Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 1 of 25
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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-95
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`JURY TRIAL DEMANDED
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`NAVBLAZER, LLC,
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`
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`
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`Apple
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` v.
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`LG ELECTRONICS, INC., AND LG
`ELECTRONICS MOBILECOMM
`U.S.A., INC.,
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`
`
`
`Defendants
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`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 Defendants LG Electronics, Inc. and LG Electronics Mobilecomm U.S.A., Inc. (collectively,
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`“Defendants”) and alleges, upon information and belief, as follows:
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`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. Defendant LG Electronics, Inc. is a corporation organized and existing under the laws of Korea with
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`its principal place of business at LG Twin Towers, 128 Yeoui-daero, Yeongdungpo-gu, Seoul 150-
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`721, Republic of Korea. On information and belief, this Defendant may be served with process at its
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`principal place of business. Defendant LG Electronics, Inc. designs, makes, and sells many different
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`products throughout the world for consumer use, including wireless mobile communications devices.
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`

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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 2 of 25
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`Defendant LG Electronics, Inc. is a parent corporation of Defendant LG Electronics Mobilecomm
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`U.S.A., Inc.
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`3. Defendant LG Electronics Mobilecomm U.S.A., Inc. is a wholly-owned subsidiary of Defendant LG
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`Electronics, Inc. and is a Delaware corporation with regular and established places of business in
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`Texas at 9420 Research Blvd, Austin, Texas 78759; 21251-2155 Eagle Parkway, Fort Worth, Texas
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`76177; and 14901 Beach St, Fort Worth, TX 76177. Defendant LG Electronics Mobilecomm
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`U.S.A., Inc. is registered to do business in the State of Texas and has been since at least April 3,
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`1984. Defendant LG Electronics Mobilecomm U.S.A., Inc. may be served with process at its
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`registered agent for service of process at United States Corporation Company, 211 E. 7th Street,
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`Suite 620, Austin, Texas 78701.
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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 Defendants. Defendants have continuous and systematic
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`business contacts with the state of Texas. Defendants, directly or through subsidiaries or
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`intermediaries (including distributors, retailers, and others), conduct business extensively throughout
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`Texas, by shipping, distributing, making, using, offering for sale, selling, and advertising (including
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`the provision of interactive web pages) their products and services in the state of Texas and the
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`Western District of Texas. Defendants, directly and through subsidiaries or intermediaries (including
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`distributors, retailers, and others), have 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. Defendants have offered and sold and
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 2
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 3 of 25
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`continue to offer and sell these infringing products and services in this district, including at physical
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`stores located within this district. Defendants and their customers also commit additional acts of
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`direct infringement in this district with respect to each asserted patent through their infringing use of
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`the accused devices, including Defendants’ servers, in this district, including when Defendants and
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`their customers put the accused devices into service and receive a benefit, and Defendants are liable
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`for these additional acts of direct infringement and indirect infringement in this district. Defendants
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`have committed acts of infringement, both direct and indirect, in this district with respect to each
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`asserted patent. More specifically, Defendant LG Electronics U.S.A., Inc. distributes wireless mobile
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`communication devices to customers throughout the United States. Further, upon information and
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`belief, Defendant LG Electronics Mobilecomm U.S.A., Inc. has regular and established places of
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`business in this district at 9420 Research Blvd, Austin, Texas 78759; 21251-2155 Eagle Parkway,
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`Fort Worth, Texas 76177; and 14901 Beach St, Fort Worth, TX 76177. Moreover, upon information
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`and belief, Defendant LG Electronics Mobilecomm U.S.A., Inc.
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`imports such wireless
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`communication devices from its parent corporation Defendant LG Electronics, Inc. in South Korea,
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`where they are designed and manufactured.
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`
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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
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`INFORMATION APPARATUS AND
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`METHOD” (hereinafter collectively referred to as “the Patents-in-Suit”).
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`8. The patent application that issued as the ’782 Patent is a continuation application of U.S. Patent
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`Application Ser. No. 09/259,957, filed March 1, 1999, and entitled “VEHICLE OPERATOR
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`AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD”, now U.S. Pat. No.
