UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

NAVBLAZER, LLC,

Apple

v.

APPLE, INC.,

Defendant

Case No. 6:20-cv-85

JURY TRIAL DEMANDED

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

NavBlazer, LLC (“NavBlazer”) hereby files this Original Complaint for Patent Infringement

against Defendant Apple, Inc. (“Apple”), and alleges, upon 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. Apple is a California corporation with its principal place of business at 1 Infinite Loop, 

Cupertino, California 95014. Apple may be served with process through its registered agent CT 

Corporation System, located at 1999 Bryan St., Suite 900, Dallas, Texas 75201. Apple designs, 

manufactures, makes, uses, imports into the United States, sells, and/or offers for sale in the 

United States Apple smartphones, tablets, smartwatches, macs, and Apple servers. Apple’s 

smartphones, tablets, smartwatches, and macs are marketed, used, offered for sale, and/or sold 

throughout the United States, including within this district.

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JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331, 1332, 1338, 

and 1367.

4. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and 1400(b).

5. This Court has personal jurisdiction over Apple. Apple has continuous and systematic business 

contacts with the state of Texas. Apple, 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. Apple, 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. Apple has offered and sold 

and continues to offer and sell these infringing products and services in this district, including at 

physical Apple stores located within this district. Apple 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 Apple’s servers, in this district, including when 

Apple and its customers put the accused devices into service and receive a benefit, and Apple is 

liable for these additional acts of direct infringement and indirect infringement in this district. 

Apple 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. 

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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 in Alice. The patent examiner found that the claims are in fact patent eligible under 35 

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ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT PAGE | 4

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. 

DEFENDANT’S PRODUCTS

13. Upon information and belief, Apple, under the brand name “iPhone” and “iPad” sells, advertises, 

offers for sale, uses, or otherwise provides mobile devices with navigation functionality. On 

information and belief, these products include, but are not necessarily limited to, “iPhone 5C,” 

“iPhone 5S,” “iPhone 6,” “iPhone 6 Plus,” “iPhone 6S,” “iPhone 6S Plus,” “iPhone SE,” “iPhone

7,” “iPhone 7 Plus,” “iPhone 8,” “iPhone 8 Plus,” “iPhone X,” “iPhone XS,” “iPhone XS Max,” 

“iPhone XR,” “iPhone 11,” “iPhone 11 Pro,” “iPhone 11 Pro Max,” “iPad” (2nd generation and 

higher), “iPad 2,” “iPad Air,” “iPad Mini” (all generations), “iPad Mini 2,” iPad Mini 3,” “iPad 

Air 2,” “iPad Mini 4,” and “iPad Pro” (all generations). 

COUNT I

(Infringement of U.S. Patent No. 9,885,782)

14. Plaintiff incorporates the above paragraphs by reference.

15. Apple 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, Apple has directly infringed and continues to directly infringe at 

least Claims 1, 2, 7 and 8 of the ’782 Patent by making, using, importing, selling, and/or, 

offering for sale the Accused Instrumentalities.

17. Defendant, with knowledge of the ’782 Patent, also infringes at least Claims 1, 2, 7 and 8 of the 

’782 Patent by inducing others to infringe the ’782 Patent. In particular, Defendant intends to 

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induce its customers to infringe the ’782 Patent by encouraging its customers to use the Accused 

Instrumentalities in a manner that results in infringement.

18. Defendant also induces others, including its customers, to infringe at least Claims 1, 2, 7 and 8 of 

the ’782 Patent by providing technical support for the use of the Accused Instrumentalities. 

19. Upon information and belief, at all times Defendant owns and controls the operation of the 

Accused Instrumentalities in accordance with an end user license agreement.

20. By way of example, the Accused Instrumentalities infringes 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. The iPhone XS and iPad are representative examples and are

mobile devices (apparatuses). See Figure 1 below, showing a picture of the iPhone XS. See also 

Figure 2 below, showing a picture of the iPad.

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 1 https://www.apple.com/iphone-xs/display/ - 9/10/19

Figure 11 - Apple’s iPhone XS

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 2 https://www.apple.com/ipad-9.7/specs/ - 9/10/19 3 https://www.apple.com/iphone-xs/specs/ - 9/10/19

Figure 22 - Apple’s iPad.

