Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 1 of 27
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`
`
`Case No. 6:20-cv-89
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`JURY TRIAL DEMANDED
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`
`
`
`
`
`
`
`
`
`
`NAVBLAZER, LLC,
`
`
`
`
`
`Apple
`
` v.
`
`SAMSUNG ELECTRONICS CO.,
`LTD (A KOREAN COMPANY) AND
`SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`
`
`
`Defendants
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`NavBlazer, LLC (“NavBlazer”) hereby files this Original Complaint for Patent Infringement
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`against Samsung Electronics Co., LTD (a Korean Company) (“Samsung Electronics”) and Samsung
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`Electronics America, Inc. (“Samsung Electronics America”), (collectively, “Samsung”), and alleges,
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`upon information and belief, as follows:
`
`THE PARTIES
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`1. NavBlazer is a limited liability company organized and existing under the laws of the State of
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`Florida with its principal place of business at 600 S. Dixie Highway, Suite 605, West Palm Beach,
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`Florida 33401.
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`2. Upon information and belief, Defendant Samsung Electronics Co., LTD is a company organized and
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`existing under the laws of the Republic of Korea with its principal offices at 250, 2-ga, Taepyong-ro,
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`Jung-gu, Seoul, 100-742, South Korea. Samsung Electronics Co., LTD may be served with process
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`

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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 2 of 27
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`by serving its wholly owned subsidiary, Samsung Electronics America, Inc., via its registered agent
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`CT Corporation System at 1999 Bryan St., Suite 900, Dallas, TX 75201-3136.
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`3. Upon information and belief, Samsung Electronics America, Inc. is a company with a principal place
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`of business at 105 Challenger Road, 6th Floor, Ridgefield Park, New Jersey 07660. Samsung
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`Electronics America, Inc. may be served through its registered agent, CT Corporation System, at
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`1999 Bryan St., Suite 900, Dallas, TX 75201-3136.
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`
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`JURISDICTION AND VENUE
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`4. This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331, 1332, 1338, and
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`1367.
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`5. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b).
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`6. This Court has personal jurisdiction over Samsung. Samsung has continuous and systematic business
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`contacts with the state of Texas. Samsung, directly or through subsidiaries or intermediaries
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`(including distributors, retailers, and others), conducts its business extensively throughout Texas, by
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`shipping, distributing, making, using, offering for sale, selling, and advertising (including the
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`provision of interactive web pages) its products and services in the state of Texas and the Western
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`District of Texas. Samsung, directly and through subsidiaries or intermediaries (including
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`distributors, retailers, and others), has purposefully and voluntarily placed infringing products and
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`services into this district and into the stream of commerce with the intention and expectation that
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`they will be purchased and used by consumers in this district. Samsung has offered and sold and
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`continues to offer and sell these infringing products and services in this district, including at physical
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`Samsung stores located within this district. Samsung and its customers also commit additional acts
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`of direct infringement in this district with respect to each asserted patent through their infringing use
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 2
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 3 of 27
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`of the accused devices, including Samsung’s servers, in this district, including when Samsung and its
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`customers put the accused devices into service and receive a benefit, and Samsung is liable for these
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`additional acts of direct infringement and indirect infringement in this district. Samsung has
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`committed acts of infringement, both direct and indirect, in this district with respect to each asserted
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`patent and has a regular and established place of business in this judicial district. For example,
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`Samsung Electronics America maintains regular and established place offices in the Western District
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`of Texas, including at 12100 Samsung Blvd, Austin, Texas 78754 and 2800 Wells Branch Pkwy,
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`Austin, Texas 78728. Further, upon information and belief, Samsung Electronics directs and
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`controls the actions of Samsung Electronics America such that it too maintains regular and
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`established offices in the Western District of Texas, including at 12100 Samsung Blvd, Austin,
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`Texas 78754, and 2800 Wells Branch Pkwy, Austin, Texas 78728. Samsung Electronics also owns
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`and operates a manufacturing facility in Austin, Texas. In addition, Samsung Electronics, and
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`Samsung Electronics America have placed or contributed to placing infringing products into the
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`stream of commerce via an established distribution channel knowing or understanding that such
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`products would be sold and used in the United States, including in the Western District of Texas. On
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`information and belief, Samsung Electronics and Samsung Electronics America also have each
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`derived substantial revenue from infringing acts in the Western District of Texas, including from the
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`sale and use of infringing products. Samsung Electronics America has maintained regular and
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`established places of business at 12100 Samsung Blvd, Austin, Texas 78754 and 2800 Wells Branch
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`Pkwy, Austin, Texas 78728.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 3
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 4 of 27
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`U.S. PATENT NOS. 9,075,136 AND 9,885,782
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`7. NavBlazer is the owner, by assignment, of U.S. Patent No. 9,075,136 and 9,885,782, each entitled
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`“VEHICLE OPERATOR AND/OR OCCUPANT
`
`INFORMATION APPARATUS AND
`
`METHOD” (hereinafter collectively referred to as “the Patents-in-Suit”).
