DCT
2:26-cv-00856
Infogation Corp v. Accesso Technology Group
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: accesso Technology Group plc (United Kingdom)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:26-cv-00856, E.D. Tex., 09/21/2026
- Venue Allegations: Venue is alleged to be proper under the alien-venue rule, as the defendant is a foreign corporation organized under the laws of England and Wales.
- Core Dispute: Plaintiff alleges that Defendant’s custom mobile applications for theme parks and other attractions infringe a patent related to navigation systems that use non-linearly scaled, artistic maps.
- Technical Context: The technology involves displaying a user-friendly, stylized "artistic" map for navigation while using underlying, non-displayed geographic data for route calculation, a system particularly suited for venues like theme parks and zoos.
- Key Procedural History: The complaint does not mention 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 section notes that standard GPS navigation displays can be uninformative or "boring" in leisure environments like parks or zoos, where stylized maps are more useful but are often "non-linearly scaled" (e.g., enlarging points of interest), making them incompatible with traditional GPS routing ’628 Patent, col. 1:40-54
- The Patented Solution: The invention solves this problem by using two separate maps: a visually appealing, non-linearly scaled "artistic map" for display to the user, and a conventional, non-displayed "geographical map" for calculations ’628 Patent, abstract When a user selects a destination on the artistic map, the system transforms the selected coordinates into a physical point (latitude and longitude) on the hidden geographical map, calculates a route using this geographical data, and then transforms the route back for display on the artistic map ’628 Patent, abstract ’628 Patent, Fig. 3 ’628 Patent, col. 2:26-40
- Technical Importance: This method allows for the combination of a rich, user-friendly visual interface with the precision of standard GPS navigation, which is valuable for guiding users through complex venues ’628 Patent, col. 1:55-66
Key Claims at a Glance
- The complaint asserts independent claims 1 (a method) and 11 (a portable device), as well as dependent claims 2, 4-8, and 11-18 Compl. ¶28
- Independent Claim 1 (method) requires:
- Downloading a non-linearly scaled "artistic map" with exaggerated objects to a computing device.
- Using a "geographical map" for navigation that is not displayed.
- Receiving a user's selection of an object on the artistic map.
- Transforming the coordinates of the selected point to a physical latitude/longitude point on the geographical map.
- Detecting the device's current location.
- Determining a navigational direction using the geographical map.
- Showing the navigational direction on the displayed artistic map.
- Independent Claim 11 (portable device) requires:
- A display screen, a memory, and a processor.
- The processor executes code to perform operations substantially similar to the steps of method claim 1, including determining coordinates on a selected object, transforming them to a physical point on a non-displayed geographical map, determining a direction, and showing it on the artistic map.
- The complaint reserves the right to assert additional claims Compl. ¶26
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "accesso custom mobile applications, GPS-enabled maps, interactive attraction maps, and related professional-services implementations" Compl. ¶17 The complaint identifies Six Flags as a customer for these apps Compl. ¶19
Functionality and Market Context
- The complaint alleges that Defendant provides "fully customized mobile apps with GPS-enabled maps" and "interactive and dynamic maps guiding guests to their next attraction" for markets like theme parks and water parks Compl. ¶19 Compl. ¶20
- Functionally, these apps are alleged to display a "customized or artistic map" on a portable device, allow users to select destinations, compute routes using "georeferenced navigation data," and render the guidance on the displayed map Compl. ¶22
- The complaint alleges that the underlying "geographic navigation data is not displayed directly" and that the route is "transformed and rendered on the displayed artistic map" Compl. ¶24
- The displayed map is described as "non-linearly scaled" because objects like attractions and points of interest are "enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale" Compl. ¶25
IV. Analysis of Infringement Allegations
'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 apps download map content and the "artistic display is non-linearly scaled because buildings, attractions, points of interest... are enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale..." | ¶22; ¶25 | col. 4:3-5 |
| wherein the computing device is portable, equipped with navigation capability and provides a traveling guidance based on a geographical map, the artistic map is not used directly by the computing device for navigation... and the geographical map is not being displayed on the display; | The apps are for mobile devices and use "georeferenced navigation data" for routing. "The geographic navigation data is not displayed directly; instead, the route and guidance are transformed and rendered on the displayed artistic map." | ¶17; ¶24 | col. 2:40-52 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object; | The apps "permit selection of a displayed object or destination." | ¶22 | col. 6:12-14 |
| transforming in the computing device 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... | "Selecting any point within the displayed region identifies substantially the same physical destination represented by latitude and longitude or equivalent geographic coordinates." The route and guidance are then "transformed." | ¶23; ¶24 | col. 6:19-21 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected; and | The apps "determine current location, compute a route or direction using georeferenced navigation data..." | ¶22 | col. 6:24-26 |
| showing the navigational direction on the artistic map being displayed. | The apps "render that guidance on the displayed map." A product image from Defendant's website shows a mobile application interface for a "SafariLand!" attraction, displaying a stylized map and location-based information. | ¶22; p. 4, S1 | col. 6:27-29 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether Defendant's "customized" and "interactive" maps Compl. ¶19 Compl. ¶20 fall within the scope of the term "artistic map" as used in the patent, which is described as showing "exaggeratedly" displayed objects ’628 Patent, col. 2:29 The analysis could turn on how "artistic" and "exaggeratedly" are construed.
