`TRAXCELL TECHNOLOGIES, LLC.,
`Plaintiff,
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`v.
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`GOOGLE LLC
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`Defendant.
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Civil Action No. 6:21-cv-01312
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`Jury Trial Demanded
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`PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
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`Traxcell Technologies, LLC. (“Traxcell”) files this Original Complaint, and demand for
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`jury trial seeking relief from patent infringement by Google LLC (“Defendant” or “Google”),
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`alleging infringement of the claims of U.S. Pat. No. 10,820,147 (collectively referred to as “Patent-
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`in-Suit”), as follows:
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`I.
`
`THE PARTIES
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`1. Plaintiff Traxcell is a Texas Limited Liability Company, with its principal place of
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`business located at 103 Country Club Drive. #508, Marshall, Texas 75672.
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`2. Defendant Google LLC is a Delaware corporation with a principal place of business located
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`at 1600 Amphitheater Parkway, Mountain View, California 94043. Google designs, manufactures,
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`uses, imports into the United States, sells, and/or offers for sale in the United States smartphones,
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`tablets, iPods, desktop computers, and notebook computers that use Google Maps. Google markets,
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`sells, and offers to sell its products and/or services, including those accused herein of infringement,
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`to actual and potential customers and end-users located in Texas and in the judicial Western District
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`of Texas such as at the Google maintains a permanent physical presence within the Western
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`District of Texas, conducting business from at least its locations at: 9606 North Mo- Pac
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`Expressway, Suite 700, Austin, Texas 78759; 500 West 2nd Street, Suite 2000, Austin, Texas
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`78701; 4100 Smith School Road, Austin, Texas 78744; as well as other locations in and around
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`the Austin area.
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`3. Google is registered to do business in Texas and can be served via its registered agent,
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`Corporation Service Company dba CSC – Lawyers Incorporating Service Company at 211 East
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`7th Street, Suite 620, Austin, Texas 78701-3218.
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`4. Google has placed or contributed to placing infringing products like the Google Maps for
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`use on a computing device connected to a wireless network into the stream of commerce via an
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`established distribution channel knowing or understanding that such products would be sold and
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`used in the United States, including in the Western District of Texas. On information and belief,
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`Google also has derived substantial revenues from infringing acts, including but not limited to
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`advertising, business APIs, private usage, OEM usage, and/or the like.
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`II. JURISDICTION AND VENUE
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`5. This is an action for patent infringement arising under the patent laws of the U.S., 35 U.S.C.
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`§§ 1 et. seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331,
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`1332(a) and 1338(a).
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`6. This Court has personal jurisdiction over Defendants because: Defendants are present
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`within or has minimum contacts within the State of Texas and this judicial district;
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`Defendants have purposefully availed itself of the privileges of conducting business in the
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`State of Texas and in this judicial district; Defendants regularly conducts business within
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`the State of Texas and within this judicial district; and Plaintiff’s cause of action arises
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`directly from Defendants’ business contacts and other activities in the State of Texas and
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`in this judicial district. The amount in controversy is more than $75,000.00.
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`7. Venue is proper in this judicial district per 28 U.S.C. §§ 1391 and 1400(b). Google has
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`committed acts of infringement in this judicial district and maintains regular and
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`established places of business in this district, as set forth above. Google has continuous and
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`systematic business contacts with the State of Texas. Google, directly or through
