DCT

5:24-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 Defendant Google has its corporate headquarters and a regular and established place of business in the district, and has allegedly committed acts of infringement there.
Core Dispute: Plaintiff alleges that Defendant’s Google Search engine infringes a patent related to methods for ranking the relevancy of web pages by combining on-page content analysis with link-based analysis.
Technical Context: The technology concerns foundational internet search engine architecture, specifically methods for improving the speed and relevance of search results by pre-calculating and storing page ranks based on both intrinsic content and extrinsic hyperlink data.
Key Procedural History: The complaint notes that claim terms from the patent-in-suit were construed in a prior litigation against Microsoft. It also alleges that the patent-in-suit has been cited as prior art in numerous Google patents, which Plaintiff proffers as evidence of Defendant’s knowledge of the patent.

Case Timeline

Date	Event
2001-01-10	U.S. Patent No. 7,356,530 Priority Date
2007	Google introduces personalized search as a default feature
2008-04-08	U.S. Patent No. 7,356,530 Issues
2010-06	Google releases its "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 Invention Explained

Problem Addressed: At the time of the invention, the rapid, disorganized growth of the World Wide Web made it difficult for users to find relevant information. Search engines were often overwhelmed, returning thousands of irrelevant pages, and were susceptible to manipulation ("spamming") where authors would repeat keywords to artificially inflate a page's ranking without adding value. (Compl. ¶¶9, 12; ’530 Patent, col. 1:15-19, col. 3:20-27).
The Patented Solution: The patent describes a method for ranking web pages that moves beyond simple keyword matching. The system calculates a "page weight"—a measure of a page's importance based on the probability a user will visit it—and uses this weight to create two distinct scores. An "intrinsic ranking factor" is determined from the page's own content, adjusted by its page weight. An "extrinsic ranking factor" is determined from the hyperlinks pointing to the page, considering the anchor text of those links and the page weight of the linking pages. These factors are then combined to produce a final rank, which is calculated in advance and stored in an indexed database for fast retrieval when a user submits a query. (Compl. ¶¶17, 21-22; ’530 Patent, Abstract, col. 5:4-33).
Technical Importance: This approach provided a more robust and less manipulable ranking system, improving both the quality and speed of search results by pre-computing ranks that incorporated the web's link structure as a measure of authority. (Compl. ¶¶16, 34-35).

Key Claims at a Glance

The complaint asserts at least independent claim 1. (Compl. ¶48).
The essential elements of independent claim 1 include:
- 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 a given word on a given page, determining an "intrinsic ranking factor" by analyzing the page's content to get a "content score" and adjusting that score by the page's "page weight".
- For that same word and page, determining an "extrinsic ranking factor" by analyzing inbound links from other pages, determining an "anchor weight" for each link, adjusting the "anchor weight" by the "page weight" of the linking page, and combining the adjusted anchor weights.
- Ranking the page for the word by "combining" the intrinsic and extrinsic ranking factors.
- Creating an indexed database of pages ranked for selected words to produce ranked search results in response to a subsequent query. (’530 Patent, col. 13:9-14:48).
The complaint does not explicitly reserve the right to assert dependent claims, but the infringement count refers to "numerous claims" of the patent. (Compl. ¶48).

III. The Accused Instrumentality

Product Identification

Google’s Search technology and services ("Google Search"). (Compl. ¶48).

Functionality and Market Context

The complaint alleges that Google Search employs a system that performs the patented method. This includes using its "Googlebot" software to crawl and index web pages without limitation to topic. (Compl. ¶52). It is alleged that Google determines a "page weight" for each page, known as "PageRank," which evaluates the probability a user will visit a page based on the number and quality of links to it. (Compl. ¶54).
The functionality is further described as analyzing the content on each page for keywords (an intrinsic factor) and analyzing anchor text from linking pages (an extrinsic factor), with both analyses being influenced by PageRank. (Compl. ¶¶58, 60). These factors are allegedly combined to produce a final ranking, which is stored in Google’s pre-indexed database to allow for rapid retrieval of search results. (Compl. ¶¶62, 64). The complaint alleges that these technologies are central to Google's dominance of the internet search market. (Compl. ¶42).