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`9,075,136. U.S. Patent Application Ser. No. 09/259,957, filed March 1, 1999, claims priority to U.S.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 3
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 4 of 25
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`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.”
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`9. The Patents-in-Suit are valid, enforceable, and were duly issued in full compliance with Title 35 of
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`the United States Code.
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`10. The inventions described and claimed in the Patents-in-Suit were invented by Raymond Anthony
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`Joao.
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`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
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`’782 Patent were eligible under 35 USC §101 in view of the United States Supreme Court’s decision
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`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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`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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`DEFENDANT’S PRODUCTS
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`14. Upon information and belief, Defendant sells, advertises, offers for sale, uses, or otherwise provides
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`mobile devices that utilize the Android operating system including, but not limited to, the “LG G8X
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`ThinQ Dual Screen,” “LG G8X ThinQ,” “LG V50 ThinQ 5G,” “LG V40 ThinQ,” “LG V35 ThinQ,”
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`“LG V30 ThinQ,” “LG V30,” “LG V20,” “LG G7 ThinQ,” “LG Neon Plus,” “LG Aristo 4+,” “LG
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 4
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 5 of 25
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`Aristo 3+,” “LG Aristo 3,” “LG Tribute Royal,” “LG Tribute Empire,” “LG Stylo 5+,” “LG Stylo
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`5,” “LG Stylo 4,” “LG Stylo 4 Plus,” “LG Stylo 3 Plus Titanium,” “LG Stylo 3 LTE,” “LG K40,”
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`“LG K30,” “LG K20,” “LG Journey LTE,” “LG Rebel,” “LG Rebel 4 LTE,” “LG Xpression Plus
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`2,” “LG Xpression Plus,” “LG Harmony 3,” “LG Arena 2,” “LG Prime 2,” “LG Escape Plus,” “LG
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`Solo LTE,” “LG K8S,” “LG G7 fit,” “LG Q7+,” “LG Premier Pro LTE,” “LG phoenix 4,” “LG
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`Risio 3,” “LG Fortune 2,” “LG K8,” “LG K8+,” “LG X charge,” “LG G6,” “LG G6+,” “LG G5,”
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`and “LG X venture” series of mobile devices (“Accused Instrumentalities”) that infringe the Patents-
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`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. Defendant 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, Defendant 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
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`sale the Accused Instrumentalities.
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`18. Defendant, with knowledge of the ’782 Patent, also infringes at least Claims 1, 2 and 7 of the ’782
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`Patent by inducing others to infringe the ’782 Patent. In particular, Defendant intends to induce its
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`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. Defendant 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-00095 Document 1 Filed 02/07/20 Page 6 of 25
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`20. Upon information and belief, at all times Defendant 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
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`global positioning device, wherein the global positioning device determines a location of the
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`apparatus or a location of a vehicle. Defendant’s “LG G8 ThinQ” is a representative example of the
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`Accused Instrumentalities and is a mobile device (apparatus). See Figure 1 below, which is an
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`excerpt from the LG G8 ThinQ Specification Sheet, attached herein as Exhibit A, showing a picture
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`of the LG G8 ThinQ.
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`
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`Figure 11 - Defendant’s LG G8 ThinQ
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`
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`22. The LG G8 ThinQ 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 an excerpt from the LG G8 ThinQ Specification Sheet indicating the LG
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`1 LG G8 ThinQ Specification Sheet – page 1
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 6
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 7 of 25
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`G8 ThinQ utilizes A-GPS and S-GPS “for Enhanced Location Accuracy.” A GPS device is necessarily
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`required to utilize A-GPS and S-GPS. Further, it is well known that GPS location technology determines
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`a location of the apparatus on which the GPS device is installed or located.
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`Figure 22 - LG G8 ThinQ Specs
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`
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`24. See also Figure 3 below, which is an excerpt from the LG G8 ThinQ User’s Manual, attached herein as
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`Exhibit B, indicating that the LG G8 ThinQ is loaded with the Google Maps application.
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`2 LG G8 ThinQ Specification Sheet – page 4
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 7
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 8 of 25
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`Figure 33 - Google Maps Application on the LG G8 ThinQ
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`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 LG G8 ThinQ User Manual – page 120
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 8
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 9 of 25
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`Figure 44 - Google Maps navigation display
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`26. The LG G8 ThinQ 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 an excerpt from the LG G8 ThinQ Specification Sheet indicating that it
`utilizes the Qualcomm Snapdragon 855 Octo-core processor.