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`subsidiaries or intermediaries (including distributors, retailers, contract manufacturers, and
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`others), conducts its business extensively throughout Texas, by shipping, manufacturing,
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`distributing, offering for sale, selling, and advertising (including the provision of
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`interactive web pages) its products and services in the State of Texas and the Western
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`District of Texas. Google, directly or through subsidiaries or intermediaries (including
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`distributors, retailers, contract manufacturers, and others), has purposefully and voluntarily
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`placed its infringing products and services into this District and into the stream of
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`commerce with the intention and expectation that they will be purchased and used by
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`consumers in this District.
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`III.
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`INFRINGEMENT (’147 Patent (Attached and incorporated by reference))
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`8. On October 27, 2020, U.S. Patent No. 10,820,147 (“the ’147 patent”) entitled “Mobile
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`wireless device providing off-line and on-line geographic navigation information” (attached as
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`Exhibit C) was duly and legally issued by the U.S. Patent and Trademark Office. Traxcell owns
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`the ’147 patent by assignment.
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`9. The ’147 Patent’s Abstract states, “A mobile device, wireless network and their method of
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`operation provide both on-line (connected) navigation operation, as well as off-line navigation
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`from a local database within the mobile device. Routing according to the navigation system can be
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`controlled by traffic congestion measurements made by the wireless network that allow the
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`navigation system to select the optimum route based on expected trip duration.”
`3
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`Claim 1
`1. A wireless
`communications
`system including:
`
`
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`10. The following preliminary exemplary chat provides Traxcell’s allegations of infringement.
`
`
`Corresponding Structure in Accused Systems
`The Google Maps online navigation service and the Google Maps server-side or cloud
`infrastructure needed to provide the service, constitute the “Accused System”.
`Each combination having at least one item listed on Exhibit A, at least one item listed on Exhibit
`B, and at least one item listed on Exhibit C is a wireless communications system.
`Because infringement liability is not dependent on ownership, e.g., use of a system can infringe
`(35 U.S.C. § 271), infringement is not dependent on ownership of all limitations of a claim.
`
`
`
`a first radio-
`frequency
`transceiver within
`a wireless mobile
`communications
`device and an
`associated first
`antenna to which
`the first radio-
`frequency
`transceiver is
`coupled, wherein
`the first radio-
`frequency
`transceiver is
`configured for
`radio-frequency
`communication
`with a wireless
`communications
`network;
`
`Plaintiff contends each item listed on Exhibit B corresponds to this claim limitation because each
`Exhibit-B item is a device that provides communicative access to a wireless network by
`transceivers designed and used for radio-frequency communication and at least one antenna.
`When a wireless communication device transceivers and antennas are in communication, they are
`coupled. Further, in addition to being so coupled, the transceiver of each Exhibit-B item is also
`configured for RF-communication wireless communication networks, such as AT&T, Verizon, T-
`Mobile, and other US networks (Cellular or WLAN) via Google Maps which comes preloaded on
`Exhibit-B items.
`Plaintiff contends each item listed on Exhibit B corresponds to this claim limitation because each
`Exhibit-B item includes a radio frequency transceiver. Wireless mobile communication device —
`including but not limited to Google’s branded devices such as Google Pixel 5, pixel 4a 5G, pixel
`4a, pixel 4 XL, pixel 4, pixel 3a XL, pixel 3a, pixel 3 XL, pixel 3, pixel 2, pixel 2 XL, pixel XL,
`pixel, pixel C or other (third-parties) branded devices such as Samsung Galaxy S20 Ultra, Galaxy
`S20 plus, Galaxy S20, Galaxy Z fold, Galaxy S10, Galaxy A series, etc. (refer Exhibit B for
`complete list) — include radio-frequency transceivers and an associated antenna. When wireless
`communication device transceivers and antennas are in communication, they are coupled. Further,
`in addition to being so coupled, the transceiver of each Exhibit-B item is also configured for RF-
`communication with the wireless communication network.
`
`The following exemplifies this limitation’s existence in Accused Systems:
`
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`4
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication device (Exhibit
`B), such as Google pixel 4a includes antenna
`connector.
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`
`
`Attachment 1 (Google Pixel 4XL showing antenna connector) at 21.
`
`
`Wireless mobile communication device (Exhibit
`B), such as Google pixel 4a includes antenna
`Board.
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`
`
`Source: Antenna of Google pixel 4a Teardown by PBKreviews (Time 3:58/8:36)
`Link: https://www.youtube.com/watch?v=pTPup76PxNo
`5
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`