21. The iPhone XS and iPad both use a global positioning device, wherein the global positioning device 

determines a location of the apparatus or a location of a vehicle.

22. See Figures 3 and 4 below, which are screenshots from Apple’s website describing the “location” 

features of the iPhone XS and iPad, respectfully, which each include “Assisted GPS.” The iPhone XS and 

the iPad must necessarily include a global positioning device in order to offer “Assisted GPS.”

Figure 33 - iPhone XS location specifications

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 4 https://www.apple.com/ipad-9.7/specs/ - 9/10/19 5 https://www.apple.com/iphone-xs/specs/ - 9/10/19

Figure 44 - iPad location specifications

23. See also Figures 5 and 6 below, which are screenshots from Apple’s website listing the applications that 

come “built-in” with the iPhone XS and iPad, respectfully. The applications include Apple’s “Maps” 

application, which provides location information and navigation information utilizing Apple’s “Assisted 

GPS.”

Figure 55 - iPhone built-in applications

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 6 https://www.apple.com/ipad-9.7/specs/ - 9/10/19

Figure 66 - iPad built-in applications

24. See also Figures 7 and 8 below, which are screenshots from Apple’s website describing Apple’s “Maps” 

application. Apple states that “[w]ith turn-by-turn spoken directions, interactive 3D views, proactive 

suggestions, lane guidance, and more, Maps gets you where you want to go.” 

25. In Fig. 8, Apple states that “Maps predicts the places you’re most likely to go and recommends the fastest 

way to get there based on traffic, time of day, your location, and your schedule” (emphasis added). Fig. 8 

also includes a mock-up of an iPhone running the Maps application, in which the blue dot on the map 

represents the current location of the device (i.e., iPhone XS or iPad). Thus, the iPhone XS and iPad are 

capable of determining “a location of the apparatus” using “Assisted GPS” and displaying the location of 

the apparatus using the “Maps” application.

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 7 https://www.apple.com/ios/maps/ - 9/10/19 8 https://www.apple.com/ios/maps/ - 9/10/19

Figure 77 - Maps application

Figure 88 - Maps application

26. The iPhone XS and iPad both use a processing device, wherein the processing device processes 

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 9 https://www.apple.com/iphone-xs/a12-bionic/ - 9/10/19

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 9 below, which is a screenshot of Apple’s website explaining the “Apple-designed CPU” 

(i.e., processor) used in the iPhone XS. See also Figure 10 below, which is a screenshot of Apple’s 

website indicating that the A10 Fusion chip (i.e., processor) is used in the iPad.

28. The processing devices used in the iPhone XS and iPad are 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 “Assisted GPS” and the “Maps” application.

Figure 99 - iPhone XS CPU

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 10 https://www.apple.com/ipad-9.7/specs/ - 9/10/19

Figure 1010 - iPad A10 chip

29. See also Figure 11 below, which is a screenshot from Apple’s website describing Apple’s “Maps” 

application. Apple states that “Maps helps you find the way to your destination with turn-by-turn 

spoken directions, guidance on which lane you should be in, and the current speed limit.” Fig. 11 also 

includes a mock-up of an iPhone running the Maps application, in which the device’s current location 

is shown as a blue arrow with a circle around it and the travel route is highlighted with a blue line.

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 11 https://www.apple.com/ios/maps/ - 9/10/19

Figure 1111 - Maps application

30. The iPhone XS and iPad both use 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 11, reproduced below, describing that “Maps helps you find the way to your destination 

with turn-by-turn spoken directions, guidance on which lane you should be in, and the current speed 

limit.” Fig. 11 also includes a mock-up of an iPhone running the Maps application, in which the 

device’s current location is shown as a blue arrow with a circle around it and the travel route is 

highlighted with a blue line. The iPad is also bundled with the Maps application and would operate in 

the same manner.

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Figure 11 - Maps application

32. The iPhone XS and iPad both use a receiver, wherein the receiver receives traffic information or 

information regarding a traffic condition.

33. See Figure 8, reproduced below, in which Apple states that “Maps predicts the places you’re most 

likely to go and recommends the fastest way to get there based on traffic, time of day, your location, 

and your schedule” (emphasis added).

34. See also Figure 11, reproduced below, describing that “Maps helps you find the way to your 

destination with turn-by-turn spoken directions, guidance on which lane you should be in, and the 

current speed limit. Along the way, it can factor in real-time traffic information, so you’ll know 

exactly how long until you arrive” (emphasis added).