- Technical Questions: The complaint alleges that the accused system uses a non-displayed "geographical map" and "transforms" route data for display Compl. ¶24 A key technical question for the court will be whether the accused apps actually perform this two-map transformation process, or if they use an alternative architecture, such as a single, layered map file where visual elements are directly linked to geographic data without the claimed "transformation" step.
V. Key Claim Terms for Construction
The Term: "artistic map"
- Context and Importance: This term is foundational to the patent's scope. Its construction will be critical in determining whether Defendant’s allegedly "customized" maps infringe. Practitioners may focus on this term because its breadth will dictate whether the patent covers a wide range of modern digital maps or is limited to more stylized, pictorial representations.
- Intrinsic Evidence for a Broader Interpretation: The specification suggests the term applies to maps for leisure activities where "landmarks, point of interests, or animals may be exaggeratedly shown" ’628 Patent, col. 1:58-60, which could encompass any map that prioritizes user experience over strict geographic scale.
- Intrinsic Evidence for a Narrower Interpretation: The patent title itself refers to "Artistic Maps," and the specification describes the map as being "artisticly made to make the navigation as a pleasant experience" ’628 Patent, col. 1:64-66 Figure 1 depicts a highly stylized, pictorial zoo map, which could support an argument that the term is limited to such non-photorealistic or non-technical representations.
The Term: "transforming"
- Context and Importance: This term defines the core technical mechanism of the invention—linking the displayed artistic map to the non-displayed geographic map. How this term is defined will be crucial to the infringement analysis, as it describes a specific internal software operation.
- Intrinsic Evidence for a Broader Interpretation: The claims require "transforming... the pair of coordinates to a physical point" ’628 Patent, cl. 1 without specifying a particular mathematical method. The specification mentions various techniques, including "image deformation techniques" ’628 Patent, col. 6:51 and transforming points on a road network ’628 Patent, col. 7:6-14, suggesting the term is not limited to a single algorithm.
- Intrinsic Evidence for a Narrower Interpretation: The detailed description and figures illustrate a distinct process of converting coordinates from one system (the artistic map) to another (the geographical map) ’628 Patent, Fig. 3 ’628 Patent, col. 4:33-43 A party might argue that "transforming" requires two separate and distinct data sets and a computational step to convert between them, as opposed to a system using a single data file with different layers or data attributes.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement, stating that Defendant distributes the accused apps and provides "documentation, SDKs, demonstrations, updates, marketing, and technical support instructing customers and users to operate the accused functions" Compl. ¶32 It further alleges direct infringement by end-users Compl. ¶31
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving notice of the lawsuit via service of the complaint Compl. ¶33 Compl. ¶34 The complaint does not allege pre-suit knowledge of the ’628 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "artistic map", rooted in the patent’s examples of stylized zoo maps with "exaggeratedly shown" objects, be construed to cover Defendant's "customized" and "interactive" digital maps used in modern theme park applications?
- A key evidentiary question will be one of technical proof: can Plaintiff produce evidence, likely through discovery and source code review, to demonstrate that Defendant's software architecture employs a separate, non-displayed "geographical map" and performs the claimed "transformation," or do the accused apps operate on a different technical principle that falls outside the claim language?
- A third question concerns damages: given that willfulness is pleaded based on post-suit notice only, the potential for enhanced damages may depend on whether Plaintiff can uncover evidence of pre-suit knowledge of the patent during discovery.
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