`
`8. The patent application that issued as the ’782 Patent is a continuation application of U.S. Patent
`
`Application Ser. No. 09/259,957, filed March 1, 1999, and entitled “VEHICLE OPERATOR
`
`AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD”, now U.S. Pat. No.
`
`9,075,136. U.S. Patent Application Ser. No. 09/259,957, filed March 1, 1999, claims priority to U.S.
`
`Provisional Patent Application Ser. No. 60/076,800, filed March 4, 1998, and entitled “VEHICLE
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`OPERATOR AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD.”
`
`9. The Patents-in-Suit are valid, enforceable, and were duly issued in full compliance with Title 35 of
`
`the United States Code.
`
`10. The inventions described and claimed in the Patents-in-Suit were invented by Raymond Anthony
`
`Joao.
`
`11. The priority date of each of the Patents-in-Suit is at least as early as March 4, 1998.
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`12. The Patents-in-Suit relate generally to an apparatus and method for providing a user with one or
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`more possible travel routes to a destination, as well as additional information regarding the one or
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`more possible travel routes, such as traffic conditions, road conditions, traffic flow, weather
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`information and/or other useful information.
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`13. During prosecution of the ’782 Patent, the patent examiner considered whether the claims of the
`
`’782 Patent were eligible under 35 USC §101 in view of the United States Supreme Court’s decision
`
`in Alice. The patent examiner found that the claims are in fact patent eligible under 35 USC §101
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`because all pending claims are directed to patent-eligible subject matter, none of the pending claims
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 4
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 5 of 27
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`are directed to an abstract idea and there would be no preemption of the abstract idea or the field of
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`the abstract idea.
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`
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`
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`SAMSUNG’S PRODUCTS
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`14. Upon information and belief, Samsung sells, advertises, offers for sale, uses, or otherwise provides
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`mobile devices that utilize the Android operating system including, but not necessarily limited to, the
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`“Galaxy Fold,” “Galaxy 5G,” “Galaxy S,” “Galaxy Note,” “Galaxy A,” “Galaxy M,” “Galaxy
`
`Grand,” “Galaxy On,” “Galaxy C” and “Galaxy J” series of mobile devices (“Accused
`
`Instrumentalities”) that infringe the Patents-in Suit.
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`COUNT I
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`(Infringement of U.S. Patent No. 9,885,782)
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`15. Plaintiff incorporates the above paragraphs by reference.
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`16. Samsung has been on notice of the ’782 Patent at least as early as the date it received service of this
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`Original Complaint.
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`17. Upon information and belief, Samsung has directly infringed and continues to directly infringe at
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`least Claims 1, 2 and 7 of the ’782 Patent by making, using, importing, selling, and/or, offering for
`
`sale the Accused Instrumentalities.
`
`18. Samsung, with knowledge of the ’782 Patent, also infringes at least Claims 1, 2 and 7 of the ’782
`
`Patent by inducing others to infringe the ’782 Patent. In particular, Samsung intends to induce its
`
`customers to infringe the ’782 Patent by encouraging its customers to use the Accused
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`Instrumentalities in a manner that results in infringement.
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`19. Samsung also induces others, including its customers, to infringe at least Claims 1, 2 and 7 of the
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`’782 Patent by providing technical support for the use of the Accused Instrumentalities.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 5
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 6 of 27
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`20. Upon information and belief, at all times Samsung owns and controls the operation of the Accused
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`Instrumentalities in accordance with an end user license agreement.
