DCT
2:26-cv-00859
Infogation Corp v. NNG Software Developing Commercial LLC
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Infogation Corporation (Texas)
- Defendant: NNG Software Developing and Commercial LLC (Hungary)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:26-cv-00859, E.D. Tex., 09/21/2026
- Venue Allegations: Venue is asserted under the alien-venue rule, which provides that a non-U.S. resident may be sued in any judicial district, on the basis that the Defendant is a Hungarian corporation.
- Core Dispute: Plaintiff alleges that Defendant’s iGO navigation software infringes a patent related to displaying a non-linearly scaled, stylized "artistic" map to a user while using separate, non-displayed geographic data for route calculation and guidance.
- Technical Context: The technology involves the user interface layer of digital navigation systems, blending aesthetic or simplified map visuals with the precision of underlying georeferenced data.
- 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
- 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 describes conventional GPS displays as potentially "boring" and ineffective for leisure activities, such as touring a park or zoo, where artistic maps are common (col. 1:29-38). On such maps, points of interest may be displayed in a stylized manner, but standard GPS systems might not show them until a user is very close, making navigation difficult (col. 1:49-54).
- The Patented Solution: The invention proposes a two-layer system that displays a "non-linearly scaled" artistic map to the user while performing navigation calculations on a separate, hidden geographic map (col. 2:28-39). When a user selects a point on an exaggerated object (e.g., an animal exhibit on a zoo map), the system captures the screen coordinates, transforms them into a single physical point represented by latitude and longitude, calculates a route to that point, and then transforms the resulting directional guidance back onto the artistic map for the user to follow (col. 2:41-52; '628 Patent, FIG. 3).
- Technical Importance: This method allows for the creation of engaging, user-friendly navigation experiences using stylized or aesthetically pleasing maps without compromising the functional accuracy of the underlying geographic routing data (col. 1:60-65).
Key Claims at a Glance
- The complaint asserts infringement of at least claims 1, 4-8, and 11-18 Compl. ¶25 The lead independent claims are method Claim 1 and apparatus Claim 11.
- Independent Claim 1 (Method) includes the essential elements of:
- Downloading a non-linearly scaled, artistic map with exaggerated objects, while not displaying the underlying geographic map.
- Receiving a user's selection of an object on the artistic map.
- Determining coordinates for a point on the selected object.
- Transforming those coordinates to a "physical point" (latitude/longitude) in the geographic map, where all points on the object "correspond substantially to" that single physical point.
- Detecting the device's current location.
- Determining a navigational direction to the physical point using the geographic map.
- Showing the navigational direction on the displayed artistic map.
- Independent Claim 11 (Apparatus) recites a portable device with a display, memory, and a processor configured to perform the core operations outlined in Claim 1.
- The complaint reserves the right to assert additional claims Compl. ¶25
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "NNG iGO and non-licensed implementations of its routing, 3D visualization, POI, map-update, and customizable HMI functions" Compl. ¶17
Functionality and Market Context
- The complaint alleges that the NNG iGO software downloads digital map content and displays a "customized or artistic map" on a portable device Compl. ¶21 This display is described as "non-linearly scaled" because objects like buildings and attractions are "enlarged, modeled, extruded, emphasized, or otherwise displayed out of strict geographic scale" Compl. ¶24
- According to the complaint, the software computes routes using georeferenced navigation data that is maintained separately and is "not displayed directly" Compl. ¶23 Instead, the calculated route and guidance are transformed and rendered on the displayed artistic map Compl. ¶23
- The complaint positions the accused product as part of a "global navigation-software business" with "worldwide availability" and "white-label implementations" Compl. ¶20
IV. Analysis of Infringement Allegations
The complaint alleges that the NNG iGO software performs each step of the patented method. The complaint provides a screenshot of the accused NNG iGO software displaying a stylized map of Paris, with an exaggerated rendering of the Eiffel Tower, to illustrate the accused functionality Compl. p. 4, S1
’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... wherein... the geographical map is not being displayed... | The accused software downloads digital map content and displays a "customized or artistic map" where objects are enlarged and displayed out of strict geographic scale Compl. ¶21 Compl. ¶24 The underlying geographic data is not displayed Compl. ¶23 | ¶21; ¶23; ¶24 | col. 8:26-35 |
| receiving in the computing device a selection on the one of the objects from the user as a selected object | The software permits a user to select a displayed object or destination Compl. ¶21 | ¶21 | col. 8:36-38 |
| transforming in the computing device the pair of coordinates to a physical point represented by a pair of latitude and longitude... the points representing the selected object... corresponding substantially to the physical point... | Selecting any point within a displayed region of an object "identifies substantially the same physical destination represented by latitude and longitude or equivalent geographic coordinates" Compl. ¶22 | ¶22 | col. 8:41-50 |
| detecting a current location of the computing device in the geographical map | The software determines the device's current location Compl. ¶21 | ¶21 | 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 software computes a route or direction using the georeferenced navigation data Compl. ¶21 | ¶21 | col. 8:53-56 |
| showing the navigational direction on the artistic map being displayed | The software renders the calculated route and guidance on the displayed artistic map Compl. ¶21 Compl. ¶23 | ¶21; ¶23 | col. 8:57-58 |
Identified Points of Contention
- Scope Questions: The infringement theory raises a question of claim scope: does the term "artistic map", which the patent primarily exemplifies with leisure maps for zoos or parks (col. 1:46-48; '628 Patent, FIG. 1), read on the commercial city navigation maps allegedly used in the accused iGO product?
