DCT
1:17-cv-01503
Guada Tech LLC v, Vice Media LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Guada Technologies LLC (Texas)
- Defendant: Vice Media LLC (Delaware)
- Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
- Case Identification: 1:17-cv-01503, D. Del., 10/24/2017
- Venue Allegations: Venue is asserted based on Defendant's incorporation in the State of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s website, which allows users to search for content, infringes a patent related to navigating hierarchical data structures.
- Technical Context: The technology concerns methods for allowing users to more efficiently navigate complex, layered information systems, such as websites or automated phone menus, by "jumping" directly to relevant content based on keywords.
- Key Procedural History: The complaint notes that the patent-in-suit was cited as prior art during the prosecution of patents assigned to IBM, Fujitsu, and Harris Corporation. Subsequent to the filing of this complaint, the asserted patent was subject to Inter Partes Review (IPR) proceedings (IPR2021-00875, IPR2022-00217), which resulted in a certificate issued on March 3, 2023, cancelling all claims of the patent.
Case Timeline
| Date | Event |
|---|---|
| 2002-11-19 | ’379 Patent Priority Date |
| 2007-06-12 | ’379 Patent Issue Date |
| 2017-10-24 | Complaint Filing Date |
| 2021-05-03 | IPR2021-00875 Filed |
| 2021-11-22 | IPR2022-00217 Filed |
| 2023-03-03 | IPR Certificate Issued; All claims of ’379 Patent cancelled |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,231,379 - Navigation in a Hierarchical Structured Transaction Processing System
- Patent Identification: U.S. Patent No. 7,231,379, "Navigation in a Hierarchical Structured Transaction Processing System," issued June 12, 2007.
The Invention Explained
- Problem Addressed: The patent describes the problem of navigating complex, hierarchically arranged networks of choices, such as automated telephone menus or websites. As the number of nodes or choices grows, traversing the network from a starting point to a desired "goal vertex" can become difficult and frustrating for a user, potentially requiring navigation through an excessive number of steps (Compl. ¶11; ’379 Patent, col. 2:8-18).
- The Patented Solution: The invention proposes a method to navigate the hierarchical network more efficiently by allowing a user to "jump" from one node to another non-adjacent node. This is achieved by associating nodes with "keywords" and using an "inverted index" to map user input containing a keyword directly to a relevant destination node, bypassing the need to traverse the intermediate nodes in the hierarchy (Compl. ¶11; ’379 Patent, col. 3:29-43). The system can thereby skip over multiple levels of a menu tree to reach the user's intended destination more quickly (’379 Patent, col. 3:29-34).
- Technical Importance: This approach aimed to improve the user experience in computer-based transaction systems by making navigation feel more natural and efficient, reducing the rigid, step-by-step interaction common in prior art systems (’379 Patent, col. 2:21-30).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶13).
- The essential elements of independent claim 1 are:
- at a first node, receiving an input from a user of the system, the input containing at least one word identifiable with at least one keyword from among multiple keywords,
- identifying at least one node, other than the first node, that is not directly connected to the first node but is associated with the at least one keyword, and
- jumping to the at least one node.
- The complaint states infringement of "one or more claims" and reserves the right to pursue other claims (’379 Patent, col. 21:47-22:18; Compl. ¶15).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the website at
https://www.viceland.com/en_usand its associated subsites, web pages, and functionality (Compl. ¶13).