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`21. By way of example, the Accused Instrumentalities infringe Claim 1 of the ’782 Patent by use of a
`
`global positioning device, wherein the global positioning device determines a location of the
`
`apparatus or a location of a vehicle. Samsung’s “Galaxy S10” is a representative example of the
`
`Accused Instrumentalities and is a mobile device (apparatus). See Figure 1 below, which is a
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`screenshot from Samsung’s website showing a picture of the Galaxy S10.
`
`
`
`
`Figure 11 - Samsung’s Galaxy S10
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`22. The Galaxy S10 uses a global positioning device, wherein the global positioning device determines a
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`location of the apparatus or a location of a vehicle.
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`23. See Figure 2 below, which is a screenshot from Samsung’s website indicating the Galaxy S10 utilizes
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`GPS location technology. A GPS device is necessarily required to utilize GPS location technology.
`
`
`1 https://www.samsung.com/us/mobile/phones/galaxy-s/galaxy-s10-plus-512gb-unlocked-sm-g975uckexaa/#specs - 9/14/19
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 6
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 7 of 27
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`Further, it is well known that GPS location technology determines a location of the apparatus on which
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`the GPS device is installed or located.
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`
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`
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`Figure 22 - Galaxy S10 Specs
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`
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`24. See also Figure 3 below, which is an excerpt from the Galaxy S10 User’s Manual, indicating that the
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`Galaxy S10 is loaded with the Google Maps application.
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`2 https://www.samsung.com/us/mobile/phones/galaxy-s/galaxy-s10-plus-512gb-unlocked-sm-g975uckexaa/#specs - 9/14/19
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 7
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 8 of 27
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`Apps
`
`Maps
`Get directions and other location-based information. You must enable location
`services to use Google Maps. For more information, see Location on page 134.
`
`Visit support.google.com/maps to learn more.
`
`Photos
`Store and back up your photos and videos automatically to your Google Account
`with Google Photos™.
`
`Visit support.google.com/photos to learn more.
`
`Play Movies & TV
`Watch movies and TV shows purchased from Google Play. You can also view
`videos saved on your device.
`
`Visit play.google.com/store/movies to learn more.
`
`Play Music
`Play music and audio files on your device.
`
`Visit support.google.com/music to learn more.
`
`Play Store
`Find new apps, movies and TV shows, music, books, magazines, and games in
`the Google Play™ store.
`
`Visit support.google.com/play to learn more.
`
`YouTube
`Watch and upload YouTube™ videos right from your device.
`
`Visit support.google.com/youtube to learn more.
`
`
`Figure 33 - Page 96 of the Galaxy S10 User’s Manual
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`97
`
`
`
`25. See also Figure 4 below, which is a screenshot from Google’s website showing a mock up of the
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`navigation display for Google Maps. The blue arrow indicates the current location of the device.
`
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`3 Samsung Galaxy S10e|S10|S10+ User Manual – page 96
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 8
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 9 of 27
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`
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`
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`Figure 44 - Google Maps navigation display
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`26. The Galaxy S10 uses a processing device, wherein the processing device processes information
`regarding the location of the apparatus or the location of the vehicle and information regarding a
`destination, wherein the processing device determines or identifies a travel route to the destination on
`or along a road, a roadway, a highway, a parkway or an expressway.
`27. See Figure 5 below, which is a screenshot of Samsung’s website explaining that “A more powerful
`processor and up to 12 GB of RAM means better performance with less energy.”
`
`Figure 55 - Galaxy S10 processor
`
`
`
`
`4 https://www.google.com/maps/about/#!#jump-link - 9/14/19
`5 https://www.samsung.com/us/mobile/galaxy-s10/performance/?fromHL=true - 9/14/19
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 9
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 10 of 27
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`28. The processing device used in the Galaxy S10 is necessarily used to process the information regarding
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`the location of the apparatus or vehicle and the destination, as well as to calculate the travel route to
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`the destination using the Google Maps application that is included with the Galaxy S10.
`
`29. See also Figure 4, reproduced below, which is a screenshot from Google’s website showing a mock
`
`up of the navigation display for Google Maps, which is included with the Galaxy S10. The blue arrow
`
`indicates the current location of the device and the blue line identifies the route to the destination along
`
`a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM”
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`indicates the distance to the destination in miles and estimated time of arrival at the destination.
`
`
`
`Figure 4 - Google Maps navigation display
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`
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`30. The Galaxy S10 uses a display device or a speaker, wherein the display device displays information
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`regarding the travel route or the speaker provides audio information regarding the travel route.
