Problem Addressed: The patent's background describes conventional GPS displays as potentially "boring" and uninformative in leisure settings like parks or zoos, as they often fail to display points of interest until a user is very close, showing only roads and "unrelated landmarks" instead '628 Patent, col. 1:38-53
- The Patented Solution: The invention proposes a navigation system that uses two distinct map layers: a user-facing "artistic map" and a background "geographic map" '628 Patent, Fig. 3 The artistic map is "non-linearly scaled," meaning points of interest can be "exaggeratedly shown" to be more user-friendly '628 Patent, col. 2:12-15 When a user selects a destination on the artistic map, the system captures the coordinates of the selection, transforms them into a corresponding physical point (e.g., latitude and longitude) on the unseen geographic map, calculates a route using that geographic data, and then displays the resulting navigational guidance on the artistic map '628 Patent, abstract '628 Patent, col. 2:30-39
- Technical Importance: This approach enables the creation of engaging, visually customized navigation experiences (e.g., for theme parks or airports) that are functionally grounded in precise, real-world coordinate systems '628 Patent, col. 1:60-63
Key Claims at a Glance
- The complaint asserts independent claims 1 (a method) and 11 (a portable device), along with dependent claims 4-8 and 12-18 Compl. ¶28
- Independent claim 1 of the ’628 Patent recites the essential elements:
- Downloading an "artistic map" that is "non-linearly scaled" and has "exaggeratedly shown" objects.
- Receiving a user's selection of one of the objects.
- Determining a pair of coordinates for a point on the selected object.
- Transforming those coordinates to a "physical point" (latitude/longitude) in a "geographical map" that is not displayed.
- Detecting the device's current location in the geographical map.
- Determining a navigational direction from the current location to the selected object using the geographical map.
- Showing the navigational direction on the displayed artistic map.
- The complaint reserves the right to assert additional claims Compl. ¶26
III. The Accused Instrumentality
Product Identification
- Product Identification: VisioOne, Visioglobe navigation SDKs, Map Editor, and customer applications that implement these products Compl. ¶17
Functionality and Market Context
- The accused instrumentalities are alleged to provide "custom 3D maps, turn-by-turn navigation, georeferenced maps, and web, iOS, and Android delivery" Compl. ¶19 The complaint specifically notes their use for indoor mapping at LaGuardia Airport Compl. ¶21
- The complaint alleges the products operate by displaying a "customized or artistic map" and allowing users to select a destination Compl. ¶22 A route is then computed using "georeferenced navigation data," which is allegedly maintained separately from the "branded, stylized, or three-dimensional presentation layer" and is not directly displayed to the user Compl. ¶24
- The complaint asserts that the displayed maps are "non-linearly scaled" because objects such as points of interest are "enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale to facilitate selection and navigation" Compl. ¶25
- The complaint provides a visual example of an accused Visioglobe map, depicting a stylized, three-dimensional, bird's-eye view of a building complex with surrounding landscaping Compl. p. 4
IV. Analysis of Infringement Allegations
Claim Chart Summary
- Claim Chart Summary: The complaint alleges that the Accused Instrumentalities meet every limitation of at least claim 1 Compl. ¶26 The core allegations are summarized below.
'628 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| downloading from a network into a computing device an artistic map, the artistic map being non-linearly scaled and including various objects being exaggeratedly shown... | The Accused Instrumentalities download digital map content and display a "customized or artistic map" where objects are "enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale." | ¶22; ¶25 | col. 8:26-36 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The accused system permits "selection of a displayed object or destination" on the map. | ¶22 | col. 8:36-37 |
| determining by the computing device a pair of coordinates for one of the points on the selected object | When a user selects a region, the system identifies associated destination coordinates. | ¶23 | col. 8:38-40 |
| transforming... the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map not being shown on the display... | The system allegedly transforms the selection into a destination represented by latitude and longitude, using "georeferenced navigation data" that is not directly displayed. | ¶23; ¶24 | col. 8:41-50 |
| detecting a current location of the computing device in the geographical map | The system determines the user's current location. | ¶22 | col. 8:51-52 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected | The system computes a route or direction using the georeferenced navigation data. | ¶22 | col. 8:53-56 |
| showing the navigational direction on the artistic map being displayed | The system renders the computed route or guidance on the displayed artistic map. | ¶22; ¶24 | col. 8:57-58 |
Identified Points of Contention
- Scope Questions: The patent’s specification and figures primarily use outdoor leisure environments (e.g., a zoo map) to illustrate the invention '628 Patent, Fig. 1 '628 Patent, col. 4:3-6 The complaint accuses products used for indoor navigation Compl. ¶6 Compl. ¶21 This raises the question of whether the term "artistic map" and the associated claims, developed in an outdoor context, can be construed to read on the functionally different environment of indoor building navigation.
