DCT
2:26-cv-00857
Infogation Corp v. Mapspeople As
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: MapsPeople A/S (Denmark)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:26-cv-00857, E.D. Tex., 09/21/2026
- Venue Allegations: Venue is asserted based on the alien-venue rule, which states that a foreign entity can be sued in any judicial district, as Defendant is a Danish corporation. The complaint also notes the presence of a U.S. subsidiary with an office in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s "MapsIndoors" indoor mapping platform infringes a patent related to navigation systems that use non-linearly scaled, "artistic" visual maps.
- Technical Context: The technology at issue involves methods for reconciling visually stylized, non-geographically-accurate maps (e.g., for theme parks, campuses, or large buildings) with precise, data-driven GPS route calculation.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or a prior licensing relationship between the parties.
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, "Method and Apparatus for Navigating on Artistic Maps", issued October 23, 2018.
The Invention Explained
- Problem Addressed: The patent's background section identifies a shortcoming in traditional GPS navigation systems when used for leisure activities, such as touring a zoo or park ʼ628 Patent, col. 1:46-54 Standard GPS displays, which rely on strictly scaled maps, are often unhelpful in these environments, while the artistic, non-scaled maps provided by the venues cannot be used directly for GPS navigation ʼ628 Patent, col. 1:46-54
- The Patented Solution: The invention discloses a method to bridge this gap. It uses a non-linearly scaled, "artistic map" where points of interest are exaggerated for user-friendliness ʼ628 Patent, col. 2:28-30 When a user selects a point on this artistic map (e.g., tapping on a large cartoon image of a lion), the system captures the screen coordinates, transforms them into a single, precise physical location (latitude and longitude) on a hidden geographical map, calculates a route to that location, and then transforms the route guidance back for display on the artistic map ʼ628 Patent, abstract ʼ628 Patent, Fig. 3 This allows for navigation that is both visually intuitive and geographically accurate.
- Technical Importance: The technology provided a framework for combining the aesthetic and usability benefits of stylized maps with the technical precision of satellite-based navigation systems.
Key Claims at a Glance
- The complaint asserts infringement of independent claims 1 and 11, along with several dependent claims Compl. ¶28
- Independent Claim 1 (Method): The core elements include:
- Downloading a non-linearly scaled "artistic map" with exaggerated objects, while a corresponding "geographical map" is not displayed.
- Receiving a user's selection of an object on the artistic map.
- Transforming the coordinates of a point on the selected object into a single physical point (latitude/longitude) on the geographical map.
- A key feature is that different points on the artistic object all correspond "substantially" to the same single physical point.
- Determining a navigational direction from a current location to that physical point.
- Displaying the resulting navigational direction on the artistic map.
- Independent Claim 11 (Apparatus): This claim recites a "portable device" with a processor and memory configured to perform the essential steps outlined in method claim 1.
- The complaint reserves the right to assert additional claims as the case proceeds Compl. ¶26
III. The Accused Instrumentality
Product Identification
The complaint names "MapsIndoors, MapsIndoors SDKs, web/mobile implementations, and customer applications implementing the platform" as the Accused Instrumentalities Compl. ¶17
Functionality and Market Context
The complaint alleges that the MapsIndoors platform provides "customized 2D/3D georeferenced maps" with "turn-by-turn guidance" Compl. ¶19 It is alleged to operate by maintaining separate data layers: a "branded, stylized, or three-dimensional presentation layer" shown to the user, and underlying "georeferenced navigation and route data" that is not directly displayed Compl. ¶24 According to the complaint, the displayed map is "non-linearly scaled" because objects like buildings, rooms, and points of interest are "enlarged, modeled, extruded, [or] emphasized" to facilitate user interaction Compl. ¶25 The complaint includes a marketing image from the Defendant's website, which depicts the MapsIndoors interface on a laptop, tablet, and smartphone, illustrating its stylized map view and cross-platform nature Compl. p. 4
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 Accused Instrumentalities allegedly download digital map content and display a "customized or artistic map" that 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. 2:28-30 |
| the geographical map is not being displayed on the display | The complaint alleges that the "geographic navigation data is not displayed directly; instead, the route and guidance are transformed and rendered on the displayed artistic map." | ¶24 | col. 7:35-37 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The system allegedly permits "selection of a displayed object or destination," where objects are rendered as "selectable screen regions." | ¶22; ¶23 | col. 2:30-33 |
| transforming...the pair of coordinates to a physical point represented by a pair of latitude and longitude in the geographical map...the points representing the selected object having different pairs of coordinates, but all...corresponding substantially to the physical point | The complaint alleges that "Selecting any point within the displayed region identifies substantially the same physical destination represented by latitude and longitude or equivalent geographic coordinates." | ¶23 | col. 7:48-52 |
| detecting a current location of the computing device in the geographical map | The accused system is alleged to "determine current location." | ¶22 | col. 8:1-2 |
| determining according to the geographical map a navigational direction from the current location to the one of the objects being selected | The accused system allegedly can "compute a route or direction using georeferenced navigation data." | ¶22 | col. 8:5-8 |
| showing the navigational direction on the artistic map being displayed | The system is alleged to "render that guidance on the displayed map." | ¶22 | col. 8:9-11 |
- Identified Points of Contention:
- Scope Questions: A potential issue for the court may be whether the term "artistic map", which is frequently exemplified in the patent with outdoor leisure venues like zoos ʼ628 Patent, Fig. 1, can be construed to read on the Defendant's "MapsIndoors" product, which focuses on structured indoor environments. While the claim language is not explicitly limited, the specification's focus could be used to argue for a narrower interpretation of the claimed subject matter.
