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Andrew Lund
Ms. Vanstraten
English 10
30 March 2016

Cuozzo speed technologies v. Garmin international LLC.


In the world of technology, innovation is a difficult and expensive process. This heavy
price for improvement drives some to try to copy someone else's idea. Garmin, an international
technology company, is most well-known for its GPS technology. Garmin recently started
including a speed limit indicator in their GPS products that alerts the driver when they begin to
exceed the speed limit. Shortly afterward, another technology company, Cuozzo speed
technologies, brought forth a complaint to Garmin about a previously made patent for a speed
limit indicator. After Garmin refused to admit fault or offer compensation, Cuozzo took the case
to court. In the case of Cuozzo v. Garmin, it is apparent that Garmin infringed on the patent made
by Cuozzo for a speed limit indicator, and this is apparent in the incorporation of the exact same
concept and product of a speed limit indicator in multiple Garmin products.
The case of Cuozzo v. Garmin started when Garmin began to produce GPS devices with a
speed limit indicator. Cuozzo had developed a speed limit indicator before, that was built into a
vehicle. The Cuozzo developed speed limit indicator also relied on an array of gauges. The
lawyer for Garmin argued that Garmin did not infringe upon the patent because of the lack of the
use of a gauge array (Garmin 11). Garmin also highlighted the fact that their speed limit indicator
was not integrated into the vehicle, but rather into the GPS itself.

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The speed limit indicator designed by Cuozzo uses a GPS system to determine the legal
speed limit for that area. A wheel behind the needle of the speedometer has red and white regions
showing the speeds that are within and outside of the legal limit. The wheel rotates to match the
legal speed limit when switching between roads. If the speed of the vehicle becomes greater than
that of the legal limit, the needle of the speedometer will pass into the red region of the gauge,
giving the driver a visual indication that they need to slow down, and an audible tone is
generated to warn the driver as well (Cuozzo). The Garmin developed feature for Garmin GPS
products uses the same system to detect what the current speed limit is, and warns the driver by
displaying the drivers current speed in white font on the corner of the GPS display, and if the
speed limit is exceeded, the font of the numbers becomes red (DriveLuxe).
Even though Garmin did not infringe upon the technical details of the Cuozzo held
patent, Cuozzo has argued that Garmin copied the idea of a speed limit indicator from Cuozzo.
The copying of an idea, if apparent enough, is grounds for a lawsuit. Knowing this, Cuozzo sued
on the grounds of fraudulent concept replication. Cuozzo sued for recognition, a lump sum
payout, and a royalty on all products sold with a speed limit indicator. Without the technical
details on their side, this suit proved difficult for Cuozzo.
On March 5, 2013, the patent trial and appeal board formed a verdict. The verdict was to
the favor of Garmin. The verdict stated that Garmin was not infringing upon Cuozzo's patent
because of a lack of technical based evidence given by Cuozzo. The board also determined that
Garmin "did not intentionally copy the idea of a speed limit indicator... and made the innovation
independently..." (Garmin 9). This cancels the claim that Garmin copied the idea of the speed

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limit indicator and frees Garmin of any blame thereof. The very evidence that Cuozzo lacked
was a major cause in their loss of the case.
After Cuozzo was denied by the patent trial and appeal board, they brought the case to
the federal court of appeals. The case ended up making its way to the supreme courts attention at
the end of 2015. The case is now in a waiting list to be heard before the supreme court along with
many other cases later this year. Cuozzo is hoping that the supreme court will view their case
differently than the board and force Garmin to provide Cuozzo with ample compensation
(Quinn). Although the patent trial and appeal board did not force Garmin to take any action
regarding the previously made patent, it is apparent that Garmin infringed on the patent made by
Cuozzo for a speed limit indicator, and this is apparent in the incorporation of the exact same
concept and product of a speed limit indicator in multiple Garmin products. Garmin may not
have necessarily infringed upon some of the deep technical details, they certainly infringed upon
the use of the concept of a speed limit indicator. The board determined that because Garmin did
not purposefully copy the idea, they were not at fault for the use of it to make money. This
determination conflicts with the principle of fair game where if an idea is even accidentally
copied, the original maker of the idea should get some compensation; a "piece of the pie." Also,
the determination that Garmin made no extra money off of the installment of a speed limit
indicator is also very arguable and could be disproved with a more extensive study.

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Works Cited
GARMIN INTERNATIONAL, INC. ET AL. 18. THE PATENT TRIAL AND APPEAL BOARD. 5
Mar. 2013. Print.
"Garmin DriveLuxe 50 LMTHD Specs." Garmin Products. Garmin, n.d. Web. 9 Apr.
2016. <https://buy.garmin.com/en-US/US/on-the-road/automotive/garmindriveluxe-50lmthd/prod523329.html>.
Cuozzo, Giuseppe A. Speed Limit Indicator and Method for Displaying Speed and the
Relevant Speed Limit. Giuseppe A. Cuozzo, assignee. Patent US6778074 B1.
18 Mar. 2002. Print.
Quinn, Gene. "Supreme Court Accepts Cuozzo Speed Technologies IPR Appeal IPWatchdog.com | Patents & Patent Law." IPWatchdogcom Patents Patent Law
Supreme Court Accepts Cuozzo Speed Technologies IPR Appeal Comments.
IPWatchdog, 15 Jan. 2016. Web. 09 Apr. 2016.

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