`

`Claim 1
`
`
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication device
`(Exhibit B), such as Google pixel 5
`includes antenna Board.
`
`Source: Antenna of Google pixel 5 Teardown by PBKreviews (Time-5:50/7:21)
`Link: https://www.youtube.com/watch?v=PPvlSHyok68
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`
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`Wireless mobile communication
`device (Exhibit B) such as Samsung
`Galaxy S20 includes RF transceiver.
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`
`
`
`Attachment 2 (Teardown of Samsung Galaxy S20 showing RF Transceiver component) at 8.
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`
`6
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`

`

`Claim 1
`
`
`
`Corresponding Structure in Accused Systems
`
`Attachment 2 (ifixit Teardown of Samsung Galaxy S20 showing antenna) at 05.
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`
`
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`Wireless mobile communication device (Exhibit
`B), such as Samsung Galaxy S20 includes
`antenna cables.
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`7
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication
`device (Exhibit B) such as Google
`Pixel includes RF transceiver.
`
`Attachment 13 (Google Pixel showing RF Transceiver component) at 9&10.
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`8
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication
`device (Exhibit B) such as Samsung
`Galaxy S20 Ultra includes RF
`transceiver.
`
`
`Attachment 3 (RF-Transceiver and antenna of Galaxy S20 device coupled with
`communication network) at 7.
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`9
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication device
`(Exhibit B) such as Samsung Galaxy S20
`Ultra includes RF transceiver antenna
`(mmwave) designed to connect wireless
`communication network (Verizon, AT&T,
`T-Mobile, etc.) .
`
`
`Attachment 3 (RF-Transceiver and antenna of Galaxy S20 device coupled with
`communication network) at 10.
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`10
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless mobile communication
`device (Exhibit B) able to connect
`to a wireless communication
`network
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`
`
`Attachment 14 (Method to connect a wireless communication network via Google pixel 4a
`device) at 1.
`
`
`
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`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), Such as Galaxy
`S20, Pixel 4a, Pixel 4a 5G, Pixel 5
`
`
`Attachment 15 (Google Maps application preloaded on Samsung Galaxy S20) at 113.
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`11
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`

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`Claim 1
`
`Corresponding Structure in Accused Systems
`
`
`Attachment 4 (Google Maps application preloaded on Pixel 4a, Pixel 4a 5G, and Pixel 5) at 1.
`
`
`Wireless mobile communication
`device (Exhibit B) able to connect
`to a wireless communication
`network
`
`
`Attachment 7 (Pixel phone hardware tech specs) at 6.
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`12
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`

