IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TRAXCELL TECHNOLOGIES, LLC,
`Plaintiff,
`
`v.
`GOOGLE LLC,
`Defendant.
`
`CASE NO. 6:21-cv-00023
`
`JURY DEMAND
`
`PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`Traxcell Technologies, LLC. (“Traxcell”) files this Original Complaint, and demand for
`
`jury trial seeking relief from patent infringement by Google LLC (“Defendant” or “Google”),
`
`alleging infringement of the claims of U.S. Pat. No. 9,918,196 and U.S. Pat. No. 9,549,388
`
`(collectively referred to as “Patents-in-Suit”), as follows:
`
`I.
`
`THE PARTIES
`
`1. Plaintiff Traxcell is a Texas Limited Liability Company, with its principal place of
`
`business located at 103 Country Club Drive. #508, Marshall, Texas 75672.
`
`2. Defendant Google LLC is a Delaware corporation with a principal place of business located
`
`at 1600 Amphitheater Parkway, Mountain View, California 94043. Google designs, manufactures,
`
`uses, imports into the United States, sells, and/or offers for sale in the United States smartphones,
`
`tablets, iPods, desktop computers, and notebook computers that use Google Maps. Google
`
`markets, sells, and offers to sell its products and/or services, including those accused herein of
`
`infringement, to actual and potential customers and end-users located in Texas and in the judicial
`
`Western District of Texas such as at the Google maintains a permanent physical presence within
`
`the Western District of Texas, conducting business from at least its locations at: 9606 North Mo-
`
`Pac Expressway, Suite 700, Austin, Texas 78759; 500 West 2nd Street, Suite 2000, Austin, Texas
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`1
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`

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`78701; 4100 Smith School Road, Austin, Texas 78744; as well as other locations in and around
`
`the Austin area.
`
`3. Google is registered to do business in Texas and can be served via its registered agent,
`
`Corporation Service Company dba CSC – Lawyers Incorporating Service Company at 211 East
`
`7th Street, Suite 620, Austin, Texas 78701-3218.
`
`4. Google has placed or contributed to placing infringing products like the Google Maps for
`
`use on a computing device connected to a wireless network into the stream of commerce via an
`
`established distribution channel knowing or understanding that such products would be sold and
`
`used in the United States, including in the Western District of Texas. On information and belief,
`
`Google also has derived substantial revenues from infringing acts, including but not limited to
`
`advertising, business APIs, private usage, OEM usage, and/or the like.
`
`II. JURISDICTION AND VENUE
`
`5. This is an action for patent infringement arising under the patent laws of the U.S., 35 U.S.C.
`
`§§ 1 et. seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331,
`
`1332(a) and 1338(a).
`
`6. This Court has personal jurisdiction over Defendants because: Defendants are present
`
`within or has minimum contacts within the State of Texas and this judicial district;
`
`Defendants have purposefully availed itself of the privileges of conducting business in the
`
`State of Texas and in this judicial district; Defendants regularly conducts business within
`
`the State of Texas and within this judicial district; and Plaintiff’s cause of action arises
`
`directly from Defendants’ business contacts and other activities in the State of Texas and
`
`in this judicial district. The amount in controversy is more than $75,000.00.
`
`
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`

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`7. Venue is proper in this judicial district per 28 U.S.C. §§ 1391 and 1400(b). Google has
`
`committed acts of infringement in this judicial district and maintains regular and
`
`established places of business in this district, as set forth above. Google has continuous and
`
`systematic business contacts with the State of Texas. Google, directly or through
`
`subsidiaries or intermediaries (including distributors, retailers, contract manufacturers, and
`
`others), conducts its business extensively throughout Texas, by shipping, manufacturing,
`
`distributing, 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. Google, directly or through subsidiaries or intermediaries (including
`
`distributors, retailers, contract manufacturers, and others), has purposefully and voluntarily
`
`placed its 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.
`
`III. INFRINGEMENT (‘196 Patent (attached as Exhibit A))
`
`8. On March 13, 2018, U.S. Patent No. 9,918,196 (“the ’196 patent”), attached as Exhibit A,
`
`entitled “Internet queried directional navigation system with mobile and fixed originating
`
`location determination” was duly and legally issued by the U.S. Patent and Trademark
`
`Office. Traxcell owns the ’196 patent by assignment.