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`Figure 55 - LG G8 ThinQ processor
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`
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`28. The processing device used in the LG G8 ThinQ is necessarily used to process the information
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`regarding the location of the apparatus or vehicle and the destination, as well as to calculate the travel
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`4 https://www.google.com/maps/about/#!#jump-link - 9/14/19
`5 LG G8 ThinQ Specification Sheet – page 4
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 9
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 10 of 25
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`route to the destination using the Google Maps application that is included with the LG G8 ThinQ.
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`29. 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 LG G8 ThinQ. The blue
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`arrow indicates the current location of the device and the blue line identifies the route to the
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`destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi
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`• 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the
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`destination.
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`
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`Figure 4 - Google Maps navigation display
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`
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`30. The LG G8 ThinQ 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.
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`31. See Figure 1, reproduced below, showing the display of the LG G8 ThinQ.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 10
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 11 of 25
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`Figure 1 - Defendant’s LG G8 ThinQ
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`
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`32. 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 LG G8 ThinQ. The blue
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`arrow indicates the current location of the device and the blue line identifies the route to the
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`destination along a road. Further, “12min” indicates the time remaining to the destination, and “5.1 mi
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`• 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the
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`destination.
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`Figure 4 - Google Maps navigation display
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 11
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 12 of 25
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`33. The LG G8 ThinQ 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 LG G8 ThinQ. Google Maps is described as
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`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 LG G8 ThinQ, must necessarily include a receiver for receiving real-time
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`traffic information.
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`Figure 66 - Google Maps navigation display
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`
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`35. The LG G8 ThinQ provides the traffic information or the information regarding a traffic condition via
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`the display device or via the speaker.
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`36. See Figure 1, reproduced below, showing the display of the LG G8 ThinQ.
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`
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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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`PAGE | 12
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 13 of 25
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`Figure 1 - Defendant’s LG G8 ThinQ
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`
`
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`37. 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 LG G8 ThinQ. 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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`
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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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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 13
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 14 of 25
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`of an apparatus that “receives maintenance information associated with the travel route or maintenance
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`information associated with a second travel route to the destination, and further wherein the apparatus
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`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.”
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`39. See Figure 7 below, which is a screenshot from Google’s website explaining the meaning of various
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`visual symbols used in the Google Maps application, which is included in the LG G8 ThinQ. The
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`visual symbols include symbols indication “road closures” and “construction,” both of which can be
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`considered “maintenance information.” Figure 7 also indicates that “[f]or road closures, you’ll find a
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`dotted 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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`Figure 77 - Visual Symbols in the Google Maps Application
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`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 | 14
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 15 of 25
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` (Infringement of U.S. Patent No. 9,075,136)
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`40. Plaintiff incorporates the above paragraphs by reference.
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`41. Defendant has been on notice of the ’136 Patent at least as early as the date it received service of
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`this Original Complaint.
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`42. Upon information and belief, Defendant has infringed and continues to infringe at least Claims
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`55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by making,
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`using, importing, selling, and/or, offering for sale the Accused Instrumentalities.
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`43. Defendant, with knowledge of the ’136 Patent, infringes at least Claims 55, 56, 61, 66, 69-71, 76,
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`79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by inducing others to infringe at least
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`Claims 55, 56, 61, 66, 69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent. In
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`particular, Defendant intends to induce its customers to infringe at least Claims 55, 56, 61, 66,
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`69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by encouraging its
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`customers to use the Accused Instrumentalities in a manner that results in infringement.
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`44. Defendant also induces others, including its customers, to infringe at least Claims 55, 56, 61, 66,
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`69-71, 76, 79, 82, 85, 86, 88, 89, 91, 94, 97 and 98 of the ’136 Patent by providing technical
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`support for the use of the Accused Instrumentalities.
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`45. Upon information and belief, at all times Defendant owns and controls the operation of the
`
`Accused Instrumentalities in accordance with an end user license agreement.