`

`Claim 1
`a first processor
`within the wireless
`mobile
`communications
`device coupled to
`the at least one
`first radio-
`frequency
`transceiver
`
`Corresponding Structure in Accused Systems
`Plaintiff contends each item listed on Exhibit B corresponds to this claim limitation because each
`Exhibit-B item includes a processor. Wireless mobile communication device- including but not
`limited to Google’s branded devices such as Google Pixel 5, pixel 4a 5G, pixel 4a, pixel 4 XL,
`pixel 4, pixel 3a XL, pixel 3a, pixel 3 XL, pixel 3, pixel 2, pixel 2 XL, pixel XL, pixel, pixel C or
`other (third-parties) branded devices such as Samsung Galaxy S20 Ultra, Galaxy S20 plus,
`Galaxy S20, Galaxy Z fold, Galaxy S10, Galaxy A series, etc. (refer Exhibit B for complete list)
`has a processor, for example, Quad-Core/ Octa-core processor.
`Each Exhibit-B-listed mobile wireless communications device’s motherboard processor is
`programmed to process location-service information; i.e., to receive a location of the device from
`the wireless communications network (which is communicated to the device from the first RF
`transceiver) and generate an indication of the device’s location with respect to geographic features
`according to mapping information stored within the device. For example, the motherboard
`processor may use Google Maps to view and find places around the globe. The processor and
`base station transceivers communicate by RF communication and, thus, when doing so are
`communicatively coupled.
`The following exemplifies the existence of this limitation in Accused Systems:
`
`Processer within the
`wireless
`communication device
`
`
`
`
`
`
`
`
`
`
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`
`
`Source: Processor of Google pixel 4a Teardown by PBKreviews (Time-5:42/8:36)
`Link: https://www.youtube.com/watch?v=pTPup76PxNo&ab_channel=PBKreviews
`
`
`
`
`Attachment 7 (Specifications of Google pixel 5) at 1.
`
`
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`13
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`Processer within the
`wireless
`communication
`device (Exhibit B),
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Processer within the wireless
`communication device (Exhibit B),
`such as google pixel 5 configured to
`communicate with wireless
`communication network with help of
`inbuilt RF transceiver. Further, the
`processor receive a location of the
`wireless mobile communications
`device (Exhibit B) from the wireless
`communications network
`
`
`
`Attachment 7 (Specifications of Google pixel 5) at 2.
`
`
`
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`14
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Processe
`r within
`the
`wireless
`communi
`cation
`device
`(Exhibit
`B), such
`as
`Google
`Pixel 4a,
`Pixel 4a
`5G and
`Pixel 5
`
`
`Attachment 4 (Processor of Google Pixel 4a, Pixel 4a 5G and Pixel 5) at 1.
`
`
`
`
`
`15
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Processer within the wireless
`communication device (Exhibit B), such
`as Samsung Galxy S20 coupled with RF
`transceiver and Wi-Fi Module
`
`
`
`Attachment 2 (Teardown of Samsung Galaxy S20 showing RF Transceiver component) at 8.
`
`
`
`
`
`16
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Processer within the wireless communication
`device (Exhibit B), such as Google pixel
`coupled with RF transceiver and Wi-Fi
`Module
`
`
`
`
`
`programmed to
`receive
`information
`indicative of a
`location of the
`wireless mobile
`communications
`device and
`generate an
`indication of a
`location of the
`wireless mobile
`communications
`device with respect
`to geographic
`
`Attachment 13 (Google Pixel showing RF Transceiver component) at 9&10.
`Plaintiff contends the Exhibit-B-listed mobile-wireless-communications device’s motherboard
`processor is programmed to process location-service information; i.e., to receive a location of the
`device from the wireless communications network and generate an indication of the device’s
`location.
`For example, the motherboard processor may use Google Maps to obtain the device’s location
`and provide direction from that location to a destination. Wireless mobile communication device-
`including but not limited to Google’s branded devices such as Google Pixel 5, pixel 4a 5G, pixel
`4a, pixel 4 XL, pixel 4, pixel 3a XL, pixel 3a, pixel 3 XL, pixel 3, pixel 2, pixel 2 XL, pixel XL,
`pixel, pixel C or other (third-parties) branded devices such as Samsung Galaxy S20 Ultra, Galaxy
`S20 plus, Galaxy S20, Galaxy Z fold, Galaxy S10, Galaxy A series, etc. (refer Exhibit B for
`complete list) has a processor for example, Quad-Core processor. When wireless communication
`device transceivers and processor are in communication, they are coupled. Further, the Location-
`based Service (LBS) provider, such as Google Map, on the Exhibit-B utilizes the processor
`coupled to the transceiver to estimates/receive the location on mobile wireless communications
`devices (specifically one or more of the mobile wireless communications devices identified on
`17
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`