`
`9. The ’196 Patent’s Abstract states, “A mobile wireless network and a method of operation
`
`provide directional assistance in response to an Internet query. The directional assistance
`
`is provided from a location of the querying device to a destination that may be selectively
`
`prompted based on whether the destination is a nearby business, a type of business, a street
`
`address, or another mobile device or fixed telephone location. The location of the querying
`
`
`
`
` 3
`
`

`

`device is also selectively determined depending on whether the que1y ing device is a
`
`wireless device such as a mobile telephone, or whether the device has a presumed fixed
`
`location, such as an ordinaiy telephone connected to a public-switched telephone network
`
`(PSTN).
`
`10. The following preliminary exemplaiy chaii provides notice of Traxcell's allegations of
`
`infringement.
`
`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`A method of providing The Google Maps online navigation service and the Google Maps server-side or cloud
`navigation assistance
`infrastmcture needed to provide the service, constitute the "Accused System" .
`to a user of a
`communications
`device, the method
`compnsmg:
`
`The te1m "Google Maps" encompasses and includes all the versions and variants of the Google
`Maps web (for PC) and the Google Maps app (Google Maps app for Android and iOS devices)
`and the applications suppo1ied by the Google Maps Platfo1m.
`
`The "method of providing navigation assistance to a user of a communications device" refers to
`the method by which Google Maps provides online navigation assistance (directions) to a user of
`a commlmications device or UE ( example: mobile phone, smartphone, laptop, tablet, iPhone,
`iPad etc.) including the Google Maps app or including a browser plugin enabling access to the
`Google Maps website or having other means to access the Google Maps website, for que1y ing
`and receiving navigation instructions for travelling from a staiiing location ( cunent location of
`the communications device or a location specified by its user as the ' origin') to a destination
`location (a location specified by the said user as the ' destination').
`
`The "communications device" refers to a UE ( example: mobile phone, smaiiphone, laptop, tablet,
`iPhone, iPad etc.) including the Google Maps app or including a browser plugin enabling access
`to the Google Maps website or having other means to access the Google Maps website for
`que1y ing and receiving navigation instructions for ti·avelling from a staiiing location ( cunent
`location of the communications device or a location specified by its user as the 'origin') to a
`destination location (a location specified by the said user as the 'destination').
`
`4
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`The said "communications device" (th e user of the said "communications device") is device of
`including but not limited to Verizon, T-Mobile, Sprint, SPRINT, Nokia, and th e other United
`States communications device provider.
`
`Verizon, T-Mobile, Sprint, suppo1is the Google Maps online navigation service on devices that
`are subscribed to wireless telecommunications network services of the Verizon, T-Mobile,
`Sprint, SPRINT, Nokia or any other united states canier. Verizon, T-Mobile, SPRINT, etc.
`provides the mobile data service required to use the Google Maps online navigation service.
`
`Google Maps provides navigation assistance (directions) to a "user of a communications device"
`for travelling from a starting location (Ex: Starbucks, 13-25 Astor Pl, New York, NY 10003,
`USA) to a destination location (Ex: Central Park South, New York, NY, USA).
`
`receiving, by a
`directional assistance
`service, an Internet
`query initiated at the
`communications
`device an d directed via
`the Internet to initiate a
`request for
`navigational assistan ce
`to a destination;
`
`Navigation using Google Maps online navigation service is a well-known example of off board
`navigation. To elaborate, an off board navigation system is a client/server system wherein only
`the user interface (UI) resides on the client's (user 's) communications device and all the
`databases (GIS and/or mapping) and infrastm cture required for computation (ofroute, distance,
`travel tim e, traffic etc.) reside remotely on a server or a network of servers (the server-side)
`located on the world wide web (www). The server-side could also comprise virtual (instead of
`physical) or cloud server infrastmcture. The client side (user interface or UI at a user's
`communications device) can only communicate with the server-side via the Internet.
`
`This claim elem ent refers to the method and process involved in initiating a navigation que1y ,
`using Google Maps online navigation service, to obtain directions (navigation assistance) for
`travelling from a starting location to a destination location. The process involved in initiating the
`said navigation que1y includes inputting a destination location at the Google Maps ' user interface
`(UI) at the user's communications device, and sending the said que1y via Internet to the remote
`Google Maps server (cloud server). The said remote Google Maps server (cloud server) receives
`the said que1y via Internet.
`
`The te1m "directional assistance service" herein refers to Google Maps online navigation service
`supported and facilitated by wireless telecommunications network of the Verizon, T-Mobile,
`Sprint, SPRINT, Nokia or any oth er united states caiTier.
