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Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 1 of 25
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`
`
`
`
`
`
`
`NAVBLAZER, LLC,
`
`
`
` v.
`
`MOTOROLA MOBILITY LLC,
`
`
`
`Case No. 6:20-cv-100
`
`JURY TRIAL DEMANDED
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`NavBlazer, LLC (“NavBlazer”) hereby files this Original Complaint for Patent Infringement
`
`against Motorola Mobility LLC (“Motorola”), and alleges, on information and belief, as follows:
`
`THE PARTIES
`
`1. NavBlazer is a limited liability company organized and existing under the laws of the State of
`
`Florida with its principal place of business at 600 S. Dixie Highway, Suite 605, West Palm Beach,
`
`Florida 33401.
`
`2. On information and belief, Motorola Mobility LLC is a Delaware limited liability company with its
`
`principal office located at 222 W. Merchandise Mart Plaza, Suite 1800, Chicago, Illinois 60654.
`
`3. This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331, 1332, 1338, and
`
`JURISDICTION AND VENUE
`
`1367.
`
`4. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 and 1400(b). Motorola is registered to
`
`do business in Texas, and upon information and belief, Motorola has transacted business in this
`
`District and has committed acts of direct and indirect infringement in this District by, among other
`
`things, importing, offering to sell, and selling products that infringe the asserted patents. On
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 1
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`

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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 2 of 25
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`information and belief, Motorola has regular and established places of business in the District,
`
`including service centers in Austin, Waco, and San Antonio, Texas. On information and belief, these
`
`service centers are dedicated to the service and support of Motorola products, including the Accused
`
`Products1 On information and belief, Motorola also employs employees and advertises jobs in this
`
`District.2
`
`5. This Court has personal jurisdiction over Motorola. Motorola has continuous and systematic
`
`business contacts with the state of Texas. Motorola, directly or through subsidiaries or intermediaries
`
`(including distributors, retailers, and others), conducts its business extensively throughout Texas, by
`
`shipping, distributing, making, using, offering for sale, selling, and advertising (including the
`
`provision of interactive web pages) its products and services in the state of Texas and the Western
`
`District of Texas. Motorola, directly and through subsidiaries or intermediaries (including
`
`distributors, retailers, and others), has purposefully and voluntarily placed infringing products and
`
`services into this district and into the stream of commerce with the intention and expectation that
`
`they will be purchased and used by consumers in this district. Motorola has offered and sold and
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`continues to offer and sell these infringing products and services in this District, including at
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`physical Motorola stores located within this district. Motorola and its customers also commit
`
`additional acts of direct infringement in this district with respect to each asserted patent through their
`
`infringing use of the accused devices, including Motorola’s servers, in this district, including when
`
`Motorola and its customers put the accused devices into service and receive a benefit, and Motorola
`
`is liable for these additional acts of direct infringement and indirect infringement in this district.
`
`
`1 See, e.g., https://www.service-center-locator.com/motorola/texas/motorola-austin-texas.html.
`
`2 See, e.g., https://lenovocareers.com/areas-mobile.html. Motorola Mobility LLC is a subsidiary of Lenovo Group
`Ltd.
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 2
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`

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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 3 of 25
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`Motorola has committed acts of infringement, both direct and indirect, in this district with respect to
`
`each asserted patent and has a regular and established place of business in this judicial district.
`
`
`
`U.S. PATENT NOS. 9,075,136 AND 9,885,782
`
`6. NavBlazer is the owner, by assignment, of U.S. Patent No. 9,075,136 and 9,885,782, each entitled
`
`“VEHICLE OPERATOR AND/OR OCCUPANT
`
`INFORMATION APPARATUS AND
`
`METHOD” (hereinafter collectively referred to as “the Patents-in-Suit”).
`
`7. 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
`
`OPERATOR AND/OR OCCUPANT INFORMATION APPARATUS AND METHOD.”
`
`8. The Patents-in-Suit are valid, enforceable, and were duly issued in full compliance with Title 35 of
`
`the United States Code.
`
`9. The inventions described and claimed in the Patents-in-Suit were invented by Raymond Anthony
`
`Joao.
`
`10. The priority date of each of the Patents-in-Suit is at least as early as March 4, 1998.
`
`11. The Patents-in-Suit relate generally to an apparatus and method for providing a user with one or
`
`more possible travel routes to a destination, as well as additional information regarding the one or
`
`more possible travel routes, such as traffic conditions, road conditions, traffic flow, weather
`
`information and/or other useful information.
`
`12. 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
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 3
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`