`

`Claim 1
`features
`
`Corresponding Structure in Accused Systems
`Exhibit B) by utilizing wireless communication network or first computer.
`For example, the motherboard processor may use Google Maps to view and find places around
`the globe. Google map can also show your current location and provide direction (including with
`respect to geographic features such as nearby restaurants) from your location/source to any
`destination. In using Google Maps App, the mobile wireless communication device’s
`motherboard processor generates signals for displaying on the device’s screen a blue dot that
`shows the current location of the wireless mobile communication device. The Google map app
`estimates the location of the device from 3 sources: GPS (GPS uses satellites and knows your
`location within a few meters), Wi-Fi (the location of nearby Wi-Fi networks helps Maps know
`where you are), and cell towers (cell tower can be accurate up to a few thousand meters). When
`Google Maps isn’t sure about your location, a light blue circle around the blue dot is shown. You
`might be anywhere within the light blue circle. The smaller the circle, the more certain the app is
`about your location.
`Furthermore, Google Maps App provides flexibility to download maps on SD card/internal
`memory of communication device (Exhibit B) examples of compatible devices is Samsung
`Galaxy S20, Pixel 4a, Pixel 4a 5G, Pixel 5, etc., and navigate offline. When internet is slow or
`mobile data is expensive, or communication device cannot connect to internet, an area can be
`saved to phone or tablet (Exhibit B) from Google maps app and use it when offline.
`Communication device can use Offline maps for Navigation through the downloaded area without
`internet.
`The following exemplifies the existence of this limitation in Accused Systems:
`
`
`
`
`18
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 4 (Processor of Google Pixel 4a, Pixel 4a 5G and Pixel 5) at 1.
`
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`19
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Processer within the wireless
`communication device (Exhibit B), such
`as Samsung Galxy S20 coupled with RF
`transceiver and Wi-Fi Module
`
`
`
`Attachment 2 (RF Transceiver and Processor of Samsung Galaxy S20) at 8.
`
`
`
`
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`20
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20. Current location of the device is
`determined if location is enabled
`
`
`Attachment 5 (how to use turn by turn Google map) at 1.
`
`
`
`
`
`21
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20.
`
`
`Attachment 5 (how to use turn by turn google map) at 2&3.
`
`
`
`
`
`22
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless communication network (e.g.
`Verizon, AT&T, T-Mobile, etc.) used to
`estimate the location of the Wireless
`communication device (Exhibit B) on Google
`Maps.
`
` Attachment 6 (Find Current Location on Google map) at 1.
`
`
`
`
`
`
`Attachment 8 (How map finds your current location) at 2.
`
`Attachment 8 (Current location shown on google map) at 3.
`
`
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`
`
`
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`23
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Geographical features cities, streets, etc., on Google
`Maps
`
`Blue Dot indicating location the map
`
`Processor of the wireless communication
`device estimated the location of the
`wireless communication device (Exhibit
`B) from wireless communication network.
`The Blue dot showing estimated location.
`
`
`Source: Location estimation on the Wireless communication device
`Attachment 22 (Location estimation on the Wireless communication device) at 10.
`
`
`
`
`By default the “Location setting”
`is set at “High accuracy” mode,
`wherein, for example, accuracy of
`location of a communications
`device determined based on
`locations of nearby Wi-Fi network
`infrastructure (access points or
`hotspots) is further enhanced or
`fine-tuned by Google Maps Server
`additionally using the said
`communications device’s GPS
`location and the location data
`obtained from the mobile network
`(Cell tower information and/or
`Location of the communications
`device determined through the
`Assisted-GPS method by the said
`mobile network) serving the said
`communications device.
`
`
`
`
`
`24
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`
`Attachment 45 (Google Maps_Android app_Location settings) at 1.
`
`
`Attachment 46 (Find and improve your location’s accuracy - Android - Google Maps Help)
`at 1.
`
`
`
`25
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 44 (How Google uses location information – Privacy & Terms – Google) at 2
`&3.
`
`
`
`
`Wireless communication device receive the location of the
`Wireless communication device (Exhibit B) on Google Map
`from Wireless communication networks (e.g. Verizon, AT&T,
`T-Mobile, etc.)
`
`
`
`26
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 21 (Manage your Pixel phone’s location settings) at 2.
`
`
`
`27
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 40 (Manage your Pixel phone’s location settings) at 3 & 4.
`
`
`
`
`
`28
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`The user of the wireless device can select
`the method of the location estimation
`
`Attachment 33 (Google Maps Not Updating Location) at 4.
`
`
`
`
`
`29
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 38 (Google, Android and Location Tracking) at 2.
`
`
`
`
`
`30
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 38 (Google, Android and Location Tracking) at 5.
`
`
`
`
`
`31
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 38 (Google, Android and Location Tracking) at 6.
`
`
`
`
`
`Attachment 29 (Google Privacy Policy) at 4.
`
`
`
`32
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 39 (Google Map_Permissions) at 1.
`
`Attachment 17 (Cell Towers/Wi-Fi Nodes (RF transceivers) in a wireless communication
`network) at 1.
`
`
`
`
`
`
`
`Attachment 12 (Location of the device determined using cell tower) at 1&2.
`
`
`
`
`33
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps application makes use of wireless communication
`network, having cell towers (Exhibit A) or Wi-Fi access points
`(Exhibit A), to estimate the location of the Wireless
`communication device (Exhibit B).
`
`
`Attachment 12 (Location is estimated using cell tower/wi-fi network) at 3 & 4.
`
`
`
`
`
`Attachment 12 (Location is estimated using cell tower/wi-fi network) at 5.
`
`
`
`34
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`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 41 (Android Location Providers - GPS or Network Provider?) at 1 & 2.
`
`Attachment 42 (Optimize location for battery) at 2.
`
`
`
`
`Attachment 43 (Google Maps Wikipedia) at 5 & 6.
`
`
`35
`
`
`
`
`
`
`
`

