DCT

4:22-cv-07008

Viega LLC v. Locket IP LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:22-cv-07008, N.D. Cal., 11/08/2022
  • Venue Allegations: Plaintiff Viega alleges venue is proper in the Northern District of California because a substantial portion of events, including the operation of its allegedly infringing website, occurred there, and because a large proportion of its employees and customers are located in the district.
  • Core Dispute: Plaintiff Viega seeks a declaratory judgment that it does not infringe Defendant Locket IP’s patent related to user interface design, and that the patent’s claims are invalid.
  • Technical Context: The technology concerns methods for automatically reorganizing graphical user interfaces that display multiple content "cards" or "windows" to highlight regions of interest based on user preferences.
  • Key Procedural History: This is a declaratory judgment action filed by Viega in response to an October 26, 2022 notice letter from Locket IP alleging infringement. The complaint notes that Locket IP has filed numerous lawsuits asserting the same patent against other defendants in 2022, and that Locket IP is associated with IP Edge LLC, which the complaint characterizes as a "prolific patent monetization firm."

Case Timeline

Date Event
2010-12-22 Earliest Priority Date for U.S. Patent No. 10,514,832 (’832 Patent) (from Provisional App. 61/426,509)
2019-12-24 U.S. Patent No. 10,514,832 Issued
2022-10-26 Locket IP sends notice letter and claim chart to Viega alleging infringement of the '832 Patent
2022-11-08 Viega files Complaint for Declaratory Judgment

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.

U.S. Patent No. 10,514,832 - Method for locating regions of interest in a user interface

The Invention Explained

  • Problem Addressed: The patent describes the task of finding specific items of interest across multiple open windows or "cards" on a display as "cumbersome," particularly when the content within those cards exceeds the viewable area of the screen (ʼ832 Patent, col. 1:29-37).
  • The Patented Solution: The invention is a method to automatically adjust the layout of displayed cards in response to a user command. The system determines "regions of interest" within each card based on stored user preference information (e.g., a user profile, prior activity), and then repositions the cards to make these specific regions visible without requiring the user to scroll through each card individually ('832 Patent, Abstract; col. 1:39-44). The system can also optionally remove cards that lack any regions of interest and replace them with new ones that do ('832 Patent, col. 10:47-51).
  • Technical Importance: The method aims to reduce user input and streamline content discovery in interfaces, like electronic program guides or media libraries, that present large amounts of information simultaneously ('832 Patent, col. 1:45-51).

Key Claims at a Glance

  • The complaint identifies independent claim 1 as being asserted by Locket IP (Compl. ¶17).
  • Independent Claim 1 (Method):
    • determining, in response to a user command, regions of interest within each of a plurality of cards by searching information indicating previous user preferences; and
    • 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 Locket IP's notice letter accuses Viega of infringing claim 1, but Viega seeks a declaratory judgment of non-infringement and invalidity for all claims of the patent (Compl. ¶1, 17, 41).

III. The Accused Instrumentality

Product Identification

  • The "Viega website" (Compl. ¶17).

Functionality and Market Context

  • The complaint identifies Viega as a long-time manufacturer of press-fitted pipes and plumbing products (Compl. ¶13).
  • Locket IP's notice letter allegedly identified the Viega website as the infringing instrumentality and accused Viega of infringement "by making, using, selling and/or offering for sale, as well as instructing Viega customers to use" the website (Compl. ¶16-17).
  • The complaint does not provide specific details about the technical functionality of the Viega website that is alleged to infringe the '832 Patent.

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not provide a claim chart or a detailed narrative of the defendant's infringement theory. It states that Locket IP provided a claim chart asserting its infringement theory, but that chart was not included as an exhibit with the complaint (Compl. ¶15). The complaint broadly denies that the Viega website infringes any valid claim of the '832 Patent (Compl. ¶33, Prayer for Relief ¶A).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: A central question will be whether the functionality of the Viega website, a commercial site for plumbing products, falls within the scope of a method claim directed at managing user interfaces with "cards" containing media assets like television shows or videos ('832 Patent, col. 7:60-8:29).
  • Technical Questions: The dispute will likely focus on whether the Viega website performs the specific steps recited in claim 1. Key questions include:
    • Does the website, in response to a single "user command," automatically determine "regions of interest" based on "previous user preferences"?
    • Does the website then automatically "reposition" a plurality of "cards" to simultaneously display those determined regions of interest?
    • Does the website "remove cards not included in the first group from the display area" as part of this update process?