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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 4 of 25
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`in Alice. The patent examiner found that the claims are in fact patent eligible under 35 USC §101
`
`because all pending claims are directed to patent-eligible subject matter, none of the pending claims
`
`are directed to an abstract idea and there would be no preemption of the abstract idea or the field of
`
`the abstract idea.
`
`
`
`
`
`MOTOROLA’S PRODUCTS
`
`13. Upon information and belief, Motorola sells, advertises, offers for sale, uses, or otherwise provides
`
`mobile devices that utilize the Android operating system including, but not limited to, the “Motorola
`
`Razr,” “Moto Z3,” “Moto Z4,” “Moto Z3 Play,” “Moto G Stylus,” “Moto G Power,” “Moto G6,”
`
`“Moto G6 Play,” “Moto G7,” “Moto E5,” “Moto E5 Play,” “Moto E6,” “Motorola One,” “Motorola
`
`One Hyper,” “Motorola One Action,” and “Motorola One Zoom” series of mobile devices
`
`(“Accused Instrumentalities”) that infringe the Patents-in Suit.
`
`COUNT I
`
`(Infringement of U.S. Patent No. 9,885,782)
`
`14. Plaintiff incorporates the above paragraphs by reference.
`
`15. Motorola has been on notice of the ’782 Patent at least as early as the date it received service of this
`
`Original Complaint.
`
`16. Upon information and belief, Motorola has directly infringed and continues to directly infringe at
`
`least Claims 1, 2 and 7 of the ’782 Patent by making, using, importing, selling, and/or, offering for
`
`sale the Accused Instrumentalities.
`
`17. Motorola, 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, Motorola intends to induce its
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 4
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`