`
`31. See Figure 1, reproduced below, showing the display of the Galaxy S10.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 10
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 11 of 27
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`Figure 1 - Samsung’s Galaxy S10
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`
`
`32. See also Figure 4, reproduced below, which is a screenshot from Google’s website showing a mock
`
`up of the navigation display for Google Maps, which is included with the Galaxy S10. The blue arrow
`
`indicates the current location of the device and the blue line identifies the route to the destination along
`
`a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM”
`
`indicates the distance to the destination in miles and estimated time of arrival at the destination.
`
`Figure 4 - Google Maps navigation display
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 11
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 12 of 27
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`33. The Galaxy S10 uses a receiver, wherein the receiver receives traffic information or information
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`regarding a traffic condition.
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`34. See Figure 6 below, which is a screenshot from Google’s website showing a mock up of the navigation
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`display for Google Maps, which is included with the Galaxy S10. Google Maps is described as
`
`providing “Real-time traffic updates” and the mock up of the navigation display shows traffic
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`information being displayed at the bottom of the device display. The device running the Google Maps
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`application, such as the Galaxy S10, must necessarily include a receiver for receiving real-time traffic
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`information.
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`Figure 66 - Google Maps navigation display
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`
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`35. The Galaxy S10 provides the traffic information or the information regarding a traffic condition via
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`the display device or via the speaker.
`
`36. See Figure 1, reproduced below, showing the display of the Galaxy S10.
`
`
`
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`6 https://www.google.com/maps/about/#!#jump-link - 9/14/19
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 13 of 27
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`Figure 1 - Samsung’s Galaxy S10
`
`
`
`
`37. See also Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up
`
`of the navigation display for Google Maps, which is included with the Galaxy S10. Google Maps is
`
`described as providing “Real-time traffic updates” and the mock up of the navigation display shows
`
`traffic information being displayed at the bottom of the device display.
`
`Figure 6 - Google Maps navigation display
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 13
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 14 of 27
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`38. By way of another example, the Accused Instrumentalities infringe Claim 7 of the ’782 Patent by use
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`of an apparatus that “receives maintenance information associated with the travel route or maintenance
`
`information associated with a second travel route to the destination, and further wherein the apparatus
`
`provides the maintenance information associated with the travel route or the maintenance information
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`associated with the second travel route via the display device or the speaker.”
`
`39. See Figure 7 below, which is a screenshot from Google’s website explaining the meaning of various
`
`visual symbols used in the Google Maps application. The visual symbols include symbols indication
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`“road closures” and “construction,” both of which can be considered “maintenance information.”
`
`Figure 7 also indicates that “[f]or road closures, you’ll find a dotted red line where the road is closed.”
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`These symbols are visually displayed on the map that is displayed on the display device of the
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`Accused Instrumentalities.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 14
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 15 of 27
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`Figure 77 - Visual Symbols in the Google Maps Application
`
`
`
`
`
` (Infringement of U.S. Patent No. 9,075,136)
`
`40. Plaintiff incorporates the above paragraphs by reference.
`
`41. Samsung has been on notice of the ’136 Patent at least as early as the date it received service of
`
`this Original Complaint.
`
`42. Upon information and belief, Samsung has infringed and continues to infringe at least Claims 55,
`
`56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by making,
`
`using, importing, selling, and/or, offering for sale the Accused Instrumentalities.
`
`7 https://support.google.com/maps/answer/3092439?hl=en&ref_topic=3093390 – 2/5/20
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 15
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 16 of 27
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`43. Samsung, with knowledge of the ’136 Patent, infringes at least Claims 55, 56, 61, 66, 69-71, 76,
`
`79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by inducing others to infringe at least
`
`Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent. In
`
`particular, Samsung intends to induce its customers to infringe at least Claims 55, 56, 61, 66, 69-
`
`71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by encouraging its customers
`
`to use the Accused Instrumentalities in a manner that results in infringement.
`
`44. Samsung also induces others, including its customers, to infringe at least Claims 55, 56, 61, 66,
`
`69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by providing technical
`
`support for the use of the Accused Instrumentalities.
`
`45. Upon information and belief, at all times Samsung owns and controls the operation of the
`
`Accused Instrumentalities in accordance with an end user license agreement.