V. Key Claim Terms for Construction

The complaint explicitly identifies a term from claim 1 as a basis for an invalidity challenge, making its construction critical.

The Term

  • "the at least one region of interest of multiple cards" ('832 Patent, col. 12:5-7).

Context and Importance

  • Viega alleges that this limitation, and the claim as a whole, is indefinite under 35 U.S.C. § 112 because the phrase "has no antecedent basis and is vague and ambiguous" (Compl. ¶39). The resolution of this indefiniteness argument depends directly on whether a person of ordinary skill in the art would understand the scope of this term with reasonable certainty in light of the specification. Practitioners may focus on this term because its awkward phrasing ("...of multiple cards included a first group...") could create ambiguity about what is being displayed and how it relates to the previously defined "plurality of cards."

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification provides broad examples of what "regions of interest" could be, including user-indicated interests in "actors, television shows, directors, sports teams, music, and the like" ('832 Patent, col. 9:24-27). This could support an interpretation where any content matching a user's profile constitutes a "region of interest."
  • Evidence for a Narrower Interpretation: The claim requires updating the display to show the region of interest "within all of the multiple cards included in the first group" ('832 Patent, col. 12:10-13). This suggests a specific outcome where a curated "group" of cards is manipulated. Figures 13 and 14 illustrate a specific embodiment where cards (1320, 1330, 1340) are vertically repositioned to bring distinct regions of interest (1325, 1335, 1345) into a single display area (1310). This could support a narrower construction requiring a specific, coordinated rearrangement of multiple, distinct card objects.

VI. Other Allegations

Indirect Infringement

  • The complaint states that Locket IP's notice letter accused Viega of infringement by "instructing Viega customers to use" the Viega website (Compl. ¶16). This suggests Locket IP's infringement theory includes a claim for induced infringement under 35 U.S.C. § 271(b), based on the allegation that Viega actively encourages its customers to perform the steps of the patented method.

Willful Infringement

  • As a declaratory judgment plaintiff, Viega does not make willfulness allegations. However, the complaint is predicated on the "Notice Letter" from Locket IP, which established Viega's knowledge of the patent and the infringement allegations as of October 26, 2022 (Compl. ¶14). Viega also seeks a declaration that the case is "exceptional" under 35 U.S.C. § 285, which could entitle it to attorney's fees, citing Locket IP's litigation campaign and assertion of a patent that Viega alleges is "clearly directed to patent-ineligible subject matter" (Compl. ¶30, 40, Prayer for Relief ¶D).

VII. Analyst’s Conclusion: Key Questions for the Case

  1. Patent Eligibility: A threshold issue will be Viega's § 101 challenge. Is claim 1 directed to the "abstract idea of updating a user interface based on user preferences," as Viega alleges, and if so, do the claim elements, considered individually and as an ordered combination, supply an "inventive concept" sufficient to transform the abstract idea into a patent-eligible application? (Compl. ¶28, 40).
  2. Claim Indefiniteness: A core validity question will be whether the phrase "the at least one region of interest of multiple cards" renders claim 1 indefinite under § 112. The court must decide if the patent provides sufficient guidance for a skilled artisan to understand the boundaries of this limitation with reasonable certainty (Compl. ¶39).
  3. Factual Infringement: If the patent survives the validity challenges, a key evidentiary question will be one of technical operation. Does the Viega website actually perform the claimed method? The case may turn on whether Viega's site automatically searches for user preferences and repositions multiple "cards" in a coordinated manner, or whether its functionality is fundamentally different from the specific steps recited in the claim.