`
`5
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`The "communications device" refers to a UE ( example: mobile phone, smartphone, laptop, tablet,
`iPhone, iPad etc.) including the Google Maps app or including a browser plugin enabling access
`to the Google Maps website or having other means to access the Google Maps website, for
`que1ying and receiving navigation instructions for ti·avelling from a staiiing location ( cunent
`location of the communications device or a location specified by its user as the 'origin') to a
`destination location (a location specified by the said user as the 'destination').
`
`The method of using the Google Maps for navigation includes initiating a que1y at the
`communications device to initiate a request for navigational assistance for ti-avelling from a
`staiiing point (which could be the cunent location of the user's communications device) to a
`destination, by specifying (inputting) the destination and the staiiing point (if different from the
`cunent location of the user's communications device).
`
`The said que1y is directed via the Internet to the remote Google Maps server (cloud server). In
`other words, the Google Maps server ( cloud server) receives the said que1y through the Internet.
`Google Maps online navigation is an example of off board navigation. In other words, Google
`Maps online navigation system is a client/server system wherein only the user interface (UI)
`resides on the client's (user's) communications device and all the databases (GIS and/or
`mapping) and infrasti-ucture required for computation ( of route, distance, ti·avel time, ti-affic etc.)
`reside remotely on a Google Maps server or a network of servers (the server-side) located on the
`world wide web (www). The server-side could also comprise viiiual (instead of physical) or
`cloud server infrastm cture. The client side (user interface or UI at a user's communications
`device) can only communicate with the server-side via the Internet. In other words, destination is
`input and a que1y is initiation at the Google Maps user interface (UI) at the client device and the
`que1y (including the input destination) is communicated from the client-side (client or user's
`communications device) to the remote server-side (Google Maps server) via the Internet. The
`Google Maps server, upon receiving the que1y (including the input destination) communicated
`from the client-side (client or user 's communications device) via the Internet, identifies the
`required map tiles (or grid squai·es), computes or calculates the route(s), and downloads the
`required map tiles (or grid squares) and the computed or calculated route(s) to the client-side
`(client or user 's communications device) via the Internet.
`
`The aforementioned fact that Google Maps online navigation is an example of off-boai·d
`navigation is established from the following details available in the public domain -
`
`a) In Atta.chment 8, which is a copy of infonnation on off-board navigation available on the
`Wikipedia, Google Maps ( online navigation) is cited as an example of off-board navigation
`system . The following is mentioned therein -
`
`6
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`"In addition to navigation software, there are also route planner as offboard solution. The
`difference to the conventional route planning in the Internet is the possibility of the location
`trnnsmission of the user. Google Maps offers such a mobile route planner with the Google Maps
`Mobile software."
`
`Attachment 8 also elaborates on and describes off-board navigation. The following is mentioned
`therein-
`
`"The oftboard navigation allows the use of a mobile phone as a navigation system, with the
`route data and maps not stored on the device. Using special navigation software, the user contacts
`an external server via UMTS or GPRS and downloads the desired route info1mation and maps
`from there. In eve1yday language, off-board navigation is also called "mobile phone navigation".
`
`"The difference between offboard navigation and onboard navigation: In the case of onboard
`navigation, the route data and maps are stored together with navigation software in the mobile
`device. This requires a lot of storage space, so onboard navigation is only suitable for devices
`with a larger processor and more storage space, such as PDAs and smartphones. For offboard
`navigation, however, are now many popular mobile phones with Java operating system (J2ME).
`A prerequisite for offboard navigation is that the mobile phone can connect to the Internet via
`UMTS or GPRS. Both variants require GPS reception. It must therefore have an integrated or an
`externally connected GPS receiver (GPS mouse). If an external GPS receiver is used, the two
`devices are now usually coupled together via Bluetooth."
`
`b) In Attachment 9, which is a copy of info1mation on Google Maps navigation available on the
`Wikipedia, Google Maps ( online navigation) is described as an off-board navigation system,
`which subsequent to receiving a destination input at the client-side user interface (UI) obtains
`map and route information (from its server) via the Internet. The following is mentioned therein -
`
`"Google Maps Navigation is a mobile application developed by Google for the Android and iOS
`operating systems that was later integrated into the Google Maps mobile app. The application
`uses an Internet connection to a GPS navigation system to provide tum-by-tum voice-guided
`instmctions on how to anive at a given destination. The application requires connection to
`Internet data (e.g. 3G, 4G, WiFi, etc.) and nonnally uses a GPS satellite connection to dete1mine
`its location. A user can enter a destination into the application, which will plot a path to it. The
`app displays the user's progress along the route and issues instructions for each tum."
