DCT
1:18-cv-01217
Sentius Intl LLC v. LG Electronics USA Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sentius International, LLC (Virginia)
- Defendant: LG Electronics U.S.A. (Delaware) and LG Electronics Inc. (Republic of Korea)
- Plaintiff’s Counsel: Farnan LLP
- Case Identification: 1:18-cv-01217, D. Del., 01/18/2019
- Venue Allegations: Venue is alleged to be proper as Defendant LG-USA is incorporated in Delaware, and a substantial part of the alleged infringement, including marketing and sales, occurs in the district.
- Core Dispute: Plaintiff alleges that Defendants’ smartphone spell-check functionality infringes a patent related to a system for linking portions of electronic text to external reference materials.
- Technical Context: The technology concerns methods for identifying discrete segments of data (like words) in an electronic document and linking them to associated reference information (like dictionary definitions or translations) for display to a user.
- Key Procedural History: The asserted patent is a reissued patent. The complaint alleges that Defendants had knowledge of the patent and their infringement at least by February 9, 2016, a date nearly three years prior to the complaint's filing, which may form the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 1994-02-16 | U.S. Patent No. RE43,633 Priority Date |
| 2012-09-04 | U.S. Patent No. RE43,633 Issue Date |
| 2016-02-09 | Alleged date of Defendants' knowledge of the ’633 patent |
| 2019-01-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. RE43,633, "System and Method for Linking Streams of Multimedia Data to Reference Material for Display," issued September 4, 2012.
The Invention Explained
- Problem Addressed: The patent describes the difficulty non-native speakers face when reading a foreign language, particularly one with an ideographic alphabet like Japanese. A reader must frequently stop to look up unknown characters or words in a dictionary, a "frustrating" process that disrupts learning and comprehension (’633 Patent, col. 2:49-56).
- The Patented Solution: The invention provides a system where a user can click on any word or phrase in an electronic text, and the system automatically retrieves and displays relevant reference information, such as a pronunciation, definition, or translation (’633 Patent, Abstract; col. 4:22-29). This is achieved by an indexing scheme that maps the location (offset) of each word in the text to a look-up table containing links to external multimedia references, without embedding the links directly into the source text (’633 Patent, col. 6:37-49).
- Technical Importance: This approach aimed to make foreign language texts more accessible by integrating dictionary and reference tools directly into the reading experience, thereby reducing the friction of traditional study methods (’633 Patent, col. 4:1-5).
Key Claims at a Glance
- The complaint asserts independent claims 17, 62, 101, and 146, and dependent claim 18 (Compl. ¶10). The analysis focuses on claim 17, which is detailed in the complaint.
- Independent Claim 17 (System Claim):
- means for determining a beginning position address of a textual source material stored in an electronic database;
- means for cutting the textual source material into a plurality of discrete pieces;
- means for determining starting point addresses and ending point addresses of the plurality of discrete pieces based upon the beginning position address;
- means for recording in a look-up table the starting and ending point addresses;
- means for linking the plurality of discrete pieces to external reference materials... by recording in the look-up table... links to the external reference materials...;
- means for selecting a discrete portion of an image of the source material;
- means for determining a display address of the selected discrete portion;
- means for converting the display address of the selected discrete portion to an offset value from the beginning position address;
- means for comparing the offset value with the starting and ending point addresses recorded in the look-up table to identify one of the plurality of discrete pieces;
- means for selecting one of the external reference materials corresponding to the identified one of the plurality of discrete pieces; and
- means for displaying on a computer the selected one of the external reference materials.
- The complaint reserves the right to assert dependent claims, explicitly identifying claim 18 (Compl. ¶23).
III. The Accused Instrumentality
Product Identification
- The accused products are LG Smartphones, including but not limited to the LG Nexus 4, LG Optimus G, LG Optimus F3, LG Optimus F7, LG G Flex, and LG Nexus 5, along with their associated applications such as LG Email and LG Message (Compl. ¶10, ¶25).
Functionality and Market Context
- The complaint alleges that the accused products contain a spell-check feature that infringes the ’633 patent (Compl. ¶11, ¶26). This feature is alleged to identify misspelled words, determine their position within a document, and record these positions in a look-up table. The complaint alleges that when a user selects a misspelled word, the system uses its position to link to a spell-check dictionary and display suggested corrections (Compl. ¶26). The complaint alleges misspelled words are identified by a "red squiggly underline" (Compl. ¶11).