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`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. Defendant’s “LG G8 ThinQ” is a representative example of
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`the Accused Instrumentalities and is a mobile device (apparatus). See Figure 1, reproduced
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 15
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 16 of 25
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`below, which is an excerpt from the LG G8 ThinQ Specification Sheet, attached herein as
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`Exhibit A, showing a picture of the LG G8 ThinQ.
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`Figure 1 - Defendant’s LG G8 ThinQ
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`
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`47. The LG G8 ThinQ uses a global positioning device, wherein the global positioning device determines a
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`position or a location of a vehicle.
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`48. See Figure 2, reproduced below, which is an excerpt from the LG G8 ThinQ Specification Sheet
`
`indicating the LG G8 ThinQ utilizes A-GPS and S-GPS “for Enhanced Location Accuracy.” A GPS
`
`device is necessarily required to utilize A-GPS and S-GPS. Further, it is well known that GPS location
`
`technology determines a location of the apparatus on which the GPS device is installed or located.
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`Figure 2 - LG G8 ThinQ Specs
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 16
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 17 of 25
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`49. See also Figure 3, reproduced below, which is an excerpt from the LG G8 ThinQ User’s Manual,
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`attached herein as Exhibit B, indicating that the LG G8 ThinQ is loaded with the Google Maps
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`application.
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`Figure 3 - Google Maps Application on the LG G8 ThinQ
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`
`
`
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`50. See also Figure 4, 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. The blue arrow indicates the current location of the device.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 17
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 18 of 25
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`Figure 4 - Google Maps navigation display
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`
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`51. The LG G8 ThinQ uses a processing device, wherein the processing device processes information
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`regarding the position or the location of the vehicle and information regarding a destination to which
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`the vehicle can travel on at least one of a road, a roadway, a highway, a parkway, and an expressway,
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`and further wherein the processing device determines or identifies a travel route to the destination.
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`52. See Figure 5, reproduced below, which is an excerpt from the LG G8 ThinQ Specification Sheet
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`indicating that it utilizes the Qualcomm Snapdragon 855 Octo-core processor.
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`
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`Figure 5 - LG G8 ThinQ processor
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`
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`53. The processing device used in the LG G8 ThinQ is necessarily used to process the information
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`regarding the location of the apparatus or vehicle and the destination, as well as to calculate the travel
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 18
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 19 of 25
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`route to the destination using the Google Maps application that is included with the LG G8 ThinQ.
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`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 LG G8 ThinQ. 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
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`• 12:42 PM” indicates the distance to the destination in miles and estimated time of arrival at the
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`destination.
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`Figure 4 - Google Maps navigation display
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`
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`55. The LG G8 ThinQ 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.
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`56. See Figure 1, reproduced below, showing the display of the LG G8 ThinQ.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 19
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 20 of 25
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`Figure 1 - Defendant’s LG G8 ThinQ
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`
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`57. 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 LG G8 ThinQ. 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
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`destination.
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`Figure 4 - Google Maps navigation display
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`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 20
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 21 of 25
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`
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`58. The LG G8 ThinQ 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 LG G8 ThinQ. 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 LG G8 ThinQ, must necessarily include a receiver for receiving real-
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`time traffic information.
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`Figure 6 - Google Maps navigation display
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`
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`60. The LG G8 ThinQ provides the traffic information or the information regarding a traffic condition at
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`the vehicle via the display device or via the speaker.
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 22 of 25
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`61. See Figure 1, reproduced below, showing the display of the LG G8 ThinQ.
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`
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`Figure 1 - Defendant’s LG G8 ThinQ
`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 LG G8 ThinQ. Google Maps is
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`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.
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`Figure 6 - Google Maps navigation display
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 23 of 25
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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 below, which is a screenshot from Google’s website explaining the meaning of
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`various visual symbols used in the Google Maps application. The visual symbols include
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`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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`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-00095 Document 1 Filed 02/07/20 Page 24 of 25
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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 Defendant 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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`
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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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`Dated: February 7, 2020
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`Respectfully Submitted
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`/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
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`Case 6:20-cv-00095 Document 1 Filed 02/07/20 Page 25 of 25
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`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
`
`ATTORNEYS FOR
`NAVBLAZER LLC
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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