DCT
2:23-cv-00265
McWane Inc v. Locket IP LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: McWane, Inc. and McWane Plant and Industrial, LLC (Delaware)
- Defendant: Locket IP LLC (Texas)
- Plaintiff’s Counsel: Maynard, Cooper & Gale, P.C.
- Case Identification: McWane, Inc. and McWane Plant and Industrial, LLC v. Locket IP LLC, 2:23-cv-00265, N.D. Ala., 03/02/2023
- Venue Allegations: Venue is asserted in the Northern District of Alabama on the basis that a substantial part of the events giving rise to the claim occurred in the district, specifically Defendant's infringement accusations, which were directed via letter and email to Plaintiffs' executives located in Alabama.
- Core Dispute: Plaintiffs seek a declaratory judgment that their commercial websites do not infringe Defendant’s patent related to methods for rearranging elements in a graphical user interface.
- Technical Context: The technology concerns user interface design, specifically a method for automatically identifying and displaying "regions of interest" within multiple on-screen "cards" or windows based on user preferences to reduce manual navigation.
- Key Procedural History: This declaratory judgment action was filed after Plaintiffs received a notice letter dated November 25, 2022, from Defendant's agent, IP Edge LLC, alleging infringement and providing a claim chart. The complaint notes that Defendant has filed numerous lawsuits asserting the same patent against other companies, many of which allegedly settled quickly, and that several other companies have also filed declaratory judgment actions against Defendant.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-22 | '832 Patent Priority Date |
| 2019-12-24 | '832 Patent Issue Date |
| 2022-11-25 | Locket IP sends notice letter to McWane |
| 2023-03-02 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 10,514,832, "Method for Locating Regions of Interest in a User Interface," issued December 24, 2019.
The Invention Explained
- Problem Addressed: The patent identifies that when a user is presented with multiple windows or "cards" of content, it can be "cumbersome" for the user to "scroll through each window or card individually to find specific areas or topics of interest" ('832 Patent, col. 1:28-33).
- The Patented Solution: The invention proposes a method to automatically address this problem. In response to a single user command, the system determines "regions of interest" within multiple displayed cards based on the user's preferences and then rearranges the cards so that these specific regions are shown, "without requiring a user to manipulate such cards/windows individually" ('832 Patent, col. 1:42-45). This process can involve moving cards up or down and removing cards that do not contain a region of interest to consolidate the view ('832 Patent, col. 10:41-50; Figs. 15-16).
- Technical Importance: The described method aims to improve the efficiency and usability of graphical user interfaces, particularly on devices where extensive manual manipulation of on-screen elements is difficult or time-consuming ('832 Patent, col. 1:34-37).
Key Claims at a Glance
- The complaint identifies independent claims 1 (method), 7 (apparatus), and 13 (computer-readable medium) as being at the center of the dispute (Compl. ¶¶ 38-40).
- The essential elements of independent claim 1 include:
- determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences;
- updating for display the plurality of cards to visibly show in a display area of a display device the at least one region of interest of multiple cards included in a first group of the plurality of cards;
- wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area; and
- to visibly display the at least one region of interest within all of the multiple cards included in the first group within the display area of the display device.
- The complaint notes that the dispute extends to claims dependent on these independent claims (Compl. ¶ 43).
III. The Accused Instrumentality
Product Identification
- The "Waterman Website," which is operated by Waterman, a division of Plaintiff McWane Plant and Industrial, LLC, as well as Plaintiffs' other websites (Compl. ¶¶ 14, 18, 42).
Functionality and Market Context
- The complaint describes McWane as a "leading manufacturer and supplier of water distribution systems and equipment" (Compl. ¶ 12). The accused Waterman Website is presumably a commercial website related to these products.
- The complaint does not provide a detailed technical description of the accused website's functionality. Instead, it asserts that the websites do not perform the key functions required by the patent claims, such as determining regions of interest based on user preferences or repositioning on-screen elements in the claimed manner (Compl. ¶ 42). The core of Plaintiffs' non-infringement position is a fundamental lack of the claimed functionality in the accused instrumentality.