`
`7
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`"Once the user has searched for a destination, the map will cache along the intended route. Note
`that the application requires an Internet connection to search for the route, but once a route has
`been found, the user no longer requires an Internet connection as the route is temporarily saved
`onto the device."
`
`c) In Attachment 10, which is a copy of infonnation on Google Maps available on the Wikipedia,
`Google Maps ( online navigation) is described as an off-board navigation system, wherein
`subsequent to inputting a destination input at the client-side user interface (UI) map tiles (or grid
`squares) are downloaded to the client-side (user's communications device) from the remote
`Google Maps server via the Internet. The following is mentioned therein -
`
`"As the user drags the map, the grid squares are downloaded from the server and inserted into the
`page. When a user searches for a business, the results are downloaded in the background for
`inse1tion into the side panel and map; the page is not reloaded."
`
`d) Attachment 11 describes Google Maps ( online navigation) as an online and off board
`navigation system, which upon destination input and que1y initiation at the UI at the client
`device, downloads maps to the client device from its remote server via Internet. Attachment 11
`also elaborates on and describes a typical "online/off board navigation system".
`
`The following is mentioned therein -
`
`"Navigation online / oftboard This refers to a navigation solution that does not store your maps
`in the internal memo1y of the smaitphone or on its SD cai·d, but during use continuously from a
`server on the Internet. Thus, a continuous, wideband broadband Internet connection (UMTS,
`HSDP A, in the future also L TE) during the navigation is mandato1y requirement.
`Benefits of this online solution: You do not have to wony about map updates, but always
`automatically use the most up-to-date maps available. In addition, the two most populai· online
`navigation solutions for Android ai·e free: Skobbler from a Berlin company and the well-known
`Google Maps Navigation."
`
`Attachment 11 also mentions the ainount of data Google Maps ( online navigation) requires. The
`following is mentioned therein -
`
`8
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`"However, th ese free online solutions ce1iainly have disadvantages: they cause considerable data
`traffic between the server of the navigation solution provider and your smartphone. If you only
`select the map view on Google Maps, you can significantly reduce the traffic: A 55-kilometer
`route caused only 1 MB of traffic in Google Maps Navigation in the map view. In the satellite
`view, it was on the same route 11 MB of traffic!"
`
`"And of course, an online solution requires a good internet connection. So, if you're often away
`from metropolitan areas in areas with poor data connectivity and therefore usually surf at edge
`speeds, then you should opt for an onboard solution. However, the use of Google Maps
`Navigation worked well with Edge, if you do not unnecessarily increase the resulting traffic.
`Therefore, our tip: With an online navigation solution like Google Maps Navigation, you
`should do without the satellite view and only choose the map view if the internet connection is
`poor and / or the monthly traffic limit is low."
`
`e) Attachment 12 describes Google Maps (online navigation) as an off board navigation system,
`which upon destination input and que1y initiation at the UI at the client device, downloads maps
`to the client device from its remote server via Internet. The following is mentioned therein -
`"Using GPS and mobile network, Google Maps locates you with astonishing precision. If you are
`looking for restaurants, petrol stations or A TMs, you will not only get the corresponding contact
`details and the position on the map, but you can also be directed there directly. With Google Map
`you always check your cmTent position and find the best route to your desired destination. Who
`wants to use the free navigation frequently, should get an internet flat rate, as Google Maps pulls
`the map data from the Internet (Offboard- Navigation)."
`
`f) Attachment 4 indicates that Google Maps ( online navigation) is an off board navigation
`system, which upon destination input and que1y initiation at the UI at the client device,
`downloads maps to the client device from its remote server via Internet. It also confnms that
`wireless telecommunications network (T-Mobile, Verizon, SPRINT, etc.) provides the mobile
`data service required to use the Google Maps online navigation service. The following is
`mentioned therein -
`
`"Google maps has offline maps feature save mobile data. Global Positioning Service - GPS is
`provided free of cost by satellite eve1ywhere. Data will be used to get maps on the go with T
`Mobile, Verizon, Sprint, Ai1iel, Vodafone."
`
`"Google maps app is FREE to use but they do need area maps to be downloaded. Google maps
`allows offline or without internet access of their maps, if you have downloaded them earlier on
`your mobile."
`
`9
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`"If not downloaded, and you use Google maps to find directions using your own FREE GPS
`receiver (installed in your smartphone) using your mobile internet connection to get maps on the
`go and show you directions."