IV. Analysis of Infringement Allegations
RE43,633 Infringement Allegations
| Claim Element (from Independent Claim 17) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| means for determining a beginning position address of a textual source material stored in an electronic database | The document editor in the accused applications allegedly assigns a zero position address to the first character of the document text. | ¶12 | col. 16:52-55 |
| means for cutting the textual source material into a plurality of discrete pieces | A spell-check parser allegedly parses the document to cut the text into individual words and phrases, which are identified as discrete character strings. | ¶13 | col. 16:56-58 |
| means for determining starting point addresses and an ending point addresses of the plurality of discrete pieces based upon the beginning position address | The spell-check parser allegedly identifies the beginning and ending character position offsets for misspelled words relative to the beginning position of the text. | ¶14 | col. 16:59-63 |
| means for recording in a look-up table the starting and ending point addresses | The accused devices allegedly have software that maintains a look-up table storing the beginning and ending character offsets for potential misspelled words. | ¶15 | col. 16:64-66 |
| means for linking the plurality of discrete pieces to external reference materials... | The software allegedly maintains a look-up table that stores a link to the correctly spelled replacement word in a spell-check dictionary. | ¶16 | col. 17:1-8 |
| means for selecting a discrete portion of an image of the source material | The user is offered the option to click on the highlighted, red-squiggled misspelled word via the touch interface. | ¶17 | col. 17:9-11 |
| means for determining a display address of the selected discrete portion | The software allegedly identifies the horizontal and vertical coordinates of the display location where the user's touch input was received. | ¶18 | col. 17:12-14 |
| means for converting the display address of the selected discrete portion to an offset value from the beginning position address | The software allegedly includes instructions to identify the character position offset value corresponding to the coordinates of the user's touch input. | ¶19 | col. 17:15-19 |
| means for comparing the offset value with the starting and ending point addresses recorded in the look-up table to identify one of the plurality of discrete pieces | The software allegedly determines if the identified character position is present in the look-up table and, if present, identifies the corresponding entry. | ¶20 | col. 17:20-24 |
| means for selecting one of the external reference materials corresponding to the identified one of the plurality of discrete pieces... | The document editor is allegedly programmed to resolve a pointer to identify and retrieve one or more corresponding character strings from a spell-check dictionary. | ¶21 | col. 17:25-30 |
| means for displaying on a computer the selected one of the external reference materials | The retrieved, correctly spelled words are passed to the document editor to be displayed as suggested corrections for the character string. | ¶22 | col. 17:31-33 |
- Identified Points of Contention:
- Scope Questions: Claim 17 is drafted in "means-plus-function" format. A central issue will be construing these limitations, which are restricted to the corresponding structures disclosed in the patent's specification and their equivalents. The dispute will likely focus on whether the software architecture in LG's spell-check system (e.g., its "spell check parser" and "document editor") is structurally equivalent to the "link engine," "visual editor," and "viewer indexor" described in the ’633 patent (e.g., ’633 Patent, FIG. 1).
- Technical Questions: The complaint alleges on "information and belief" that the accused system creates a look-up table with start/end addresses for misspelled words. A key factual question will be whether the accused system actually operates this way, or if it uses a different technical method for identifying words and linking them to a dictionary that falls outside the scope of the claimed "means for recording" and "means for linking."
V. Key Claim Terms for Construction
A significant portion of asserted claim 17 is written in means-plus-function format. The construction of these terms will be dispositive.
The Term: "means for cutting the textual source material into a plurality of discrete pieces"
Context and Importance: This term defines how the source text is segmented for indexing. The plaintiff alleges this covers a "spell check parser" that cuts text into "individual words and phrases" (Compl. ¶13). Practitioners may focus on this term because its scope depends on the specific "cutting" structure described in the patent, raising the question of whether a standard spell-check parser is structurally equivalent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discusses the function in general terms, stating the process "divides the text into the individual components of text that are linked with the additional reference material" (’633 Patent, col. 7:5-8).
- Evidence for a Narrower Interpretation: The patent describes the corresponding structure as a "simple visual editor, for example a point and click system using a pointing device, such as a mouse" (’633 Patent, col. 7:4-6) and a "grammar parser 23" and "link engine 22" (FIG. 1). A court may find the scope is limited to systems containing these specific components or their equivalents, not any generic parsing software.
The Term: "means for linking the plurality of discrete pieces to external reference materials"
Context and Importance: This is the core of the invention, defining the mechanism that connects a piece of text to its associated reference data. The infringement allegation hinges on whether the accused spell-check dictionary function is an equivalent structure to what the patent discloses.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the purpose is to link "component words and phrases... to a foreign language dictionary" or "other reference materials, such as graphics and/or sound" (’633 Patent, col. 7:20-22).
- Evidence for a Narrower Interpretation: The corresponding structure is described as a "link engine 22" that "builds an index 21" and records links in a "look-up table" based on start/end position offsets (’633 Patent, FIG. 1; col. 6:55-62). The scope may be limited to this specific offset-based indexing architecture, raising the question of whether the accused system's method for accessing a dictionary constitutes a structural equivalent.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that to the extent method claims 62 or 146 involve user activity, "Defendants have made the benefits of its spell check functionality conditioned on the user's performance of said steps and have established the manner or timing of that performance" (Compl. ¶27). It further alleges Defendants are responsible for user infringement because they direct and/or control the user's performance of those actions (Compl. ¶34).
- Willful Infringement: Willfulness is alleged based on Defendants having "had knowledge of infringement of the '633 patent at least by February 9, 2016" (Compl. ¶31). This alleges pre-suit knowledge of the patent and the allegedly infringing activity.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and structural equivalence: Given that the asserted independent system claim is drafted entirely in means-plus-function format, the case will likely turn on whether the software components of LG's accused spell-check feature are legally equivalent to the specific structures (e.g., "visual editor," "link engine," "viewer indexor") disclosed in the ’633 patent's specification.
- A key evidentiary question will be one of technical operation: Does the accused LG spell-check system function as alleged on "information and belief," specifically by creating a "look-up table" with start/end addresses for discrete text pieces and using user-selected offsets to retrieve dictionary suggestions? Or does it employ a different, non-infringing technical architecture to achieve a similar result?