35. A receiver is necessarily required in order to receive real-time traffic information.

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Figure 8 - Maps application

Figure 11 - Maps application

36. The iPhone XS and iPad both provide the traffic information or the information regarding a traffic 

condition via the display device or via the speaker.

37. See Figure 12 below, which is a screenshot from Apple’s website that explains how to display traffic 

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 12 https://support.apple.com/guide/iphone/get-traffic-and-other-info-iphbe0a968ca/ios - 9/10/19

conditions on the “Maps” application on an iPhone. Apple states that “[o]range indicates slowdowns 

and red indicates stop-and-go traffic.”

Figure 1212 - Traffic information on Maps application.

38. See also Figure 13 below, which is a screenshot from Apple’s website that explains how to display 

traffic conditions on the “Maps” application on an iPad. Apple states that “[o]range indicates 

slowdowns and red indicates stop-and-go traffic.”

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 13 https://support.apple.com/guide/ipad/get-traffic-and-other-info-ipad9934089f/ios - 9/10/19 14 https://support.apple.com/guide/ipad/get-traffic-and-weather-info-ipad9934089f/ipados - 1/30/20

Figure 1313 - Traffic information on Maps application

39. By way of another example, the Accused Instrumentalities infringe Claim 8 of the ’782 Patent by use 

of an apparatus that receives information regarding a weather condition and that provides the 

information regarding the weather condition via a display device. See Figure 14 below, describing how 

one can zoom on the map to obtain current weather conditions.

Figure 1414 - Traffic information on Maps application

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(Infringement of U.S. Patent No. 9,075,136)

40. Plaintiff incorporates the above paragraphs by reference.

41. Apple 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, Apple has infringed and continues to infringe at least Claims 55, 

56, 61, 62, 66, 69-71, 76, 77, 79, 82, 85, 86, 88, 89, 91, 94, 95, 97 and 98 of the ’136 Patent by 

making, using, importing, selling, and/or, offering for sale the Accused Instrumentalities. 

43. Defendant, with knowledge of the ’136 Patent, infringes the ’136 Patent by inducing others to 

infringe the ’136 Patent. In particular, Defendant intends to induce its customers to infringe the 

’136 Patent by encouraging its customers to use the Accused Instrumentalities in a manner that 

results in infringement.

44. Defendant also induces others, including its customers, to infringe the ’136 Patent by providing 

technical support for the use of the Accused Instrumentalities. 

45. Upon information and belief, at all times Defendant owns and controls the operation of the 

Accused Instrumentalities in accordance with an end user license agreement.

46. By way of example, the Accused Instrumentalities infringes 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. On information and belief, the iPhone XS and iPad are 

mobile devices (apparatuses). See Figure 1 below, showing a picture of the iPhone XS. See also 

Figure 2 below, showing a picture of the iPad.

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Figure 1 - Apple’s iPhone XS

Figure 2 - Apple’s iPad

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47. The iPhone XS and iPad both use a global positioning device, wherein the global positioning device 

determines a location of the apparatus or a location of a vehicle.

48. See Figures 3 and 4 below, which are screenshots from Apple’s website describing the “location” 

features of the iPhone XS and iPad, respectfully, which each include “Assisted GPS.” The iPhone XS and 

the iPad must necessarily include a global positioning device in order to offer “Assisted GPS.”

Figure 3 - iPhone XS location specifications

Figure 4 - iPad location specifications

49. See also Figures 5 and 6 below, which are screenshots from Apple’s website listing the applications that 

come “built-in” with the iPhone XS and iPad, respectfully. The applications include Apple’s “Maps” 

application, which provides location information and navigation information utilizing Apple’s “Assisted 

GPS.”

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Figure 5 - iPhone built-in applications

Figure 6 - iPad built-in applications

50. See also Figures 7 and 8 below, which are screenshots from Apple’s website describing Apple’s “Maps” 

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application. Apple states that “[w]ith turn-by-turn spoken directions, interactive 3D views, proactive 

suggestions, lane guidance, and more, Maps gets you where you want to go.” 