`

`Claim 1
`according to
`mapping
`information stored
`within the wireless
`mobile
`communications
`device,
`
`Corresponding Structure in Accused Systems
`Plaintiff contends the Exhibit-B-listed mobile-wireless-communications device’s motherboard
`processor is programmed to process location-service information; i.e., to receive a location of the
`device from the wireless communications network and generate an indication of the device’s
`location.
`For example, the motherboard processor may use Google Maps to obtain the device’s location
`and provide direction from that location to a destination. Wireless mobile communication device-
`including but not limited to Google’s branded devices such as Google Pixel 5, pixel 4a 5G, pixel
`4a, pixel 4 XL, pixel 4, pixel 3a XL, pixel 3a, pixel 3 XL, pixel 3, pixel 2, pixel 2 XL, pixel XL,
`pixel, pixel C or other (third-parties) branded devices such as Samsung Galaxy S20 Ultra, Galaxy
`S20 plus, Galaxy S20, Galaxy Z fold, Galaxy S10, Galaxy A series, etc. (refer Exhibit B for
`complete list) has a processor for example, Quad-Core processor. When wireless communication
`device transceivers and processor are in communication, they are coupled. Further, the Location-
`based Service (LBS) provider, such as Google Map, on the Exhibit-B utilizes the processor
`coupled to the transceiver to estimates/receive the location on mobile wireless communications
`devices (specifically one or more of the mobile wireless communications devices identified on
`Exhibit B) by utilizing wireless communication network or first computer.
`For example, the motherboard processor may use Google Maps to view and find places around
`the globe. Google map can also show your current location and provide direction (including with
`respect to geographic features such as nearby restaurants) from your location/source to any
`destination. In using Google Maps App, the mobile wireless communication device’s
`motherboard processor generates signals for displaying on the device’s screen a blue dot that
`shows the current location of the wireless mobile communication device. The Google map app
`estimates the location of the device from 3 sources: GPS (GPS uses satellites and knows your
`location within a few meters), Wi-Fi (the location of nearby Wi-Fi networks helps Maps know
`where you are), and cell towers (cell tower can be accurate up to a few thousand meters). When
`Google Maps isn’t sure about your location, a light blue circle around the blue dot is shown. You
`might be anywhere within the light blue circle. The smaller the circle, the more certain the app is
`about your location.
`Furthermore, Plaintiff contends Google Maps App provides flexibility to download maps on SD
`card/internal memory of communication device (Exhibit B) examples of compatible devices is
`Samsung Galaxy S20, Pixel 4a, Pixel 4a 5G, Pixel 5, etc., and navigate offline. When internet is
`slow or mobile data is expensive, or communication device cannot connect to internet, an area can
`be saved to phone or tablet (Exhibit B) from Google maps app and use it when offline.
`Communication device can use Offline maps for Navigation through the downloaded area without
`internet.
`The following exemplifies the existence of this limitation in Accused Systems:
`
`
`
`
`36
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Preloaded application Google Map on the Wireless mobile device utilizes the
`processor coupled to the transceiver to estimates/receive the location on mobile
`wireless communications device by utilizing wireless communication network
`
`Attachment 4 (Processor of Google Pixel 4a, Pixel 4a 5G and Pixel 5) at 1.
`
`
`
`
`
`37
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20. Current location of the device is
`determined if location is enabled.
`
`
`Attachment 5 (how to use turn by turn Google map) at 1.
`
`
`
`
`
`38
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20.
`
`
`Attachment 5 (how to use turn by turn google map) at 2&3.
`
`
`
`
`
`39
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless communication networks (e.g.
`Verizon, AT&T, T-Mobile, etc.)
`estimate/determine the location of the
`Wireless communication device (Exhibit B)
`on Google Maps.
`
`
` Attachment 6 (Find Current Location on Google map) at 1.
`
`
`
`
`
`Attachment 8 (How map finds your current location) at 2.
`
`Attachment 8 (Current location shown on google map) at 3.
`
`
`
`
`
`
`
`40
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Blue Dot indicating location the map
`
`Processor of the wireless communication
`device estimated the location of the
