DCT
4:24-cv-07147
Looksmart Group Inc v. Google LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LookSmart Group, Inc. (Nevada)
- Defendant: Google, LLC (Delaware)
- Plaintiff’s Counsel: Bunsow De Mory LLP; Ahmad, Zavitsanos & Mensing, PLLC
- Case Identification: 4:24-cv-07147, N.D. Cal., 07/17/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of California because Google has its corporate headquarters and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Google Search engine infringes a patent related to methods for pre-ranking web pages by combining on-page content analysis with link-based authority metrics.
- Technical Context: The technology concerns foundational internet search engine architecture designed to improve the speed and relevance of search results by performing computationally intensive ranking calculations before a user query is received.
- Key Procedural History: The complaint notes that several key claim terms were previously construed in a litigation involving Microsoft. It also references the prosecution history of a Google-owned patent, U.S. Patent No. 10,839,029, where Google successfully argued that similar search-ranking technology constituted a patent-eligible improvement to computer functionality, a point that may be used to preemptively counter a potential subject matter eligibility challenge under 35 U.S.C. § 101.
Case Timeline
| Date | Event |
|---|---|
| 2001-01-10 | ’530 Patent Priority Date |
| 2007 | Google introduces personalized search as a default feature |
| 2008-04-08 | U.S. Patent No. 7,356,530 Issued |
| 2010-06 | Google releases "Caffeine" search index |
| 2025-07-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,356,530 - "Systems and Methods of Retrieving Relevant Information"
- Patent Identification: U.S. Patent No. 7,356,530, “Systems and Methods of Retrieving Relevant Information,” issued April 8, 2008 (the “’530 Patent”).
The Invention Explained
- Problem Addressed: At the time of invention, the rapid, disorganized growth of the World Wide Web made it difficult for users to find relevant information efficiently. Existing search engines often returned thousands of irrelevant pages and were susceptible to "spamming," where web authors could manipulate rankings by repeating keywords ('530 Patent, col. 3:5-26).
- The Patented Solution: The patent describes a system that improves search speed and relevance by pre-calculating page ranks for specific keywords before a user submits a query. This rank is a combination of two factors: an "intrinsic rank" derived from the content of the page itself, and an "extrinsic rank" derived from analyzing the hyperlink structure of the web—specifically, the anchor text of incoming links and the "page weight" (a measure of importance) of the pages providing those links ('530 Patent, Abstract; col. 5:4-32). By performing this analysis and storing the results in an indexed database, the system can deliver ranked results nearly instantaneously ('530 Patent, col. 4:19-24).
- Technical Importance: This pre-computation architecture represented a technological solution to the dual problems of latency and relevance that challenged early search engines (Compl. ¶¶16, 35-36).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 ('530 Patent, Compl. ¶48).
- Claim 1 of the ’530 Patent contains the following essential elements:
- Crawling the World Wide Web to produce a collection of pages.
- For each page, determining a "page weight" based on the probability of visitors viewing it.
- For keyword-page pairs, determining an "intrinsic ranking factor" by analyzing the page's content and adjusting a content score by the page weight.
- For those same pairs, determining an "extrinsic ranking factor" by analyzing inbound hypertext links, determining an "anchor weight," adjusting it by the linking page's page weight, and combining the results.
- Ranking the page for the word by "combining the intrinsic and extrinsic ranking factors."
- Creating an indexed database of the ranked pages to produce ranked search results in response to a subsequent query.
- The complaint does not explicitly reserve the right to assert other claims, but its infringement allegations focus exclusively on claim 1.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Google's internet search engine technology and services ("Google Search") (Compl. ¶48).
Functionality and Market Context
- The complaint alleges that Google Search employs a system that mirrors the patented method. It describes Googlebot software crawling the web to collect pages (Compl. ¶52), the use of the PageRank algorithm to determine a "page weight" for each page based on the link structure of the web (Compl. ¶54), and the analysis of on-page keywords and inbound link anchor text to determine relevance (Compl. ¶¶58, 60). These factors are allegedly combined to generate a final rank, and the results are stored in a pre-indexed database to allow for rapid retrieval upon a user's query (Compl. ¶¶62, 64). The complaint provides a screenshot from a Google Developer website that describes its crawler, Googlebot, constantly crawling the web to discover and index new pages (Compl. p. 14).
- The complaint alleges that these technical features are foundational to Google's success and have enabled its "unparalleled dominance of the Internet search market" (Compl. ¶42).