`
`46. By way of example, the Accused Instrumentalities infringe Claim 55 of the ’136 Patent by use of
`
`a global positioning device, wherein the global positioning device determines a location of the
`
`apparatus or a location of a vehicle. Samsung’s “Galaxy S10” is a representative example of the
`
`Accused Instrumentalities and is a mobile device (apparatus). See Figure 1, reproduced below,
`
`which is a screenshot from Samsung’s website showing a picture of the Galaxy S10.
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 16
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 17 of 27
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`Figure 1 - Samsung’s Galaxy S10
`
`
`
`47. The Galaxy S10 uses a global positioning device, wherein the global positioning device determines a
`
`position or a location of a vehicle.
`
`48. See Figure 2, reproduced below, which is a screenshot from Samsung’s website indicating the Galaxy
`
`S10 utilizes GPS location technology. A GPS device is necessarily required to utilize GPS location
`
`technology. Further, it is well known that GPS location technology determines a location of the apparatus
`
`on which the GPS device is installed or located.
`
`Figure 2 - Galaxy S10 Specs
`
`
`
`49. See also Figure 3, reproduced below, which is an excerpt from the Galaxy S10 User’s Manual,
`
`indicating that the Galaxy S10 is loaded with the Google Maps application.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 17
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 18 of 27
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`Apps
`
`Maps
`Get directions and other location-based information. You must enable location
`services to use Google Maps. For more information, see Location on page 134.
`
`Visit support.google.com/maps to learn more.
`
`Photos
`Store and back up your photos and videos automatically to your Google Account
`with Google Photos™.
`
`Visit support.google.com/photos to learn more.
`
`Play Movies & TV
`Watch movies and TV shows purchased from Google Play. You can also view
`videos saved on your device.
`
`Visit play.google.com/store/movies to learn more.
`
`Play Music
`Play music and audio files on your device.
`
`Visit support.google.com/music to learn more.
`
`Play Store
`Find new apps, movies and TV shows, music, books, magazines, and games in
`the Google Play™ store.
`
`Visit support.google.com/play to learn more.
`
`YouTube
`Watch and upload YouTube™ videos right from your device.
`
`Visit support.google.com/youtube to learn more.
`
`97
`
`
`
`Figure 3 - Page 96 of the Galaxy S10 User’s Manual
`
`
`
`50. See also Figure 4 below, which is a screenshot from Google’s website showing a mock up of the
`
`navigation display for Google Maps. The blue arrow indicates the current location of the device.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 18
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 19 of 27
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`Figure 4 - Google Maps navigation display
`
`
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`51. The Galaxy S10 uses a processing device, wherein the processing device processes information
`
`regarding the position or the location of the vehicle and information regarding a destination to which
`
`the vehicle can travel on at least one of a road, a roadway, a highway, a parkway, and an expressway,
`
`and further wherein the processing device determines or identifies a travel route to the destination.
`
`52. See Figure 5, reproduced below, which is a screenshot of Samsung’s website explaining that “A more
`
`powerful processor and up to 12 GB of RAM means better performance with less energy.”
`
`Figure 5 - Galaxy S10 processor
`
`
`
`53. The processing device used in the Galaxy S10 is necessarily used to process the information regarding
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 19
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 20 of 27
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`the location of the apparatus or vehicle and the destination, as well as to calculate the travel route to
`
`the destination using the Google Maps application that is included with the Galaxy S10.
`
`54. See also Figure 4, reproduced below, which is a screenshot from Google’s website showing a mock
`
`up of the navigation display for Google Maps, which is included with the Galaxy S10. The blue arrow
`
`indicates the current location of the device and the blue line identifies the route to the destination along
`
`a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM”
`
`indicates the distance to the destination in miles and estimated time of arrival at the destination.
`
`Figure 4 - Google Maps navigation display
`
`
`
`55. The Galaxy S10 uses a display device or a speaker, wherein the display device displays information
`
`regarding the travel route or the speaker provides audio information regarding the travel route.
`
`56. See Figure 1, reproduced below, showing the display of the Galaxy S10.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 20
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 21 of 27
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`Figure 1 - Samsung’s Galaxy S10
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`57. See also Figure 4, reproduced below, which is a screenshot from Google’s website showing a mock
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`up of the navigation display for Google Maps, which is included with the Galaxy S10. The blue arrow
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`indicates the current location of the device and the blue line identifies the route to the destination along
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`a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi • 12:42 PM”
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`indicates the distance to the destination in miles and estimated time of arrival at the destination.