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
As this is a complaint for a declaratory judgment of non-infringement, the following table summarizes Plaintiffs' specific denials of infringement with respect to Claim 1 of the ’832 Patent.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences | Plaintiff asserts its websites do not perform this step of determining regions of interest within "cards" by searching for previous user preferences. | ¶42 | col. 11:56-60 |
| updating for display the plurality of cards to visibly show in a display area of a display device the at least one region of interest of multiple cards included in a first group of the plurality of cards | Plaintiff asserts its websites do not perform this step of updating a display to visibly show a region of interest for multiple cards in a "first group." | ¶42 | col. 11:60-65 |
| wherein said updating includes repositioning the plurality of cards to remove cards not included in the first group from the display area and to visibly display the at least one region of interest within all of the multiple cards included in the first group... | Plaintiff asserts its websites do not perform this step of repositioning cards to remove some from the display and show the regions of interest for all cards remaining in the group. | ¶42 | col. 11:65-col. 12:4 |
- Identified Points of Contention:
- Technical Questions: A primary factual dispute will be whether the accused websites perform any function that could be characterized as automatically repositioning content display based on user preferences. Plaintiffs' complaint suggests a complete operational mismatch between the accused websites and the claimed method (Compl. ¶ 42). The case may require evidence on how the websites' user interfaces are generated and whether they dynamically adapt in the manner claimed.
- Scope Questions: The dispute raises the question of whether standard website features, such as search filters or personalized content modules, fall within the scope of the patent's claims. For example, does a filtered search result page constitute "repositioning the plurality of cards to remove cards not included in the first group"?
V. Key Claim Terms for Construction
- The Term: "regions of interest"
- Context and Importance: This term is central to the invention, defining what the system must identify and present to the user. Its construction will determine whether the accused websites' display of information meets this limitation. Practitioners may focus on this term because its scope will dictate whether any personalized content on a website qualifies.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that regions of interest can be "topics, metadata, graphics, and the like" determined from "user preference information" ('832 Patent, col. 10:12-15). This could support a reading that covers a wide variety of personalized content.
- Evidence for a Narrower Interpretation: The figures and background description frame the invention as solving the problem of having to scroll within a given window or card ('832 Patent, col. 1:28-33). Figures 13 and 14, for example, show "regions of interest" (1325, 1335, 1345) as specific visual sub-parts of larger "card" containers (1320, 1330, 1340), suggesting a more structured, graphical definition rather than just a topic.
- The Term: "repositioning the plurality of cards to remove cards not included in the first group"
- Context and Importance: This limitation describes a specific mechanism for updating the display. The infringement analysis will depend on whether this requires a specific type of visual rearrangement, which Plaintiffs allege their websites do not perform (Compl. ¶ 42).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue this language covers any filtering process where non-relevant items are hidden from view, a common function in web interfaces.
- Evidence for a Narrower Interpretation: The patent provides a specific embodiment in Figures 15 and 16 where "intervening cards" (1530, 1540, 1560) that lack an area of interest are "deleted/removed from display area," causing the remaining cards (1520, 1570) to be moved together to fill the space ('832 Patent, col. 10:60-63). This suggests a specific visual consolidation, not merely hiding non-matching results.
VI. Other Allegations
- Indirect Infringement: Defendant's notice letter allegedly accused Plaintiffs of infringement by "instructing Waterman customers to use" the website (Compl. ¶ 18). The complaint preemptively denies any active inducement or contributory infringement, stating that Plaintiffs do not instruct others to perform the claimed steps and that the accused instrumentality is suitable for substantial non-infringing use (Compl. ¶¶ 44-47).
- Willful Infringement: As a declaratory judgment action filed by the accused infringer, the complaint does not allege willfulness. However, it establishes that Defendant provided Plaintiffs with notice of the alleged infringement on November 25, 2022 (Compl. ¶ 13). This date of notice would be relevant to any subsequent claim of willful infringement that Defendant might bring.
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of operational reality: what technical evidence, if any, can Defendant produce to show that Plaintiffs' commercial websites actually perform the specific, multi-step process of determining "regions of interest" based on "previous user preferences" and then "repositioning" and "removing" on-screen "cards" as required by Claim 1? Plaintiffs' complaint frames the dispute as a fundamental absence of such functionality.
- The case will also turn on a question of definitional scope: can the patent's claim terms, which appear to describe a specific type of graphical user interface for managing multiple content windows, be construed broadly enough to read on the more conventional features of a commercial e-commerce website, such as its search and filtering capabilities?