IV. Analysis of Infringement Allegations
’530 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| crawling the World Wide Web to produce a collection of pages without limitation to topic | Google Search uses its "Googlebot" software to systematically scan and index new or updated web pages from across the web without topical limitation. The complaint includes a graphic from Google explaining that "web crawlers gather information from across hundreds of billions of webpages" (Compl. p. 14). | ¶52 | col. 13:12-14 |
| for each page in the collection of pages, examining a probability of visitors viewing a particular page to determine a page weight for said particular page | Google Search determines a page weight, identified as PageRank, for each page, which allegedly "evaluated the probability that users will visit a particular web page based on the number and quality of links to that page." | ¶54 | col. 13:15-17 |
| determining an intrinsic ranking factor for use of a selected word on a selected page... by examining content related to the selected word on the selected page to determine a content score and adjusting the content score in accordance with the page weight of the selected page | Google’s algorithms allegedly determine an intrinsic ranking factor by analyzing on-page content for keywords to assign a "content score," which is then adjusted based on the page's PageRank (page weight). A supporting visual from Google explains how its algorithms "analyze the content of webpages" (Compl. p. 16). | ¶58 | col. 13:20-27 |
| determining an extrinsic ranking factor for use of the selected word on the selected page by, for each linking page... examining text associated with the outbound hypertext link... to determine an anchor weight... adjusting the anchor weight in accordance with the page weight of the linking page and combining the adjusted anchor weights... | Google Search allegedly determines an extrinsic factor by examining anchor text from linking pages, assigning an "anchor weight" to each link, and adjusting that weight based on the PageRank of the linking page. The complaint includes a Google-sourced graphic about the importance of link text (Compl. p. 17). | ¶60 | col. 13:28-39 |
| ranking the selected page for the selected word by combining the intrinsic and extrinsic ranking factors related thereto | Google Search allegedly ranks pages by combining the intrinsic (content-based) and extrinsic (link-based) factors to determine a page's overall relevance for a given search query. | ¶62 | col. 13:40-42 |
| creating a database of the collection of pages indexed by the plurality of selected words... so that ranked search results are produced in response to a subsequent query which includes one or more of the selected words | Google Search allegedly maintains a "pre-indexed database of web pages" with "pre-computed rankings" that its search engine accesses to "produce a set of relevant, ranked search results." A visual in the complaint describes the "Google index" as a "huge database stored in many, many (many!) computers" (Compl. p. 18). | ¶64 | col. 13:43-47 |
Identified Points of Contention
- Scope Questions: A central dispute may concern whether Google's proprietary PageRank algorithm falls within the scope of the term "page weight" as defined in the patent. While the complaint equates the two (Compl. ¶54), the patent describes a specific calculation method involving a "page weight reservoir" that could be a basis for a narrower interpretation ('530 Patent, col. 7:18-47).
- Technical Questions: The complaint alleges that Google "combin[es]" intrinsic and extrinsic factors (Compl. ¶62), but provides little detail on the specific mechanism. A key factual question will be whether Google's complex and likely multi-faceted ranking algorithm performs a step that maps onto the "combining" limitation of claim 1, which the specification exemplifies with a specific additive formula ('530 Patent, col. 5:40-41).
V. Key Claim Terms for Construction
The Term: "page weight"
- Context and Importance: This term is fundamental to both the intrinsic and extrinsic ranking steps. The plaintiff's infringement theory depends on construing this term to read on Google's PageRank.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification provides a functional definition: "the probability of visitors viewing the page" ('530 Patent, col. 5:24-25). This could support an interpretation covering any metric that models user navigation probability based on link analysis.
- Evidence for a Narrower Interpretation: The specification details a specific embodiment for calculating page weight that uses a "hypothetical page, termed a page weight reservoir" ('530 Patent, col. 7:18-20). A defendant may argue the term is limited to results from this or a similar methodology.
The Term: "combining the intrinsic and extrinsic ranking factors"
- Context and Importance: This is the final step in calculating the pre-computed rank. The scope of "combining" will dictate what evidence is needed to prove infringement of this element.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of "combining" is general and could encompass any mathematical or logical operation that uses both factors as inputs to produce a single output rank.
- Evidence for a Narrower Interpretation: The specification discloses a specific formula for this step:
WR(K;a)=IR(K;a)+e·ER(K;a)('530 Patent, col. 5:40-41). A defendant could argue that "combining" should be limited to this particular additive method.
VI. Other Allegations
Indirect Infringement
The complaint does not plead a separate count for indirect infringement.
Willful Infringement
The complaint alleges that Google had pre-suit knowledge of the ’530 Patent. The basis for this allegation is that the patent has been "cited as prior art to numerous of Google's own patents and patent applications for over a decade" (Compl. ¶43). It further alleges that given the "integral nature" of the invention to Google's search engine and these repeated citations, Google "clearly knew that it was practicing the claimed invention" (Compl. ¶44). These allegations form the basis for a potential claim of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "page weight," which is described in the patent with a specific "page weight reservoir" embodiment, be construed broadly enough to read on Google's well-known but proprietary PageRank algorithm?
- A second central question will be one of subject matter eligibility: will the court view claim 1 as being directed to a patent-eligible "improvement in computer-related technology," as the complaint argues by citing Google's own prosecution history, or as an abstract idea of organizing and ranking information, which has been a frequent basis for invalidating software patents?
- A key evidentiary question will be one of technical proof: what evidence can be adduced to demonstrate that Google's highly complex and confidential search algorithm performs the specific steps of "adjusting" a content score by page weight and "combining" the intrinsic and extrinsic factors in the manner required by the claim?