`
`"Remember, Google maps (if maps not ah-eady available) would need the internet connection and
`would incur internet data charges in
`
`roaming."
`
`So, based on the foregoing info1mation it is established that navigation using Google Maps
`online navigation service is an example of off board navigation. As we have learnt, an off board
`navigation system is a client/server system wherein only the user interface (UI) resides on the
`client's (user's) communications device and all the databases (GIS and/or mapping) and
`infrastmcture required for computation ( of route, distance, travel time, traffic etc.) reside
`remotely on a server or a network of servers (the server-side) located on the world wide web
`(www). The server-side could also comprise virtual (instead of physical) or cloud server
`infrastmcture. The client side (user interface or UI at a user's communications device) can only
`communicate with the server-side via the Internet. In other words, destination is input and a
`que1y is initiation at the Google Maps user interface (UI) at the client device and the que1y
`(including the input destination) is communicated from the client-side (client or user 's
`communications device) to the remote server-side (Google Maps server) via the Internet. The
`Google Maps server, upon receiving the que1y (including the input destination) communicated
`from the client-side (client or user 's communications device) via the Internet, identifies the
`required map tiles (or grid squares), computes or calculates the route(s), and downloads the
`required map tiles (or grid squares) and the computed or calculated route(s) to the client-side
`(client or user 's communications device) via the Internet.
`
`The said que1y is communicated from the Google Maps' client-side to the Google Maps server in
`the fo1m of a URL
`
`The method of using the Google Maps for navigation includes initiating a que1y at the
`communications device to initiate a request for navigational assistance for travelling from a
`staiting point (which could be the cunent location of the user's communications device) to a
`destination, by specifying (inputting) the destination and the staiting point (if different from the
`cmTent location of the user's communications device).
`
`The said que1y is directed via the Internet to the remote Google Maps server (cloud server). In
`other words, the Google Maps server ( cloud server) receives the said que1y through the Internet.
`
`

`

`Exemplary Claim
`
`responsive to receiving
`the Internet que1y,
`detennining whether
`or not the
`communications
`device is a mobile
`wireless
`communications
`device;
`
`Corresponding Structure in Accused Systems
`
`Google Maps is programmed to identify the "phone type" ( or device type) and the "unique
`identifier" of the communications device (UEat which the said navigation que1y is initiated. In
`other words, Google Maps detennines whether or not the said communications device (UE) is a
`mobile wireless communications device (UE).
`
`"a mobile wireless communications device" refers to a mobile wireless communications device
`or UE (example: mobile phone, smartphone, laptop, tablet, iPhone, iPad etc.), which includes the
`Google Maps app or includes a browser plugin enabling access to the Google Maps website or
`has other means to access the Google Maps website for que1ying and receiving navigation
`instmctions for travelling from a staiting point (cmTent location of the communication 's device
`or a location specified by its user as the 'origin') to a destination location (a location specified by
`the said user as the ' destination').
`
`In Attachment 20, Google Privacy Policy document, it is cleai·ly mentioned that Google (Google
`Maps) collects info1mation such as device type, phone number and unique identifiers pertaining
`to the communications device (UE) at which a navigation que1y is initiated and communicated
`to the Google Maps server. In other words, Google Maps has means to determine whether a
`que1ying communications device (UE) is a mobile wireless communications device (UE) or not.
`
`The following is mentioned therein -
`
`"Info1mation we collect as you use om services
`
`From the aforementioned, it is also confomed that whenever a communications device uses
`Google Maps, info1mation such as mobile network info1mation including name of the carrier
`serving the said communications device ai·e collected by Google (Google Maps). In other words,
`Google Maps can also asce1tain whether the communications device (UE) at which the said
`navigation que1y is initiated, is connected to the Google Maps server through a wireless
`telecommunications network service (i.e. through RF signal-based communication) or through a
`Wi-Fi network suppo1ted by a fixed-line or wired broadband Internet service.
`
`A copy of the Google Play webpage displaying info1mation on Google Maps app updated on
`November 8, 2018, it is cleai·ly mentioned that the Google Maps app has access to Phone, Device
`ID and Call info1mation pe1taining to the device on which it is installed, and it can read "phone
`status and identity" . In other words, Google Maps has means to detennine whether a querying
`communications device (UE) is a mobile wireless communications device (UE) or not.
`
`Google Maps app installed on a communications device can ''view Wi-Fi connections" and can
`"view network connections" pe1taining to the said communications device.