Functionality and Market Context
- The complaint focuses on the website’s functionality for navigating a hierarchical arrangement of content. It alleges the website has navigable nodes, such as categories for "Shows," "Schedule," and "Watch Free," which are interconnected hierarchically. For example, a "Shows" node contains nodes for particular shows, which in turn contain nodes for specific episodes (Compl. ¶13). The functionality at issue is a search box that accepts user input and allows the user to find and navigate to specific content, such as a particular episode, based on keywords (Compl. ¶13).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’379 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at a first node, receiving an input from a user of the system, the input containing at least one word identifiable with at least one keyword from among multiple keywords, | The website utilizes a search box on its home page (a first node) to accept user input. This input contains words identifiable with keywords used by the system to identify content, such as particular show episodes. | ¶13 | col. 21:50-54 |
| identifying at least one node, other than the first node, that is not directly connected to the first node but is associated with the at least one keyword, | The system identifies a node corresponding to a particular episode that relates to the keyword entered by the user. This episode node is not directly connected to the home page node. | ¶13 | col. 21:55-59 |
| and jumping to the at least one node. | The system allows the user to "jump" to the identified episode/node without traversing preceding generic category nodes (e.g., the "Shows" category node or a specific show's main page node). | ¶¶13-14 | col. 21:60-61 |
- Identified Points of Contention:
- Technical Questions: A central question is whether the accused website's search function operates in the manner claimed. The complaint does not provide evidence on whether the website employs a system of pre-defined "keywords" associated with specific "nodes" and an "inverted index" structure as described in the patent, or if it uses a more conventional database search or text-indexing technology.
- Scope Questions: The analysis may turn on the construction of key claim terms. For instance, does a standard search result link, which takes a user from a search results page to a content page, constitute "jumping to the at least one node" as claimed? Further, what is the scope of "not directly connected to the first node"? Does this language exclude any node that could be reached via a standard hyperlink from the first node, or does it have a more specific meaning within the patent's context of hierarchical tree traversal?
V. Key Claim Terms for Construction
The Term: "not directly connected"
Context and Importance: This term is fundamental to the inventive concept of "jumping" over intermediate levels of a hierarchy. The infringement theory depends on showing that the accused system navigates from a start node (e.g., the homepage) to a destination node (e.g., an episode page) while bypassing nodes that would lie on a conventional path (e.g., a show category page). The definition will determine what constitutes a bypass.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent frequently discusses the problem in terms of avoiding traversal of the "rigid hierarchical manner" and eliminating the "necessity for making many choices" (’379 Patent, col. 5:12-14, col. 3:33-34). This could suggest that any navigation that avoids a multi-click, pre-defined menu path could be considered a "jump" to a node that is "not directly connected."
- Evidence for a Narrower Interpretation: The patent specification describes a "tree" structure with parent and child nodes, where edges connect a vertex to the options presented in its corresponding "menu" (’379 Patent, col. 3:15-26). This may support a narrower definition where "directly connected" means an immediate parent-child relationship in a formally defined tree, and a "jump" must skip at least one level in that specific structure.
The Term: "jumping"
Context and Importance: This term defines the core infringing action. Practitioners may focus on this term because its construction will distinguish the claimed method from conventional web searching. The court will need to determine if presenting a hyperlink in a list of search results and having a user click it constitutes "jumping to the at least one node."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent summary describes the invention as a method for "navigating efficiently and naturally" and facilitating navigation "more efficiently," which could be argued to encompass modern search engine functionality (’379 Patent, col. 2:21-30).
- Evidence for a Narrower Interpretation: The detailed description explains that the system will "directly identify" a node via an index and "jump to that node without first traversing any other node" (’379 Patent, Abstract). This suggests an automated, system-directed process of identifying and moving to a single destination, which may be different from a user selecting one link from a list of many possible results.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a count for indirect infringement and does not allege specific facts to support the knowledge or intent elements required for such a claim.
- Willful Infringement: The complaint does not allege willful infringement. It alleges that Defendant had constructive notice of the patent by operation of law (Compl. ¶16), but does not allege pre- or post-suit knowledge of infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim scope: can the method of "jumping" to a "not directly connected" node, as described in the context of traversing a hierarchical menu tree, be construed to read on the functionality of a modern website search engine that returns a list of hyperlinks to a user?
- A key evidentiary question will be whether the underlying architecture of the accused website functions as claimed. The case would require discovery into whether the website employs a system of "keywords" and an "inverted index" to map user input to non-adjacent content "nodes," or if it relies on a different, non-infringing search technology.
- A dispositive procedural issue overshadows the case: given that all asserted claims of the ’379 patent were cancelled in a post-filing IPR proceeding, the basis for the infringement action no longer exists, rendering the substantive technical questions moot.