- Technical Questions: Claim 1 requires that when transforming coordinates, "all of the different pairs of coordinates for the selected object" correspond "substantially to the physical point" '628 Patent, col. 8:47-50 The complaint alleges that selecting "any point within the displayed region identifies substantially the same physical destination" Compl. ¶23 A factual dispute may arise over whether the accused system's mapping from a selectable screen area to a single coordinate pair satisfies this claim limitation, and what the evidentiary standard for "substantially" will be.
V. Key Claim Terms for Construction
The Term: "artistic map"
- Context and Importance: This term appears in both independent claims and is foundational to the patent's scope. Its construction will be critical in determining whether the accused stylized 3D indoor maps fall within the patent's purview. Practitioners may focus on this term because its definition could either broadly cover any non-standard map or be limited to the specific creative, illustrative examples shown in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the map as "non-linearly scaled" with "exaggeratedly shown" objects '628 Patent, col. 2:12-14, and states it may be "artisticly made to make the navigation as a pleasant experience" '628 Patent, col. 1:63-65 This could support an argument that any map designed for user experience over geographic accuracy qualifies.
- Evidence for a Narrower Interpretation: The primary example is a stylized 2D zoo map '628 Patent, Fig. 1 A party could argue that the term implies a certain level of creative illustration, as opposed to a more functional but still non-geographic schematic like a 3D architectural rendering.
The Term: "non-linearly scaled"
- Context and Importance: This term defines a key technical characteristic of the "artistic map." The infringement analysis may turn on whether the accused maps' method of emphasizing certain features meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract equates non-linear scaling with having "various objects being exaggeratedly shown" '628 Patent, abstract The complaint alleges the accused maps do this by enlarging or extruding objects Compl. ¶25, which may support a broad reading.
- Evidence for a Narrower Interpretation: The specification provides a specific example of non-linear scaling where the map has higher resolution at the center of the display and lower resolution toward the edges, creating a "fisheye" effect '628 Patent, Figs. 4B-4C '628 Patent, col. 5:40-47 A defendant could argue this specific, systematic distortion of scale is required, rather than just the selective enlargement of individual map objects.
VI. Other Allegations
Indirect Infringement
- The complaint alleges active inducement of infringement, asserting that Defendant provides "documentation, SDKs, demonstrations, updates, marketing, and technical support instructing customers and users" to use the accused products in an infringing manner Compl. ¶32
Willful Infringement
- Willfulness allegations are based on post-suit conduct. The complaint alleges Defendant has "actual knowledge" of the ’628 Patent "at least as of service of this Complaint" and that continued infringement constitutes willful infringement Compl. ¶¶33-34 No pre-suit knowledge is alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "artistic map," exemplified in the patent with a two-dimensional, illustrative zoo map, be construed to cover the three-dimensional, architectural renderings used in the accused indoor navigation systems?
- A key infringement question will center on the technical meaning of "non-linearly scaled": does the accused products' method of selectively enlarging or emphasizing points of interest meet this claim limitation, or does the patent require a more systematic distortion of scale across the map, such as the "fisheye" view described in the specification?
- An evidentiary question will be one of functional correspondence: does the accused system's alleged practice of mapping a selectable screen region to a single geographic coordinate pair Compl. ¶23 satisfy the claim requirement that "all" points on the selected object "substantially" correspond to the same physical point '628 Patent, col. 8:47-50?
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