Linfo IP LLC v. Alibaba Group US Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Linfo IP, LLC (Texas)
  • Defendant: Alibaba Group (U.S.) Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 4:24-cv-03098, N.D. Cal., 05/22/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Defendant has a regular and established place of business in Sunnyvale, California, and has committed alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s system for discovering, extracting, and presenting information within text content infringes a patent related to user interfaces for information discovery.
• Technical Context: The technology concerns methods for analyzing unstructured text to identify and categorize information (e.g., user opinions) and providing user interface tools to filter, highlight, or extract that information, addressing the market challenge of information overload in large datasets like user reviews.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit. Plaintiff states it is a non-practicing entity.

Case Timeline

Date	Event
2011-12-09	U.S. Patent No. 9,092,428 Priority Date
2015-07-28	U.S. Patent No. 9,092,428 Issued
2024-05-22	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 9,092,428 - System, methods and user interface for discovering and presenting information in text content

Issued July 28, 2015

The Invention Explained

• Problem Addressed: The patent’s background section identifies the problem of "data overload, or information overload," where finding specific, needed information within large volumes of unstructured text—such as locating all negative comments about "room service" within hundreds of hotel reviews—is difficult and time-consuming using conventional search methods. (’428 Patent, col. 1:12-38).
• The Patented Solution: The invention describes a computer-assisted method that analyzes text to associate "grammatical, semantic, and contextual attributes" with words or phrases (tokens). It then provides a user with "interface objects" that allow the user to select a specific attribute (e.g., "positive opinion") and perform an action (e.g., "extract" or "highlight") on all text content associated with that attribute. This provides a structured way to filter and digest information beyond simple keyword searching. (’428 Patent, Abstract; col. 3:15-28).
• Technical Importance: The technology aims to provide more efficient tools for users to analyze and digest large amounts of text, particularly user-generated content like reviews, by categorizing information based on meaning (semantics) rather than just keywords. (’428 Patent, col. 1:56-63).

Key Claims at a Glance

• The complaint asserts claims 1-20 of the ’428 patent. (Compl. ¶10). The lead independent claims appear to be claim 1 (method) and claim 14 (system).
• Independent Claim 1 (Method) includes the following essential elements:
  • Obtaining a text content comprising words or phrases.
  • Displaying a first and second "semantic attribute" for users to select from.
  • Identifying words or phrases in the text content associated with the selected semantic attribute.
  • Displaying an "actionable user interface object" associated with a label representing the name or description of the semantic attribute.
  • Allowing a user to select the name/description via the interface object.
  • Performing an action (e.g., extracting, displaying, hiding, highlighting) on the identified words or phrases.
• The complaint reserves the right to assert infringement of claims 1-20. (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

The complaint does not name a specific product or service. It accuses "a system with methods and user interface for discovering information in a text content and extracting and presenting the information" that is maintained, operated, and administered by Defendant. (Compl. ¶10).

Functionality and Market Context

• The complaint alleges that Defendant's system performs infringing methods by allowing for the discovery, extraction, and presentation of information within text content. (Compl. ¶10, ¶12).
• The complaint alleges that Defendant puts the claimed inventions "into service" and that without Defendant's actions, the "claimed-inventions embodiments" would not have been put into service. (Compl. ¶10).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart in an "Exhibit B" but does not attach it. (Compl. ¶11). The narrative infringement theory alleges that Defendant’s system provides users with interface objects to act on discovered information, "such as extracting, displaying or hiding, or highlighting or un-highlighting words or phrases in a text content." (Compl. ¶9). It further alleges that Defendant's system infringes by "discovering information in a text content and extracting and presenting the information." (Compl. ¶10). A detailed, element-by-element analysis is not possible without the referenced exhibit or more specific factual allegations. The complaint states the allegations are "preliminary and are therefore subject to change." (Compl. ¶11).

V. Key Claim Terms for Construction

"semantic attribute" (Claim 1)

• Context and Importance: This term is the core of the invention's classification system. The infringement analysis will depend on whether the functionalities offered by Defendant's system (e.g., filters for "positive reviews" or categories) can be classified as "semantic attributes" as defined by the patent. Practitioners may focus on this term because its scope will determine whether generic filtering mechanisms fall within the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states that meanings of a word or phrase can be named "connotation" or "semantic attributes" and provides a non-exhaustive list of examples, suggesting the term is not limited to those specific examples. (’428 Patent, col. 8:23-29).
  • Evidence for a Narrower Interpretation: The specification provides specific examples of semantic attributes, such as "opinion" (with values like "positive" or "negative"), a term being a "drug," or a "pain-reliever." (’428 Patent, col. 8:29-34). A party could argue the term is limited to these types of conceptual or functional classifications, rather than simple topics.

"actionable user interface object" (Claim 1)

• Context and Importance: This term defines the mechanism through which the user interacts with the system. The dispute may turn on whether a standard filter checkbox, a search button, or a hyperlink in Defendant's system qualifies as the specific "actionable user interface object" required by the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent states the object can be "a set of radio buttons, a slider, or any sort of object that allows a user to selectively indicate an option," which may support a broad interpretation covering various standard UI elements. (’428 Patent, col. 9:1-3).
  • Evidence for a Narrower Interpretation: Claim 1 requires the object to be "associated with a label representing the first name or description or the second name or description" of the semantic attribute. This could be interpreted to require a UI element specifically and explicitly tied to the semantic category (e.g., a button labeled "Show positive opinions"), as opposed to a generic, unlabeled input field. (’428 Patent, col. 16:11-15).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. It claims inducement is based on Defendant actively encouraging or instructing customers on how to use its products and services to perform the infringing actions. (Compl. ¶12-13).
• Willful Infringement: The complaint alleges Defendant has known of the ’428 Patent and the underlying technology "from at least the filing date of the lawsuit." (Compl. ¶12-13). It further includes a prayer for a declaration of willful infringement and treble damages if discovery reveals pre-suit knowledge. (Compl., Prayer for Relief ¶e).

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

1. A central issue will be one of claim scope and construction: can the patent’s term "semantic attribute" be construed to cover the filtering or categorization functionalities within Alibaba's systems, or is it limited to the more specific opinion- and topic-based analysis detailed in the patent's embodiments? The definition of "actionable user interface object" will also be critical in determining whether generic UI elements meet the claim limitations.
2. A key evidentiary question will be whether Plaintiff can demonstrate that Defendant’s system performs the claimed method steps. Given the high-level nature of the complaint, the case may turn on Plaintiff’s ability to prove, through discovery, that Defendant’s system specifically "identifies" words associated with a "semantic attribute" and provides a dedicated UI to "perform an action" on them, as distinct from conventional keyword search or pre-programmed filtering.