- Technical Questions: The allegation that selecting any point on a displayed object maps to "substantially the same physical destination" may become a point of dispute Compl. ¶22 A key factual question will be what evidence demonstrates that the accused system performs this specific many-to-one transformation, and how much locational variance is permitted by the claim term "substantially."
V. Key Claim Terms for Construction
The Term: "artistic map"
Context and Importance: This term is fundamental to the patent's scope. Its construction will determine whether the patent is limited to the specialized leisure maps described in the specification's examples or if it covers a broader category of stylized or non-literal digital maps, including the commercial city maps allegedly used by the Defendant. Practitioners may focus on this term because the applicability of the patent to the accused product hinges on its definition.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims and summary describe the map in general terms as "non-linearly scaled" and including "various objects being exaggeratedly shown" '628 Patent, claim 1 '628 Patent, col. 2:28-31 This language does not explicitly limit the map's context.
- Evidence for a Narrower Interpretation: The patent's background and detailed description repeatedly anchor the invention's utility in "leisure activities, such as touring a city, a park and a zoo" (col. 1:46-48; '628 Patent, col. 4:51-53), and Figure 1 depicts a zoo map. This could support an argument that an "artistic map" is one used for a specific, contained leisure venue.
The Term: "corresponding substantially to the physical point"
Context and Importance: This phrase from Claim 1 is critical for determining infringement of the transformation element. The dispute may turn on whether selecting different parts of a large, exaggerated icon in the accused product leads to a single geographic coordinate, or a set of coordinates close enough to be considered "substantially" the same point. The definition of "substantially" will be a central issue.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of the word "substantially" itself suggests that the correspondence does not have to be mathematically exact and that some degree of tolerance or approximation is permitted.
- Evidence for a Narrower Interpretation: The specification provides an example where "any point in the object 'lion' means a single location in the actual geographic map" (col. 4:61-64). This could be argued to teach a strict many-to-one mapping to a single coordinate, limiting the scope of "substantially" to a very small or zero tolerance.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement under 35 U.S.C. § 271(b), stating that NNG encourages infringement by providing "documentation, SDKs, demonstrations, updates, marketing, and technical support instructing customers and users" to use the accused software in an infringing manner Compl. ¶31
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after having "actual knowledge of the '628 Patent and the infringement alleged herein at least as of service of this Complaint" Compl. ¶32 The complaint seeks enhanced damages based on this alleged post-notice conduct Compl. ¶33
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may depend on the court’s determination of several key issues, framed as open questions:
A core issue will be one of definitional scope: can the term "artistic map", which is rooted in the patent's examples of zoo and park maps, be construed to cover the commercial-grade, stylized city navigation maps allegedly featured in the NNG iGO product?
A key evidentiary question will be one of technical implementation: does the accused software’s transformation logic meet the claim limitation requiring that different points selected on an exaggerated object "correspond substantially to" a single physical point? The outcome may depend on evidence showing how the accused system maps screen selections to geographic coordinates and the degree of locational variance the court permits under the term "substantially."
Analysis metadata