`wireless communication device (Exhibit
`B) from wireless communication network.
`The Blue dot showing estimated location.
`
`
`Geographical features cities, streets, etc., on Google Maps
`
`Source: Location estimation on the Wireless communication device
`Attachment 22 (Location estimation on the Wireless communication device) at 10.
`
`
`
`
`
`41
`
`
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`Attachment 16 (How to use Pixel 4a GPS and location-based services) at 9.
`
`
`The Google maps are made available
`both online and offline, and are stored
`in wireless communication device
`(Exhibit B) memory
`
`
`Attachment 10 (Google Map-Download an offline map on pixel 4a) at 1.
`
`
`
`
`
`42
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`The Google maps are made available both online
`and offline, and are stored in wireless
`communication device (Exhibit B) memory
`
`Attachment 9 (Mapping information stored on wireless communication device) at 1.
`
`
`
`
`
`43
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Attachment 32 (Get directions & show routes) at 3.
`
`
`
`
`
`44
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`
`
`Attachment 31 (Download google map) at 2.
`
`Plaintiff contends the motherboard processor (i.e., processor on the motherboard) of each Exhibit-
`B-listed item (i.e., mobile
`Wireless communications device) meets this limitation. The processor processes location-service
`information, including
`displaying user navigation information according to the device’s location with regards to
`geographic features and a user-specified
`Destination. For example, using Google map app for more examples of location services
`processed by each Exhibit-B device’s motherboard processor) the device user locates the device’s
`current location on the google map app and then provide details for
`a destination on the options, provided in the Google map app. The user can then navigate (i.e., the
`processor processes display information) in real time from current location to destination. The
`processor displays navigation in the Google Maps app to display turn-by-turn directions. Using
`the Google map app, the processor will show the directions and use real-time traffic information
`to find the best route to the specified destination.
`The following exemplifies this limitation’s existence in Accused Systems:
`
`and wherein the first
`processor
`determines user
`navigation
`information and
`displays the user
`navigation
`information
`according to the
`location of the
`wireless mobile
`communications
`device with respect
`to the geographic
`features and a
`destination
`specified at the
`wireless mobile
`communications
`device,
`
`
`
`45
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Preloaded application Google Map on the Wireless mobile device utilizes the
`processor coupled to the transceiver to estimates/receive the location on mobile
`wireless communications device by utilizing wireless communication network
`
`Attachment 4 (Processor of Google Pixel 4a, Pixel 4a 5G, and Pixel 5) at 1.
`
`
`
`
`
`46
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20. Current location of the device is
`determined if location is enabled
`
`
`Attachment 5 (how to use turn by turn Google map) at 1.
`
`
`
`
`
`47
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Google Maps preloaded in the Wireless mobile
`communication devices (Exhibit B), such as
`Galaxy S20.
`
`
`Attachment 5 (how to use turn by turn google map) at 2&3.
`
`
`
`
`
`48
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Wireless communication networks (e.g.
`Verizon, AT&T, T-Mobile, etc.)
`estimate/determine the location of the
`Wireless communication device (Exhibit B)
`on Google Maps.
`
`
` Attachment 6 (Find Current Location on Google map) at 1.
`
`
`
`
`
`Attachment 8 (How map finds your current location) at 2.
`
`Attachment 8 (Current location shown on google map) at 3.
`
`
`
`
`
`
`
`49
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`Blue Dot indicating location the map
`
`Processor of the wireless communication
`device estimate the location of the
`wireless communication device (Exhibit
`B) from wireless communication network.
`The Blue dot showing estimated location.
`
`
`Geographical features cities, streets, etc., on Google Maps
`
`Source: Location estimation on the Wireless communication device
`Attachment 22 (Location estimation on the Wireless communication device) at 10.
`
`
`
`
`
`50
`
`

`

`Claim 1
`
`Corresponding Structure in Accused Systems
`
`The Google maps are made available
`both online and offline, and are
`stored in wireless communication
`de