- Technical Questions: A key technical question is whether the Accused Instrumentalities perform the specific transformation required by the claim: mapping multiple different screen coordinates on a single selectable object to "substantially" the same single physical (lat/long) point. The complaint alleges this occurs Compl. ¶23, but the actual implementation of Defendant's mapping between its visual layer and its geographic data layer will be a central factual question for the litigation.
V. Key Claim Terms for Construction
The Term: "artistic map"
- Context and Importance: This term is foundational to the patent, defining the type of user-facing interface the invention is designed to improve. The outcome of the case may depend on whether Defendant's "MapsIndoors" 2D/3D models are construed as being "artistic maps". Practitioners may focus on this term because Defendant could argue its product is a technical, georeferenced model, distinct from the illustrative, cartoon-like examples in the patent's specification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent suggests the term is flexible, noting the map may be "artisticly made to make the navigation as a pleasant experience" ʼ628 Patent, col. 1:64-66 The complaint also characterizes the accused map as a "stylized, or three-dimensional presentation layer" Compl. ¶24, language that could support a broad definition encompassing any non-standard, stylized digital map.
- Evidence for a Narrower Interpretation: The specification repeatedly uses examples of zoo and park maps ʼ628 Patent, col. 1:61-63 ʼ628 Patent, Fig. 1 and describes objects as "exaggeratedly shown" ʼ628 Patent, col. 2:13-14 This could support an argument that the term is limited to highly distorted, illustrative maps rather than the more structured 3D models used for indoor navigation.
The Term: "objects being exaggeratedly shown"
- Context and Importance: This phrase, linked to the "artistic" and "non-linearly scaled" nature of the map, is a critical limitation distinguishing the invention from a standard scaled map. Infringement will hinge on whether the visual elements in MapsIndoors are deemed to be "exaggeratedly shown".
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent links the exaggeration to a functional purpose: "to assist a visitor to locate what is desired to be seen" ʼ628 Patent, col. 4:4-6 This could support an interpretation where any purposeful deviation from strict scale to improve usability, such as enlarging icons or extruding buildings, qualifies as an exaggeration.
- Evidence for a Narrower Interpretation: A party could argue this term requires a high degree of artistic distortion beyond simple non-linear scaling. For example, it might be argued that the term implies a qualitative, illustrative exaggeration (like a cartoon animal) rather than a quantitative scaling or extrusion of an otherwise geometrically-correct object.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement under 35 U.S.C. § 271(b). The basis for this allegation is Defendant's alleged distribution of the Accused Instrumentalities along with "documentation, SDKs, demonstrations, updates, marketing, and technical support instructing customers and users to operate the accused functions in the infringing manner" Compl. ¶32
- Willful Infringement: The claim for willfulness is based on post-suit knowledge. The complaint asserts that Defendant has knowledge of the '628 Patent "at least as of service of this Complaint" and that any continued infringement after this notice is "deliberate and willful" Compl. ¶33 Compl. ¶34
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "artistic map", which is rooted in the patent's examples of outdoor, leisure-venue maps, be construed by the court to cover the more structured, 2D/3D models of indoor spaces used by the accused "MapsIndoors" platform?
- A central evidentiary question will be one of technical implementation: does the accused system’s method for handling user selections on its map meet the specific claim requirement that various points on a single visual object are transformed to "substantially" the same single geographic coordinate, or does it employ a fundamentally different mapping logic between its visual and data layers?
Analysis metadata