`
`11
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`responsive to
`detennining that the
`communications
`device is the mobile
`wireless
`communications
`device, the directional
`assistance service
`detennining and using
`a present location of
`the mobile wireless
`communications
`device as a location of
`the communications
`device;
`
`In other words, Google Maps can also asce11ain whether the communications device (UE) at
`which the said navigation que1y is initiated, is connected to the Google Maps server through a
`wireless telecommunications network service (i.e. through RF signal-based communication) or
`through a Wi-Fi network suppo1ied by a fixed-line or wired broadband Internet service.
`
`In summary, Google Maps has means to determine whether a querying communications device
`(UE) is a mobile wireless communications device (UE) or not, and also whether the said
`communications device (UE) is connected to the Google Maps server through a wireless
`telecommunications network service (i.e. through RF signal-based communication) or through a
`Wi-Fi network suppo1i ed by a fixed-line or wired broadband Internet service.
`
`If the Google Maps online navigation service determines that the said navigation que1y has been
`initiated at a mobile wireless communications device (UE), and that the said que1y was
`communicated through a wireless telecommunications network service (i.e. through RF signal(cid:173)
`based communication), Google Maps detennines cunent location of the mobile wireless
`communications device (UE) and uses it as the staiiing point for providing navigation
`inf01mation (instm ctions or directions) to travel to the destination input by the user of the said
`communications device (UE).
`
`The "the mobile wireless communications device" or the "communications device" refers to the
`mobile wireless communications device or UE ( exainple: mobile phone, smaiiphone, laptop,
`tablet, iPhone, iPad etc.) at which the navigation que1y was initiated.
`
`A user can simply input a "destination" entiy and initiate a navigation que1y on the Google
`Maps' client-side user interface (UI) at the user 's mobile wireless communications device
`(Google Maps app on an Android sma11phone). The Google Maps server, upon receiving the
`navigation que1y (including input "destination") from the client-side via Internet, dete1mines the
`"cm-rent location" of the user's mobile wireless communications device, uses it as the default
`sta11ing point, asce11ains the location of the input "destination", computes or calculates the
`route(s) and directions, and downloads the computed or calculated route(s) and directions to the
`user 's mobile wireless communications device.
`
`A user can simply input a "destination" entiy and initiate a navigation que1y on the Google
`Maps' client-side user interface (UI) at the user 's mobile wireless communications device
`(Google Maps app on an Android sma11phone). The Google Maps server, upon receiving the
`navigation que1y (including input "destination") from the client-side via Internet, dete1mines the
`"cm-rent location" of the user's mobile wireless communications device, uses it as the default
`sta11ing point, asce11ains the location of the input "destination", computes or calculates the
`
`12
`
`

`

`Exemplary Claim
`
`Corresponding Structure in Accused Systems
`
`route(s) and directions, and downloads th e computed or calculated route(s) and directions to th e
`user 's m obile wireless communications device.
`
`As has been mentioned with reference to the previous claim elem ent, Google Maps, upon
`receiving a navigation que1y from a user 's communications device, detennines whether or not the
`said communications device is a mobile wireless communications device.
`
`Aa user can simply input a "destination" entiy and initiate a navigation que1y on the Google
`Maps' client-side user interface (UI) at the user 's mobile wireless communications device
`(Google Maps app on a smartphone). Implying that the Google Maps server, upon receiving the
`navigation que1y (including input "destination") from the client-side via Internet, determines the
`"cm-rent location" of th e user's m obile wireless communications device, uses it as th e default
`sta1t ing point, asce1tains the location of th e input "destination", computes or calculates the
`route(s) and directions, and downloads th e computed or calculated route(s) and directions to th e
`user 's m obile wireless communications device.
`
`A user can simply input a "destination" entiy and initiate a navigation que1y on the Google
`Maps' client-side user interface (UI) at the user 's mobile wireless communications device
`(Google Maps app on an Android phone or tablet). The Google Maps server, upon receiving the
`navigation que1y (including input "destination") from the client-side via Internet, determines the
`"cm-rent location" of th e user's m obile wireless communications device, uses it as th e default
`sta1t ing point, asce1tains the location of th e input "destination", computes or calculates the
`route(s) and directions, and downloads th e computed or calculated route(s) and directions to th e
`user 's m obile wireless communications device.
`
`responsive to
`detennining that the
`communications
`device is not the
`m obile wireless
`communications
`device, obtaining a
`fixed location
`associated with the
`communications
`device to detennine
`the location of the
`
`As mentioned previously, Google