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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 5 of 25
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`customers to infringe the ’782 Patent by encouraging its customers to use the Accused
`
`Instrumentalities in a manner that results in infringement.
`
`18. Motorola also induces others, including its customers, to infringe at least Claims 1, 2 and 7 of the
`
`’782 Patent by providing technical support for the use of the Accused Instrumentalities.
`
`19. Upon information and belief, at all times Motorola owns and controls the operation of the Accused
`
`Instrumentalities in accordance with an end user license agreement.
`
`20. 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. Motorola’s “Moto G7” is a representative example of the
`
`Accused Instrumentalities and is a mobile device (apparatus). See Figure 1 below, which is a
`
`screenshot from Motorola’s website, showing a picture of the Moto G7.
`
`
`
`Figure 13 - Motorola’s Moto G7
`
`
`
`
`3 https://www.motorola.com/us/products/moto-g-gen-7 - 2/10/20
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 5
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 6 of 25
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`21. The Moto G7 uses a global positioning device, wherein the global positioning device determines a
`
`location of the apparatus or a location of a vehicle.
`
`22. See Figure 2 below, which is a screenshot from Motorola’s website, indicating the Moto G7 utilizes
`
`GPS and A-GPS. A GPS device is necessarily required to utilize GPS and A-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.
`
`
`
`
`
`
`
`Figure 24 - Moto G7 Connectivity
`
`
`
`23. See also Figure 3 below, which is a screenshot from Motorola’s website indicating that the Moto G7 is
`
`bundled with the Android 9 Pie operating system.
`
`
`4 https://support.motorola.com/us/en/products/cell-phones/moto-g-family/moto-g7/documents/MS137727 - 2/10/20
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 6
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 7 of 25
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`Figure 35 - Moto G7 Specifications
`
`
`
`24. See also Figure 4 below, which is an excerpt from the Moto G7 User Guide, attached herein as Exhibit A,
`
`indicating that the Moto G7 is preloaded with the Google Maps application.
`
`
`
`Figure 46 - Google Maps Application on the Moto G7
`
`
`5 https://www.motorola.com/us/products/moto-g-gen-7 - 2/10/20
`6 Moto G7 User Guide – page 24
`
`
`
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 7
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 8 of 25
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`
`
`25. See also Figure 5 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.
`
`
`
`
`
`Figure 57 - Google Maps navigation display
`
`26. The Moto G7 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 3, reproduced below, which is a screenshot from Motorola’s website indicating that it
`utilizes the Qualcomm Snapdragon 632 processor.
`
`
`
`7 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 | 8
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 9 of 25
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`Figure 3 - Moto G7 processor
`
`
`
`28. The processing device used in the Moto G7 is necessarily used to process the information regarding
`
`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 Moto G7.
`
`29. See also Figure 5, 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 Moto G7. 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.
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 9
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 10 of 25
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`Figure 5 - Google Maps navigation display
`
`
`
`30. The Moto G7 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.
`
`31. See Figure 1, reproduced below, showing the display of the Moto G7.
`
`Figure 1 - Motorola’s Moto G7
`
`
`
`32. See also Figure 5, 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 Moto G7. The blue arrow
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 10
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 11 of 25
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`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 5 - Google Maps navigation display
`
`
`
`33. The Moto G7 uses a receiver, wherein the receiver receives traffic information or information
`
`regarding a traffic condition.
`
`34. See Figure 6 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 Moto G7. 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. The device running the Google Maps application, such
`
`as the Moto G7, must necessarily include a receiver for receiving real-time traffic information.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 11
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 12 of 25
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`Figure 68 - Google Maps navigation display
`
`
`
`35. The Moto G7 provides the traffic information or the information regarding a traffic condition via the
`
`display device or via the speaker.
`
`36. See Figure 1, reproduced below, showing the display of the Moto G7.
`
`
`
`Figure 1 - Motorola’s Moto G7
`
`
`
`
`8 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-00100-ADA Document 1 Filed 02/10/20 Page 13 of 25
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`
`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 Moto G7. 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
`
`
`
`38. By way of another example, the Accused Instrumentalities infringe Claim 7 of the ’782 Patent by use
`
`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
`
`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, which is included in the Moto G7. The visual
`
`symbols include symbols indication “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
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 13
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 14 of 25
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`dotted red line where the road is closed.” These symbols are visually displayed on the map that is
`
`displayed on the display device of the Accused Instrumentalities.
`
`Figure 79 - 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. Motorola 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, Motorola 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.
`
`
`9 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-00100-ADA Document 1 Filed 02/10/20 Page 15 of 25