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`Figure 4 - Google Maps navigation display
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 22 of 27
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`58. The Galaxy S10 uses a receiver, wherein the receiver receives traffic information or information
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`regarding a traffic condition, wherein the traffic information or the information regarding a traffic
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`condition is transmitted from a computer, a transmitter, or a device, located at a location remote from
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`the vehicle.
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`59. See Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up of
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`the navigation display for Google Maps, which is included with the Galaxy S10. Google Maps is
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`described as providing “Real-time traffic updates” and the mock up of the navigation display shows
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`traffic information being displayed at the bottom of the device display. The device running the Google
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`Maps application, such as the Galaxy S10, must necessarily include a receiver for receiving real-time
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`traffic information.
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`Figure 6 - Google Maps navigation display
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`60. The Galaxy S10 provides the traffic information or the information regarding a traffic condition at the
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`vehicle via the display device or via the speaker.
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 23 of 27
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`61. See Figure 1, reproduced below, showing the display of the Galaxy S10.
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`Figure 1 - Samsung’s Galaxy S10
`62. See also Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up
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`of the navigation display for Google Maps, which is included with the Galaxy S10. Google Maps is
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`described as providing “Real-time traffic updates” and the mock up of the navigation display shows
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`traffic information being displayed at the bottom of the device display.
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`Figure 6 - Google Maps navigation display
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 24 of 27
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`63. By way of another example, the Accused Instrumentalities infringe Claims 61 of the ’136 Patent
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`by use of an apparatus that “receives maintenance information associated with the travel route or
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`maintenance information associated with a second travel route to the destination, and further
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`wherein the apparatus provides the maintenance information associated with the travel route or
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`the maintenance information associated with the second travel route.”
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`64. See Figure 7, reproduced below, which is a screenshot from Google’s website explaining the
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`meaning of various visual symbols used in the Google Maps application. The visual symbols
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`include symbols indication “road closures” and “construction,” both of which can be considered
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`“maintenance information.” Figure 7 also indicates that “[f]or road closures, you’ll find a dotted
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`red line where the road is closed.” These symbols are visually displayed on the map that is
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`displayed on the display device of the Accused Instrumentalities.
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 25 of 27
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`Figure 78 - Visual Symbols in the Google Maps Application
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`8 https://support.google.com/maps/answer/3092439?hl=en&ref_topic=3093390 – 2/5/20
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 26 of 27
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`PRAYER FOR RELIEF
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`WHEREFORE, NavBlazer respectfully requests the Court enter judgment against
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`Defendant:
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`Declaring that Samsung has infringed each of the Patents-in-Suit;
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`Awarding NavBlazer its damages suffered as a result of Apple’s infringement of the Patents-in-
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`Suit;
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`Awarding NavBlazer its costs, attorneys’ fees, expenses, and interest;
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`Awarding NavBlazer ongoing post-trial royalties; and
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`Granting NavBlazer such further relief as the Court finds appropriate.
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`NavBlazer demands trial by jury, under Fed. R. Civ. P. 38.
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`JURY DEMAND
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`1.
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`2.
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`3.
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`4.
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`5.
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`Case 6:20-cv-00089-ADA Document 1 Filed 02/05/20 Page 27 of 27
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`Dated: February 5, 2020
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`Respectfully Submitted
`/s/ Thomas Fasone III
`Thomas Fasone III
`Texas Bar No. 00785382
`tfasone@ghiplaw.com
`M. Scott Fuller
`Texas Bar No. 24036607
`sfuller@ghiplaw.com
`René A. Vazquez
`Pro Hac Vice Anticipated
`rvazquez@ghiplaw.com
`Randall T. Garteiser
`Pro Hac Vice Anticipated
`rgarteiser@ghiplaw.com
`Christopher A. Honea
`Pro Hac Vice Anticipated
`chonea@ghiplaw.com
`
`
`GARTEISER HONEA, PLLC
`119 W. Ferguson Street
`Tyler, Texas 75702
`Telephone: (903) 705-7420
`Facsimile: (888) 908-4400
`
`
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Ave, Suite 2000
`Austin, Texas 78701
`Tel/Fax: (512) 865-7950
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`ATTORNEYS FOR
`NAVBLAZER LLC
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 27
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