TomTom, Inc. v. Adolph, No. 14-1699 (Fed. Cir. 2015)Annotate this Case
The 836 patent describes “[a] method and device for generating, merging and updating data” that can then be used to provide a mobile unit with current, and continuously updated, accurate road network, route, and traffic information, “to establish a method to generate appropriate data utilizable for a practical destination tracking system which carries out a permanent self-updating and with data generation which requires little effort. The method is also appropriate for deriving destination tracking data from the data generated in accordance with the aforesaid method.” Claim 1, the only asserted independent claim, indicates that, as the mobile unit (e.g., an automobile) travels, its location is determined at set time intervals and it generates and stores the data measured at each node. In a suit accusing TomTom’s customer of infringing the patent’s European counterpart, TomTom sought a declaratory judgment that the 836 patent was invalid as obvious and anticipated. The court construed: “destination tracking system of at least one mobile unit,” “generating and updating data for use in,” “node,” and “the storage device,” the parties requested judgment of non-infringement. The Federal Circuit reversed, stating that the terms should be construed to reflect their plain and ordinary meaning.