DCT
2:22-cv-06995
Local Gear Inc v. Locket IP LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Local Gear Inc. dba locally.com (Louisiana)
- Defendant: Locket IP LLC (Texas)
- Plaintiff’s Counsel: Buchalter
- Case Identification: 2:22-cv-06995, C.D. Cal., 09/27/2022
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because a substantial part of the events giving rise to the claim occurred in the district, specifically a demand letter sent by Defendant to Plaintiff's customer located there.
- Core Dispute: Plaintiff seeks a declaratory judgment that its software system does not infringe Defendant's patent related to user interfaces that automatically rearrange content based on user preferences, and further seeks to have the patent declared invalid and unenforceable.
- Technical Context: The technology involves methods for improving graphical user interfaces on devices by automatically identifying and displaying "regions of interest" from multiple content "cards" or windows, thereby reducing the need for manual searching and scrolling.
- Key Procedural History: The complaint states this action was filed in response to a demand letter and claim chart sent by Defendant Locket IP to Plaintiff's customer, Shimano North American Fishing, Inc., on August 26, 2022. The complaint characterizes Locket IP as a non-practicing entity whose licensing advisor is IP Edge LLC.
Case Timeline
| Date | Event |
|---|---|
| 2010-12-22 | U.S. Patent No. 10,514,832 Earliest Priority Date |
| 2019-12-24 | U.S. Patent No. 10,514,832 Issue Date |
| 2022-08-26 | Defendant sends demand letter to Plaintiff's customer |
| 2022-09-27 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,514,832 - "Method for Locating Regions of Interest in a User Interface" (Issued Dec. 24, 2019)
The Invention Explained
- Problem Addressed: The patent describes the task of finding specific information across multiple open windows or "cards" on a media device as potentially "cumbersome," particularly when the display area is limited and requires a user to scroll through each card individually. (’832 Patent, col. 1:26-37).
- The Patented Solution: The invention provides a method where, upon a single user command, the system automatically identifies "regions of interest" within multiple on-screen cards and rearranges the cards to make those specific regions visible to the user. (’832 Patent, Abstract; col. 1:39-44). The system determines what constitutes a "region of interest" by referencing user preference information, such as a user profile or past viewing habits, and then applies a search function to locate that content on the displayed cards. (’832 Patent, col. 10:11-39; Fig. 17).
- Technical Importance: This technology sought to streamline content discovery on devices like tablets and computers by automatically surfacing personalized content from various sources without requiring extensive manual navigation by the user. (’832 Patent, col. 1:26-37).
Key Claims at a Glance
- The complaint primarily contests infringement of independent Claim 1. (Compl. ¶¶27-28).
- Claim 1 recites a method with two main steps:
- "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 make the regions of interest visible, which includes "repositioning the plurality of cards to remove cards not included in the first group from the display area" and displaying the regions of interest from the remaining cards.
- The complaint also makes general denials of infringement as to "any claim of the '832 Patent." (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
- The "Locally software system" or "Locally product" provided to Plaintiff's customers, as implemented on the website of Shimano North American Fishing, Inc. (Compl. ¶¶1, 12, 23).
Functionality and Market Context
- The complaint is for declaratory judgment and provides minimal detail on the accused product's functionality. It is described as a "software system" that Plaintiff provides to customers. (Compl. ¶23). The primary focus of the complaint is on what the product allegedly does not do, rather than a description of its features. (Compl. ¶28). The complaint does not contain allegations regarding the product's market position, aside from identifying Shimano as a "significant customer." (Compl. ¶11). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
- ’832 Patent Infringement Allegations
As this is a complaint for declaratory judgment, the following table summarizes the Plaintiff's (Local Gear's) contentions of non-infringement from the complaint.
| Claim Element (from Independent Claim 1) | Alleged Non-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 | The complaint asserts the Locally product does not include this functionality. | ¶28 | 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... | The complaint asserts the Locally product does not include this functionality. | ¶28 | col. 11:60-12:5 |
| ...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 asserts the Locally product does not include this functionality. | ¶28 | col. 12:3-7 |
Identified Points of Contention
- Technical Questions: A central factual dispute will be the actual operation of the Locally software system. The complaint denies key functionalities but does not describe the alternative mechanism used for displaying information. Evidence will be required to establish how the accused system sorts, filters, and presents data to users.