IV. Analysis of Infringement Allegations

U.S. Patent No. 7,356,530 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" crawler to systematically scan and index web pages from across the web without topical restriction. A screenshot from a Google developer website illustrates this process of crawling and indexing. (Compl. p. 14).	¶52	col. 4:9-11
for each page..., examining a probability of visitors viewing a particular page to determine a page weight	Google Search determines a PageRank score for each page, which is alleged to evaluate the probability that users will visit that page based on the quality and quantity of inbound links.	¶54	col. 7:12-15
determining an intrinsic ranking factor for use of a selected word on a selected page... by examining content... to determine a content score and adjusting the content score in accordance with the page weight	Google’s algorithms analyze the on-page content for relevance to keywords to assign a content score, which is then adjusted based on the page's PageRank (the alleged page weight).	¶58	col. 6:28-30
determining an extrinsic ranking factor... by... 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 is alleged to determine an extrinsic factor by examining anchor text on pages that link to a subject page. This anchor weight is allegedly adjusted by the PageRank of the linking page, and the adjusted weights are combined.	¶60	col. 8:61-63
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 factors (content-based) with extrinsic factors (link-based) to determine the overall relevance and placement in search results. A screenshot explains that "Search algorithms look at many factors" to provide useful information. (Compl. p. 17).	¶62	col. 6:37-39
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	Google maintains a pre-indexed database ("Google index") containing pre-computed rankings, which allows its search engine to access and produce a set of ranked search results quickly upon receiving a user's query.	¶64	col. 5:10-13

Identified Points of Contention:
- Scope Questions: A central question may be whether Google's "PageRank" is coextensive with the claimed term "page weight". The patent defines "page weight" as a "probability of visitors viewing the page" used to adjust both intrinsic and extrinsic scores. The dispute may focus on whether PageRank, as implemented by Google, performs this specific dual-adjusting function.
- Technical Questions: The claim recites a specific method of "combining" intrinsic and extrinsic factors. Given that Google’s ranking algorithm is famously complex and considers hundreds of signals, a key technical question will be whether its method of combination is the same as, or equivalent to, the method disclosed and claimed in the patent, or if it operates in a fundamentally different way.

V. Key Claim Terms for Construction

The Term: "page weight"
Context and Importance: This term is foundational to the claim, as it is used to calculate both the "intrinsic ranking factor" and the "extrinsic ranking factor". Its construction will determine whether Google's PageRank algorithm falls within the scope of the claim. Practitioners may focus on this term because the complaint directly equates it with PageRank, making the accuracy of that technical analogy a central point of dispute. (Compl. ¶54).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself defines the term functionally as being determined by "examining a probability of visitors viewing a particular page." (’530 Patent, col. 13:15-17). This could support an argument that any metric of page popularity or authority based on user visit probability meets the definition.
- Evidence for a Narrower Interpretation: The specification describes a specific method for calculating page weight based on a "random but well-defined manner" of a user traveling the web, involving a "hypothetical page weight reservoir" to handle terminal pages. (’530 Patent, col. 7:12-32). This could support a narrower construction limited to this specific "random surfer" model.
The Term: "combining the intrinsic and extrinsic ranking factors"
Context and Importance: The final ranking step requires this "combining" of the two previously calculated factors. How this combination occurs is critical to the infringement analysis. The dispute will likely center on whether Google's method of integrating hundreds of ranking signals constitutes the specific "combining" act of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language does not specify the mathematical nature of the combination, which could suggest that any method that uses both factors as inputs to generate a final rank would suffice.
- Evidence for a Narrower Interpretation: The specification discloses a specific formula for this combination: WR(K;a)=IR(K;a)+e·ER(K;a), where the extrinsic rank is weighted by an adjustable parameter e. (’530 Patent, col. 6:37-44). This suggests the combination is a specific type of weighted sum, potentially narrowing the claim's scope to methods that use a similar additive combination.

VI. Other Allegations

Indirect Infringement: The complaint focuses on direct infringement under 35 U.S.C. § 271(a) and does not plead separate counts for induced or contributory infringement. (Compl. ¶48).
Willful Infringement: The complaint alleges that Google has known about the ’530 Patent for over a decade, citing as evidence the fact that the patent has been cited as prior art in "numerous of Google's own patents and patent applications." (Compl. ¶43). It further alleges that Google "clearly knew that it was practicing the claimed invention" but continued to do so without a license. (Compl. ¶44).

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

A primary issue will be one of definitional scope: Does Google's PageRank algorithm, as used within its broader ranking system, meet the claim limitation of a "page weight" that is used to adjust both a content-derived "intrinsic ranking factor" and a link-derived "extrinsic ranking factor" in the manner recited by the patent?
A second core issue relates to operational correspondence: Does Google's method of synthesizing hundreds of different signals into a final page rank constitute the specific act of "combining" the "intrinsic and extrinsic ranking factors" as claimed, particularly in light of the specification's disclosure of a specific additive formula?
Finally, a threshold question of patent eligibility may arise, as anticipated by the plaintiff's arguments. The case may turn on whether the court views the claims as being directed to a patent-eligible improvement in computer-specific search technology, or to an abstract idea of ranking information which is not patentable subject matter under 35 U.S.C. § 101.