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`43. Motorola, 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, Motorola 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. Motorola 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 Motorola 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. Motorola’s “Moto G7” is a representative example of the
`
`Accused Instrumentalities and is a mobile device (apparatus). See Figure 1, reproduced below,
`
`which is an excerpt from the Moto G7 Specification Sheet, attached herein as Exhibit A,
`
`showing a picture of the Moto G7.
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 15
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 16 of 25
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`Figure 1 - Motorola’s Moto G7
`
`
`
`47. The Moto G7 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 Motorola’s website, indicating the Moto G7
`
`utilizes GPS and A-GPS. A GPS device is necessarily required to utilize GPS and A-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.
`
`Figure 2 - Moto G7 Specs
`
`
`
`49. See also Figure 3, reproduced below, which is a screenshot from Motorola’s website indicating that the
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 16
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 17 of 25
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`Moto G7 is bundled with the Android 9 Pie operating system.
`
`Figure 3 - Moto G7 Specifications
`
`
`
`50. See also Figure 4, reproduced below, which is an excerpt from the Moto G7 User’s Manual, attached
`
`herein as Exhibit A, indicating that the Moto G7 is preloaded with the Google Maps application.
`
`
`
`Figure 4 - Google Maps Application on the Moto G7
`
`
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 17
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 18 of 25
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`51. See also Figure 5, reproduced 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.
`
`Figure 5 - Google Maps navigation display
`
`
`
`52. The Moto G7 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.
`
`53. See Figure 3, reproduced below, which is a screenshot from Motorola’s website indicating that it
`
`utilizes the Qualcomm Snapdragon 632 processor.
`
`
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`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 18
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 19 of 25
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`Figure 5 - Moto G7 processor
`
`
`
`54. The processing device used in the Moto G7 is necessarily used to process the information regarding
`
`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 Moto G7.
`
`55. See also Figure 5, 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 Moto G7. 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.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 19
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 20 of 25
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`Figure 5 - Google Maps navigation display
`
`56. The Moto G7 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.
`
`57. See Figure 1, reproduced below, showing the display of the Moto G7.
`
`Figure 1 - Motorola’s Moto G7
`
`
`
`58. See also Figure 5, 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 Moto G7. 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.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 20
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 21 of 25
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`Figure 5 - Google Maps navigation display
`
`
`
`
`
`59. The Moto G7 uses a receiver, wherein the receiver receives traffic information or information
`
`regarding a traffic condition, wherein the traffic information or the information regarding a traffic
`
`condition is transmitted from a computer, a transmitter, or a device, located at a location remote from
`
`the vehicle.
`
`60. See 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 Moto G7. 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. The device running the Google
`
`Maps application, such as the Moto G7, must necessarily include a receiver for receiving real-time
`
`traffic information.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 21
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 22 of 25
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`Figure 6 - Google Maps navigation display
`
`
`
`61. The Moto G7 provides the traffic information or the information regarding a traffic condition at the
`
`vehicle via the display device or via the speaker.
`
`62. See Figure 1, reproduced below, showing the display of the Moto G7.
`
`Figure 1 - Motorola’s Moto G7
`63. See also Figure 6, reproduced below, which is a screenshot from Google’s website showing a mock up
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`PAGE | 22
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`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 23 of 25
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`of the navigation display for Google Maps, which is included with the Moto G7. 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
`
`
`
`64. By way of another example, the Accused Instrumentalities infringe Claims 61 of the ’136 Patent
`
`by use 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 associated with the second travel route.”
`
`65. See Figure 7, reproduced 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 “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.” These symbols are visually displayed on the map that is
`
`displayed on the display device of the Accused Instrumentalities.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`PAGE | 23
`
`

`

`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 24 of 25
`
`
`Figure 7 - Visual Symbols in the Google Maps Application
`
`
`
`
`PRAYER FOR RELIEF
`
`WHEREFORE, NavBlazer respectfully requests the Court enter judgment against
`
`Motorola:
`
`Declaring that Motorola has infringed each of the Patents-in-Suit;
`
`Awarding NavBlazer its damages suffered as a result of Apple’s infringement of the Patents-in-
`
`Suit;
`
`Awarding NavBlazer its costs, attorneys’ fees, expenses, and interest;
`
`Awarding NavBlazer ongoing post-trial royalties; and
`
`Granting NavBlazer such further relief as the Court finds appropriate.
`
`
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`PAGE | 24
`
`

`

`Case 6:20-cv-00100-ADA Document 1 Filed 02/10/20 Page 25 of 25
`
`NavBlazer demands trial by jury, under Fed. R. Civ. P. 38.
`
`JURY DEMAND
`
`
`
`Dated: February 10, 2020
`
`
`
`
`
`
`
`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
`
`ATTORNEYS FOR
`NAVBLAZER LLC
`
`
`
`
`
`
`
`ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`PAGE | 25
`
`

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