51. In Fig. 8, Apple states that “Maps predicts the places you’re most likely to go and recommends the fastest 

way to get there based on traffic, time of day, your location, and your schedule” (emphasis added). Fig. 8 

also includes a mock-up of an iPhone running the Maps application, in which the blue dot on the map 

represents the current location of the device (i.e., iPhone XS or iPad). Thus, the iPhone XS and iPad are 

capable of determining “a location of the apparatus” using “Assisted GPS” and displaying the location of 

the apparatus using the “Maps” application.

Figure 7 - Maps application

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Figure 8 - Maps application

52. The iPhone XS and iPad both use 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.

53. See Figure 9 below, which is a screenshot of Apple’s website explaining the “Apple-designed CPU” 

(i.e., processor) used in the iPhone XS. See also Figure 10 below, which is a screenshot of Apple’s 

website indicating that the A10 Fusion chip (i.e., processor) is used in the iPad.

54. The processing devices used in the iPhone XS and iPad are 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 “Assisted GPS” and the “Maps” application.

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Figure 9 - iPhone XS CPU

Figure 10 - iPad A10 chip

55. See also Figure 11 below, which is a screenshot from Apple’s website describing Apple’s “Maps” 

application. Apple states that “Maps helps you find the way to your destination with turn-by-turn 

spoken directions, guidance on which lane you should be in, and the current speed limit.” Fig. 11 also 

includes a mock-up of an iPhone running the Maps application, in which the device’s current location 

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is shown as a blue arrow with a circle around it and the travel route is highlighted with a blue line.

Figure 11 - Maps application

56. The iPhone XS and iPad both use 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 11, reproduced below, describing that “Maps helps you find the way to your destination 

with turn-by-turn spoken directions, guidance on which lane you should be in, and the current speed 

limit.” Fig. 11 also includes a mock-up of an iPhone running the Maps application, in which the 

device’s current location is shown as a blue arrow with a circle around it and the travel route is 

highlighted with a blue line. The iPad is also bundled with the Maps application and would operate in 

the same manner.

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Figure 11 - Maps application

58. The iPhone XS and iPad both use a receiver, wherein the receiver receives traffic information or 

information regarding a traffic condition.

59. See Figure 8, reproduced below, in which Apple states that “Maps predicts the places you’re most 

likely to go and recommends the fastest way to get there based on traffic, time of day, your location, 

and your schedule” (emphasis added).

60. See also Figure 11, reproduced below, describing that “Maps helps you find the way to your 

destination with turn-by-turn spoken directions, guidance on which lane you should be in, and the 

current speed limit. Along the way, it can factor in real-time traffic information, so you’ll know 

exactly how long until you arrive” (emphasis added).

61. A receiver is necessarily required in order to receive real-time traffic information.

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Figure 8 - Maps application

Figure 11 - Maps application

62. The iPhone XS and iPad both provide the traffic information or the information regarding a traffic 

condition via the display device or via the speaker.

63. See Figure 12 below, which is a screenshot from Apple’s website that explains how to display traffic 

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conditions on the “Maps” application on an iPhone. Apple states that “[o]range indicates slowdowns 

and red indicates stop-and-go traffic.”

Figure 12 - Traffic information on Maps application

64. See also Figure 13 below, which is a screenshot from Apple’s website that explains how to display 

traffic conditions on the “Maps” application on an iPad. Apple states that “[o]range indicates 

slowdowns and red indicates stop-and-go traffic.”

Figure 13 - Traffic information on Maps application

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65. By way of another example, the Accused Instrumentalities infringe Claims 62 of the ’136 Patent 

by use of an apparatus that receives information regarding a weather condition and that provides 

the information regarding the weather condition via a display device. See Figure 14 below, 

describing how one can zoom on the map to obtain current weather conditions.

Figure 14 - Traffic information on Maps application

PRAYER FOR RELIEF

WHEREFORE, NavBlazer respectfully requests the Court enter judgment against 

Defendant:

1. Declaring that Apple has infringed each of the Patents-in-Suit;

2. Awarding NavBlazer its damages suffered as a result of Apple’s infringement of the Patents-inSuit;

3. Awarding NavBlazer its costs, attorneys’ fees, expenses, and interest; 

4. Awarding NavBlazer ongoing post-trial royalties; and

5. Granting NavBlazer such further relief as the Court finds appropriate.

JURY DEMAND

NavBlazer demands trial by jury, under Fed. R. Civ. P. 38.

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Dated: February 4, 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

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