- Scope Questions: The dispute raises the question of whether a standard e-commerce search or filtering function can be considered "determining... regions of interest" based on "previous user preferences" as claimed. The scope of "user command" will also be at issue—does a generic search query qualify as the specific command recited in the claim?
V. Key Claim Terms for Construction
The Term: "regions of interest"
- Context and Importance: This term is central to the invention's scope. Its construction will likely determine whether the features of the accused software system are covered. The complaint suggests the patent is limited to "organizing and displaying television programming data," which implies a narrow construction is required. (Compl. ¶24).
- Intrinsic Evidence for a Broader Interpretation: The specification defines a region of interest by what a user is interested in, which can be determined from "a user profile where a user explicitly lists keywords or indicates various subjects that the user has interest." (’832 Patent, col. 10:14-17).
- Intrinsic Evidence for a Narrower Interpretation: The patent’s detailed description and figures heavily feature examples from media consumption, such as TV guides (Fig. 5), movie libraries (Fig. 6), and program recommendations (Fig. 11). This context may support an interpretation limited to media content rather than general e-commerce products.
The Term: "remove cards not included in the first group from the display area"
- Context and Importance: This limitation requires an affirmative act of removal, not merely shifting content off-screen. Practitioners may focus on this term because it appears to demand a specific technical implementation that may not be present in conventional filtering systems.
- Intrinsic Evidence for a Broader Interpretation: A party could argue that any filtering action that results in certain "cards" no longer being displayed effectively "removes" them from the display area, even if they are just hidden or moved out of the current view.
- Intrinsic Evidence for a Narrower Interpretation: Claim 1 requires "repositioning" and "remov[ing]," suggesting two distinct actions. The specification appears to confirm this, describing an embodiment where intervening non-relevant cards are "deleted/removed from display area." (’832 Patent, col. 9:60-64; Fig. 16).
The Term: "cards"
- Context and Importance: The claims operate on a "plurality of cards." Whether the elements displayed by the accused system (e.g., product listings in a search result) qualify as "cards" will be a key infringement question.
- Intrinsic Evidence for a Broader Interpretation: The specification states that "cards" can represent a wide variety of applications, including "web pages, browsers, [and] rendered media services." (’832 Patent, col. 8:55-59).
- Intrinsic Evidence for a Narrower Interpretation: The patent figures consistently show "cards" as discrete, visually-contained graphical objects, each representing a single item like a movie or TV show. (’832 Patent, Figs. 5-7). An argument could be made that simple text-based list items do not meet this visual and structural definition.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both contributory and induced infringement. (Compl. ¶¶27, 30-31). As a DJ plaintiff, Local Gear provides no factual allegations to support an inducement theory but rather denies that it "actively induce[s]" or "actively contribute[s] to its customers' infringement." (Compl. ¶¶30-31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "regions of interest," which is described in the patent primarily through the lens of personalized media guides, be construed broadly enough to read on the product filtering and display functions of the accused e-commerce software?
- A key invalidity question will be one of patentable subject matter: does Claim 1 recite a specific, unconventional method for improving a user interface, or is it directed to the patent-ineligible abstract idea of "selecting, sorting, and displaying... information by user interest" (Compl. ¶40) without a sufficient inventive concept, as will be tested under 35 U.S.C. § 101?
- A central evidentiary question will be one of functional operation: does the accused system's display logic perform the specific claimed step of "remov[ing] cards not included in the first group from the display area," or does it employ a conventional filtering or sorting method that falls outside the literal scope of the claims?